ML20052D791

Attachment 2 - Proposed CoC Pages - (Non-Proprietary)

ML20052D791
Person / Time
Site:	07201032
Issue date:	02/07/2020
From:	Office of Nuclear Material Safety and Safeguards
To:	Holtec
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ML20052D786	List: ML20052D791
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5018075
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NRC FORM 651 ATTACHMENT 2 TO HOLTEC LETTER 5018075 U.S. NUCLEAR REGULATORY COMMISSION (10-2004) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Page 1 of 4 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 Expiration Date Docket No. Amendment No. Amendment Effective Date Package Identification No.

Date 1032 TBD June 12, 72-1032 7 TBD USA/72-1032 2031 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 FW MPC 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 FW MPC Storage System DESCRIPTION:

The HI-STORM FW MPC Storage System consists of the following components: (1) interchangeable multi-purpose canisters (MPCs), which contain the fuel; (2) a storage overpack (HI-STORM FW), which contains the MPC during storage; and (3) a transfer cask (HI-TRAC VW), which contains the MPC during loading, unloading and transfer operations. The MPC stores up to 37 pressurized water reactor fuel assemblies or up to 89 boiling water reactor fuel assemblies.

The HI-STORM FW MPC Storage System is certified as described in the Final Safety Analysis Report (FSAR) 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.

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ATTACHMENT 2 TO HOLTEC LETTER 5018075 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1032 FOR SPENT FUEL STORAGE CASKS Amendment No. 5 Supplemental Sheet Page 2 of 4 DESCRIPTION (continued)

There are three types of MPCs: the MPC-37, MPC-89 and MPC-32ML. The number suffix indicates the maximum number of fuel assemblies permitted to be loaded in the MPC. All MPC models have the same external diameter.

The HI-TRAC VW transfer cask provides shielding and structural protection of the MPC during loading, unloading, and movement of the MPC from the cask loading area to the storage overpack. The transfer cask is a multi-walled (carbon steel/lead/carbon steel) cylindrical vessel with a neutron shield jacket or neutron shield cylinder attached to the exterior and a retractable bottom lid used during transfer operations.

The HI-STORM FW storage overpack provides shielding and structural protection of the MPC during storage.

The overpack is a heavy-walled steel and concrete, cylindrical vessel. Its side wall consists of plain (un-reinforced) concrete that is enclosed between inner and outer carbon steel shells. The overpack has air inlets at the bottom and air outlets at the top to allow air to circulate naturally through the cavity to cool the stored MPC. The inner shell has supports attached to its interior surface to guide the MPC during insertion and removal and provide a means to protect the MPC confinement boundary against impactive or impulsive loadings. A loaded MPC is stored within the HI-STORM FW storage overpack in a vertical orientation.

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 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 of the FSAR. At completion of welding the MPC shell to baseplate, an MPC confinement weld helium leak test shall be performed using a helium mass spectrometer. 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.

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, a HI-TRAC VW transfer cask, or any HI-STORM FW overpack 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.

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ATTACHMENT 2 TO HOLTEC LETTER 5018075 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1032 FOR SPENT FUEL STORAGE CASKS Amendment No. 5 Supplemental Sheet Page 3 of 4

5. APPROVED CONTENTS Contents of the HI-STORM FW MPC Storage System must meet the fuel specifications given in Appendix B to this certificate.

6. DESIGN FEATURES Features or characteristics for the site or system must be in accordance with Appendix B to this certificate.

7. CHANGES TO THE CERTIFICATE OF COMPLIANCE The holder of this certificate who desires to make changes to the certificate, which includes Appendix A (Technical Specifications) and Appendix B (Approved Contents and Design Features), shall submit an application for amendment of the certificate.

8. SPECIAL REQUIREMENTS FOR FIRST SYSTEMS IN PLACE The air mass flow rate through the cask system will be determined by direct measurements of air velocity in the overpack cooling passages for the first HI-STORM FW MPC Cask System placed into service by any user with a heat load equal to or greater than 30 kW. The velocity will be measured using direct measurements of air velocity in the inlet vents. An analysis shall be performed of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR.

