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Tn America, LLC - Application for Certificate of Compliance No. 1042 Amendment No. 2 to NUHOMS Eos System, Revision 7 - Revised Response to Request for Additional Information
	ML21027A324
Person / Time
Site:	07201042
Issue date:	01/27/2021
From:	Narayanan P; TN Americas LLC
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML21027A321	List: ML21027A324;
References
	CAC-001028, E-58012, EPID L-2019-LLA-0078
	Download: ML21027A324 (142)
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Enclosure 1 to E-58012 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas-J+C )

State of Maryland ) SS.

County of-Howard f-1.,rif.3,N,-e r,3 )

I, Prakash Narayanan, depose and say that I am Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in confonnance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information .

The information for which proprietary treatment is sought is contained in Enclosure 6 as listed below:

Enclosure 6 - Portions of certain updated final safety analysis report (UFSAR) chapters and drawings These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade secret, privileged or as confidential commercial or financial infonnation.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in detennining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

I) The infonnation sought to be withheld from public disclosure involves portions of the RAis and responses, and portions of the UFSAR files, all related to the design of the NUHOMSEOS System, which are owned and have been held in confidence by TN Americas LLC.

2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.

3) Public disclosure of the infom1ation is likely to cause substantial harm to the competitive position of TN Americas LLC, because the information consists of descriptions of the design and analysis of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such infonnation to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their product' s position or impair the position of TN Americas LLC's product, and avoid developing similar data and analyses in support of their processes, methods or apparatus.

Further the deponent sayeth not.

Prakash Narayanan Chief Technical Officer, TN Americas LLC Subscribed and sworn before me this 27tl' day of January, 2021.

~:z-My Commission Expires .fiL! -11ZJ_£.ul/

Page 1 of 1

RAIs and Responses Enclosure 2 to E-58012 RAI 6-4:

Clarify if fuel assemblies (FAs) containing reconstitution rods are allowed to be loaded in the peripheral locations of the DSC and revise the UFSAR and/or TS to reflect these limits as necessary.

On page 1-24 of the HSM-MX UFSAR, the applicant states: Reconstituted assemblies containing up to five replacement irradiated stainless steel rods per assembly or an unlimited number of low enriched or natural uranium fuel rods or unirradiated non-fuel rods are acceptable for storage in an EOS-89BTH DSC as intact FAs.

On page 2-6 of the same UFSAR, the applicant states: Fuel assemblies are evaluated with five irradiated stainless steel rods per assembly, 40 rods per EOS-37PTH DSC, and 100 rods per EOS-89BTH DSC. The cooling time is the same as unreconstituted FAs. The reconstituted rods can be at any location in the FAs. There is no limit on the number of reconstituted FAs per DSC; the FAs containing irradiated stainless steel reconstituted rods are modeled in the inner compartments as shown in Figure 6-1 for EOS-37PTH and Figure 6-2 for EOS-89BTH of Chapter 6.

However, the staff notes that Table 1-1t of the CoC No. 1004 TS states that the maximum number of irradiated stainless steel rods in reconstituted assemblies per the 61BTH Type II DSC is 40, the maximum number of irradiated stainless steel rods per reconstituted fuel assembly is 10, and the maximum number of reconstituted assemblies per DSC with unlimited number of low enriched UO2 rods or Zr rods or Zr pellets or unirradiated stainless steel rods is 61.

The staff also notes that the TS for amendment 2 of the HSM-MX system includes: Number of RECONSTITUTED FUEL ASSEMBLIES [per the 61BTH Type II DSC [is] 61. However, information on the maximum number of irradiated stainless steel rods in reconstituted assemblies per the 61BTH Type II DSC and the maximum number of irradiated stainless steel rods per reconstituted fuel assembly is missing from both the TS and UFSAR for the HSM-MX system.

The staff needs this information to determine if the HSM-MX meet the regulatory requirements of 10 CFR 236(d).

Revised Response to RAI 6-4:

Updated Final Safety Analysis Report (UFSAR) Section B.6.2.6 has been revised to provide fuel assembly source terms for reconstituted fuel assemblies containing both 5 and 10 irradiated stainless steel rods per fuel assembly. The OS197 TC and HSM-MX analyses documented in UFSAR Sections B.6.4.3 and B.6.4.4, respectively, have been updated to address 24 reconstituted fuel assemblies with 5 irradiated stainless steel rods per fuel assembly on the basket periphery (total of 120 irradiated stainless steel rods per DSC). Results Tables B.6-13, B.6-14, B.6-16, and B.6-17 are updated. New UFSAR Tables B.6-18 through B.6-26 have been added to support the reconstituted fuel analysis.

Due to the dose rate increase, the occupational exposure estimate in UFSAR Section B.11.2 has been updated, including UFSAR Tables B.11-1 and B.11-2.

Page 1 of 2

RAIs and Responses Enclosure 2 to E-58012 The fuel assembly source terms for reconstituted fuel assemblies containing 10 irradiated stainless steel rods per fuel assembly are used in a sensitivity study to demonstrate that dose rates are approximately the same for the 5 and 10 irradiated stainless steel rod reconstituted fuel assemblies when the number of irradiated stainless steel rods per DSC is held constant at 120, see UFSAR Tables B.6-25 and B.6-26. Section 2.3 of the Technical Specifications (TS) has been modified to include additional restrictions for reconstituted fuel assemblies containing irradiated stainless steel rods. TS Figure 7 has been added to illustrate additional restrictions for loading reconstituted fuel assemblies containing irradiated stainless steel rods in the peripheral locations.

MCNP input and output files are included in Enclosure 9.

Note: The above Enclosure 9 was previously submitted with Amendment 2, Revision 6, dated October 29, 2020 (ML20315A417)

Impact:

TS Section 2.3 has been revised as described in the response. TS Figure 7 has been added as described in the revised response.

UFSAR Sections B.6.2.6, B.6.4.3, B.6.4.4, and Section B.11.2 have been revised as described in the response.

UFSAR Tables B.6-13, B.6-14, B.6-16, B.6-17, B.11-1 and B.11-2 have been revised as described in the response.

UFSAR Tables B.6-18 through B.6-26 have been added as described in the response.

Note: The above UFSAR sections and tables revised and added were previously submitted with Amendment 2, Revision 6, dated October 29, 2020 (ML20315A417)

Page 2 of 2

Enclosure 3 to E-58012 List of New CoC 1042 Amendment 2, Revision 7 Technical Specifications Changes and Justifications Changed Technical Specifications (TS) Area and Justification Page Number Table of Contents, List of Updated Tables, and List of Figures As described in the revised response to Shielding RAI 6-4, 2.3 (RECONSTITUTED FUEL Section 2.3 has been modified to provide additional ASSEMBLIES) restrictions for reconstituted fuel assemblies containing (Page 2-7) irradiated stainless steel rods.

As described in the revised response to Shielding RAI 6-4, Figure 7 Figure 7 has been added to illustrate additional restrictions for (Page F-27) loading reconstituted fuel assemblies containing irradiated stainless steel rods in the peripheral locations.

Page 1 of 1

Enclosure 4 to E-58012 List of Changed TS and UFSAR Pages Involved in CoC 1042 Amendment 2, Revision 7 Technical Specifications Pages 2-7 F-27 UFSAR Pages and Drawing Sheets Dwg EOS01-1000-SAR Sheet 1 Dwg EOS01-1005-SAR Sheet 1 3.9.1-1 3.9.1-2 3.9.1-4 3.9.1-32 3.9.1-34 3.9.1-37 3.9.1-38 3.9.1-59 3.9.1-60 3.9.1-62 3.9.1-63 3.9.1-70 3.9.1-71 3.9.1-72 3.9.1.73 8-25 8-30 Page 1 of 1

Enclosure 5 to E-58012 CoC 1042 Proposed Amendment 2, Revision 7 Technical Specifications

Revision 7 to Amendment 2 Proposed Technical Specifications CoC 1042 APPENDIX A NUHOMS EOS SYSTEM GENERIC TECHNICAL SPECIFICATIONS Amendment 2

TABLE OF CONTENTS PAGE 1.0 Use and Application ................................................................................................1-1 1.1 Definitions .................................................................................................. 1-1 1.2 Logical Connectors .................................................................................... 1-5 1.3 Completion Times ...................................................................................... 1-7 1.4 Frequency ................................................................................................ 1-10 2.0 Functional and Operating Limits .............................................................................2-1 2.1 Fuel to be Stored in the EOS-37PTH DSC ................................................. 2-1 2.2 Fuel to be Stored in the EOS-89BTH DSC ................................................. 2-4 2.3 Fuel to be stored in the 61BTH Type 2 DSC .............................................. 2-6 2.4 Functional and Operating Limits Violations................................................. 2-9 3.0 Limiting Condition for Operation (LCO) and Surveillance Requirement (SR)

