ML20225A193

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Attachment 3: HI-STORM FW Amendment 7 Certificate of Compliance, Appendix a
ML20225A193
Person / Time
Site: 07201032
Issue date: 08/12/2020
From:
Holtec
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML20225A188 List:
References
5018079
Download: ML20225A193 (10)
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Text

ATTACHMENT 3 TO HOLTEC LETTER 5018079 Definitions 1.1 1.1 Definitions Term Definition MULTI-PURPOSE CANISTER MPCs are the sealed spent nuclear fuel canisters (MPC) which consist of a honeycombed fuel basket contained in a cylindrical canister shell which is welded to a baseplate, lid with welded port cover plates, and closure ring. The MPC provides the confinement boundary for the contained radioactive materials.

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

NON-FUEL HARDWARE NON-FUEL HARDWARE is defined as Burnable Poison Rod Assemblies (BPRAs), Thimble Plug Devices (TPDs), Control Rod Assemblies (CRAs),

Axial Power Shaping Rods (APSRs), Wet Annular Burnable Absorbers (WABAs), Rod Cluster Control Assemblies (RCCAs), Control Element Assemblies (CEAs), Neutron Source Assemblies (NSAs), water displacement guide tube plugs, orifice rod assemblies, instrument tube tie rods (ITTRs),

vibration suppressor inserts, and components of these devices such as individual rods.

OVERPACK OVERPACKs are the casks which receive and contain the sealed MPCs for interim storage on the ISFSI.

They provide gamma and neutron shielding, and in some versions may provide for ventilated air flow to promote heat transfer from the MPC to the environs.

The term OVERPACK does not include the TRANSFER CASK.

PLANAR-AVERAGE INITIAL PLANAR AVERAGE INITIAL ENRICHMENT is the ENRICHMENT average of the distributed fuel rod initial enrichments within a given axial plane of the assembly lattice.

REPAIRED/RECONSITUTED Spent nuclear fuel assembly which contains dummy FUEL ASSEMBLY fuel rods that displaces an amount of water greater than or equal to the original fuel rods and/or which contains structural repairs so it can be handled by normal means. If irradiated dummy stainless steel rods are present in the fuel assembly, the dummy/replacement rods will be considered in the site specific dose calculations.

Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-3 1 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 Multi-Purpose Canister (MPC) 3.1.1 ACTIONS (continued)

D. Required Actions and D.1 Remove all fuel assemblies 30 days associated Completion from the SFSC.

Times not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify that the MPC cavity has been dried in Once, prior to accordance with the applicable limits in Table TRANSPORT 3-1. OPERATIONS SR 3.1.1.2 Verify MPC helium backfill quantity is within the Once, prior to limit specified in Table 3-2 for the applicable MPC TRANSPORT model. Re-performance of this surveillance is not OPERATIONS required upon successful completion of Action B.2.2.

SR 3.1.1.3 Verify that the helium leak rate through the MPC Once, prior to vent port confinement weld meets the leaktight TRANSPORT criteria of ANSI N14.5-1997 and verify that the OPERATIONS helium leak rate through the MPC drain port confinement weld meets the leaktight criteria of ANSI N14.5-1997. This surveillance does not need to be performed in the MPC utilizes the redundant port cover design.

Certificate of Compliance No. 1032 Amendment No. 765 Appendix A 3.1.1-3 2 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 SFSC Heat Removal System 3.1.2 3.1 SFSC INTEGRITY 3.1.2 SFSC Heat Removal System LCO 3.1.2 The SFSC Heat Removal System shall be operable

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

The SFSC Heat Removal System is operable when 50% or more of each of the inlet and outlet vent areas are unblocked and available for flow or when air temperature requirements are met. This LCO does not apply to the HI-STORM FW UV, which does not include an SFSC heat removal system.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Heat Removal A.1 Remove blockage. N/A System operable, but partially (<50%) blocked.

B. SFSC Heat Removal B.1 Restore SFSC Heat 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> System inoperable. Removal System to operable status.