The thermal validation test and analysis results shall be submitted in a letter report to the NRC pursuant to 10 CFR 72.4. To satisfy condition 8 for casks of the same system type, in lieu of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed test and analysis submitted by letter report to the NRC that demonstrates validation of the analytic methods described in Chapter 4 of the FSAR.

9. PRE-OPERATIONAL TESTING AND TRAINING EXERCISE A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM FW MPC 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 FW MPC 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.

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 overpack.

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ATTACHMENT 2 TO HOLTEC LETTER 5018075 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1032 FOR SPENT FUEL STORAGE CASKS Amendment No. 5 Supplemental Sheet Page 4 of 4

h. Placement of the HI-STORM FW MPC Storage System at the ISFSI.

i. HI-STORM FW MPC 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 they have already been successfully carried out at a site to load a HI-STORM 100 System (USNRC Docket 72-1014).

10. AUTHORIZATION The HI-STORM FW MPC 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 and B. The HI-STORM FW MPC Storage System may be fabricated and used in accordance with any approved amendment to CoC No. 1032 listed in 10 CFR 72.214.

Each of the licensed HI-STORM FW MPC Storage System components (i.e., the MPC, 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. The HI-STORM FW MPC Storage System may be installed on an ISFSI pad with the HI-STORM 100 Cask System (USNRC Docket 72-1014) provided an assessment is performed by the CoC holder that demonstrates design compatibility.

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

1. Appendix A

2. Appendix B 4 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 CERTIFICATE OF COMPLIANCE NO. 1032 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM FW MPC STORAGE SYSTEM 5 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 SFSC Heat Removal System 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlets are free 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is:

137oF for OVERPACKS containing MPC-37s, 168oF for OVERPACKS containing MPC-89s, 130 oF for OVERPACKS containing MPC-32MLs Certificate of Compliance No. 1032 Amendment No. 7 Appendix A 3.1.2-2 6 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 3.4 Tables Table 3-1 MPC Cavity Drying Limits Note 6 Method of Fuel Moisture Burnup MPC Type MPC Heat Load (kW)

Removal (MWD/MTU)

(Notes 1 and 2) 44.09 (Pattern A in Tables 2.3-1A, B, C of Appendix B) 45.00 (Pattern B in Table 2.3-1A of Appendix B) 37.4 (Figures 2.3-1 through 2.3-3 of MPC-37 Appendix B) 39.95 (Figures 2.3-4 through 2.3-6 of Appendix B)

All 44.85 (Figures 2.3-7 through 2.3-9 VDS (Notes 3 Assemblies of Appendix B) and 4) or FHD 45,000 (Note 4) 44.16 (Pattern A in Table 2.3-5 of MPC-32ML Appendix B) 46.36 (Table 2.3-2A of Appendix B) 46.2 (Figures 2.3-10 and 2.3-11 of Appendix B)

MPC-89 46.14 (Figures 2.3-12 and 2.3-13 of Appendix B) 48.48 (Figure 2.3-14 of Appendix B)

MPC-37 29.6 (Table 2.3-3 of Appendix B)

One or more VDS (Notes 3 28.70 (Pattern B in Table 2.3-5 of assemblies MPC-32ML and 4) or FHD Appendix B)

> 45,000 (Note 4)

MPC-89 30.0 (Table 2.3-4 of Appendix B)

Certificate of Compliance No. 1032 Amendment No. 7 Appendix A 3.4-1 7 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 3.4 Tables Method of Fuel Moisture Burnup MPC Type MPC Heat Load (kW)

Removal (MWD/MTU)

(Notes 1 and 2) 44.09 (Pattern A in Tables 2.3-1A, B, C of Appendix B) 45.00 (Pattern B in Table 2.3-1A of Appendix B) 37.4 (Figures 2.3-1 through 2.3-3 of MPC-37 Appendix B) 39.95 (Figures 2.3-4 through 2.3-6 of Appendix B) 44.85 (Figures 2.3-7 through 2.3-9 One or more of Appendix B) VDS (Notes 3, 4, assemblies and 5) or FHD

