Text

HI-STORM Umax - Draft Certificate of Compliance for Spent Fuel Storage Casks, and Technical Specifications
	ML20002A310
Person / Time
Site:	HI-STORM 100
Issue date:	12/15/2019
From:	; Holtec
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML20002A299	List: ML20002A300; ML20002A303; ML20002A305; ML20002A307; ML20002A310;
References
	5021056
	Download: ML20002A310 (53)
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NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (10-2004) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Page 1

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The U.S. Nuclear Regulatory Commission is issuing this Certificate of Compliance pursuant to Title 10 of the Code of Federal Regulations, Part 72, "Licensing Requirements for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste" (10 CFR Part 72). This certificate is issued in accordance with 10 CFR 72.238, certifying that the storage design and contents described below meet the applicable safety standards set forth in 10 CFR Part 72, Subpart L, and on the basis of the Final Safety Analysis Report (FSAR) of the cask design. This certificate is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, and the conditions specified below.

Certificate No.

Effective Date Expiration Date Docket No.

Amendment No.

Amendment Effective Date Package Identification No.

1040 TBD TBD 72-1040 3

USA/72-1040 Issued To: (Name/Address)

Holtec International Holtec Center One Holtec Drive Marlton, NJ 08053 Safety Analysis Report Title Holtec International Final Safety Analysis Report for the HI-STORM UMAX Canister Storage System This certificate is conditioned upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Technical Specifications) and Appendix B (Approved Contents and Design Features), and the conditions specified below:

APPROVED SPENT FUEL STORAGE CASK Model No.: HI-STORM UMAX Canister Storage System DESCRIPTION:

The HI-STORM UMAX Canister Storage System consists of the following components: (1) interchangeable canisters, which contain the fuel; (2) underground Vertical Ventilated Modules (VVMs), which contains the canisters during storage; and (3) a transfer cask (HI-TRAC VW), which contains the canister during loading, unloading and transfer operations. The multi-purpose canister (MPC) stores up to 37 pressurized water reactor fuel assemblies or up to 89 boiling water reactor fuel assemblies. The HI-STORM UMAX may also store a dry shielded canister (DSC) which contains up to 24 pressurized water reactor fuel assemblies.

The HI-STORM UMAX Canister Storage System is certified as described in the UMAX Final Safety Analysis Report (FSAR) supplemented by the information on the analyzed canisters and transfer cask, and in the U. S.

Nuclear Regulatory Commissions (NRC) Safety Evaluation Report (SER) accompanying the Certificate of Compliance (CoC).

The MPC is the confinement system for the stored fuel. It is a welded, cylindrical canister with a honeycombed fuel basket, a baseplate, a lid, a closure ring, and the canister shell. All MPC components that may come into contact with spent fuel pool water or the ambient environment are made entirely of stainless steel or passivated aluminum/aluminum alloys. The canister shell, baseplate, lid, vent and drain port cover plates, and closure ring are the main confinement boundary components. All confinement boundary components are made entirely of stainless steel. The honeycombed basket provides criticality control.

Similarly, the welded DSC provides confinement and criticality control for the storage and transfer of irradiated fuel. The principle component subassemblies of the DSC are the shell with integral bottom cover plate and shield plug, top shield plug, top cover plate, and basket assembly. The DSC confinement boundary consists of stainless steel cylindrical shell and the top and bottom cover plate assemblies. The shell length is fuel specific.

The internal basket assembly for the 24PT1 is composed of guide sleeves, support rods, and spacer disks.

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NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Supplemental Sheet Certificate No.

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DESCRIPTION (continued)

The DSC basket assembly aids in the insertion of the fuel assemblies, enhances subcriticality during loading operations, and provides structural support.

There are two types of MPCs permitted for storage in HI-STORM UMAX VVM: the MPC-37 and MPC-89. The number suffix indicates the maximum number of fuel assemblies permitted to be loaded in the MPC. Both MPC models have the same external diameter. The DSC type permitted for storage in the HI-STORM UMAX is the DSC-24PT1.

The HI-TRAC VW transfer cask provides shielding and structural protection of the canister during loading, unloading, and movement of the canister from the cask loading area to the VVM. The transfer cask is a multi-walled (carbon steel/lead/carbon steel) cylindrical vessel with a neutron shield jacket attached to the exterior and a retractable bottom lid used during transfer operations. The HI-TRAC VW is also used for transfer of the DSC-24PT1.

The HI-STORM UMAX VVM utilizes a storage design identified as an air-cooled vault or caisson. The HI-STORM UMAX VVM relies on vertical ventilation instead of conduction through the fill material around the VVM, as it is essentially a below-grade storage cavity. Air inlets and an air outlet allow air to circulate naturally through the cavity to cool the canister inside. The subterranean steel structure is seal welded to prevent ingress of any groundwater in the canister storage cavity from the surrounding subgrade, and it is mounted on a stiff foundation. The surrounding subgrade and a top surface pad provide significant radiation shielding. A loaded canister is stored within the HI-STORM UMAX VVM in a vertical orientation.

HI-STORM UMAX Version MSE is a structurally strengthened embodiment of the VVM engineered for deployment at sites with its Design Basis Earthquake with ZPA in excess of 2.12Gs (resultant horizontal) and up to 1.0G (vertical).

CONDITIONS

1. OPERATING PROCEDURES Written operating procedures shall be prepared for handling, loading, movement, surveillance, and maintenance. The users site-specific written operating procedures shall be consistent with the technical basis described in Chapter 9 and canister specific Chapter 9 supplements of the FSAR.

2. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written acceptance tests and a maintenance program shall be prepared consistent with the technical basis described in Chapter 10 and canister specific Chapter 10 supplements of the FSAR.

For the MPCs, at completion of welding the MPC shell to baseplate, an MPC confinement weld helium leak test shall be performed using a helium mass spectrometer. This test shall include the base metals of the MPC shell and baseplate. A helium leakage test shall also be performed on the base metal of the fabricated MPC lid. The confinement boundary welds leakage rate test shall be performed in accordance with ANSI N14.5 to leaktight criterion. If a leakage rate exceeding the acceptance criteria is detected, then the area of leakage shall be determined and the area repaired per ASME Code Section III, Subsection NB, Article NB-4450 requirements. Re-testing shall be performed until the leakage rate acceptance criterion is met.

