ML20108E929

NRC-2020-000169 - Resp 1 - Final, Agency Records Subject to the Request Are Enclosed. Part 9 of 9

ML20108E929
Person / Time
Issue date:	04/15/2020
From:	NRC/OCIO
To:
Shared Package
ML20108E919	List: ML20108E920 ML20108E921 ML20108E922 ML20108E923 ML20108E924 ML20108E925 ML20108E926 ML20108E927 ML20108E928 ML20108E929
References
FOIA, NRC-2020-000169
Download: ML20108E929 (35)

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AOL I EC PROPRIE I ARV INFORMATION HI-STORM FW SYSTEM FSAR APPENDIX 13.A TECHNICAL SPECIFICATION BASES FOR THE HOLTEC HI-STORM FW MPC STORAGE SYSTEM HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-l HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION BASES TABLE OF CONTENTS B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY .......... 13.A-3 B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ......................... 13.A-6 B 3.1 SFSC INTEGRITY ................................................................................... 13.A-11 B 3.1.1 Multi-Purpose Canister (MPG) ................................................................. 13.A-11 B 3.1.2 SFSC Heat Removal System ................................................................... 13.A-1?

B 3.1.3 MPC Cavity Reflooding ............................................................................ 13.A-22 B 3.2 SFSC RADIATION PROTECTION ......................................................... 13.A-25 B 3.2.1 TRANSFER CASK Surface Contamination ............................................. 13.A-25 B 3.3 SFSC CRITICALITY CONTROL .............................................................. 13.A-28 B 3.3.1 Boron Concentration ................................................................................ 13.A-28 HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-2 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

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

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

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

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

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

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

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-3 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

lelObTi;C PROPRIETARY INFORMATION LCO Applicability B 3.0 BASES LCO 3.0.2 Completing the Required Actions is not required when an LCO is met or (continued) is no longer applicable, unless otherwiise stated in the individual Specifications.

The Completion Times of the Required Actions are also applicable when a system or component is removed from service intentionally. The reasons for intentionally relying on the ACTIONS include, but are not limited to, performance of Surveillances, preventive maintenance, corrective maintenance, or investigation of operational problems.

Entering ACTIONS for these reasons must be done in a manner that does not compromise safety. Intentional entry into ACTIONS should not be made for operational convenience.

LCO 3.0.3 This specification is not applicable to a dry storage cask system because it describes conditions under which a power reactor must be shut down when an LCO is not met and an associated ACTION is not met or provided. The placeholder is retained for consistency with the power reactor technical specifications.

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

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

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

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

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-4 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

HO! rec PROPRIETARY INFORMATION LCO Applicability B 3.0 BASES LCO 3.0.4 The provisions of LCO 3.0.4 shall not prevent changes in specified (continued) conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of LCO 3.0.4 shall not prevent changes in specified conditions in the Applicability that are related to the unloading of an SFSC.

Exceptions to LCO 3.0.4 are stated in the individual Specifications.

Exceptions may apply to all the ACTIONS or to a specific Required Action of a Specification.

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

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

b. Other equipment meets the applicable LCOs.

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

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-5 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

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

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

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

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

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

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

Surveillances, including Surveillances invoked by Required Actions, do not have to be performed on equipment that has been determined to not meet the LCO because the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior to returning equipment to service. Upon completion of maintenance, appropriate post-maintenance testing is required. This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with SR 3.0.2. Post maintenance testing may not be possible in the current specified conditions in the Applicability due to the necessary dry storage cask system parameters not having been established. In these situations, the equipment may be considered to meet the LCO provided testing has been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function . This will allow dry fuel storage activities to proceed to a specified condition where other necessary post maintenance tests can be completed.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-6 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION SR Applicability B 3.0 BASES SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency for Surveillances and any Required Action with a Completion Time that requires the periodic performance of the Required Action on a "once per... " interval.

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

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

These exceptions are stated in the individual Specifications as a Note in the Frequency stating, "SR 3.0.2 is not applicable."

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portion of a periodic Completion Time that requires performance on a "once per... " basis. The 25% extension applies to each performance after the initial performance. The initial performance of the Required Action, whether it is a particular Surveillance or some other remedial action, is considered a single action with a single Completion Time. One reason for not allowing the 25% extension to this Completion Time is that such an action usually verifies that no loss of function has occurred by checking the status of redundant or diverse components or accomplishes the function of the affected equipment in an alternative manner.

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

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-7 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION SR Applicability B 3.0 BASES SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment as not meeting the LCO or an affected variable outside the specified limits when a Surveillance has not been completed within the specified Frequency. A delay period of up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with SR 3.0.2, and not at the time that the specified Frequency was not met.

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

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

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

Failure to comply with specified Frequencies for SRs is expected to be an infrequent occurrence. Use of the delay period established by SR 3.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-8 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PRO~RIETARY INFORMATIOl<l SR Applicability B 3.0 BASES SR 3.0.3 If a Surveillance is not completed within the allowed delay period, then (continued) the equipment is considered to not meet the LCO or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment does not meet the LCO, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

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

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

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

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

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a change in specified condition. When a system, subsystem, division, component, device, or variable is outside its specified limits, the associated SR(s) are not required to be performed per SR 3.0.1, which states that Surveillances do not have to be performed on equipment that has been determined to not meet the LCO.

When equipment does not meet the LCO, SR 3.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed . Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing specified conditions of the Applicability. However, since the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions that may (or may not) apply to specified condition changes.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-9 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION SR Applicability B 3.0 BASES SR 3.0.4 The provisions of SR 3.0.4 shall not prevent changes in specified (continued) conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of LCO 3.0.4 shall not prevent changes in specified conditions in the Applicability that are related to the unloading of an SFSC.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance.