> 45,000 44.16 (Pattern A in Table 2.3-5 of (Note 4)

MPC-32ML Appendix B) 46.36 (Table 2.3-2A of Appendix B) 46.2 (Figures 2.3-10 and 2.3-11 of Appendix B)

MPC-89 46.14 (Figures 2.3-12 and 2.3-13 of Appendix B) 48.48 (Figure 2.3-14 of Appendix B)

Notes:

1. VDS means a vacuum drying system. The acceptance criterion when using a VDS is the MPC cavity pressure shall be 3 torr for 30 minutes while the MPC is isolated from the vacuum pump.

2. FHD means a forced helium dehydration system. The acceptance criterion when using an FHD system is the gas temperature exiting the demoisturizer shall be 21oF for 30 minutes or the gas dew point exiting the MPC shall be 22.9oF for 30 minutes.

3. Vacuum drying of the MPC must be performed with the annular gap between the MPC and the TRANSFER CASK filled with water.

4. Heat load limits are set for each cell; see Appendix B Section 2.3.

Certificate of Compliance No. 1032 Amendment No. 7 Appendix A 3.4-2 8 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 3.4 Tables

5. Vacuum drying of the MPC must be performed using cycles of the drying system, according to the guidance contained in ISG-11 Revision 3. The time limit for these cycles shall be determined based on site specific conditions.

6. If the Holtec Thermal Topical Report is utilized to develop loading patterns, the limits in this table do not apply.

Certificate of Compliance No. 1032 Amendment No. 7 Appendix A 3.4-3 9 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 3.4 Tables Table 3-2 MPC Helium Backfill Limits Note 1, 2 Decay Heat Limits Applied Pressure range MPC Model (per Appendix B Section 2.3) (psig)

Table 2.3-1C 42.0 and 50.0 Table 2.3-3 Table 2.3-1B 42.0 and 47.8 Table 2.3-1A, Pattern A 42.0 and 45.5 Table 2.3-1A, Pattern B 41.0 and 46.0 MPC-37 Figure 2.3-1 Figure 2.3-2 45.5 and 49.0 Figure 2.3-3 Figure 2.3-4 Figure 2.3-5 44.0 and 47.5 Figure 2.3-6 Figure 2.3-7 Figure 2.3-8 44.5 and 48.0 Figure 2.3-9 Table 2.3-2B 42.0 and 50.0 Table 2.3-4 Table 2.3-2A 42.5 and 47.5 MPC-89 Figure 2.3-10 Figure 2.3-11 42.0 and 47.0 Figure 2.3-12 Figure 2.3-13 Figure 2.3-14 42.0 and 46.0 MPC-32ML Table 2.3-5, All Patterns 41.5 and 45.5 Notes:

1. Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF.