Applicability.............................................................................................................3-1 3.1 DSC Fuel Integrity ...................................................................................... 3-3 3.1.1 Fuel Integrity during Drying ............................................................3-3 3.1.2 DSC Helium Backfill Pressure ........................................................3-5 3.1.3 Time Limit for Completion of DSC Transfer ....................................3-7 3.2 Cask Criticality Control ............................................................................. 3-10 3.2.1 Soluble Boron Concentration........................................................3-10 3.3 Radiation Protection ................................................................................. 3-12 3.3.1 DSC and TRANSFER CASK (TC) Surface Contamination ...........3-12 4.0 Design Features .....................................................................................................4-1 4.1 Site............................................................................................................. 4-1 4.1.1 Site Location ..................................................................................4-1 4.2 Storage System Features........................................................................... 4-1 4.2.1 Storage Capacity............................................................................4-1 4.2.2 Storage Pad ...................................................................................4-1 4.3 Canister Criticality Control .......................................................................... 4-1 4.3.1 Neutron Absorber Tests .................................................................4-2 4.3.2 High Strength Low Alloy Steel for Basket Structure for EOS-37PTH and EOS-89BTH DSCs. .....................................................4-2 4.4 Codes and Standards ................................................................................ 4-3 4.4.1 HORIZONTAL STORAGE MODULE (HSM) ..................................4-3 4.4.2 DRY SHIELDED CANISTER (DSC) (EOS-37PTH, EOS-89BTH, and 61BTH Type 2) ...........................................................4-3 4.4.3 TRANSFER CASK .........................................................................4-4 4.4.4 Alternatives to Codes and Standards .............................................4-4 4.5 Storage Location Design Features ........................................................... 4-12 4.5.1 Storage Configuration ..................................................................4-12 4.5.2 Concrete Storage Pad Properties to Limit DSC Gravitational Loadings Due to Postulated Drops ...............................................4-12 4.5.3 Site Specific Parameters and Analyses ........................................4-12 5.0 Administrative Controls ...........................................................................................5-1 5.1 Programs ................................................................................................... 5-1 5.1.1 Radiological Environmental Monitoring Program ............................5-1 5.1.2 Radiation Protection Program ........................................................5-1 5.1.3 HSM Thermal Monitoring Program .................................................5-3 5.2 Lifting Controls ........................................................................................... 5-7 5.2.1 TC/DSC Lifting Height and Temperature Limits ..............................5-7 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 ii

TABLE OF CONTENTS (continued) PAGE 5.2.2 Cask Drop ......................................................................................5-7 5.3 Concrete Testing ........................................................................................ 5-8 5.4 Hydrogen Gas Monitoring .......................................................................... 5-9 5.5 EOS-HSM Wind Deflectors ........................................................................ 5-9 List of Tables Table 1 Fuel Assembly Design Characteristics for the EOS-37PTH DSC ........................... T-1 Table 2 Maximum Uranium Loading per FFC for Failed PWR Fuel .................................... T-1 Table 3 Co-60 Equivalent Activity for CCs Stored in the EOS-37PTH DSC ........................ T-1 Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH ................................ T-2 Table 5 Minimum B-10 Content in the Neutron Poison Plates of the EOS-37PTH DSC ...... T-4 Table 6 Fuel Assembly Design Characteristics for the EOS-89BTH DSC ........................... T-5 Table 7A PWR Minimum Enrichments as a Function of Burnup ............................................ T-6 Table 7B EOS-37PTH DSC Fuel Qualification Table, All Fuel .............................................. T-7 Table 7C Deleted .................................................................................................................. T-8 Table 8 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for EOS-89BTH DSC ................................................................................ T-9 Table 9 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Intact Fuel) ................................................. T-10 Table 10 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Damaged Fuel) ........................................... T-11 Table 11 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Failed and Damaged Fuel) ......................... T-12 Table 12 Maximum Lattice Average Initial Enrichments and Minimum B-10 Areal Density for the 61BTH Type 2 DSC for > 16 Damaged Fuel Assemblies ............. T-13 Table 13 BWR Fuel Assembly Design Characteristics for the 61BTH Type 2 DSC ............ T-14 Table 14 Maximum Uranium Loading per FFC for Failed 61BTH Type 2 Fuel .................... T-15 Table 15 System Configurations for EOS-37PTH HLZCs ................................................... T-16 Table 16 System Configurations for EOS-89BTH HLZCs ................................................... T-17 Table 17 System Configurations for 61BTH Type 2 HLZCs ................................................ T-18 Table 18 BWR Minimum Enrichments as a Function of Burnup (61BTH Type 2 DSC) ....... T-19 Table 19 61BTH Type 2 DSC Fuel Qualification Table, All Fuel ......................................... T-20 Table 20 61BTH Type 2 DSC Fuel Qualification Table, HLZC 2, 4, 5, 6, 7, and 8, Peripheral Locations ............................................................................................ T-21 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 iii

TABLE OF CONTENTS (continued) PAGE List of Figures Figure 1A Heat Load Zone Configuration 1 for the EOS-37PTH DSC .................................... F-1 Figure 1B Heat Load Zone Configuration 2 for the EOS-37PTH DSC .................................... F-2 Figure 1C Heat Load Zone Configuration 3 for the EOS-37PTH DSC .................................... F-3 Figure 1D Heat Load Zone Configuration 4 for the EOS-37PTH DSC .................................... F-4 Figure 1E Heat Load Zone Configuration 5 for the EOS-37PTH DSC .................................... F-5 Figure 1F Heat Load Zone Configuration 6 for the EOS-37PTH DSC .................................... F-6 Figure 1G Heat Load Zone Configuration 7 for the EOS-37PTH DSC .................................... F-7 Figure 1H Heat Load Zone Configuration 8 for the EOS-37PTH DSC .................................... F-8 Figure 1I Heat Load Zone Configuration 9 for the EOS-37PTH DSC .................................... F-9 Figure 1J Heat Load Zone Configuration 10 for the EOS-37PTH DSC ................................ F-10 Figure 1K Heat Load Zone Configuration 11 for the EOS-37PTH DSC ................................ F-11 Figure 2 EOS-89BTH DSC Heat Load Zone Configurations and Fuel Qualification ........... F-12 Figure 3 Peripheral (P) and Inner (I) Fuel Locations for the EOS-37PTH DSC .................. F-14 Figure 4A Heat Load Zone Configuration 1 for the 61BTH Type 2 DSC ............................... F-15 Figure 4B Heat Load Zone Configuration 2 for the 61BTH Type 2 DSC ............................... F-16 Figure 4C Heat Load Zone Configuration 3 for the 61BTH Type 2 DSC ............................... F-17 Figure 4D Heat Load Zone Configuration 4 for the 61BTH Type 2 DSC ............................... F-18 Figure 4E Heat Load Zone Configuration 5 for the 61BTH Type 2 DSC ............................... F-19 Figure 4F Heat Load Zone Configuration 6 for the 61BTH Type 2 DSC ............................... F-20 Figure 4G Heat Load Zone Configuration 7 for the 61BTH Type 2 DSC ............................... F-21 Figure 4H Heat Load Zone Configuration 8 for the 61BTH Type 2 DSC ............................... F-22 Figure 4I Heat Load Zone Configuration 9 for the 61BTH Type 2 DSC ............................... F-23 Figure 4J Heat Load Zone Configuration 10 for the 61BTH Type 2 DSC ............................. F-24 Figure 5 Location of Damaged and Failed Fuel Assemblies inside the 61BTH Type 2 DSC ..................................................................................................................... F-25 Figure 6 Peripheral (P) and Inner (I) Fuel Locations for the 61BTH Type 2 DSC ............... F-26 Figure 7 Peripheral Location Restrictions for Reconstituted Fuel with Irradiated Stainless Steel Rods for the 61BTH Type 2 DSC ................................................ F-27 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 iv

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

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

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

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

BLEU FUEL Blended Low Enriched Uranium (BLEU) FUEL material is generated by down-blending high enriched uranium (HEU). Because the feedstock contains both unirradiated and irradiated HEU, fresh BLEU fuel has elevated concentrations of U-232, U-234, and U-236.

CONTROL COMPONENTS (CCs) Authorized CCs include Burnable Poison Rod Assemblies (BPRAs), Thimble Plug Assemblies (TPAs), Control Rod Assemblies (CRAs), Control Element Assemblies (CEAs), Control Spiders, Rod Cluster Control Assemblies (RCCAs), Axial Power Shaping Rod Assemblies (APSRAs), Orifice Rod Assemblies (ORAs), Peripheral Power Suppression Assemblies (PPSAs), Vibration Suppression Inserts (VSIs), Flux Suppression Inserts (FSIs), Burnable Absorber Assemblies (BAAs), Neutron Source Assemblies (NSAs) and Neutron Sources. CCs not explicitly listed are also authorized as long as external materials are limited to zirconium alloys, nickel alloys, and stainless steels. Non-fuel hardware that are positioned within the fuel assembly after the fuel assembly is discharged from the core such as Guide Tubes or Instrument Tube Tie Rods or Anchors, Guide Tube Inserts, BPRA Spacer Plates or devices that are positioned and operated within the fuel assembly during reactor operation such as those listed above are also considered to be authorized CCs.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-1

Definitions 1.1 1.1 Definitions (continued)

DAMAGED FUEL DAMAGED FUEL assemblies are fuel assemblies containing fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks. The extent of damage in the fuel assembly, including non-cladding damage, is to be limited so that a fuel assembly maintains its configuration for normal and off-normal conditions.