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NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Supplemental Sheet Certificate No.

1040 Amendment No.

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3. QUALITY ASSURANCE Activities in the areas of design, purchase, fabrication, assembly, inspection, testing, operation, maintenance, repair, modification of structures, systems and components, and decommissioning that are important-to-safety shall be conducted in accordance with a Commission-approved quality assurance program which satisfies the applicable requirements of 10 CFR Part 72, Subpart G, and which is established, maintained, and executed with regard to the storage system

4. HEAVY LOADS REQUIREMENTS Each lift of an MPC, DSC, or a HI-TRAC VW transfer cask must be made in accordance to the existing heavy loads requirements and procedures of the licensed facility at which the lift is made. A plant-specific review of the heavy load handling procedures (under 10 CFR 50.59 or 10 CFR 72.48, as applicable) is required to show operational compliance with existing plant specific heavy loads requirements. Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 5.2 of Appendix A or Appendix C as applicable.

5. APPROVED CONTENTS Contents of the HI-STORM UMAX Canister Storage System must meet the fuel specifications for each canister in the appendices to this certificate as follows:

Canister Approved Contents Appendix MPC-37 Appendix B MPC-89 Appendix B DSC-24PT1 Appendix D

6. DESIGN FEATURES Features or characteristics for the site or system must be in accordance with the applicable appendix to this certificate, identified in item 5.

7. CHANGES TO THE CERTIFICATE OF COMPLIANCE The holder of this certificate who desires to make changes to the certificate, which includes all the appendices (A through D), shall submit an application for amendment of the certificate.

8. PRE-OPERATIONAL TESTING AND TRAINING EXERCISE - MPCs only A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM UMAX Canister Storage System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the MPC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:

a. Moving the MPC and the transfer cask into the spent fuel pool or cask loading pool.

b. Preparation of the HI-STORM UMAX Canister Storage System for fuel loading.

c. Selection and verification of specific fuel assemblies to ensure type conformance.

d. Loading specific assemblies and placing assemblies into the MPC (using a dummy fuel assembly),

including appropriate independent verification.

e. Remote installation of the MPC lid and removal of the MPC and transfer cask from the spent fuel pool or cask loading pool.

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NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Supplemental Sheet Certificate No.

1040 Amendment No.

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f.

MPC welding, NDE inspections, pressure testing, draining, moisture removal (by vacuum drying or forced helium dehydration, as applicable), and helium backfilling. (A mockup may be used for this dry-run exercise.)

g. Transfer of the MPC from the transfer cask to the VVM.

h. HI-STORM UMAX Canister Storage System unloading, including flooding MPC cavity and removing MPC lid welds. (A mockup may be used for this dry-run exercise.)

Any of the above steps can be omitted if the site has already successfully loaded a Holtec MPC System.

PRE-OPERATIONAL TESTING AND TRAINING EXERCISE - DSCs only A dry run training exercise of the handling, unloading and transfer of the DSC in the HI-STORM UMAX Canister Storage System shall be conducted by the licensee prior to the first movement of a loaded DSC into a HI-STORM UMAX VVM. The training exercise shall not be conducted with spent fuel in the DSC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:

a. Transfer of the DSC from the NUHOMS storage module to the HI-TRAC VW.

b. Transfer of the DSC from the HI-TRAC VW to the VVM

c. Unloading of the DSC from storage in the HI-STORM UMAX

d. Unloading of the fuel from the DSC (in accordance with CoC 72-1029)

9. AUTHORIZATION The HI-STORM UMAX Canister Storage System, which is authorized by this certificate, is hereby approved for general use by holders of 10 CFR Part 50 licenses for nuclear reactors at reactor sites under the general license issued pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR 72.212, this certificate, and the attached Appendices A through D. The HI-STORM UMAX Canister Storage System may be fabricated and used in accordance with any approved amendment to CoC No. 1040 listed in 10 CFR 72.214. Each of the licensed HI-STORM UMAX Canister Storage System components (i.e., the canister, overpack, and transfer cask), if fabricated in accordance with any of the approved CoC Amendments, may be used with one another provided an assessment is performed by the CoC holder that demonstrates design compatibility..

FOR THE U. S. NUCLEAR REGULATORY COMMISSION DRAFT Dated TBD Attachments:

1. Appendix A

2. Appendix B

3. Appendix C

4. Appendix D ATTACHMENT 3 TO HOLTEC LETTER 5021056 4 of 53

CERTIFICATE OF COMPLIANCE NO. 1040 APPENDIX C TECHNICAL SPECIFICATIONS FOR THE STORAGE OF 24PT1-DSC IN HI-STORM UMAX CANISTER STORAGE SYSTEM ATTACHMENT 3 TO HOLTEC LETTER 5021056 5 of 53

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-i TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1-1 1.1 Definitions............................................................................................ 1.1-1 1.2 Logical Connectors.............................................................................. 1.2-1 1.3 Completion Times................................................................................ 1.3-1 1.4 Frequency............................................................................................ 1.4-1 2.0 NOT USED 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY............ 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY............................. 3.0-2 3.1 SFSC INTEGRITY............................................................................ 3.1.1-1 3.1.1 SFSC Heat Removal System................................................. 3.1.1-1 4.0 NOT USED.................................................................................................. 4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS...................................... 5.0-1 5.1 Radioactive Effluent Control Program.................................................. 5.0-1 5.2 Transport Evaluation Program............................................................. 5.0-2 5.3 Radiation Protection Program.............................................................. 5.0-3 5.4 DSC Verification Requirements........................................................... 5.0-5 ATTACHMENT 3 TO HOLTEC LETTER 5021056 6 of 53

Definitions 1.1 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-1 1.0 USE AND APPLICATION

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

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

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

AMBIENT TEMPERATURE AMBIENT TEMPERATURE for Short Term Operations (operations involving use of the HI-TRAC, a Lifting device, and/or an on-site transport device) is defined 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.

CANISTER TRANSFER CANISTER TRANSFER begins when the CHA containing the canister is lifted off the TRANSFER CASK bottom lid and ends when the canister is supported from beneath by the OVERPACK (or the reverse).