A Surveillance that could not be performed until after entering the LCO Applicability would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been reached.

Further discussion of the specific formats of SRs' annotation is found in Section 1.4, Frequency.

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-10 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATIOl<l Multi-Purpose Canister B 3.1.1 B 3.1 SFSC Integrity B 3.1.1 Multi-Purpose Canister (MPC)

BASES BACKGROUND A TRANSFER CASK with an empty MPC is placed in the spent fuel pool and loaded with fuel assemblies meeting the requirements of the Coe. A lid is then placed on the MPC. The TRANSFER CASK and MPC are raised to the top of the spent fuel pool surface. The TRANSFER CASK and MPC are then moved into the preparation area where the MPC lid is welded to the MPC shell and the welds are inspected and tested. The water is drained from the MPC cavity and drying is performed. The MPC cavity is backfilled with helium. Then, the MPC vent and drain port cover plates and closure ring are installed and welded. Inspections are performed on the welds.

MPC cavity moisture removal using vacuum drying or forced helium dehydration is performed to remove residual moisture from the MPC cavity space after the MPC has been drained of water. If vacuum drying is used, any water that has not drained from the fuel cavity evaporates from the fuel cavity due to the vacuum. This is aided by the temperature increase due to the decay heat of the fuel.

If forced helium dehydration is used, the dry gas introduced to the MPC cavity through the vent or drain port absorbs the residual moisture in the MPC. This humidified gas exits the MPC via the other port and the absorbed water is removed through condensation and/or mechanical drying. The dried helium is then forced back to the MPC until the temperature acceptance limit is met.

After the completion of drying, the MPC cavity is backfilled with helium meeting the requirements of the Coe.

Backfilling of the MPC fuel cavity with helium promotes gaseous heat dissipation and the inert atmosphere protects the fuel cladding. Backfilling the MPC with helium in the required quantity eliminates air in-leakage over the life of the MPC because the cavity pressure rises due to heat up of the confined gas by the fuel decay heat during storage.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-l l HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION Multi-Purpose Canister B 3.1.1 BASES APPLICABLE The confinement of radioactivity during the storage of spent fuel in SAFETY the MPG is ensured by the confinement boundary of the MPG in ANALYSIS which the fuel assemblies are stored. Long-term integrity of the fuel and cladding depend on storage in an inert atmosphere. This is accomplished by removing water from the MPG and backfilling the cavity with an inert gas. The thermal analyses of the MPG assume that the MPG cavity is filled with dry helium of a minimum quantity to ensure the assumptions used for convection heat transfer are preserved. Keeping the backfill pressure below the maximum value preserves the initial condition assumptions made in the MPG over-pressurization evaluation.

LCO A dry, helium filled , and sealed MPG establishes an inert heat removal environment necessary to ensure the integrity of the fuel cladding. Moreover, it also ensures that there will be no air in-leakage into the MPG cavity that could damage the fuel cladding over the storage period.

APPLICABILITY The dry, sealed, and inert atmosphere is required to be in place prior to TRANSPORT OPERATIONS to ensure both the confinement and heat removal mechanisms are in place during these operating periods. These conditions are not required during LOADING OPERATIONS or UNLOADING OPERATIONS as these conditions are being established or removed , respectively, during these periods in support of other activities being performed with the stored fuel.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-12 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PRe~RIETARY INFORMATIOl<l Multi-Purpose Canister B 3.1.1 BASES ACTIONS A note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each MPG. This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each MPG not meeting the LCO. Subsequent MPCs that do not meet the LCO are governed by subsequent Condition entry and application of associated Required Actions.

A.1 If the cavity vacuum drying pressure or demoisturizer exit gas temperature limit has been determined not to be met prior to TRANSPORT OPERATIONS, an engineering evaluation is necessary to determine the potential quantity of moisture left within the MPG cavity. Since moisture remaining in the cavity during these modes of operation represent a long-term degradation concern, immediate action is not necessary. The Completion Time is sufficient to complete the engineering evaluation commensurate with the safety significance of the CONDITION.

A.2 Once the quantity of moisture potentially left in the MPG cavity is determined, a corrective action plan shall be developed and actions initiated to the extent necessary to return the MPG to an analyzed condition. Since the quantity of moisture estimated under Required Action A.1 can range over a broad scale, different recovery strategies may be necessary. Since moisture remaining in the cavity during these modes of operation represent a long-term degradation concern, immediate action is not necessary. The Completion Time is sufficient to develop and initiate the corrective actions commensurate with the safety significance of the CONDITION.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-13 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION Multi-Purpose Canister B 3.1.1 BASES ACTIONS B.1 (continued) If the helium backfill quantity limit has been determined not to be met prior to TRANSPORT OPERATIONS, an engineering evaluation is necessary to determine the quantity of helium within the MPG cavity. Since too much or too little helium in the MPG during these modes represents a potential overpressure or heat removal degradation concern, an engineering evaluation shall be performed in a timely manner. The Completion Time is sufficient to complete the engineering evaluation commensurate with the safety significance of the CONDITION.