The extent of cladding damage is also limited so that no release of pellet material is observed during inspection and handling operations in the pool prior to loading operations. DAMAGED FUEL assemblies shall also contain top and bottom end fittings. DAMAGED FUEL assemblies may also contain missing or partial fuel rods.

DRY SHIELDED An EOS-37PTH DSC, EOS-89BTH DSC, and CANISTER (DSC) 61BTH Type 2 DSC are sealed containers that provide confinement of fuel in an inert atmosphere.

FAILED FUEL FAILED FUEL is defined as ruptured fuel rods, severed fuel rods, loose fuel pellets, fuel fragments, or fuel assemblies that may not maintain configuration for normal or off-normal conditions.

FAILED FUEL may contain breached rods, grossly breached rods, or other defects such as missing or partial rods, missing grid spacers, or damaged spacers to the extent that the assembly may not maintain configuration for normal or off-normal conditions. FAILED FUEL shall be stored in a failed fuel canister (FFC).

FUEL BUILDING The FUEL BUILDING is the site-specific area or facility where the LOADING OPERATIONS take place.

FUEL CLASS A FUEL CLASS includes fuel assemblies of the same array size for a particular type of fuel design.

For example, WEV 17x17, WEO 17x17, and ANP Advanced MK BW 17x17 fuel assemblies are part of a WE 17x17 FUEL CLASS.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-2

Definitions 1.1 1.1 Definitions (continued)

HORIZONTAL An HSM is a reinforced concrete structure for STORAGE MODULE (HSM) storage of a loaded DSC at a spent fuel storage installation. Where the term HSM is used without distinction, this term shall apply to both the EOS-HSM and HSM-MX.

The term EOS-HSM refers to the base unit for storage of a single DSC as a single piece (EOS-HSM) or as a split base (EOS-HSMS).

The term MATRIX (HSM-MX) refers to the two-tiered staggered structure for storage of the DSCs.

INDEPENDENT SPENT FUEL The facility within a perimeter fence licensed for STORAGE INSTALLATION storage of spent fuel within HSMs.

(ISFSI)

INTACT FUEL Fuel assembly with no known or suspected cladding defects in excess of pinhole leaks or hairline cracks, and with no missing rods.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on a DSC in a TC while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the DSC and end when the TC is ready for TRANSFER OPERATIONS (i.e., when the cask is in a horizontal position on the transfer trailer.) LOADING OPERATIONS do not include DSC transfer between the TC and the HSM.

LOW-ENRICHED OUTLIER FUEL LOW-ENRICHED OUTLIER FUEL is PWR and (LEOF) BWR fuel with enrichments below the minimum enrichment specified in Table 7A and Table 18, respectively.

RECONSTITUTED FUEL ASSEMBLY A RECONSTITUTED FUEL ASSEMBLY is a fuel assembly where one or more fuel rods are replaced by low enriched uranium or natural uranium fuel rods or non-fuel rods.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI, while a DSC containing fuel assemblies is located in an HSM on the storage pad within the ISFSI perimeter.

STORAGE OPERATIONS do not include DSC transfer between the TC and the HSM.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-3

Definitions 1.1 1.1 Definitions (continued)

TRANSFER CASK (TC) A TRANSFER CASK (TC) (EOS-TC108, EOS-TC125, EOS-TC135, and OS197/OS197H/OS197FC-B/OS197HFC-B) consists of a licensed NUHOMS System TC.

When used without distinction, the term EOS-TC includes the EOS-TC108, EOS-TC125, and EOS-TC135. The term OS197 includes the OS197/OS197H/OS197FC-B/OS197HFC-B. The TC is placed on a transfer trailer for movement of a DSC to the HSM.

TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities involving the movement of a TC loaded with a DSC containing fuel assemblies.

TRANSFER OPERATIONS begin after the TC has been placed horizontal on the transfer trailer ready for TRANSFER OPERATIONS and end when the DSC is at its destination and/or no longer horizontal on the transfer trailer. TRANSFER OPERATIONS include DSC transfer between the TC and the HSM.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on a DSC to unload fuel assemblies.

UNLOADING OPERATIONS begin when the DSC is no longer horizontal on the transfer trailer and end when the last fuel assembly has been removed from the DSC. UNLOADING OPERATIONS do not include DSC transfer between the HSM and the TC.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-4

Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

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

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action).

The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

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

EXAMPLES The following examples illustrate the use of logical connectors:

EXAMPLE 1.2-1 ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO (Limiting A.1 Verify Condition for AND Operation) not met.

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

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-5

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO not met. A.1 Stop OR A.2 A.2.1 Verify AND A.2.2 A.2.2.1 Reduce OR A.2.2.2 Perform OR A.3 Remove This example represents a more complicated use of logical connectors.

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

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-6

Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO are not met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the facility is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the facility is not within the LCO Applicability.

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

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

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action B.1 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated B.1 Completion AND Time not met.

B.2 Perform Action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2 (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-7

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES Condition B has two Required Actions. Each Required Action has its own (continued) separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

EXAMPLES EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not A.1 Restore system 7 days within limit. to within limit.

B. Required Action B.1 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated B.1.

Completion Time AND not met.

B.2 Perform Action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2.

When a system is determined to not meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Condition A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-8

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

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

Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months compliance with LCO.

B. Required Action B.1 Perform Action 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated B.1.

Completion Time AND not met.

B.2 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2.

The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis.

When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

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

TIME NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-9

Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.

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

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-10

Frequency 1.4 1.4 Frequency (continued)

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

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

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

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-11

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES EXAMPLE 1.4-2 (continued)

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

The use of once indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by AND).

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

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

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-12

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

Not required to be met until 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after verifying the helium leak rate is within limit.

Verify EOS DSC vacuum drying Once after verifying the helium pressure is within limit. leak rate is within limit.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the specified Frequency. Should the vacuum drying pressure not be met immediately following verification of the helium leak rate while in LOADING OPERATIONS, this Note allows 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months to perform the Surveillance. The Surveillance is still considered to be performed within the specified Frequency.

Once the helium leak rate has been verified to be acceptable, 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months , plus the extension allowed by SR 3.0.2, would be allowed for completing the Surveillance for the vacuum drying pressure. If the Surveillance was not performed within this 96 hour0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months interval, there would then be a failure to perform the Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 1-13

Fuel to be Stored in the EOS-37PTH DSC 2.1 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Fuel to be Stored in the EOS-37PTH DSC PHYSICAL PARAMETERS:

FUEL CLASS Unconsolidated B&W 15x15, WE 14x14, WE 15x15, WE 17x17, CE 14x14, CE 15x15 and CE 16x16 FUEL CLASS PWR fuel assemblies (with or without CCs) that are enveloped by the fuel assembly design characteristics listed in Table 1.

Number of FUEL ASSEMBLIES with CCs 37 Maximum Assembly plus CC Weight 1900 lbs DAMAGED FUEL ASSEMBLIES:

Number and Location of DAMAGED Maximum of 8 DAMAGED FUEL Assemblies.

FUEL Assemblies Balance may be INTACT FUEL, empty slots, or dummy assemblies. Number and Location of DAMAGED FUEL assemblies are shown in Figures 1F, 1H, 1J, and 1K. The DSC basket cells which store DAMAGED FUEL assemblies are provided with top and bottom end caps.

FAILED FUEL:

Number and Location of FAILED FUEL Maximum of 4 FAILED FUEL locations. Balance may be INTACT FUEL assemblies, empty slots, or dummy assemblies. Number and Location of FAILED FUEL assemblies are shown in Figures 1F, 1H, 1J, and 1K. FAILED FUEL shall be stored in a failed fuel canister (FFC).

Maximum Uranium Loadings per FFC for Per Table 2 FAILED FUEL RECONSTITUTED FUEL ASSEMBLIES:

Number of RECONSTITUTED FUEL 37 ASSEMBLIES per DSC BLENDED LOW ENRICHED URANIUM (BLEU) FUEL Assemblies:

Number of BLEU FUEL Assemblies 37 per DSC (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-1

Fuel to be Stored in the EOS-37PTH DSC 2.1 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

THERMAL PARAMETERS:

Heat Load Zone Configuration and Decay Limitations on decay heats are presented in the Heat Calculations respective HLZC tables in Figures 1A through 1K.

The maximum allowable heat loads may be reduced based on the thermal analysis methodology in the UFSAR. However, the maximum decay heat for each FA shall not exceed the values specified in the aforementioned figures.

The licensee is responsible for ensuring that uncertainties in fuel enrichment and burnup are correctly accounted for in the decay heat calculations.

For FAs with active fuel length shorter than 144 inches, reduce the maximum heat load per FA in each loading zone of the HLZCs using a scaling factor (SF) as shown below.

qShort FA qBounding FA SF ,

La ,Short FA k eff ,Short FA SF .

La ,Bounding FA k eff ,Bounding FA Where, keff= Effective conductivity for FA, q = Decay heat load per assembly defined for each loading zone, La= Active fuel length, SF= Scaling factor (SF) for short FAs.