2. If the Holtec Thermal Topical Report is utilized to develop loading patterns, the limits in this table do not apply.

Certificate of Compliance No. 1032 Amendment No. 7 Appendix A 3.4-4 10 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 CERTIFICATE OF COMPLIANCE NO. 1032 APPENDIX B APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM FW MPC STORAGE SYSTEM 11 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 Figure 2.3-6 Loading Pattern 37D3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Standard Fuel per Cell Heat Load Limits.......................................................... 2-31 Figure 2.3-7 Loading Pattern 37E1 for MPC-37 Loading Pattern for MPCs Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits ..................... 2-32 Figure 2.3-8 Loading Pattern 37E2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Long Fuel per Cell Heat Load Limits ....................................................................................... 2-33 Figure 2.3-9 Loading Pattern 37E3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits.................................................................. 2-34 Figure 2.3-10 Loading Pattern 89A1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits ....................................................................................... 2-35 Figure 2.3-11 Loading Pattern 89A2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits ................................................................................. .2-36 Figure 2.3-12 Loading Pattern 89B1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per cell Heat Load Limits..2-37 Figure 2.3-13 Loading Pattern 89B2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits..2-38 Figure 2.3-14 Loading Pattern 89C1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits..2-39 Table 2.4-1 Polynomial Functions for Minimum Burnup as a Function of Initial Enrichment .. 2-41 Table 2.4-2 Burnup Credit Configurations . 2-42 Table 2.4-3 In-Core Operating Requirements . .2-43 Table 2.5-1 Burnup and Cooling Time Fuel Qualification Requirements for MPC-32ML........................................................................................ 2-44 Table 2.5-2 Burnup and Cooling Time Fuel Qualification Requirements for MPC-37 And MPC-89 ..................................................................................... 2-45 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 ........................................................................................ 3-2 3.4 Site Specific Parameters and Analyses ........................................................... 3-11 3.5 Combustible Gas Monitoring During MPC Lid Welding and Cutting ................ 3-14 Certificate of Compliance No. 1032 Amendment No. 7 Appendix B ii 12 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 Approved Contents 2.0 2.3 Decay Heat Limits This section provides the limits on fuel assembly decay heat for storage in the HI-STORM FW System. The method to verify compliance, including examples, is provided in Chapter 13 of the HI-STORM FW FSAR. If a heat load pattern is established following the Holtec Thermal Methodology Topical report, the following decay heat limits in Section 2.3.1 do not apply.

2.3.1 Fuel Loading Decay Heat Limits Tables 2.3-1A, 2.3-1B, and 2.3-1C provide the maximum allowable decay heat per fuel storage location for MPC-37. Tables 2.3-2A and 2.3-2B provide the maximum allowable decay heat per fuel storage location for MPC-89. No drying time limits are required for decay heat values meeting the limits in these tables when using FHD to dry moderate or high burnup fuel and when using VDS to dry moderate burnup fuel. Drying time limits apply when using VDS to dry high burnup fuel with decay heat values meeting the limits in these tables. Tables 2.3-3 and 2.3-4 provide the maximum allowable decay heat per fuel storage location for MPC-37 and MPC-89, respectively, with no drying time limits imposed, when using VDS to dry high burnup fuel. Table 2.3-5 provides the maximum allowable decay heat per fuel storage location for the MPC-32ML for both FHD and VDS drying. The per cell limits in these tables apply to cells containing undamaged fuel or damaged fuel in DFCs/DFIs or fuel debris in DFCs.

Figures 2.3-1 through 2.3-14 provide alternative loading patterns for the MPC-37 and MPC-89, with undamaged fuel and a combination of undamaged fuel and damaged fuel in DFCs/DFIs and fuel debris in DFCs.

The per cell limits in these figures are applicable when using vacuum drying or FHD to dry moderate or high burnup fuel in accordance with Table 3-1 of Appendix A of the CoC. The MPC-37 patterns are based on the fuel length to be stored in the MPC, see Table 2.3-6.

A minor deviation from the prescribed loading pattern in an MPCs permissible contents to allow one slightly thermally-discrepant fuel assembly per quadrant to be loaded as long as the peak cladding temperature for the MPC remains below the ISG-11 Rev 3 requirements is permitted for essential dry storage campaigns to support decommissioning.

Certificate of Compliance No. 1032 Amendment No. 7 Appendix B 2-21 13 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 Approved Contents 2.0 1.665 1.665 0.20 (D/F) (D/F) 0.12 0.12 0.19 0.425 1.44 0.425 0.19 (D/F) (D/F) 0.35 0.35 0.16 1.06 0.315 0.35 0.315 1.06 0.16 (D/F) (D/F) 0.18 1.06 0.265 0.285 0.34 0.285 0.265 1.06 0.18 1.665 1.665 0.595 0.315 0.27 0.65 0.165 0.65 0.27 0.315 0.595 (D/F) (D/F) 0.20 1.445 0.385 0.34 0.17 0.125 0.17 0.34 0.385 1.445 0.20 1.665 1.665 0.595 0.315 0.27 0.65 0.165 0.65 0.27 0.315 0.595 (D/F) (D/F) 0.18 1.06 0.265 0.285 0.34 0.285 0.265 1.06 0.18 0.35 0.35 0.16 1.06 0.315 0.35 0.315 1.06 0.16 (D/F) (D/F) 0.12 0.12 0.19 0.425 1.44 0.425 0.19 (D/F) (D/F) 1.665 1.665 0.20 (D/F) (D/F)