DAMAGED FUEL ASSEMBLY (for 24PT1-DSC only)

DAMAGED FUEL ASSEMBLY is a fuel assembly with known or suspected cladding defects greater than pinhole leaks or hairline cracks or an assembly with partial or missing rods.

DRY SHIELDED CANISTER (DSC)

DSC is a welded pressure vessel that provides confinement of INTACT or DAMAGED FUEL ASSEMBLIES in an inert atmosphere FAILED FUEL CAN A FAILED FUEL CAN confines any loose material and gross fuel particles to a known, subcritical volume during normal, off-normal and accident conditions and facilitates handling and retrievability.

FUEL DEBRIS (24PT1)

An intact or partial fuel rod not contained in a fuel assembly grid or an individual intact or partial fuel pellet not contained in a fuel rod. FUEL DEBRIS may be inserted in a ROD STORAGE BASKET.

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Definitions 1.1 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-2 1.1 Definitions Term Definition FUEL BUILDING The FUEL BUILDING is the site-specific power plant facility, governed by the regulations of 10 CFR Part 50, where the loaded OVERPACK or TRANSFER CASK is transferred to or from the transporter.

INTACT FUEL ASSEMBLY (24PT1)

Spent nuclear fuel assemblies without known or suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means.

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

The facility within a perimeter fence licensed for storage of spent fuel.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on a TRANSFER CASK while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the canister and end when the TRANSFER CASK is suspended from or secured on the transporter. LOADING OPERATIONS does not include MPC TRANSFER.

OVERPACK For the HI-STORM UMAX, the term OVERPACK is synonyms with the term VVM defined below.

RECONSTITUED FUEL ASSEMBLY (24PT1)

RECONSTITUTED FUEL ASSEMBLIES include assemblies in which leaking fuel rods are replaced with either stainless steel rods or intact fuel rods, and which could undergo further irradiation ROD STORAGE BASKET A 9x9 array of tubes in a lattice that has approximately the same dimensions as a standard fuel assembly SPENT FUEL STORAGE CASKS (SFSCs)

SFSCs are containers approved for the storage of spent fuel assemblies at the ISFSI. The HI-STORM UMAX SFSC System consists of the OVERPACK and its integral canister.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while an SFSC containing spent fuel is situated within the ISFSI perimeter. STORAGE OPERATIONS does not include CANISTER TRANSFER.

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Definitions 1.1 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-3 1.1 Definitions Term Definition TRANSFER CASK TRANSFER CASKs are containers designed to contain the canister during and after loading of spent fuel assemblies, and prior to and during unloading and to transfer the canister to or from the OVERPACK.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on a TRANSFER CASK loaded with one or more fuel assemblies when it is being moved after LOADING OPERATIONS or before UNLOADING OPERATIONS. TRANSPORT OPERATIONS begin when the TRANSFER CASK is first suspended from or secured on the transporter and end when the TRANSFER CASK is at its destination and no longer secured on or suspended from the transporter. TRANSPORT OPERATIONS includes DSC TRANSFER.

VERTICAL VENTILATED MODULE (VVM)

The VVM is a subterranean type overpack which receives and contains the sealed canister for interim storage at the ISFSI. The VVM supports the MPC in a vertical orientation and provide gamma and neutron shielding and also provides air flow through cooling passages to promote heat transfer from the MPC to the environs.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SFSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the TRANSFER CASK is no longer suspended from or secured on the transporter and end when the last fuel assembly is removed from the SFSC.

UNLOADING OPERATIONS does not include MPC TRANSFER.

ZR ZR means any zirconium-based fuel cladding or fuel channel material authorized for use in a commercial nuclear power plant reactor.

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Logical Connectors 1.2 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.2-1 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

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

BACKGROUND Several levels of logic may be used to state Required Actions.

These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

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Logical Connectors 1.2 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.2-0 1.2 Logical Connectors (continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 VERIFY...

AND A.2 Restore...

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

(continued)

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Logical Connectors 1.2 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.2-1 1.2 Logical Connectors EXAMPLES (continued)

EXAMPLE 1.2-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 Stop...

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove...

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

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Completion Times 1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-1 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the HI-STORM UMAX System is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time.

An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the HI-STORM UMAX System is not within the LCO Applicability.

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

(continued)

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Completion Times 1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-2 1.3 Completion Times (continued)

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Perform Action B.1 AND B.2 Perform Action B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND complete action B.2 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

(continued)

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Completion Times 1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-3 1.3 Completion Times (continued)

EXAMPLES (continued)

EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not within limit.

A.1 Restore system to within limit.

7 days B. Required Action and associated Completion Time not met.

B.1 Complete action B.1.

AND B.2 Complete action B.2.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours When a system is determined not to meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

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Completion Times 1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-4 1.3 Completion Times (continued)

EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS

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

Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 Restore compliance with LCO.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months B. Required Action and associated Completion Time not met.

B.1 Complete action B.1.

AND B.2 Complete action B.2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours The Note above the ACTIONS table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis. When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

(continued)

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Completion Times 1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-5 1.3 Completion Times (continued)

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

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Frequency 1.4 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.4-1 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

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

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

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction.

(continued)

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Frequency 1.4 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.4-2 1.4 Frequency (continued)

EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or variables are outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

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

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Frequency 1.4 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.4-3 1.4 Frequency (continued)

EXAMPLES (continued)

EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits.

Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting activity AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting the activity.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND"). This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If the specified activity is canceled or not performed, the measurement of both intervals stops. New intervals start upon preparing to restart the specified activity.

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2.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 2.0-1 2.0 This section is intentionally left blank ATTACHMENT 3 TO HOLTEC LETTER 5021056 21 of 53

LCO Applicability 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.0-1 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

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

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

LCO 3.0.3 Not applicable.

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

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

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LCO Applicability 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.0-2 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met.

For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per... basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

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

(continued)

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LCO Applicability 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.0-3 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 (continued)

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

SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with Actions or that are related to the unloading of an SFSC.

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Fuel Cool-Down 3.1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.1.1-1 3.1 SFSC INTEGRITY 3.1.1 SFSC Heat Removal System LCO 3.1.1 The SFSC Heat Removal System shall be operable

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

The SFSC Heat Removal System is operable when 50% or more of the inlet vent duct areas are unblocked and available for flow or when air temperature requirements are met.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SFSC Heat Removal System operable, but partially (<50%) blocked.