B.2 Once the quantity of helium in the MPG cavity is determined, a corrective action plan shall be developed and initiated to the extent necessary to return the MPG to an analyzed condition either by adding or removing helium or by demonstrating through analysis that all system limits will continue to be met. Since the quantity of helium estimated under Required Action B.1 can range over a broad scale, different recovery strategies may be necessary. Since elevated or reduced helium quantities existing in the MPG cavity represent a potential overpressure or heat removal degradation concern, corrective actions should be developed and impllemented in a timely manner. The Completion Time is sufficient to develop and initiate the corrective actions commensurate with the safety significance of the CONDITION.

C.1 If the helium leak rate limit has been determined not to be met prior to TRANSPORT OPERATIONS, an engineering evaluation is necessary to determine the impact of increased helium leak rate on heat removal and off-site dose. Since the HI-STORM FW OVERPACK is a ventilated system, any leakage from the MPG is transported directly to the environment. Since an increased helium leak rate represents a potential challenge to MPG heat removal and the off-site doses, reasonably rapid action is warranted. The Completion Time is sufficient to complete the engineering evaluation commensurate with the safety significance of the CONDITION.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-14 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION Multi-Purpose Canister B 3.1.1 BASES ACTIONS C.2 (continued) Once the consequences of the elevated leak rate from the MPG are determined, a corrective action plan shall be developed and initiated to the extent necessary to return the MPG to an analyzed condition. Since the recovery mechanisms can range over a broad scale based on the evaluation performed under Required Action C.1, different recovery strategies may be necessary. Since an elevated helium leak rate represents a challenge to heat removal rates and offsite doses, reasonably rapid action is required. The Completion Time is sufficient to develop and initiate the corrective actions commensurate with the safety significance of the CONDITION.

D.1 If the MPG fuel cavity cannot be successfully returned to a safe, analyzed condition, the fuel must be placed in a safe condition in the spent fuel pool. The Completion Time is reasonable based on the time required to re-flood the MPG, cut the MPG lid welds, move the TRANSFER CASK into the spent fuel pool, remove the MPC lid, and remove the spent fuel assemblies in an orderly manner and without challenging personnel.

SURVEILLANCE SR 3.1.1.1 , SR 3.1.1.2, and SR 3.1.1.3 REQUIREMENTS The long-term integrity of the stored fuel is dependent on storage in a dry, inert environment. Under certain conditions, cavity dryness may be demonstrated either by evacuating the cavity to a very low absolute pressure and verifying that the pressure is held over a specified period of time or by recirculating dry helium through the MPG cavity to absorb moisture until the gas temperature or dew point at the specified location reaches and remains below the acceptance limit for the specified time period. A low vacuum pressure or a demoisturizer exit temperature meeting the acceptance limit is an indication that the cavity is dry. Other conditions require the forced helium dehydration method of moisture removal to be used to provide necessary cooling of the fuel during drying operations.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-15 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

lelOLTEC PROPRIETARY IMFORMA I IO'l'r Multi-Purpose Canister B 3.1.1 BASES SURVEILLANCE Cooling provided by normal operation of the forced helium REQUIREMENTS dehydration system ensures that the fuel cladding temperature (continued) remains below the applicable limits since forced recirculation of helium provides more effective heat transfer than that which occurs during normal storage operations.

The conditions and requirements for drying the MPG cavity based on the burnup class of the fuel (moderate or high), heat load, and the applicable short-term temperature limit are given in the CoC/TS Appendix A, Table 3-1. The temperature limits and associated cladding hoop stress calculation requirements are consistent with the guidance in NRG Interim Staff Guidance (ISG)

Document 11 .

Having the proper quantity of helium in the MPG ensures adequate heat transfer from the fuel to the fuel basket and surrounding structure of the MPG and precludes any overpressure event from challenging the normal, off-normal, or accident design pressure of the MPG.

Meeting the helium leak rate limit prior to TRANSPORT OPERATIONS ensures there is adequate helium in the M PC for long term storage and that there is no credible effluent dose from the MPG.

All of these surveillances must be successfully performed once, prior to TRANSPORT OPERATIONS to ensure that the conditions are established for SFSC storage which preserve the analysis basis supporting the MPG design.

REFERENCES 1. FSAR Chapters 1, 4, 7 and 9

2. Interim Staff Guidance Document 11, Rev. 3

3. Interim Staff Guidance Document 18, Rev. 1 HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-16 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

HOLTEC F'RO~RIETARY lt~FORMATION SFSC Heat Removal System B 3.1.2 B 3.1 SFSC Integrity B 3.1.2 SFSC Heat Removal System BASES BACKGROUND The SFSC Heat Removal System is a passive, air-cooled ,

convective heat transfer system that ensures heat from the MPC canister is transferred to the environs by the chimney effect.

Relatively cool air is drawn into the annulus between the OVERPACK and the MPC through the inlet air ducts. The MPC transfers its heat from the canister surface to the air via natural convection. The buoyancy created by the heating of the air creates a chimney effect and the air is forced back into the environs through the outlet air ducts at the top of the OVERPACK.

APPLI CABLE The thermal analyses of the SFSC take credit for the decay heat SAFETY from the spent fuel assemblies being ultimately transferred to the ANALYSIS ambient environment surrounding the OVERPACK. Transfer of heat away from the fuel assemblies ensures that the fuel cladding and other SFSC component temperatures do not exceed applicable limits. Under normal storage conditions, the inlet and outlet air ducts are unobstructed and full air flow (i.e. , maximum heat transfer for the given ambient temperature) occurs.

Analyses have been performed for the complete obstruction of half, and all inlet air ducts. Blockage of half of the inlet air ducts reduces air flow through the OVERPACK annulus and decreases heat transfer from the MPC. Under this off-normal condition, no SFSC components exceed the short term temperature limits.