The effective conductivity for the shorter FA should be determined using the same methodology documented in the UFSAR.

For FAs with active fuel length greater than 144 inches, no scaling is required and the maximum heat loads listed for each HLZC are applicable.

Decay Heat per DSC 50.0 kW and as specified for the applicable heat load zone configuration (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-2

Fuel to be Stored in the EOS-37PTH DSC 2.1 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

RADIOLOGICAL PARAMETERS:

Maximum Assembly Average Burnup 62 GWd/MTU Minimum Cooling Time For all fuel, minimum cooling time as a function of burnup and enrichment per Table 7B.

Minimum Assembly Average Initial Fuel As specified in Table 7A as a function of assembly Enrichment average burnup.

Maximum Planar Average Initial Fuel As specified in Table 4 as a function of minimum Enrichment soluble boron concentration Minimum B-10 Concentration in Poison As specified in Table 5 Plates Number and location of LOW-ENRICHED 4 LEOF in the peripheral locations. A minimum OUTLIER FUEL (LEOF) of three non-LEOFs shall circumferentially separate LEOFs within the peripheral locations.

No limitation for LEOF in the inner locations. The peripheral and inner locations are defined in Figure 3.

CONTROL COMPONENTS (CCs)

Maximum Co-60 equivalent activity for the As specified in Table 3 CCs.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-3

Fuel to be Stored in the EOS-89BTH DSC 2.2 2.0 FUNCTIONAL AND OPERATING LIMITS 2.2 Fuel to be Stored in the EOS-89BTH DSC PHYSICAL PARAMETERS:

INTACT unconsolidated 7x7, 8x8, 9x9, and 10x10 FUEL CLASS FUEL CLASS BWR assemblies (with or without channels) that are enveloped by the fuel assembly design characteristics listed in Table 6.

NUMBER OF INTACT FUEL 89 ASSEMBLIES Channels Fuel may be stored with or without channels and associated channel hardware.

Maximum Uranium Loading 198 kg/assembly Maximum Assembly Weight with a 705 lb Channel RECONSTITUTED FUEL ASSEMBLIES:

Number of RECONSTITUTED FUEL 89 ASSEMBLIES per DSC BLENDED LOW ENRICHED URANIUM (BLEU) FUEL ASSEMBLIES:

Number of BLEU FUEL Assemblies 89 per DSC (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-4

Fuel to be Stored in the EOS-89BTH DSC 2.2 THERMAL/RADIOLOGICAL PARAMETERS:

Heat Load Zone Configuration (HLZC) Per Figure 2 for HLZC 1 or HLZC 2 or HLZC 3.

and Fuel Qualification The maximum allowable heat loads may be reduced based on the thermal analysis methodology in the UFSAR. However, the maximum decay heat for each FA shall not exceed the values specified in the aforementioned figures.

The licensee is responsible for ensuring that uncertainties in fuel enrichment and burnup are correctly accounted for during fuel qualification.

For FAs with active fuel length shorter than 144 inches, reduce the maximum decay heat for each FA in each loading zone of the HLZCs using a scaling factor (SF) as shown below.

qShort FA qBounding FA SF ,

La ,Short FA k eff ,Short FA SF .

La ,Bounding FA k eff ,Bounding FA Where, keff = Effective conductivity for FA, q = Decay heat load per assembly defined for each loading zone, La = Active fuel length, SF = Scaling factor for short FAs.

The effective conductivity for the shorter FA should be determined using the same methodology documented in the UFSAR.

For FAs with active fuel length greater than 144 inches, no scaling is required and the maximum heat loads listed for each HLZC are applicable.

Maximum Assembly Average Burnup 62 GWd/MTU Minimum Cooling Time 3.0 Years and as specified for the applicable heat load zone configuration Decay Heat per DSC 43.6 kW and as specified for the applicable heat load zone configuration Maximum Lattice Average Initial Fuel Per Table 8 Enrichment Minimum B-10 Concentration in Poison Per Table 8 Plates NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-5

Fuel to be stored in the 61BTH Type 2 DSC 2.3 2.0 FUNCTIONAL AND OPERATING LIMITS 2.3 Fuel to be stored in the 61BTH Type 2 DSC PHYSICAL PARAMETERS:

FUEL CLASS INTACT or DAMAGED or FAILED 7x7, 8x8, 9x9, 10x10 or 11x11 BWR assemblies that are enveloped by the fuel assembly design characteristics listed in Table 13 Number of INTACT FUEL ASSEMBLIES 61 Channels Fuel may be stored with or without channels and associated channel hardware.

Maximum Uranium Loading 198 kg/ assembly Maximum Assembly Weight with a 705 lbs Channel DAMAGED FUEL ASSEMBLIES:

Number and Location of DAMAGED Maximum of 61 DAMAGED FUEL assemblies as FUEL Assemblies shown in Figure 5. Balance may be INTACT FUEL, empty slots, or dummy assemblies. The DSC basket cells which store DAMAGED FUEL assemblies are provided with top and bottom end caps.

FAILED FUEL:

Number and Location of FAILED FUEL Maximum of 4 FAILED FUEL locations as shown in Figure 5 Balance may be INTACT FUEL assemblies, empty slots, or dummy assemblies. FAILED FUEL shall be stored in a failed fuel canister (FFC)

Maximum Uranium Loadings per FFC for Table 14 FAILED FUEL RECONSTITUTED FUEL ASSEMBLIES:

Number of RECONSTITUTED FUEL 61 ASSEMBLIES per DSC Maximum number of irradiated 120 stainless steel rods per DSC (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-6

Fuel to be stored in the 61BTH Type 2 DSC 2.3 Maximum number of irradiated 10 stainless steel rods per RECONSTITUTED FUEL ASSEMBLY Loading restrictions for locations Inner and peripheral loading locations are defined within the basket in Figure 6.

Inner Loading Locations:

RECONSTITUTED FUEL ASSEMBLIES may be loaded in any compartment within the inner locations.

Peripheral Loading Locations:

RECONSTITUTED FUEL ASSEMBLIES with 5 irradiated stainless steel rods per fuel assembly may be loaded into all peripheral locations (i.e., not restricted).

RECONSTITUTED FUEL ASSEMBLIES with

> 5 and 10 irradiated stainless steel rods per fuel assembly shall have at least one fuel assembly that does not contain irradiated stainless steel rods on each peripherally adjacent location (see Figure 7).

BLENDED LOW ENRICHED URANIUM (BLEU) FUEL Assemblies:

Number of BLEU FUEL Assemblies 61 per DSC THERMAL/RADIOLOGICAL PARAMETERS:

Heat Load Zone Configuration and Fuel Limitations on decay heats are presented in the Qualification respective HLZC tables in Figures 4A through 4J.

Maximum Assembly Average Burnup 62 GWd/MTU Minimum Cooling Time For all fuel, minimum cooling time as a function of burnup and enrichment per Table 19.

For the peripheral fuel of HLZC 2, 4, 5, 6, 7, and 8 only, minimum cooling time as a function of burnup and enrichment per Table 20. The peripheral and inner locations are defined in Figure 6.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-7 All Indicated Changes are in response to Revised RAI 6-4

Fuel to be stored in the 61BTH Type 2 DSC 2.3 Minimum Assembly Average Initial Fuel As specified in Table 18 as a function of assembly Enrichment average burnup.

Decay Heat per DSC 31.2 kW Maximum Lattice Average Initial Per Table 9, Table 10, Table 11 or Table 12 Enrichment Minimum B-10 Concentration in Poison Per Table 9, Table 10, Table 11 or Table 12 Plates Number and location of LOW-ENRICHED 4 LEOF in the peripheral locations. A minimum OUTLIER FUEL (LEOF) of five non-LEOFs shall circumferentially separate LEOFs within the peripheral locations. No limitation for LEOF in the inner locations. The peripheral and inner locations are defined in Figure 6.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-8

Functional and Operating Limits Violations 2.4 2.0 FUNCTIONAL OPERATING LIMITS 2.4 Functional and Operating Limits Violations If any Functional and Operating Limit of 2.1 or 2.2 or 2.3 is violated, the following ACTIONS shall be completed:

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

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

2.4.3 Within 60 days, submit a special report which describes the cause of the violation and the ACTIONS taken to restore compliance and prevent recurrence.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 2-9

LCO and SR Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) AND SURVEILLANCE REQUIREMENT (SR) APPLICABILITY LIMITING CONDITION FOR OPERATION LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

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

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

LCO 3.0.3 Not applicable to a spent fuel storage cask.

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

Exceptions to this Specification are stated in the individual Specifications.

These exceptions allow entry into specified conditions in the Applicability when the associated ACTIONS to be entered allow operation in the specified condition in the Applicability only for a limited period of time.

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

LCO 3.0.6 Not applicable to a spent fuel storage cask.

LCO 3.0.7 Not applicable to a spent fuel storage cask.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-1

LCO and SR Applicability 3.0 SURVEILLANCE REQUIREMENTS SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

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

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

Exceptions to this Specification are stated in the individual Specifications.

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

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

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

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

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-2

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity 3.1.1 Fuel Integrity during Drying LCO 3.1.1 Medium:

Helium shall be used for cover gas during drainage of bulk water (blowdown or draindown) from the DSC.