Figure 2.3-14 Loading Pattern 89C1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.)

Certificate of Compliance No. 1032 Amendment No. 7 Appendix B 2-39 14 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 Approved Contents 2.0 2.5 Burnup and Cooling Time Fuel Qualification Requirements Burnup and cooling time limits for fuel assemblies authorized for loading into MPC-32ML are provided in Table 2.5-1. Burnup and cooling time limits for fuel assemblies authorized for loading according to the alternative loading patterns shown in Figures 2.3-1 through 2.3-9 (MPC-37) and Figures 2.3-10 through 2.3-14 (MPC-89) are provided in Table 2.5-2.

The burnup and cooling time for every fuel loaded into the MPC-32ML, MPC-37 and MPC-89 must satisfy the following equation:

Ct = A

• Bu3 + B

• Bu2 + C

• Bu + D

where, Ct = Minimum cooling time (years)

Bu = Assembly-average burnup (MWd/mtU)

A, B, C, D = Polynomial coefficients listed in the Tables 2.5-1 and 2.5-2 Minimum cooling time must also meet limits specified in Table 2.1-1. If the calculated Ct is less than the cooling time limit in Table 2.1-1, the minimum cooling time in Table 2.1-1 is used.

TABLE 2.5-1 BURNUP AND COOLING TIME FUEL QUALIFICATION REQUIREMENTS FOR MPC-32ML A B C D 6.7667E-14 -3.6726E-09 8.1319E-05 2.7951E+00 Certificate of Compliance No. 1032 Amendment No. 7 Appendix B 2-44 15 of 16

ATTACHMENT 2 TO HOLTEC LETTER 5018075 Approved Contents 2.0 TABLE 2.5-2 BURNUP AND COOLING TIME FUEL QUALIFICATION REQUIREMENTS FOR MPC-37 AND MPC-89 Polynomial Coefficients Cell Decay Heat Load Limit (kW) A B C D (Note 1)

MPC-37 0.85 1.68353E-13 -9.65193E-09 2.69692E-04 2.95915E-01 0.85 < decay heat 3.5 1.19409E-14 -1.53990E-09 9.56825E-05 -3.98326E-01 MPC-89 0.32 1.65723E-13 -9.28339E-09 2.57533E-04 3.25897E-01 0.32 < decay heat 0.39 1.61236E-13 -1.24069E-08 3.67868E-04 -7.11229E-01 0.39 < decay heat 0.5 3.97779E-14 -2.80193E-09 1.36784E-04 3.04895E-01 0.5 < decay heat 0.65 2.16783E-14 -1.83483E-09 1.02512E-04 3.41558E-01 0.65 < decay heat 0.75 1.44353E-14 -1.21525E-09 8.14851E-05 3.31914E-01 0.75 < decay heat 1.1 -7.45921E-15 1.09091E-09 -1.14219E-05 9.76224E-01 1.1 < decay heat 1.45 3.10800E-15 -7.92541E-11 1.56566E-05 6.47040E-01 1.45 < decay heat 1.6 -8.08081E-15 1.23810E-09 -3.48196E-05 1.11818E+00 1.6 < decay heat 1.67 -2.69360E-15 6.46465E-10 -1.83165E-05 1.01818E+00 NOTES:

1. For BLEU fuel, coefficient D is increased by 1.

Certificate of Compliance No. 1032 Amendment No. 7 Appendix B 2-45 16 of 16