(continued)

Certificate of Compliance No. 1032 Amendment No. 65 Appendix A 3.1.2-1 3 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 3.4 Tables Table 3-1a MPC Cavity Drying Limits for HI-STORM FW 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 VDS (Notes 3 Assemblies 44.85 (Figures 2.3-7 through 2.3-9 and 4) or FHD 45,000 of Appendix B) (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 MPC-89 Appendix B) 46.14 (Figures 2.3-12 and 2.3-13 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. 75 Appendix A 3.4-1 4 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 3.4 Tables Table 3-1b MPC Cavity Drying Limits for HI-STORM FW UV Method of Fuel MPC Moisture Burnup MPC Heat Load (kW)

Type5 Removal (MWD/MTU)

(Notes 1 and 2) 24kW (Table 2.3-7A of Appendix B MPC-37 or pattern developed in accordance with 2.3-7B of Appendix B) VDS (Notes 3 All burnups and 4) or FHD (Note 4) 24kW (Table 2.3-8A of Appendix B MPC-89 or pattern developed in accordance with and 2.3-8B 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.
5. MPC-32ML is not allowed for storage in the HI-STORM FW UV.

Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-4 5 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 3.4 Tables Table 3-2a MPC Helium Backfill Limits for MPCs Stored in HI-STORM FW1 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 MPC-32ML Table 2.3-5, All Patterns 41.5 and 45.5 1 Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-5 6 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 3.4 Tables Table 3-2b MPC Helium Backfill Limits for MPCs Stored in HI-STORM FW2 UV Decay Heat Limits Applied Pressure range MPC Model (per Appendix B Section 2.3) (psig)

MPC-37 Tables 2.3-7A and 2.3-7B 42.0 and 45.5 MPC-89 Tables 2.3-8A and 2.3-8B 42.5 and 46.5 2 Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-6 7 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program

a. For lifting of the loaded MPC, TRANSFER CASK, or OVERPACK using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.
b. This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by equipment providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...).
c. The TRANSFER CASK or OVERPACK, when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and MPC TRANSFER, provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.
1. The metal body and any vertical columns of the lifting equipment shall be designed to comply with stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. All vertical compression loaded primary members shall satisfy the buckling criteria of ASME Section III, Subsection NF.
2. The horizontal cross beam and any lifting attachments used to connect the load to the lifting equipment shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with applicable sections and guidance of NUREG-0612, Section 5.1. For lifting attachments, Tthis includes applicable stress limits from ANSI N14.6.
3. The lifting equipment shall have redundant drop protection features which prevent uncontrolled lowering of the load.
4. For existing handling equipment which does not meet the above criteria, a site-specific drop analysis shall be performed as part of the 10 CFR 72.212 report to demonstrate that the acceptance criteria set forth in the HI-STORM FW FSAR are met. The analysis shall be performed using methodologies consistent with those described in the HI-STORM FW FSAR.

Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-2 8 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program 5.3.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded OVERPACK or TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

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

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

a. The top of the OVERPACK.
b. The side OVERPACK
c. The side of the TRANSFER CASK
d. The inlet and outlet ducts on the OVERPACK or on the side of the lid for a non-ventilated OVERPACK 5.3.4 Notwithstanding the limits established in Section 5.3.3, the measured dose rates on a loaded OVERPACK or TRANSFER CASK shall not exceed the following values:
a. 15 mrem/hr (gamma + neutron) on the top of the OVERPACK
b. 300 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts
c. 3500 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.3.5 The licensee shall measure the TRANSFER CASK and OVERPACK surface neutron and gamma dose rates as described in Section 5.3.8 for comparison against the limits established in Section 5.3.3 or Section 5.3.4, whichever are lower.

Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-3 9 of 10

ATTACHMENT 3 TO HOLTEC LETTER 5018079 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued)

c. A minimum of four (4) dose rate measurements shall be taken on the side of the TRANSFER CASK approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs of the water jacket. For a TRANSFER CASK with a neutron shield cylinder, dose rates shall be measured between the radial ribs of the neutron shield cylinder.
d. A dose rate measurement shall be taken on contact at the surface of each inlet and outlet vent duct screen of the OVERPACK or on the side of the lid for a non-ventilated OVERPACK.

Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-5 10 of 10

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