Pressure:

The DSC vacuum drying pressure shall be sustained at or below 3 Torr (3 mm Hg) absolute for a period of at least 30 minutes following evacuation.

APPLICABILITY: During LOADING OPERATIONS but before TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A. If the required vacuum A.1 30 days drying pressure cannot be obtained.

A.1.1 Confirm that the vacuum drying system is properly installed. Check and repair the vacuum drying system as necessary.

OR A.1.2 Establish helium pressure of at least 0.5 atm and no greater than 15 psig in the DSC.

OR A.2 Flood the DSC with 30 days spent fuel pool water or water meeting the requirements of LCO 3.2.1, if applicable, submerging all fuel assemblies.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-3

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1 Verify that the DSC vacuum drying Once per DSC, after an acceptable pressure is less than or equal to 3 Torr NDE of the inner top cover plate to (3 mm Hg) absolute for at least 30 DSC shell weld.

minutes following evacuation.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-4

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued) 3.1.2 DSC Helium Backfill Pressure LCO 3.1.2 DSC helium backfill pressure shall be 2.5 1 psig (stable for 30 minutes after filling) after completion of vacuum drying.

APPLICABILITY: During LOADING OPERATIONS but before TRANSFER OPERATIONS.

ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME

NOTE ----------------- A.1 30 days Not applicable until SR 3.1.2 is performed.

A.1.1 Maintain helium atmosphere

in the DSC cavity.

A. The required backfill AND pressure cannot be A.1.2 Confirm, check and repair obtained or stabilized.

or replace as necessary the vacuum drying system, helium source and pressure gauge.

AND A.1.3 Check and repair, as necessary, the seal weld between the inner top cover plate and the DSC shell.

OR A.2 Establish the DSC helium 30 days backfill pressure to within the limit. If pressure exceeds the criterion, release a sufficient quantity of helium to lower the DSC cavity pressure within the limit.

OR (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-5

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

COMPLETION CONDITION REQUIRED ACTION TIME A.3 Flood the DSC with spent 30 days fuel pool water or water meeting the requirements of LCO 3.2.1, if applicable, submerging all fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify that the DSC helium backfill pressure is Once per DSC, after the 2.5 1 psig stable for 30 minutes after filling. completion of SR 3.1.1 requirement.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-6

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued) 3.1.3 Time Limit for Completion of DSC Transfer LCO 3.1.3 The time to transfer the DSC to the HSM shall be within the limits.

Additionally, if the DSC and HLZC combination result in a time limit for completion of transfer from the table below, the air circulation system shall be assembled and be verified to be operable within 7 days before commencing the TRANSFER OPERATIONS of the loaded DSC.

APPLICABLE TIME LIMITS DSC MODEL HLZC (HOURS)

EOS-37PTH HLZC 1 or 2 10(1)(2)

EOS-37PTH HLZC 3 No Limit EOS-37PTH HLZC 4-11 8(1)

EOS-89BTH HLZC 1 or 2 10(1)

EOS-89BTH HLZC 3 No Limit 61BTH Type 2 HLZC 1, 2, 3, 4, or No limit 9

61BTH Type 2 5, 6, or 8 23 61BTH Type 2 7 or 10 10

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

1. The time limit for completion of a DSC transfer is defined as the time elapsed in hours after the initiation of draining of TC/DSC annulus water until the completion of insertion of the DSC into the HSM. For transfer of an EOS-DSC, the time limit for transfer operations is determined based on the EOS-37PTH DSC in EOS-TC125 with the maximum allowable heat load of 50 kW. If the maximum heat load of a DSC is less than 50 kW, a new time limit can be determined to provide additional time for transfer operations. The calculated time limit shall not be less than the time limit specified in LCO 3.1.3. The calculation should be performed using the same methodology documented in the UFSAR.

2. If HLZC 1 is used with the Type 4H basket, the time limit for transfer is reduced to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-7

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

APPLICABILITY: During LOADING OPERATIONS AND TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME

NOTE ------------------- A.1 If the TC is in the cask 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months handling area in a Not applicable until SR 3.1.3 is vertical orientation, performed.

remove the TC top

cover plate and fill the A. The required time limit for TC/DSC annulus with completion of a DSC transfer clean water.

not met. OR A.2 If the TC is in a 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (1) (2) horizontal orientation on the transfer skid, initiate air circulation in the TC/DSC annulus by starting one of the redundant blowers.

OR A.3 Return the TC to the 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (1) (2) cask handling area and follow required action A.1 above.

1. For EOS-37PTH and EOS-89BTH DSCs: If Required Action A.2 is initiated, run the blower for a minimum of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . After the blower is turned off, the time limit for completion of DSC transfer is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . If Required Action A.2 fails to complete within one hour, follow Required Action A.3 for the time remaining in the original Required Action A.3 completion time of 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . The minimum duration of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to run the blower and the time limit of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the blower is turned off for completion of the transfer operations are determined based on the EOS-37PTH DSC in EOS-TC125 with the maximum allowable heat load of 50 kW. If the maximum heat load of a DSC is less than 50 kW, new time limits can be determined to provide additional time for these transfer operations. The calculated time limits shall not be less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for completion of transfer operation after the blower is turned off. The calculation should be performed using the same methodology documented in the UFSAR.

2. For 61BTH Type 2 DSC: If Required Action A.2 is initiated, run the blower for a minimum of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . After the blower is turned off, the time limit for completion of DSC transfer is 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . If Required Action A.2 fails to complete within one hour, follow Required Action A.3 for the time remaining in the original Required Action A.3 completion time of 5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months . The minimum duration of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to run the blower and the time limit of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the blower is turned off for completion of the transfer operations are determined based on the 61BTH Type 2 DSC in OS197FC-B TC with the maximum allowable heat load of 31.2 kW. If the maximum heat load of a DSC is less than 31.2 kW, new time limits can be determined to provide additional time for these transfer operations. The calculated time limits shall not be less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for completion of transfer operation after the blower is turned off. The calculation should be performed using the same methodology documented in the UFSAR.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-8

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3 Verify that the time limit for completion of Once per DSC, after the initiation of DSC transfer is met. draining of TC/DSC annulus water.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-9

Cask Criticality Control 3.2 3.2 Cask Criticality Control 3.2.1 Soluble Boron Concentration LCO 3.2.1 The boron concentration of the spent fuel pool water and the water added to the cavity of a loaded EOS-37PTH DSC shall be at least the boron concentration shown in Table 4 for the basket type and fuel enrichment selected.

APPLICABILITY: During LOADING and UNLOADING OPERATIONS with fuel and liquid water in the EOS-37PTH DSC cavity.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A. Soluble boron concentration A.1 Suspend loading of fuel Immediately limit not met. assemblies into DSC.

AND A.2 A.2.1 Add boron and re- Immediately sample, and test the concentration until the boron concentration is shown to be at least that required.

OR A.2.2 Remove all fuel Immediately assemblies from DSC.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-10

Cask Criticality Control 3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify soluble boron concentration limit Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before insertion of the in spent fuel pool water and water to be first fuel assembly into the DSC.

added to the DSC cavity is met using AND two independent measurements (two samples analyzed by different Every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter while the individuals) for LOADING DSC is in the spent fuel pool or until OPERATIONS. the fuel has been removed from the DSC.

SR 3.2.1.2 Verify soluble boron concentration limit Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to flooding in spent fuel pool water and water to be DSC during UNLOADING added to the DSC cavity is met using OPERATIONS.

two independent measurements (two AND samples analyzed by different individuals) for UNLOADING Every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter while the OPERATIONS. DSC is in the spent fuel pool or until the fuel has been removed from the DSC.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-11

Radiation Protection 3.3 3.3 Radiation Protection 3.3.1 DSC and TRANSFER CASK (TC) Surface Contamination LCO 3.3.1 Removable surface contamination on the outer top 1 foot surface of the DSC AND the exterior surfaces of the TC shall not exceed:

a. 2,200 dpm/100 cm2 from beta and gamma sources; and

b. 220 dpm/100 cm2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS ACTIONS:

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

Separate condition entry is allowed for each DSC and TC.

CONDITION REQUIRED ACTION COMPLETION TIME A. Top 1 foot exterior surface of A.1 Decontaminate the DSC Prior to TRANSFER the DSC removable surface to bring the removable OPERATIONS contamination limits not met. contamination to within limits.

B. TC removable surface B.1 Decontaminate the TC Prior to TRANSFER contamination limits not met. to bring the removable OPERATIONS contamination to within limits NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-12

Radiation Protection 3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify that the removable contamination Once, prior to TRANSFER on the top 1 foot exterior surface of the OPERATIONS.

DSC is within limits.

SR 3.3.1.2 Verify by either direct or indirect methods Once, prior to TRANSFER that the removable contamination on the OPERATIONS.

exterior surfaces of the TC is within limits.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 3-13

Design Features 4.0 4.0 DESIGN FEATURES The specifications in this section include the design characteristics of special importance to each of the physical barriers and to the maintenance of safety margins in the NUHOMS EOS System design.