A.1 Remove blockage.

N/A B. SFSC Heat Removal System inoperable.

B.1 Restore SFSC Heat Removal System to operable status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months C. Required Action B.1 and associated Completion Time not met.

C.1 Measure SFSC dose rates in accordance with the Radiation Protection Program.

Immediately and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter AND C.2.1 Restore SFSC Heat Removal System to operable status.

64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months OR C.2.2 Transfer the DSC into a TRANSFER CASK.

64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months ATTACHMENT 3 TO HOLTEC LETTER 5021056 25 of 53

Fuel Cool-Down 3.1.3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.1.1-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all VVM inlets and outlets duct screen are free of blockage from solid debris or floodwater.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR For VVMs with installed temperature monitoring equipment, verify that the difference between the average VVM air outlet duct temperature and ISFSI ambient temperature is 49oF for VVMs containing 24PT1-DSCs.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ATTACHMENT 3 TO HOLTEC LETTER 5021056 26 of 53

4.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 4.0-1 4.0 This section is intentionally left blank ATTACHMENT 3 TO HOLTEC LETTER 5021056 27 of 53

Programs 5.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented and maintained.

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

a.

The HI-STORM UMAX Canister Storage System does not create any radioactive materials or have any radioactive waste treatment systems.

Therefore, specific operating procedures for the control of radioactive effluents are not required.

b.

This program includes an environmental monitoring program. Each general license user may incorporate SFSC operations into their environmental monitoring programs for 10 CFR Part 50 operations.

c.

An annual report shall be submitted pursuant to 10 CFR 72.44(d)(3).

(continued)

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Programs 5.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-2 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program

a. For lifting of the loaded CHA or TRANSFER CASK using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.

b. This program is not applicable when the TRANSFER CASK is in the FUEL BUILDING or is being handled by equipment providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...).

c. The TRANSFER CASK when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and CANISTER TRANSFER, provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.

1.

The metal body and any vertical columns of the lifting equipment shall be designed to comply with stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. All vertical compression loaded primary members shall satisfy the buckling criteria of ASME Section III, Subsection NF.

2.

The horizontal cross beam and any lifting attachments used to connect the load to the lifting equipment shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with applicable sections and guidance of NUREG-0612, Section 5.1. This includes applicable stress limits from ANSI N14.6.

3.

The lifting equipment shall have redundant drop protection features which prevent uncontrolled lowering of the load.

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Programs 5.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-3 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program 5.3.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

5.3.2 As part of its evaluation pursuant to 10 CFR 72.212(b)(2)(i)(C), the licensee shall perform an analysis to confirm that the dose limits of 10 CFR 72.104(a) will be satisfied under the actual site conditions and ISFSI configuration, considering the planned number of casks to be deployed and the cask contents.

5.3.3 Based on the analysis performed pursuant to Section 5.3.2, the licensee shall establish individual cask surface dose rate limits for the TRANSFER CASK and the VVM to be used at the site. Total (neutron plus gamma) dose rate limits shall be established at the following locations:

a.

The top of the VVM.

b.

The side of the TRANSFER CASK

c.

The outlet vents on the VVM 5.3.4 Notwithstanding the limits established in Section 5.3.3, the average of the measured dose rates on a loaded VVM or TRANSFER CASK shall not exceed the following values:

a.

30 mrem/hr (gamma + neutron) on the top of the closure lid of the VVM

b.

3500 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.3.5 The licensee shall measure the TRANSFER CASK and VVM surface neutron and gamma dose rates as described in Section 5.3.8 for comparison against the limits established in Section 5.3.3 or Section 5.3.4, whichever are lower.

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Programs 5.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-4 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.3.3 or Section 5.3.4, the licensee shall:

a.

Administratively verify that the correct contents were loaded in the correct fuel storage cell locations.

b.

Perform a written evaluation to verify whether a VVM at the ISFSI containing the as-loaded DSC will cause the dose limits of 10 CFR 72.104 to be exceeded.

c.

Perform a written evaluation within 30 days to determine why the surface dose rate limits were exceeded.

5.3.7 If the evaluation performed pursuant to Section 5.3.6 shows that the dose limits of 10 CFR 72.104 will be exceeded, the DSC shall not be placed into a VVM or the DSC shall be removed from the VVM until appropriate corrective action is taken to ensure the dose limits are not exceeded.

5.3.8 TRANSFER CASK and VVM surface dose rates shall be measured at approximately the following locations:

a.

A minimum of four (4) dose rate measurements shall be taken on the top of the VVM. These measurements shall be taken approximately 90 degrees apart around the circumference of the lid, approximately 18 inches radially inward from the edge of the lid.

b.

A minimum of four (4) dose rate measurements shall be taken adjacent to the outlet vent duct screen of the VVM, approximately 90 degrees apart.

c.

A minimum of four (4) dose rate measurements shall be taken on the side of the TRANSFER CASK approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs of the water jacket.

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Programs 5.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-5 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.9 The Radiation Protection Space (RPS) is the prismatic subgrade buffer zone surrounding the VVMs in a loaded ISFSI. The RPS boundary is indicated in the Licensing Drawings in Section 1.5 of the system FSAR. The RPS boundary shall not be encroached upon during any site construction activity. The jurisdictional boundary of the RPS extends down from the top of the ISFSI pad to the elevation of the Bottom surface of the Support Foundation Pad. The ISFSI design shall ensure that there is no significant loss of shielding in the RPS due to a credible accident or an extreme environment event during construction activity involving excavation adjacent to the RPS boundary.

5.4 DSC Verification Requirements Prior to storage in the HI-STORM UMAX System the following records verifications must be performed:

5.4.1 Verify through review of records that the DSC has been fabricated and loaded in accordance with the applicable limits in CoC 72-1029, including but not limited to helium backfill requirements and heat load limits.