The c omplete blockage of all inlet air ducts stops normal air cooling of the MPC. The MPC will continue to radiate heat to the relatively cooler OVERPACK. With the loss of normal air cooling, the SFSC component temperatures will increase toward their respective short-term temperature limits. None of the components reach their temperature limits over the duration of the analyzed event.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-l 7 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROF'RIETARV INFORMAi ION SFSC Heat Removal System B 3.1.2 BASES LCO The SFSC Heat Removal System must be verified to be operable to preserve the assumptions of the thermal analyses. Operability is defined as at least 50% of the inlet air ducts available for air flow (i.e., unblocked). Operability of the heat removal system ensures that the decay heat generated by the stored fuel assemblies is transferred to the environs at a sufficient rate to maintain fuel cladding and other SFSC component temperatures within design limits.

The intent of this LCO is to address those occurrences of air duct blockage that can be reasonably anticipated to occur from time to time at the ISFSI (i.e., Design Event I and II class events per ANSI/ANS-57.9). These events are of the type where corrective actions can usually be accomplished within one 8-hour operating shift to restore the heat removal system to operable status (e.g.,

removal of loose debris).

This LCO is not intended to address low frequency, unexpected Design Event Ill and IV class events (ANSI/ANS-57.9) such as design basis accidents and extreme environmental phenomena that could potentially block one or more of the air ducts for an extended period of time (i.e., longer than the total Completion Time of the LCO). This class of events is addressed site-specifically as required by Section 3.4.10 of Appendix B to the Coe.

APPLICABILITY The LCO is applicable during STORAGE OPERATIONS. Once an OVERPACK containing an MPC loaded with spent fuel has been placed in storage, the heat removal system must be operable to ensure adequate dissipation of the decay heat from the fuel assemblies.

ACTIONS A note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each SFSC. This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each SFSC not meeting the LCO. Subsequent SFSCs that don't meet the LCO are governed by subsequent Condition entry and application of associated Required Actions.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-18 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATION SFSC Heat Removal System B 3.1.2 BASES ACTIONS A.1 (continued) Although the heat removal system remains operable, the blockage should be cleared expeditiously.

B.1 If the heat removal system has been determined to be inoperable, it must be restored to operable status within eight hours. Eight hours is a reasonable period of time (typically, one operating shift) to take action to remove the obstructions in the air flow path.

C.1 If the heat removal system cannot be restored to operable status within eight hours, the innermost portion of the OVERPACK concrete may experience elevated temperatures. Therefore, dose rates are required to be measured to verify the effectiveness of the radiation shielding provided by the concrete. This Action must be performed immediately and repeated every twelve hours thereafter to provide timely and continued evaluation of the effectiveness of the concrete shielding. As necessary, the system user shall provide additional radiation protection measures such as temporary shielding. The Completion Time is reasonable considering the expected slow rate of deterioration, if any, of the concrete under elevated temperatures.

C.2.1 In addition to Required Action C.1, efforts must continue to restore cooling to the SFSC. Efforts must continue to restore the heat removal system to operable status by removing the air flow obstruction(s) unless optional Required Action C.2.2 is being implemented.

This Required Action must be complete in 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The Completion Time is consistent with the thermal analyses of this event, which show that all component temperatures remain below their short-term temperature limits up to 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> after event initiation.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-19 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

lelOb:rEG PROPRIETARY INFORMATIOl<l SFSC Heat Removal System B 3.1.2 BASES ACTIONS C.2.1 (continued)

(continued) The Completion Time reflects the 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to complete Required Action B.1 and the appropriate balance of time consistent with the applicable analysis results. The event is assumed to begin at the time the SFSC heat removal system is declared inoperable. This is reasonable considering the low probability of all inlet ducts becoming simultaneously blocked by trash or debris.

C.2.2 In lieu of implementing Required Action C.2.1, transfer of the MPC into a TRANSFER CASK will place the MPC in an analyzed condition and ensure adequate fuel cooling until actions to correct the heat removal system inoperability can be completed. Transfer of the MPC into a TRANSFER CASK removes the SFSC from the LCO Applicability since STORAGE OPERATIONS does not include times when the MPC resides in the TRANSFER CASK.

An engineering evaluation must be performed to determine if any concrete deterioration has occurred in the OVERPACK which prevents it from performing its design function. If the evaluation is successful and the air flow obstructions have been cleared, the OVERPACK heat removal system may be considered operable and the MPC transferred back into the OVERPACK. Compliance with LCO 3.1.2 is then restored. If the evaluation is unsuccessful, the user must transfer the MPC into a different, fully qualif ied OVERPACK to resume STORAGE OPERATIONS and restore compliance with LCO 3.1.2 In lieu of performing the engineering evaluation, the user may opt to proceed directly to transferring the MPC into a different, fully qualified OVERPACK or place the TRANSFER CASK in the spent fuel pool and unload the MPC.

The Completion Time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> reflects the Completion Time from Required Action C.2.1 to ensure component temperatures remain below their short-term temperature limits for the respective decay heat loads.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-20 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMA I ION SFSC Heat Removal System B 3.1.2 BASES SURVEILLANCE SR 3.1.2 REQUIREMENTS The long-term integrity of the stored fuel is dependent on the ability of the SFSC to reject heat from the MPC to the environment. There are two options for implementing SR 3.1.2, either of which is acceptable for demonstrating that the heat removal system is OPERABLE.