4.1 Site 4.1.1 Site Location Because this UFSAR is prepared for a general license, a discussion of a site-specific ISFSI location is not applicable.

4.2 Storage System Features 4.2.1 Storage Capacity The total storage capacity of the ISFSI is governed by the plant-specific license conditions.

4.2.2 Storage Pad For sites for which soil-structure interaction is considered important, the licensee is to perform site-specific analysis considering the effects of soil-structure interaction.

Amplified seismic spectra at the location of the HSM center of gravity (CG) is to be developed based on the soil-structure interaction (SSI) responses. EOS-HSM seismic analysis information is provided in UFSAR Appendix 3.9.4, Section 3.9.4.9.2. HSM-MX seismic analysis information is provided in UFSAR Appendix A.3.9.4, Section A.3.9.4.9.2.

The storage pad location shall have no potential for liquefaction at the site-specific safe shutdown earthquake (SSE) level.

Additional requirements for the pad configuration are provided in Technical Specification 4.5.2.

4.3 Canister Criticality Control The NUHOMS EOS-37PTH DSC is designed for the storage of PWR fuel assemblies with a maximum planar average initial enrichment of less than or equal to 5.0 wt. %

U-235 taking credit for soluble boron during LOADING OPERATIONS and the boron content in the poison plates of the DSC basket. The EOS-37PTH DSC uses a boron carbide/aluminum metal matrix composite (MMC) poison plate material. The EOS-37PTH DSC has two different neutron poison loading options, A and B, based on the boron content in the poison plates as listed in Table 5. Table 4 also defines the requirements for boron concentration in the DSC cavity water as a function of the DSC basket type for the various FUEL CLASSES authorized for storage in the EOS-37PTH DSC.

The NUHOMS EOS-89BTH DSC is designed for the storage of BWR fuel assemblies with a maximum lattice average initial enrichment of less than or equal to 4.80 wt. %

U-235 taking credit for the boron content in the poison plates of the DSC basket. There are three neutron poison loading options specified for the EOS-89BTH DSC depending on the type of poison material and the B-10 areal density in the plates, as specified in Table 8.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-1

Design Features 4.0 4.0 Design Features (continued)

The 61BTH Type 2 DSC is designed for the storage of BWR fuel assemblies with a maximum lattice average initial enrichment of less than or equal to 5.0 wt. % U-235 taking credit for the boron content in the poison plates of the DSC basket. The 61BTH Type 2 DSC has multiple basket configurations based on the absorber material type (borated aluminum alloy, metal matrix composite (MMC), or Boral) and boron content in the absorber plates as listed in Table 9 through Table 12.

4.3.1 Neutron Absorber Tests The neutron absorber used for criticality control in the DSC baskets may be one of the following materials:

Boron carbide/MMC BORAL (EOS-89BTH or 61BTH Type 2 DSCs only)

Borated aluminum (61BTH Type 2 DSC only)

Acceptance Testing (MMC, BORAL, and borated aluminum)

B-10 areal density is verified by neutron attenuation testing or by chemical analysis of coupons taken adjacent to finished panels, and isotopic analysis of the boron carbide powder. The minimum B-10 areal density requirements are specified in Table 5 for EOS-37PTH, Table 8 for EOS-89BTH, and Table 9 through Table 12 for 61BTH Type 2 DSCs.

Finished panels are subject to visual and dimensional inspection.

Qualification Testing (MMC only)

MMCs are qualified for use in the NUHOMS EOS System by verification of the following characteristics.

The chemical composition is boron carbide particles in an aluminum alloy matrix.

The form is with or without an aluminum skin.

The median boron carbide particle size by volume is 80 microns with no more than 10% over 100 microns.

The boron carbide content is 50% by volume.

The porosity is 3%.

4.3.2 High Strength Low Alloy Steel for Basket Structure for EOS-37PTH and EOS-89BTH DSCs.

The basket structural material shall be a high strength low alloy (HSLA) steel meeting one of the following requirements A, B, or C:

A. ASTM A829 Gr 4130 or AMS 6345 SAE 4130, quenched and tempered at not less than 1050°F, 103.6 ksi minimum yield strength and 123.1 ksi minimum ultimate strength at room temperature.

B. ASME SA-517 Gr A, B, E, F, or P.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-2

Design Features 4.0 4.0 Design Features (continued)

C. Other HSLA steel, with the specified heat treatment, meeting these qualification and acceptance criteria:

i. If quenched and tempered, the tempering temperature shall be at no less than 1000 °F, ii. Qualified prior to first use by testing at least two lots and demonstrating that the fracture toughness value KJIc 150 ksi in at -40 °F with 95%

confidence.

iii. Qualified prior to first use by testing at least two lots and demonstrating that the 95% lower tolerance limit of yield strength and ultimate strength the values in UFSAR Table 8-10.

iv. Meet production acceptance criteria based on the 95% lower tolerance limit of yield strength and ultimate strength at room temperature as determined by qualification testing described in Section 4.3.2.C.iii.

The basket structural material shall also meet one of the following production acceptance criteria for impact testing at -40 °F:

a. Charpy testing per ASTM A370, minimum absorbed energy 25 ft-lb average, 20 ft-lb lowest of three (for sub-size specimens, reduce these criteria per ASTM A370-17 Table 9), or

b. Dynamic tear testing per ASTM E604 with acceptance criterion minimum 80%

shear fracture appearance.

4.4 Codes and Standards 4.4.1 HORIZONTAL STORAGE MODULE (HSM)

The reinforced concrete HSM is designed in accordance with the provisions of ACI 349-

06. Code alternatives are discussed in Technical Specification 4.4.4. Load combinations specified in ANSI 57.9-1984, Section 6.17.3.1 are used for combining normal operating, off-normal, and accident loads for the HSM.

4.4.2 DRY SHIELDED CANISTER (DSC) (EOS-37PTH, EOS-89BTH, and 61BTH Type 2)

The DSC confinement boundary is designed, fabricated and inspected to the maximum practical extent in accordance with ASME Boiler and Pressure Vessel Code Section III, Division 1, Subsection NB, NF, and NG, for Class 1 components. The ASME code edition years and any addenda for the various DSC types and relevant subsections are provided in the table below. Code alternatives are discussed in Technical Specification 4.4.4.

DSC Type Applicable Code Edition/Year EOS-37PTH, ASME B&PV Code,Section III, Division 1, 2010 Edition with EOS-89BTH Subsection NB Addenda through 2011 61BTH Type 2 ASME B&PV Code,Section III, Division 1, 1998 Edition with Subsections NB, NG and NF Addenda through 2000 (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-3

Design Features 4.0 4.0 Design Features (continued) 4.4.3 TRANSFER CASK The EOS-TC design stress analysis and OS197 design stress analysis and fabrication, exclusive of the trunnions and the neutron shield enclosures, is performed in accordance with applicable codes as provided in the table below. The stress allowables for the upper trunnions for the EOS-TCs and the upper and lower trunnions for the OS197 conform to ANSI N14.6-1993 for single-failure-proof lifting.

TC Applicable Code Edition/Year EOS-TC ASME B&PV Code, 2010 Edition with Section III, Division 1, Addenda through 2011 Subsection NF for Class 1 supports OS197 ASME B&PV Code, 1983 Edition with Winter Section III, Division 1, 1985 Addenda Subsection NC for Class 2 vessels 4.4.4 Alternatives to Codes and Standards ASME Code alternatives for the EOS-37PTH, EOS-89BTH DSC, and 61BTH Type 2 DSC are listed below:

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-4

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB REFERENCE ASME CODE JUSTIFICATION AND COMPENSATORY CODE REQUIREMENT MEASURES SECTION/ARTICLE NCA All Not compliant with NCA NB-1100 Requirements for The canister shell, the inner top cover, the inner bottom Code Stamping of cover or bottom forging assembly, the outer top cover, Components and the drain port cover and vent port plug are designed and fabricated in accordance with the ASME Code,Section III, Subsection NB to the maximum extent practical. However, Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp, or to be ASME Certified.

NB-2121 Permitted Material Type 2205 and UNS S31803 are duplex stainless Specifications steels that provide enhance resistance to chloride-induced stress corrosion cracking. They are not included in Section II, Part D, Subpart 1, Tables 2A and 2B. UNS S31803 has been accepted for Class 1 components by ASME Code Case N-635-1, endorsed by NRC Regulatory Guide 1.84. Type 2205 falls within the chemical and mechanical requirements of UNS S31803. Normal and off-normal temperatures remain below the 600 °F operating limit. Accident conditions may exceed this limit, but only for durations too short to cause embrittlement.

NB-2130 Material must be Material is certified to meet all ASME Code criteria but supplied by ASME is not eligible for certification or Code Stamping if a approved material non-ASME fabricator is used. As the fabricator is not suppliers required to be ASME certified, material certification to NB-2130 is not possible. Material traceability and NB-4121 Material Certification certification are maintained in accordance with the by Certificate Holder NRC approved QA program associated with CoC 1042.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-5

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB (continued)

REFERENCE CODE JUSTIFICATION AND COMPENSATORY ASME CODE REQUIREMENT MEASURES SECTION/ARTICLE NB-2300 Fracture toughness Type 2205 and UNS S31803 duplex stainless steels requirements for are tested by Charpy V-notch only per NB-2300. Drop material weight tests are not required. Impact testing is not required for the vent port plug.