5.4.2 Verify through review of records that the loaded DSC is within its initial 20 year license life.

5.4.3 Verify through review of records that the DSC has not undergone transportation under Part 71.

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CERTIFICATE OF COMPLIANCE NO. 1040 APPENDIX D APPROVED CONTENTS AND DESIGN FEATURES FOR THE 24PT1-DSC IN HI-STORM UMAX CANISTER STORAGE SYSTEM ATTACHMENT 3 TO HOLTEC LETTER 5021056 33 of 53

Certificate of Compliance No. 1040 Amendment No. 2 Appendix D i

TABLE OF CONTENTS 1.0 DEFINITIONS........................................................................................................ 1-1 2.0 APPROVED CONTENTS...................................................................................... 2-1 2.1 Fuel Specifications and loading conditions........................................................ 2-1 2.2 Violations........................................................................................................... 2-1 2.3 Decay Heat Limits............................................................................................. 2-5 Table 2.1-1 Fuel Assembly Limits.......................................................................... 2-2 Table 2.1-2 PWR Fuel Assembly Characteristics.................................................. 2-4 Table 2.3-1 Permissible Heat Load for long term storage...................................... 2-5 3.0 DESIGN FEATURES............................................................................................. 3-1 3.1 Site.................................................................................................................... 3-1 3.2 Design Features Important for Criticality Control............................................... 3-1 3.3 Codes and Standards........................................................................................ 3-1 3.4 Site Specific Parameters and Analyses............................................................. 3-7 3.5 Periodic Corrosion Inspections for Underground Systems.............................. 3-14 Figure 3-1 Subgrade and Undergrade Space Nomenclature................................ 3-12 Figure 3-2 Minimum Spacer Disc Ligament Widths for 24PT................................ 3-13 Table 3-1 List of ASME Code Alternatives for 24PT1-DSC.................................... 3-3 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR HI-STORM UMAX OVERPACK and HI-TRAC VW TRANSFER CASK, PRIMARY LOAD BEARING PARTS.................................................................................. 3-5 Table 3-3 LOAD COMBINATIONS FOR THE TOP SURFACE PAD, ISFSI PAD, AND SUPPORT FOUNDATION PAD PER ACI-318 (2005)................... 3-9 Table 3-4 Values of Principal Design Parameters for the Underground ISFSI...... 3-10 ATTACHMENT 3 TO HOLTEC LETTER 5021056 34 of 53

Definitions 1.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 1-1 1.0 Definitions Refer to Appendix C for Definitions.

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Approved Contents 2.0 Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-1 2.0 APPROVED CONTENTS 2.1 Fuel Specifications and Loading Conditions

a.

Fuel shall be INTACT FUEL ASSEMBLIES or DAMAGED FUEL ASSEMBLIES. DAMAGED FUEL ASSEMBLIES shall be placed in screened confinement cans (FAILED FUEL CANS) inside the 24PT1-DSC guidesleeves. DAMAGED FUEL ASSEMBLIES shall be stored in outermost guidesleeves located at the 45, 135, 225, and 315 degree azimuth locations.

b.

Fuel stored in a 24PT1-DSC must meet the requirements in Tables 2.1-1 and 2.1-2.

C 24PT1-DSCs must meet the DSC verification requirements in Appendix C, 5.4.

2.2 Violations If any Fuel Specifications or Loading Conditions of 2.1 are violated, the following actions shall be completed:

2.2.1 The affected fuel assemblies shall be placed in a safe condition.

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

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

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Approved Contents 2.0 Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-2 Table 2.1-1 (page 1 of 2)

Fuel Assembly Limits I. CANISTER MODEL: 24PT1-DSC A. Allowable Contents

1. Uranium oxide or Mixed Oxide (MOX) PWR INTACT FUEL ASSEMBLIES, and/or DAMAGED FUEL ASSEMBLIES meeting the criteria in Table 2.1-2, with or without Control Components and meeting the following specifications (Note 1,2):

a. Cladding Type:

ZR or stainless steel

b. Maximum Initial Enrichment:

As specified in Table 2.1-2

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

Cooling Time 20 years (fuel assembly and control components)

Assembly Average Burnup 45 GWD/MTU

d. Decay Heat Per Fuel Storage Location:

As specified in Section 2.3

e. Fuel Assembly Length:

138.5 inches (unirradiated length)

f. Fuel Assembly Width:

7.76 inches (nominal design)

g. Fuel Assembly Weight:

1320 lbs (including Control Components)

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Approved Contents 2.0 Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-3 Table 2.1-1 (page 2 of 2)

Fuel Assembly Limits I. MPC MODEL: 24PT1-DSC (continued)

B. Quantity per DSC:

1. A maximum of 24 INTACT WE 14x14 MOX or stainless steel clad FUEL ASSEMBLIES OR

2. Up to four WE 14x14 stainless steel clad DAMAGED FUEL ASSEMBLIES, with the balance INTACT WE 14x14 stainless steel clad FUEL ASSEMBLIES OR

3. One MOX DAMAGED FUEL ASSEMBLY with the balance INTACT WE 14x14 stainless steel clad FUEL ASSEMBLIES A 24PT1-DSC containing less than 24 fuel assemblies may contain dummy fuel assemblies in fuel assembly slots. The dummy fuel assemblies are unirradiated, stainless steel encased structures that approximate the weight and center of gravity of a fuel assembly. No more than two empty fuel assembly slots are allowed in each DSC. They must be located at symmetrical locations about the 0-180o and 90-270o axes.

No more than 14 fuel pins in each assembly may exhibit damage.

Note 1: Control Components stored integral to WE 14x14 Assemblies in a 24PT1-DSC, shall be limited to Rod Cluster Control Assemblies (RCCAs), Thimble Plug Assemblies (TPAs), and Neutron Source Assemblies (NSAs).

Note 2: Location of Control Components within a 24PT1-DSC shall be selected based on criteria which do not change the radial center of gravity by more than 0.1 inches.

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Approved Contents 2.0 Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-4 Table 2.1-2 PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly Array/ Class WE 14x14 (UO2) with or without IFBA fuel rods WE 14x14 (MOX)

Cladding Material Stainless Steel ZR No. of Fuel Rod Locations 180 180 Fuel Clad O.D. (in.)

0.422 0.422 Fuel Clad Thickness.

(in.)

0.0165 0.0243 Fuel Pellet Dia. (in.)

(Note 2) 0.3835 0.3659 Fuel Rod Pitch (in.)