Visual observation that all inlet and outlet air ducts are unobstructed ensures that air flow past the MPC is occurring and heat transfer is taking place. Greater than 50% blockage of the total inlet or outlet air duct area renders the heat removal system inoperable and this LCO not met. 50% or less blockage of the total inlet or outlet air duct area does not constitute inoperability of the heat removal system. However, corrective actions should be taken promptly to remove the obstruction and restore full flow through the affected duct(s).

As an alternative, for an OVERPACK with air temperature monitoring instrumentation installed in the outlet air ducts, the temperature rise between ambient and the OVERPACK air outlet may be monitored to verify operability of the heat removal system.

Blocked inlet or outlet air ducts will reduce air flow and increase the temperature rise experienced by the air as it removes heat from the MPC. Based on the analyses, provided the air temperature rise is less than the limit stated in the SR, adequate air flow and, therefore, adequate heat transfer is occurring to provide assurance of long term fuel cladding integrity. The reference ambient temperature used to perform this Surveillance shall be measured at the ISFSI facility.

The Frequency of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable based on the time necessary for SFSC components to heat up to unacceptable temperatures assuming design basis heat loads, and allowing for corrective actions to take place upon discovery of blockage of air ducts.

REFERENCES 1. FSAR Chapter 4

2. ANSI/ANS 57.9-1992 HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-21 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PRO~RIETARY INf"ORMATIOl<l MPG Cavity Reflooding B 3.1.3 B 3.1 SFSC INTEGRITY B 3.1.3 M PC Cavity Reflood ing BASES BACKGROUND In the event that an MPG must be unloaded, the TRANSFER CASK with its enclosed MPG is returned to the preparation area to begin the process of fuel unloading. The MPG closure ring, and vent and drain port cover plates are removed. The MPG gas is sampled to determine the integrity of the spent fuel cladding. The pressure in the MPG cavity is ensured to be less than the 100 psig design pressure. This is accomplished via direct measurement of the MPG gas pressure or via analysis.

After ensuring the MPG cavity pressure meets the LCO limit, the MPG is then reflooded with water at a controlled rate and/or the pressure monitored to ensure that the pressure remains below 100 psig. Once the cavity is filled with water, the MPG lid weld is removed leaving the MPG lid in place. The TRANSFER CASK and MPG are placed in the spent fuel pool and the MPG lid is removed. The fuel assemblies are removed from the MPG and the MPG and TRANSFER CASK are removed from the spent fuel pool and decontaminated.

Ensuring that the MPG cavity pressure is less than the LCO limit ensures that any steam produced within the cavity is safely vented to an appropriate location and eliminates the risk of high MPG pressure due to sudden generation of large steam quantities during re-flooding.

APPLICABLE The confinement of radioactivity during the storage of sp ent SAFETY ANALYSIS fuel in the MPG is ensured by the MPG in which the fuel assemblies are stored. Standard practice in the dry storage industry has historically been to directly reflood the storage canister with water. This standard practice is known not to induce fuel cladding failures.

The integrity of the MPG depends on maintaining the internal cavity pressures within design limits. This is accomplished by introducing water to the cavity in a controlled manner such that there is no sudden formation of large quantities of steam during MPG reflooding. (Ref. 1).

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-22 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATIOl<l MPG Cavity Reflooding B 3.1.3 BASES LCO Determining the MPG cavity pressure prior to and during re-flooding ensures that there will be sufficient venting of any steam produced to avoid excessive MPG pressurization.

APPLICABILITY The MPG cavity pressure is controlled during UNLOADING OPERATIONS after the TRANSFER CASK and integral MPG are back in the FUEL BUILDING and are no longer suspended from , or secured in, the transporter. Therefore, the MPG Reflood LCO does not apply during TRANSPORT OPERATIONS and STORAGE OPERATIONS.

A note has been added to the APPLICABILITY for LCO 3.1.3 which states that the LCO is only applicable during wet UNLOADING OPERATIONS. This is acceptable since the intent of the LCO is to avoid uncontrolled MPG pressurization due to water flashing during re-flooding operations. This is not a concerning for dry UNLOADING OPERATIONS.

ACTIONS A note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each MPG.

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each MPG not meeting the LCO. Subsequent MPCs that do not meet the LCO are governed by subsequent Condition entry and application of associated Required Actions.

A If the MPG cavity pressure limit is not met, actions must be taken to restore the parameters to within the limits before initiating or continuing re-flooding the MPG.

Immediately is an appropriate Completion Time because it requires action to be initiated promptly and completed without delay, but does not establish any particular fixed time limit for completing the action. This offers the flexibility necessary for users to plan and implement any necessary work activities commensurate with the safety significance of the condition, which is governed by the MPG heat load.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-23 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I-IOLTl::C PROPRIETARY INFORMATION MPC Cavity Reflooding B 3.1 .3 BASES SURVEI LLANCE SR3.1.3.1 REQUIREMENTS The integrity of the MPC is dependent on controlling the internal MPC pressure. By controlling the MPC internal pressure prior to and during re-floodi ng the MPC, sufficient steam venting capacity exists during MPC re-flooding .

The LCO must be met on each SFSC before the initiation of MPC re-flooding operations to ensure the design and analysis basis are preserved .

REFERENCES 1. FSAR Chapters 3, 4, 9 and 12.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL REPORT Hl-21 14830 Rev. 3 13.A-24 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROPRIETARY INFORMATIOl<l TRANSFER CASK Surface Contamination B 3.2.1 B 3.2 SFSC Radiation Protection B 3.2.1 TRANSFER CASK Surface Contamination BASES BACKGROUND A TRANSFER CASK is immersed in the spent fuel pool in order to load the spent fuel assemblies. As a result, the surface of the TRANSFER CASK may become contaminated with the radioactive material from the spent fuel pool water. This contamination is removed prior to moving the TRANSFER CASK to the ISFSI, or prior to transferring the MPG into the OVERPACK, whichever occurs first, in order to minimize the radioactive contamination to personnel or the environment.