NB-2531 Drain port cover; SA-578 applies to 3/8" and thicker plate only; allow straight beam alternate UT techniques to achieve meaningful UT ultrasonic testing results.

(UT) per SA-578 for all plates for vessel NB- 2531 and NB- Vent port plug UT This plug may be made from plate or bar. Due to its 2541 and liquid penetrant small area, it has no structural function. It is leak testing (PT) tested along with the inner top cover plate after welding. Therefore, neither UT nor PT are required.

NB-4243 and NB-5230 Category C weld The shell to the outer top cover weld, the shell to the joints in vessels and inner top cover weld, and the drain port cover and vent similar weld joints in port plug welds are all partial penetration welds.

other components As an alternative to the non-destructive examination shall be full (NDE) requirements of NB-5230 for Category C welds, penetration all of these closure welds will be multi-layer welds and joints. These welds receive a root and final PT examination, except for the shall be examined by shell to the outer top cover weld. The shell to the outer UT or radiographic top cover weld will be a multi-layer weld and receive testing (RT) and multi-level PT examination in accordance with the either PT or magnetic guidance provided in NUREG 1536 Revision 1 for particle testing (MT). NDE. The multi-level PT examination provides reasonable assurance that flaws of interest will be identified. The PT examination is done by qualified personnel, in accordance with Section V and the acceptance standards of Section III, Subsection NB-5000. The cover to shell welds are designed to meet the guidance provided in NUREG-1536 Revision 1 for stress reduction factor.

NB-5520 NDE Personnel must Permit use of the Recommended Practice SNT-TC-1A be qualified to the up to the 2006 edition as permitted by the 2013 Code 1992 edition of SNT- Edition.

TC-1A (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-6

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB (continued)

REFERENCE CODE JUSTIFICATION AND COMPENSATORY ASME CODE REQUIREMENT MEASURES SECTION/ARTICLE NB-6000 All completed The DSC is not a complete or installed pressure pressure retaining vessel until the top closure is welded following systems shall be placement of fuel assemblies within the DSC. Due to pressure tested the inaccessibility of the shell and lower end closure welds following fuel loading and top closure welding, as an alternative, the pressure testing of the DSC is performed in two parts. The DSC shell, shell bottom, including all longitudinal and circumferential welds, is pneumatically tested and examined at the fabrication facility.

The shell to the inner top cover closure weld is pressure tested and examined for leakage in accordance with NB-6300 in the field.

The drain port cover and vent port plug welds will not be pressure tested; these welds and the shell to the inner top cover closure weld are helium leak tested after the pressure test.

Per NB-6324 the examination for leakage shall be done at a pressure equal to the greater of the design pressure or three-fourths of the test pressure. As an alternative, if the examination for leakage of these field welds, following the pressure test, is performed using helium leak detection techniques, the examination pressure may be reduced to 1.5 psig.

This is acceptable given the significantly greater sensitivity of the helium leak detection method.

NB-7000 Overpressure No overpressure protection is provided for the Protection EOS-37PTH or EOS-89BTH DSC. The function of the DSC is to contain radioactive materials under normal, off-normal, and hypothetical accident conditions postulated to occur during transportation.

The DSC is designed to withstand the maximum internal pressure considering 100% fuel rod failure at maximum accident temperature.

NB-8000 Requirements for The EOS-37PTH and EOS-89BTH DSC are stamped nameplates, or engraved with the information required by 10 CFR stamping and reports Part 72. Code stamping is not required for these per NCA-8000 DSCs. QA Data packages are prepared in accordance with requirements of the NRC approved QA program associated with CoC 1042.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-7

Design Features 4.0 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Confinement Boundary REFERENCE ASME ALTERNATIVES, JUSTIFICATION & COMPENSATORY CODE SECTION/ CODE REQUIREMENT MEASURES ARTICLE NCA All Not compliant with NCA. Quality Assurance is provided according to 10 CFR Part 72 Subpart G in lieu of NCA-4000.

NCA-1140 Use of Code editions and Code edition and addenda other than those specified in Section addenda 4.4.2 may be used for construction, but in no case earlier than 3 years before that specified in the Section 4.4.2 table.

Materials produced and certified in accordance with ASME Section II material specification from Code Editions and Addenda other than those specified in Section 4.4.2 may be used, so long as the materials meet all the requirements of Article 2000 of the applicable Subsection of the Section III Edition and Addenda used for construction.

NB-1100 Requirements for Code Code Stamping is not required. As Code Stamping is not required, Stamping of Components, the fabricator is not required to hold an ASME N or NPT stamp, Code reports and or to be ASME Certified.

certificates, etc.

NB-1132 Attachments with a pressure Bottom shield plug and outer bottom cover plate are outside code retaining function, including jurisdiction; these components together are much larger than stiffeners, shall be required to provide stiffening for the inner bottom cover plate; the considered part of the weld that retains the outer bottom cover plate and with it the bottom component. shield plug is subject to root and final PT examination.

NB-2130 Material must be supplied Material is certified to meet all ASME Code criteria but is not eligible by ASME approved material for certification or Code Stamping if a non-ASME fabricator is used.

suppliers. As the fabricator is not required to be ASME certified, material certification to NB-2130 is not possible. Material traceability and NB-4121 Material Certification by certification are maintained in accordance with TNs NRC approved Certificate Holder QA program.

NB-4243 and NB-5230 Category C weld joints in The shell to the outer top cover weld, the shell to the inner top cover vessels and similar weld weld, the siphon and vent cover plate welds, and the vent and joints in other components siphon block welds to the shell are all partial penetration welds.

shall be full penetration As an alternative to the NDE requirements of NB-5230 for Category joints. These welds shall be C welds, all of these closure welds will be multi-layer welds and examined by UT or RT and receive a root and final PT examination, except for the shell to the either PT or MT. outer top cover weld. The shell to the outer top cover weld will be a multi-layer weld and receive multi-level PT examination in accordance with the guidance provided in NUREG-1536 Revision 1 for NDE. The multi-level PT Examination provides reasonable assurance that flaws of interest will be identified. The PT examination is done by qualified personnel, in accordance with Section V and the acceptance standards of Section III, Subsection NB-5000. All of these welds will be designed to meet the guidance provided in NUREG-1536 Revision 1 for stress reduction factor.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-8

Design Features 4.0 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Confinement Boundary REFERENCE ASME ALTERNATIVES, JUSTIFICATION & COMPENSATORY CODE SECTION/ CODE REQUIREMENT MEASURES ARTICLE NB-6100 and 6200 All completed pressure The 61BTH Type 2 DSC is not a complete or installed pressure retaining systems shall be vessel until the top closure is welded following placement of Fuel pressure tested. Assemblies with the DSC. Due to the inaccessibility of the shell and lower end closure welds following fuel loading and top closure welding, as an alternative, the pressure testing of the DSC is performed in two parts. The DSC shell and shell bottom (including all longitudinal and circumferential welds) is pressure tested and examined at the fabrication facility.

The shell to the inner top cover closure weld are pressure tested and examined for leakage in accordance with NB-6300 in the field.

The siphon/vent cover welds are not pressure tested; these welds and the shell to the inner top cover closure weld are helium leak tested after the pressure test.

Per NB-6324, the examination for leakage shall be done at a pressure equal to the greater of the design pressure or three-fourths of the test pressure. As an alternative, if the examination for leakage of these field welds, following the pressure test, is performed using helium leak detection techniques, the examination pressure may be reduced to 1.5 psig. This is acceptable given the significantly greater sensitivity of the helium leak detection method.

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

The function of the DSC is to contain radioactive materials under normal, off-normal and hypothetical accident conditions postulated to occur during transportation and storage. The DSC is designed to withstand the maximum possible internal pressure considering 100% fuel rod failure at maximum accident temperature.

NB-8000 Requirements for The NUHOMS DSC nameplate provides the information required nameplates, stamping & by 10 CFR Part 71, 49 CFR Part 173 and 10 CFR Part 72 as reports per NCA-8000. appropriate. Code stamping is not required for the DSC. QA data packages are prepared in accordance with the requirements of TNs approved QA program.

NB-5520 NDE personnel must be Permit use of the Recommended Practice SNT-TC-1A to include up qualified to a specific to the most recent 2011 edition.

edition of SNT-TC-1A.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-9

Design Features 4.0 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Basket REFERENCE ASME ALTERNATIVES, JUSTIFICATION & COMPENSATORY CODE SECTION/ CODE REQUIREMENT MEASURES ARTICLE NCA All Not compliant with NCA. Quality Assurance is provided according to 10 CFR Part 72 Subpart G in lieu of NCA-4000.

NCA-1140 Use of Code editions and Code edition and addenda other than those specified in Section addenda 4.4.2 may be used for construction, but in no case earlier than 3 years before that specified in the Section 4.4.2 table.