0.556 0.556 Maximum Planar Average Initial Enrichment 4.05 wt. % U-235 2.84 wt.% Fissile Pu - 64 rods 3.10 wt.% Fissile Pu - 92 rods 3.31 wt.% Fissile Pu - 24 rods (Note 2)

Theoretical Density (%)

93-95 91 Active Fuel Length (in.)

120 119.4 Maximum Burnup (MWd/MTU) 45,000 25,000 Minimum Cooling Time (years) 20 20 Assembly Weight (lb) 1210 1150 No. of Guide and/or Instrument Tubes 16 16 Notes:

1. All dimensions are design nominal values. Maximum and minimum dimensions are specified to bound variations in design nominal values among fuel assemblies within a given array/class.

2. Mixed oxide assemblies contain 0.71 wt.% U-235.

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Approved Contents 2.0 Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-5 2.3 Decay Heat Limits This section provides the limits on fuel assembly decay heat for storage in the HI-STORM UMAX Canister Storage System.

2.3.1 Canister Decay Heat Limits Table 2.3-1 provides the maximum permissible decay heat under long-term storage for 24PT1-DSC in the HI-STORM UMAX System.

TABLE 2.3-1 PERMISSIBLE HEAT LOAD FOR LONG-TERM STORAGE Fuel Type Permissible Heat Load per Storage Cell (kW)

Permissible Aggregate Heat Load (kW) (Note 1)

WE 14x14 (UO2) with or without IFBA fuel rods 0.583 14.0 WE 14x14 (MOX) 0.294 13.706 Notes:

1. Aggregate heat load is defined as the sum of heat loads of all stored fuel assemblies, including integral control components.

2.3.2 When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.

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Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-1 3.0 DESIGN FEATURES 3.1 Site 3.1.1 Site Location The HI-STORM UMAX Canister Storage System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.

3.3 Codes and Standards The 24PT1-DSC is designed, fabricated, and inspected to the maximum practical extent in accordance with ASME Boiler and Pressure Vessel Code Section III, Division 1, 1992 Edition with Addenda through 1994, including exceptions allowed by Code Case-595-1, Subsections NB, NF, and NG for Class 1 components and supports, as clarified in Specification 3.3.1.

The HI-STORM UMAX VVM is structurally qualified per the newer 2010 ASME code.

The ASME Code paragraphs applicable to the manufacturing of HI-STORM UMAX VVM and transfer cask are listed in Table 3-2. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the applicable edition (including addenda) specified above, is performed by the certificate holder.

American Concrete Institute ACI-318 (2005) is the governing Code for both plain concrete and reinforced concrete as clarified in Chapter 3 of the Final Safety Analysis Report for the HI-STORM UMAX System.

3.3.1 Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the 24PT1-DSC within the HI-STORM UMAX Canister Storage System.

3.3.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code, including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternative should demonstrate that:

1.

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

2.

Compliance with the specified requirements of the ASME Codes listed in Section 3.3, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

(continued)

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Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-2 3.0 DESIGN FEATURES (continued)

TABLE 3-1 List of ASME Code Alternatives for 24PT1-DSC Component Reference ASME Code Section/Article Code Requirement Alternative, Justification & Compensatory Measures DSC Shell Assembly NCA All Not compliant with NCA NB-1100 Requirements for Code Stamping of Components The DSC shell is designed & fabricated in accordance with the ASME Code,Section III, Subsection NB to the maximum extent practical. However, Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp, or to be ASME Certified.

NB-2130 NB-4121 Material must be supplied by ASME approved material suppliers Material Certification by Certificate Holder All materials designated as ASME on the UFSAR drawings are obtained from ASME approved MM or MS supplier(s) with ASME CMTRs. Material is certified to meet all ASME Code criteria but is not eligible for certification or Code Stamping if a non-ASME fabricator is used. As the fabricator is not required to be ASME certified, material certification to NB-2130 is not possible. Material traceability &

certification are maintained in accordance with an NRC approved QA program NB-6111 All completed pressure retaining systems shall be pressure tested The shield plug support ring and vent and siphon block are not pressure tested due to the manufacturing sequence. The support ring is not a pressure-retaining item and the siphon block weld is helium leak tested after fuel is loaded and the inner top closure plate installed in accordance with Code Case N-595-1.

NB-7000 Overpressure Protection No overpressure protection is provided for the DSC.

The function of the DSC is to contain radioactive materials under normal, off-normal and hypothetical accident conditions postulated to occur during transportation and storage. The DSC s designed to withstand the maximum internal pressure considering 100% fuel rod failure at maximum accident temperature. The DSC is pressure tested to 120% of normal operating design pressure. An overpressure protection report is not prepared for the DSC.

NB-8000 Requirements for nameplates, stamping &

reports per NCA-8000 The DSC nameplate provides the information required by 10CFR Part 71, 49 CFR Part 173 and 10 CFR Part 72 as appropriate. Code stamping is not required for the DSC. In lieu of code stamping, QA Data packages are prepared in accordance with the requirements of 10 CFR Part 71, 10 CFR Part 72, and an NRC approved QA Program.

ATTACHMENT 3 TO HOLTEC LETTER 5021056 42 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-3 TABLE 3-1 List of ASME Code Alternatives for 24PT1-DSC Component Reference ASME Code Section/Article Code Requirement Alternative, Justification & Compensatory Measures 24PT1 Basket NCA All Not compliant with NCA.

NG/NF-1100 Requirements for Code Stamping of Components The DSC baskets are designed & fabricated in accordance with the ASME Code,Section III, Subsection NG/NF to the maximum extent practical as described in the UFSAR, but Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp or be ASME Certified.

NG/NF-2130 NG/NF-4121 Material must be supplied by ASME approved material suppliers Material Certification by Certificate Holder All materials designated as ASME on the UFSAR drawings are obtained from ASME approved MM or MS supplier with ASME CMTRs. Material is certified to meet all ASME Code criteria but is not eligible for certification or Code Stamping if a non-ASME fabricator is used. As the fabricator is not required to be ASME certified, material certification to NG/NF-2130 is not possible. Material traceability & certification are maintained in accordance with an NRC approved QA program.