This allows dry fuel storage activities to proceed without additional radiological controls to prevent the spread of contamination and reduces personnel dose due to the spread of loose contamination or airborne contamination. This is consistent with ALARA practices.

APPLICABLE The radiation protection measures, implemented during MPG SAFETY transfer and transportation using the TRANSFER CASK, are ANALYSIS based on the assumption that the exterior surfaces of the TRANSFER CASK have been decontaminated. Failure to decontaminate the surfaces of the TRANSFER CASK could lead to higher-than-projected occupational doses.

LCO Removable surface contamination on the TRANSFER CASK exterior surfaces and accessible surfaces of the MPG is limited to 1000 dpm/100 cm 2 from beta and gamma sources and 20 dpm/100 cm 2 from alpha sources. These limits are taken from the guidance in IE Circular 81-07 (Ref. 2) and are based on the minimum level of activity that can be routinely detected under a surface contamination control program using direct survey methods. Only loose contamination is controlled, as fixed contamination will not result from the TRANSFER CASK loading process.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-25 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

lelOLTEG PROPRIETARY l~FORMA I 10~

TRANSFER CASK Surface Contamination B 3.2.1 BASES LCO (continued) Experience has shown that these limits are low enough to prevent the spread of contamination to clean areas and are significantly less than the levels which would cause significant personnel skin dose. LCO 3.2.1 requires removable contamination to be within the specified limits for the exterior surfaces of the TRANSFER CASK and accessible portions of the MPG. The location and number of surface swipes used to determine compliance with this LCO are determined based on standard industry practice and the user's plant-specific contamination measurement program for objects of this size.

Accessible portions of the MPG means the upper portion of the MPG external shell wall accessible after the inflatable annulus seal is removed and before the annulus shield ring is installed.

The user shall determine a re,a sonable number and location of swipes for the accessible portion of the MPG. The objective is to determine a removable contamination value representative of the entire upper circumference of the MPG, while implementing sound ALARA practices.

A Note for this LCO indicates that the limits on surface contamination are not prescribed for the TRANSFER CASK if MPG TRANSFER is to occur inside the FUEL BUILDING, however plant radiation protection procedures should guide these limits for occupational dose considerations.

APPLICABILITY The applicability is modified by a note that states that the LCO is not applicable to the TRANSFER CASK if MPG transfer operations occur inside the FUEL BUILDING. This is consistent with the intent of this LCO, which is to ensure loose contamination on the loaded TRANSFER CASK and MPG outside the FUEL BUILDING is within limits. If the MPG transfer is performed inside the FUEL BUILDING the empty TRANSFER CASK remains behind and is treated like any other contaminated hardware under the user's Part 50 contamination control program.

Verification that the surface contamination is less than the limit in the LCO is performed during LOADING OPERATIONS. This occurs before TRANSPORT OPERATIONS, when the LCO is applicable. Measurement of surface contamination is unnecessary during UNLOADING OPERATIONS as surface contamination would have been measured prior to moving the subject TRANSFER CASK to the ISFSI.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-26 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

AOL I EC PROPRIETAR ( INFORMATION TRANSFER CASK Surface Contamination B 3.2.1 BASES ACTIONS A note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each TRANSFER CASK. This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each TRANSFER CASK not meeting the LCO. A subsequent use of the TRANSFER CASK that does not meet the LCO are governed by subsequent Condition entry and application of associated Required Actions.

If the removable surface contamination of a TRANSFER CASK or MPG, as applicable, which has been loaded with spent fuel is not within the LCO limits, action must be initiated to decontaminate the TRANSFER CASK or MPG and bring the removable surface contamination to within limits. The Completion Time of 7 days is appropriate given that sufficient time is needed to prepare for, and complete the decontamination once the LGO is determined not to be met.

SURVEILLANCE SR 3.2.1.1 REQUIREMENTS This SR verifies that the removable surface contamination on the TRANSFER CASK and/or accessible portions of the MPG is less than the limits in the LCO. The Surveillance is performed using smear surveys to detect removable surface contamination. The Frequency requires performing the verification during LOADING OPERATIONS in order to confirm that the TRANSFER CASK or OVERPACK can be moved to the ISFSI without spreading loose contamination.

REFERENCES 1. FSAR Chapter 9

2. NRG IE Circular 81-07.

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-27 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

lelObTi;C PROPRIETARY INFORMATION Boron Concentration B 3.3.1 B 3.3 SFSC Criticality Control B 3.3.1 Boron Concentration BASES BACKGROUND A TRANSFER CASK with an empty MPG is placed in the spent fuel pool and loaded with fuel assemblies meeting the requirements of the Certificate of Compliance. A lid is then placed on the MPG. The TRANSFER CASK and MPG are raised to the top of the spent fuel pool surface. The TRANSFER CASK and MPG are then moved into the preparation area where the MPG lid is welded to the MPG shell and the welds are inspected and tested. The water is drained from the MPG cavity and drying is performed. The MPG cavity is backfilled with helium. Then, the MPG vent and drain cover plates and MPG closure ring are installed and welded. Inspections are performed on the welds.

For those MPCs containing PWR fuel assemblies credit is taken in the criticality analyses for boron in the water within the MPG.