Table NG-3352-1 Permissible Joint Efficiency Factors Joint efficiency (quality) factor of 1 is assumed for the guidesleeve longitudinal weld. Table NG-3352 permits a quality factor of 0.5 for full penetration weld with visual inspection. Inspection of both faces provides n=(2*0.5)=1. This is justified by this gauge of material (0.12 inch) with visual examination of both surfaces which ensures that any significant deficiencies would be observed and corrected.

NG/NF-8000 Requirements for nameplates, stamping &

reports per NCA-8000 The DSC nameplate provides the information required by 10 CFR Part 71, 49 CFR Part 173 and 10 CFR Part 72 as appropriate. Code stamping is not required for the DSC. In lieu of code stamping, QA Data packages are prepared in accordance with the requirements of 10 CFR Part 71, 10 CFR Part 72 and an NRC approved QA program.

N/A N/A Oversleeve to guidesleeve welds are non-code welds which meet the requirements of AWS D1.3-98, the Structural Welding Code-Sheet Steel.

ATTACHMENT 3 TO HOLTEC LETTER 5021056 43 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-4 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR VVM PRIMARY LOAD BEARING PARTS Item Code Paragraph

[2.6.1]

Explanation and Applicability

1.

Definition of primary and secondary members NF-1215

2.

Jurisdictional boundary NF-1133 The VVMs jurisdictional boundary is defined by the bottom surface of the SFP, the top surface of the ISFSI pad and the SES side surfaces.

3.

Certification of material(structural)

NF-2130(b) and (c)

Materials shall be certified to the applicable Section II of the ASME Code or equivalent ASTM Specification.

4.

Heat treatment of material NF-2170 and NF-2180

5.

Storage of welding material NF-2400

6.

Welding procedure Section IX

7.

Welding material Section II

8.

Loading conditions NF-3111

9.

Allowable stress values NF-3112.3

10.

Rolling and sliding supports NF-3424

11.

Differential thermal expansion NF-3127

12.

Stress analysis NF-3143 NF-3380 NF-3522 NF-3523 Provisions for stress analysis for Class 3 plate and shell supports and for linear supports are applicable for Closure Lid and Container Shell, respectively.

13.

Cutting of plate stock NF-4211 NF-4211.1

14.

Forming NF-4212

15.

Forming tolerance NF-4221 Applies to the Container Shell

16.

Fitting and Aligning Tack Welds NF-4231 NF-4231.1

17.

Alignment NF-4232

18.

Storage of Welding Materials NF-4411

19.

Cleanliness of Weld Surfaces NF-4412 Applies to structural and non-structural welds ATTACHMENT 3 TO HOLTEC LETTER 5021056 44 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-5 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR VVM PRIMARY LOAD BEARING PARTS Item Code Paragraph

[2.6.1]

Explanation and Applicability

20.

Backing Strips, Peening NF-4421 NF-4422 Applies to structural and non-structural welds

21.

Pre-heating and Interpass Temperature NF-4611 NF-4612 NF-4613 Applies to structural and non-structural welds

22.

Non-Destructive Examination NF-5360 InvokesSection V

23.

NDE Personnel Certification NF-5522 NF-5523 NF-5530 ATTACHMENT 3 TO HOLTEC LETTER 5021056 45 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-6 3.0 DESIGN FEATURES (continued) 3.4 Site-Specific Parameters and Analyses Site-specific parameters and analyses that will require verification by the system user are, as a minimum, as follows:

1.

The temperature of 80o F is the maximum average yearly temperature.

2.

The allowed temperature extremes, averaged over a 3-day period, shall be greater than -40o F and less than 125o F.

3.

The resultant zero period acceleration at the top of the grade and at the elevation of the Support Foundation Pad (SFP) at the host site (computed by the Newmarks rule as the sum of A+0.4*B+0.4*C, where A, B, C denote the free field ZPAs in the three orthogonal directions in decreasing magnitude, i.e., A B C) shall be less than or equal to 1.3 and 1.214, respectively.

For HI-STORM UMAX Version MSE, the corresponding Newmark sum of the ZPAs at the top of the Support Foundation Pad is limited to 2.121 Gs and the vertical ZPA is limited to 1.0G.

4.

The analyzed flood condition of 15 fps water velocity and a height of 125 feet of water (full submergence of the loaded cask) are not exceeded.

5.

The potential for fire and explosion shall be based on site-specific considerations. The user shall demonstrate that the site-specific potential for fire is bounded by the fire conditions analyzed by the Certificate Holder, or an analysis of the site-specific fire considerations shall be performed.

6.

The moment and shear capacities of the ISFSI Structures shall meet the structural requirements under the load combinations in Table 3-3.

7.

Radiation Protection Space (RPS) as defined in Subsection 5.3.9 of Appendix C, is intended to ensure that the subgrade material in and around the lateral space occupied by the VVMs remains essentially intact under all service conditions including during an excavation activity adjacent to the RPS.

8.

The SFP for a VVM array established in any one construction campaign shall be of monolithic construction, to the extent practicable, to maximize the physical stability of the underground installation.

9.

Excavation activities contiguous to a loaded UMAX ISFSI on the side facing the excavation can occur down to the depth of the bottom surface of the SFP of the loaded ISFSI (i.e. within the area labeled Space B in Figure 3-1) considering that there may be minor variations in the depth due to normal construction practices. For excavation activities which are contiguous to the loaded ISFSI and below the depth of the bottom surface of the SFP (i.e. within the area labeled Space D in Figure 3-1), a site-specific seismic analysis will be performed to demonstrate the stability of the RPS boundary and structural integrity of the ISFSI structure. This ATTACHMENT 3 TO HOLTEC LETTER 5021056 46 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-7 analysis shall be submitted to Holtec International to be incorporated in an amendment request for NRC review and approval prior to any excavation taking place.

10.

In cases where engineered features (i.e., berms and shield walls) are used to ensure that the requirements of 10CFR72.104(a) are met, such features are to be considered important-to-safety and must be evaluated to determine the applicable quality assurance category.

11.

TRANSPORT OPERATIONS shall only be conducted with working area Ambient Temperature 0o F.

12.