To preserve the analysis basis, users must verify that the boron concentration of the water in the MPG meets specified limits when there is fuel and water in the MPG. This may occur during LOADING OPERATIONS and UNLOADING OPERATIONS.

APPLICABLE The spent nuclear fuel stored in the SFSC is required to remain SAFETY subcritical (kett :5 0.95) under all conditions of storage. The HI-ANALYSIS STORM FW SFSC is analyzed to store a wide variety of spent nuclear fuel assembly types with differing initial enrichments.

For all PWR fuel loaded in the MPC-37, credit was taken in the criticality analyses for neutron poison in the form of soluble boron in the water within the MPG. Compliance with this LCO preserves the assumptions made in the criticality analyses regarding credit for soluble boron.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-28 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEG PROPRle:r.ARY lf)IFORMAJIQN Boron Concentration B 3.3.1 BASES LCO Compliance with this LCO ensures that the stored fuel will remain subcritical with a keff ~ 0.95 while water is in the MPG.

LCOs 3.3.1.a provides the minimum concentration of soluble boron required in the MPG water for the MPC-37. The amount of soluble boron is dependent on the initial enrichment of the fuel assemblies to be loaded in the MPC. Fuel assemblies with an initial enrichment less than or equal to 4.0 wt. % U-235 require less soluble boron than those with initial enrichments greater than 4.0 wt. % U-235. For initial enrichments greater than 4.0 wt.% U-235 and up to 5.0 wt. % U-225, interpolation is permitted to determine the required minimum amount of soluble boron.

All fuel assemblies loaded into the MPC-37 are limited by analysis to maximum enrichments of 5.0 wt.% U-235.

The LCO also requires that the minimum soluble boron concentration for the most limiting fuel assembly array/class and classification to be stored in the same MPC be used. This means that the highest minimum soluble boron concentration limit for all fuel assemblies in the MPG applies in cases where fuel assembly array/classes are mixed in the same MPC. This ensures the assumptions pertaining to soluble boron used in the criticality analyses are preserved.

APPLICABILITY The boron concentration LCO is applicable whenever an MPC-37 has at least one PWR fuel assembly in a storage location and water in the MPC.

During LOADING OPERATIONS, the LCO is applicable immediately upon the loading1of the first fuel assembly in the MPG. It remains applicable until the MPG is drained of water.

During UNLOADING OPERATIONS, the LCO is applicable when the MPG is reflooded with water. Note that compliance with SR 3.0.4 assures that the water to be used to flood the MPC is of the correct boron concentration to ensure the LCO is satisfied upon entering the Applicability.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-29 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

HO! IEC PROPRIETARY INFORMATION Boron Concentration B 3.3.1 BASES ACTIONS A note has been added to the ACTIONS which states that, for this LCO, separate Condition entry is allowed for each MPG.

This is acceptable since the Required Actions for each Condition provide appropriate compensatory measures for each MPG not meeting the LCO. Subsequent MPCs that do not meet the LCO are governed by subsequent Condition entry and application of associated Required Actions.

A.1 and A.2 Continuation of LOADING OPERATIONS, UNLOADING OPERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the SFSC in compliance with the LCO. If the boron concentration of water in the MPG is less than its limit, all LOADING OPERATIONS, UNLOADING OPERATIONS or positive reactivity additions must be suspended immediately.

A.3 In addition to immediately suspending LOADING OPERATIONS, UNLOADING OPERATIONS and positive reactivity additions, action to restore the concentration to within the limit specified in the LCO must be initiated immediately. One means of complying with this action is to initiate boration of the affected MPG. In determining the required combination of boration flow rate and concentration, there is no unique design basis event that must be satisfied; only that boration is initiated without delay. In order to raise the boron concentration as quickly as possible, the operator should begin boration with the best source available for existing plant conditions.

Once boration is initiated, it must be continued until the boron concentration is restored . The restoration time depends on the amount of boron that must be injected to reach the required concentration.

(continued)

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-30 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEC PROF'RIETARV INFORMAi ION Boron Concentration B 3.3.1 BASES SURVEILLANCE SR 3.3.1.1 REQUIREMENTS The boron concentration in the MPG water must be verified to be within the applicable limit within four hours prior to entering the Applicability of the LCO. For LOADING OPERATIONS, this means within four hours of loading the first fuel assembly into the MPC using two independent measurements to ensure the requirements of 10 CFR 72.124(a) are met. These two independent measurements will be repeated every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> while the MPG is submerged in water or if water is to be added to or recirculated through the MPC.

For UNLOADING OPERATIONS, this means verifying the boron concentration in the source of borated water to be used to reflood the MPC within four hours of commencing reflooding operations and every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after until all the fuel is removed from the MPC. Two independent measurements will be taken to ensure the requirements of 10 CFR 72.124(a) are met. This ensures that when the LCO is applicable (upon introducing water into the MPC), the LCO will be met.

Surveillance Requirement 3.3.1.1 is modified by a note which states that SR 3.3.1.1 is only required to be performed if the MPC is submerged in water or if water is to be added to, or recirculated through the MPG. This reflects the underlying premise of this SR which is to ensure, once the correct boron concentration is established, it need only be verified thereafter if the MPC is in a state where the concentration could be changed. After the completion of the surveillance methods, events which might change the soluble boron concentration will be administratively controlled per the LCO. If actions are taken that could result in a reduction in the boron concentration the surveillance will be performed again.

There is no need to re-verify the boron concentration of the water in the MPC after it is removed from the spent fuel pool unless water is to be added to, or recirculated through the MPG, because these are the only credible activities that could potentially change the boron concentration during this time.

This note also prevents the interference of unnecessary sampling activities while lid closure welding and other MPC storage preparation activities are taking place in an elevated radiation area atop the MPG. Plant procedures should ensure HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 3 13.A-31 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

1IOLTEC PROPRIETARY INFORMATlmJ Boron Concentration B 3.3.1 BASES SURVEILLANCE that any water to be added to, or recirculated through the MPC REQUIREMENTS is at a boron concentration greater than or equal to the minimum boron concentration specified in the LCO.

REFERENCES 1. FSAR Chapter 6.

HOLTEC INTERNATIONAL COPYRIGHTED MATERIAL REPORT Hl-2 114830 Rev. 3 13.A-32 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

lelOLTEC PROPRIETARY l~FORMA I ION CHAPTER 14t: QUALITY ASSURANCE PROGRAM

14.0 INTRODUCTION

14.0.1 Overview This chapter provides a summary of the quality assurance program implemented by Holtec International for activities related to the design, qualification analyses, material procurement, fabrication, assembly, testing and use of structures, systems, and components of the Company's dry storage/transport systems including the HI-STORM FW system which includes the HI-TRAC VW transfer cask. This chapter is included in this FSAR to fulfill the requirements in 10 CFR 72. 140 (c) (2) and 72.2(a)(l),(b).

Important-to-safety activ ities related to construction and deployment of the HI-STORM FW system are controlled under the NRC-approved Holtec Quality Assurance Program.

The Holtec QA program manual [14.0.1) is approved by the NRC [ 14.0.2) under Docket 71-0784. The Holtec QA program satisfies the requirements of 10 CFR 72, Subpart G and 10 CFR 71, Subpart H. In accordance with l OCFR 72. 140(d), this approved 10 CFR 71 QA program will be applied to spent fuel storage cask activities under l OCFR 72. The additional record.keeping requirements of 10 CFR 72. 174 are addressed in the Holtec QA program manual and must also be complied with.

The Holtec QA program is implemented through a hierarchy of procedures and documentation, listed below.

1. Holtec Quality Assurance Program Manual

2. Holtec Quality Assurance Procedures

3. a. Holtec Standard Procedures

b. Holtec Project Procedures Quality activities performed by others on behalf of Holtec are governed by the supplier's qua lity assurance program or Holtec's QA program extended to the supplier. The type and extent of Holtec QA control and oversight is specified in the procurement documents for the specific item or service being procured. The fundamental goal of the supplier oversight portion of Holtec's QA program is to provide the assurance that activities performed in support of the supply of safety-significant items and services are performed conectly and in compliance with the procurement documents.

t This chapter has been prepared in the format and section organization set forth in Regulatory Guide 3.61.

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 0 14-1 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEG PROPRIET.ARY lf)IFORMAJIQN 14.0.2 Graded Approach to Quality Assurance Holtec International uses a graded approach to quality assurance on all safety-related or impottant-to-safety projects. This graded approach is controlled by Holtec Quality Assurance (QA) program documents as described in Subsection 14.0.1.

NUREG/CR-6407 [14.0.3] provides descriptions of quality categories A, Band C. Using the guidance in NUREG/CR-6407, Holtec International assigns a quality category to each individual, important-to-safety component of the HI-STORM FW system and HI-TRAC VW transfer cask. The ITS categories assigned to the HI-STORM FW cask components are identified in Tables 2.0. l through 2.0.8. Quality categories for ancillary equipment are provided in Chapter 9 of this FSAR. Quality categories for other equipment needed to deploy the HI-STORM FW system at a licensee's ISFSI are defined on a case-specific basis considering the component's design function using the guidelines of NUREG/CR-6407 (14.0.3).

Activities affecting quality are defined by the purchaser's procurement contract for use of the HJ-STORM FW system at an independent spent fuel storage installation (ISFSJ) under the general license provisions of 10CFR72, Subpart K. These activities include any or all of the following: design, procurement, fabrication, handling, shipping, storing, cleaning, assembly, inspection, testing, operation, maintenance, repair and monitoring of HI-STORM FW structures, systems, and components (SSCs) that are important-to-safety.

The quality assurance program described in the QA Program Manual fully complies with the requirements of 10CFR72 Subpatt G and the intent of NUREG-1536 (14.0.4].

However, NUREG-1536 does not explicitly address incorporation of a QA program manual by reference. Therefore, invoking the NRC-approved QA program in this FSAR constitutes a literal deviation from NUREG-1536 and has accordingly been added to the list of deviations in Table 1.0.3. This deviation is acceptable since important-to-safety activities are implemented in accordance with the latest revision of the Holtec QA program manual and implementing procedures. Further, incorporating the QA Program Manual by reference in this FSAR avoids duplication of information between the implementing documents and the FSAR and any discrepancies that may arise from simultaneous maintenance to the two program descriptions governing the same activities.

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 0 14-2 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017

I IOLTEG PROPRle+,ARY lf)IFORMAJIQN

14.1 REFERENCES

(14.0.1] Holtec International Quality Assurance Program, Latest Approved Revision.

(14.0.2] NRC QA Program Approval for Radioactive Material Packages No. 0784, Docket 71-0784.

(14.0.3] NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety," February 1996.

(14.0.4] NUREG-1536, "Standard Review Plan for Dry Cask Storage Systems,"

January 1997.

HOLTEC INTERNATIONAL COPYRIGHTED MATERJAL REPORT HI-2114830 Rev. 0 14-3 HI-STORM FW SYSTEM FSAR Revision 5, June 20, 2017