For those users whose site-specific design basis includes an event or events (e.g., flood) that result in the blockage of any VVM inlet or outlet air ducts for an extended period of time (i.e., longer than the total Completion Time of LCO 3.1.2), an analysis or evaluation may be performed to demonstrate adequate heat removal is available for the duration of the event. Adequate heat removal is defined as fuel cladding temperatures remaining below the short term temperature limit. If the analysis or evaluation is not performed, or if fuel cladding temperature limits are unable to be demonstrated by analysis or evaluation to remain below the short term temperature limit for the duration of the event, provisions shall be established to provide alternate means of cooling to accomplish this objective.

13.

The entire haul route shall be evaluated to ensure that the route can support the weight of the loaded transfer cask and its conveyance.

14.

The loaded transfer cask and its conveyance shall be evaluated to ensure, under the site specific Design Basis Earthquake, that the cask and its conveyance does not tipover or slide off the haul route.

(continued)

ATTACHMENT 3 TO HOLTEC LETTER 5021056 47 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-8 DESIGN FEATURES (continued)

Table 3-3 LOAD COMBINATIONS FOR THE TOP SURFACE PAD, ISFSI PAD, AND SUPPORT FOUNDATION PAD PER ACI-318 (2005)

Load Combination Case Load Combination LC-1 1.4D LC-2 1.2D + 1.6L LC-3 1.2D + E + L where:

D:

Dead Load including long-term differential settlement effects.

L:

Live Load E:

DBE for the Site ATTACHMENT 3 TO HOLTEC LETTER 5021056 48 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-9 DESIGN FEATURES (continued)

Table 3-4 Values of Principal Design Parameters for the Underground ISFSI Thickness of the Support Foundation Pad, inch (nominal) 33 Thickness of the ISFSI Pad and curb, inch (nominal) 34 Thickness of the ISFSI Pad, inch (nominal) 30 Rebar Size* and Layout* (nominal)

11 @ 9" each face, each direction Rebar Concrete Cover (top and bottom)*, inch per 7.7.1 of ACI-318 (2005)

Compressive Strength of Concrete at 28 days*, psi 4500 Compressive Strength of Subgrade, psi For Version MSE only, the Compressive Strength of Subgrade, psi 1,000 3,000 Lower Bound Shear Wave Velocity in the Subgrade lateral to the VVM (Figure 3-1 Space A), fps**

1,300 Depth Averaged Density of subgrade in Space A. (Figure 3-1)1 (lb/ft3) 120 Depth Averaged Density of subgrade in Space B. (Figure 3-1)1 (lb/ft3) 110 Depth Averaged Density of subgrade in Space C. (Figure 3-1)2 (lb/ft3) 120 Depth Averaged Density of subgrade in Space D. (Figure 3-1)3 (lb/ft3) 120 Lower Bound Shear Wave Velocity in the Subgrade below the Support Foundation Pad (Figure 3-1 Space C & D), fps**

485 ATTACHMENT 3 TO HOLTEC LETTER 5021056 49 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-10 Lower Bound Shear Wave Velocity in the Subgrade laterally surrounding the ISFSI (Figure 3-1 Space B), fps**

For Version MSE only, Nominal Strain compatible Shear wave Velocity in Space B, fps 450 344

Applies to Support Foundation Pad and ISFSI Pad.

- Strain compatible effective shear wave velocities shall be computed using the guidance provided in Section 16 of the International Building Code, 2009 Edition. Users must account for potential variability in the subgrade shear wave velocity in accordance with Section 3.7.2 of NUREG-0800.

Notes:

1. A lower average density value may be used in shielding analysis per FSAR Chapter 5 for conservatism.

2. Not required for shielding, not credited in Version MSE model.

This space will typically contain native soil. Not required for shielding, not credited in Version MSE model.

ATTACHMENT 3 TO HOLTEC LETTER 5021056 50 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-11 Figure 3 SUBGRADE AND UNDERGRADE SPACE NOMENCLATURE ATTACHMENT 3 TO HOLTEC LETTER 5021056 51 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-12 ATTACHMENT 3 TO HOLTEC LETTER 5021056 52 of 53

Design Features 3.0 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-13 3.0 DESIGN FEATURES (continued) 3.5 Periodic Corrosion Inspections for Underground Systems HI-STORM UMAX VVM ISFSIs not employing an impressed current cathodic protection system shall be subject to visual and UT inspection of at least one representative VVM to check for significant corrosion of the CEC Container Shell and Bottom Plate at an interval not to exceed 20 years. The VVM chosen for inspection is not required to be in use or to have previously contained a loaded MPC. The VVM considered to be most vulnerable to corrosion degradation shall be selected for inspection. If significant corrosion is identified, either an evaluation to demonstrate sufficient continued structural integrity (sufficient for at least the remainder of the licensing period) shall be performed or the affected VVM shall be promptly scheduled for repair or decommissioning. Through wall corrosion shall not be permitted without promptly scheduling for repair or decommissioning. Promptness of repair or decommissioning shall be commensurate with the extent of degradation of the VVM but shall not exceed 3 years from the date of inspection.

If the representative VVM is determined to require repair or decommissioning, the next most vulnerable VVM shall be selected for inspection. This inspection process shall conclude when a VVM is found that does not require repair or decommissioning. Since the last VVM inspected is considered more prone to corrosion than the remaining un-inspected VVMs, the last VVM inspected becomes the representative VVM for the remaining VVMs.

Inspections Visual Inspection: Visual inspection of the inner surfaces of the CEC Container Shell and Bottom Plate for indications of significant or through wall corrosion (i.e.,

holes).

UT Inspection: A UT inspection or an equivalent method shall be used to measure CEC shell wall thickness to determine the extent of metal loss from corrosion. A minimum of 16 data points shall be obtained, 4 near the top, 4 near the mid-height and 4 near the bottom of the CEC Container Shell all approximately 0, 90, 180, and 270 degrees apart; and 4 on the CEC Bottom Plate near the CEC Container Shell approximately 0, 90, 180, and 270 degrees apart. Locations where visual inspection has identified potentially significant corrosion shall also receive UT inspection. Locations suspected of significant corrosion may receive further UT inspection to determine the extent of corrosion.

Inspection Criteria General wall thinning exceeding 1/8 in depth and local pitting exceeding 1/4" in depth are conditions of significant corrosion.

ATTACHMENT 3 TO HOLTEC LETTER 5021056 53 of 53

ML20002A310

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