Materials produced and certified in accordance with ASME Section II material specification from Code Editions and Addenda other than those specified in Section 4.4.2 may be used, so long as the materials meet all the requirements of Article 2000 of the applicable Subsection of the Section III Edition and Addenda used for construction.

NG/NF-1100 Requirements for Code Code Stamping is not required. As Code Stamping is not required, Stamping of Components, the fabricator is not required to hold an ASME N or NPT stamp, Code reports and or to be ASME Certified.

certificates, etc.

NG/NF-2000 Use of ASME Material Some baskets include neutron absorber and aluminum plates that are not ASME Code Class 1 material. They are used for criticality safety and heat transfer, and are only credited in the structural analysis with supporting their own weight and transmitting bearing loads through their thickness. Material properties in the ASME Code for Type 6061 aluminum are limited to 400 °F to preclude the potential for annealing out the hardening properties. Annealed properties (as published by the Aluminum Association and the American Society of Metals) are conservatively assumed for the aluminum transition rails for use above the Code temperature limits.

NG/NF-2130 Material must be supplied Material is certified to meet all ASME Code criteria but is not eligible by ASME approved for certification or Code Stamping if a non-ASME fabricator is used.

material suppliers. As the fabricator is not required to be ASME certified, material certification to NG/NF-2130 is not possible. Material traceability and NG/NF-4121 Material Certification by certification are maintained in accordance with TNs NRC approved Certificate Holder QA program.

NG-3352 Table NG-3352-1 lists the The fuel compartment tubes may be fabricated from sheet with full permissible welded joints penetration seam weldments. Per Table NG-3352-1, a joint and quality factors. efficiency (quality) factor of 0.5 is to be used for full penetration weldments examined in accordance with ASME Section V visual examination (VT). A joint efficiency (quality) factor of 1.0 is utilized for the fuel compartment longitudinal seam welds (if present) with VT examination. This is justified because the compartment seam weld is thin and the weldment is made in one pass; and both surfaces of the weldment (inside and outside) receive 100% VT examination. The 0.5 quality factor, applicable to each surface of the weldment, results is a quality factor of 1.0 since both surfaces are 100% examined. In addition, the fuel compartments have no pressure retaining function and the stainless steel material that comprises the fuel compartment tubes is very ductile.

NG/NF-8000 Requirements for The NUHOMS DSC nameplate provides the information required nameplates, stamping & by 10 CFR Part 71, 49 CFR Part 173 and 10 CFR Part 72 as reports per NCA-8000. appropriate. Code stamping is not required for the DSC. QA data packages are prepared in accordance with the requirements of TNs approved QA program.

NG/NF-5520 NDE personnel must be Permit use of the Recommended Practice SNT-TC-1A to include up qualified to a specific to the most recent 2011 edition.

edition of SNT-TC-1A.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-10

Design Features 4.0 4.0 Design Features (continued)

Code alternatives for the HSM concrete specifications are listed below:

REFERENCE ALTERNATIVES, JUSTIFICATION ACI349-06 CODE REQUIREMENT AND COMPENSATORY SECTION/ARTICLE MEASURES Appendix E, Section Paragraph E.4.3 requires testing of The concrete temperature limit criteria E.4-Concrete concrete for temperatures higher than in NUREG-1536, Section 8.4.14.2 is Temperatures, those given in Paragraph E.4.1. used for normal and off-normal Paragraph E.4.3 conditions.

Alternatively, per ACI 349-13, Code Requirements for Nuclear Safety-Related Concrete Structures and Commentary, Section RE.4, the specified compressive strength, which may be tested up to 56 days, is increased to 7,000 psi for HSM fabrication so that any losses in properties (e.g., compressive strength) resulting from long-term thermal exposure will not affect the safety margins based on the specified 5,000 psi compressive strength used in the design calculations. Additionally, also as indicated in Section RE.4, short, randomly oriented steel fibers may be used to provide increased ductility, dynamic strength, toughness, tensile strength, and improved resistance to spalling.

The safety margin on compressive strength is 40% for a concrete temperature limit of 300 °F normal and off-normal conditions.

Proposed alternatives to the above-specified ASME and ACI codes, other than the aforementioned alternatives, may be used when authorized by the Director of the Office of Nuclear Material Safety and Safeguards, or designee. The applicant should demonstrate that:

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

2. Compliance with the specified requirements of above-specified ASME and ACI codes would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The applicant should also submit information regarding the environmental impact of such a request to support the NRCs NEPA regulations in 10 CFR Part 51. Any proposed alternatives must be submitted and approved prior to implementation.

Requests for exceptions in accordance with this section should be submitted in accordance with 10 CFR 72.4.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-11

Design Features 4.0 4.0 Design Features (continued) 4.5 Storage Location Design Features The following storage location design features and parameters shall be verified by the system user to assure technical agreement with the UFSAR.

4.5.1 Storage Configuration EOS-HSMs and HSM-MXs are placed together in single rows or back to back arrays. A rear shield wall is placed on the rear of any single row loaded EOS-HSM.

4.5.2 Concrete Storage Pad Properties to Limit DSC Gravitational Loadings Due to Postulated Drops The EOS-37PTH DSC and EOS-89BTH DSC have been evaluated for drops of up to 65 inches onto a reinforced concrete storage pad. The 61BTH Type 2 DSC has been evaluated for drops of up to 80 inches onto a reinforced concrete storage pad.

4.5.3 Site Specific Parameters and Analyses The following parameters and analyses are applicable to all HSMs unless specifically noted and shall be verified by the system user for applicability at their specific site. Other natural phenomena events, such as lightning, tsunamis, hurricanes, and seiches, are site specific and their effects are generally bounded by other events, but they should be evaluated by the user.

1. Flood levels up to 50 ft and water velocity of 15 fps.

2. One-hundred year roof snow load of 110 psf.

3. Normal ambient temperature is based on the heat load of the DSC as follows:

For the EOS-HSM:

a. For the EOS-37PTH DSCs with a heat load less than or equal to 41.8 kW or for the EOS-89BTH DSCs with a heat load less than or equal to 41.6 kW, the minimum temperature is -20 °F. The maximum calculated normal average ambient temperature corresponding to a 24-hour period is 90 °F.

b. For the EOS-37PTH DSCs with a heat load greater than 41.8 kW or for the EOS-89BTH DSCs with a heat load greater than 41.6 kW, the minimum temperature is -20 °F. The maximum calculated average yearly temperature is 70 °F.

For the HSM-MX:

c. The minimum temperature is -20 °F. The maximum calculated normal average ambient temperature corresponding to a 24-hour period is 90 °F.

4. Off-normal ambient temperature range of -40 °F without solar insolation to 117 °F with full solar insolation. The 117 °F off-normal ambient temperature corresponds to a 24-hour calculated average temperature of 103 °F.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-12

Design Features 4.0 4.0 Design Features (continued)

5. The response spectra at the base of the HSMs shall be compared against the response spectra defined in UFSAR Section 2.3.4 for the EOS-HSM, and Section A.2.3.4 for the HSM-MX and shown to be enveloped by the UFSAR response spectra. If it is not enveloped, stability can be demonstrated by either static or dynamic analysis.

6. The potential for fires and explosions shall be addressed, based on site-specific considerations.

7. Supplemental Shielding: In cases where engineered features (i.e., berms, shield walls) are used to ensure that the requirements of 10 CFR 72.104(a) are met, such features are to be considered important to safety and must be evaluated to determine the applicable Quality Assurance Category.

8. If an INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) site is located in a coastal salt water marine atmosphere, then any load-bearing carbon steel DSC support structure rail components for the EOS-HSM, or front and rear DSC supports for the HSM-MX shall be procured with a minimum 0.20% copper content or stainless steel shall be used for corrosion resistance. For weld filler material used with carbon steel, 1% or more nickel bearing weld material would also be acceptable in lieu of 0.20% copper content.

9. If an ISFSI site is required to evaluate blockage of air vents for durations longer than evaluated in the UFSAR, a new duration can be determined based on site-specific parameters. The evaluation should be performed using the same methodology documented in the UFSAR.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 4-13

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS 5.1 Programs Each user of the NUHOMS EOS System will implement the following programs to ensure the safe operation and maintenance of the ISFSI:

Radiological Environmental Monitoring Program (see 5.1.1 below)

Radiation Protection Program (see 5.1.2 below)

HSM Thermal Monitoring Program (see 5.1.3 below) 5.1.1 Radiological Environmental Monitoring Program

a. A radiological environmental monitoring program will be implemented to ensure that the annual dose equivalent to an individual located outside the ISFSI controlled area does not exceed the annual dose limits specified in 10 CFR 72.104(a).

b. Operation of the ISFSI will not create any radioactive materials or result in any credible liquid or gaseous effluent release.

5.1.2 Radiation Protection Program The Radiation Protection Program will establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR Part 20 and Part 72.

a. As part of its evaluation pursuant to 10 CFR 72.212, the licensee shall perform an analysis to confirm that the limits of 10 CFR Part 20 and 10 CFR 72.104 will be satisfied under the actual site conditions and configurations considering the planned number of DSCs to be used and the planned fuel loading conditions. This analysis is also used to qualify fuel considered for loading, as outlined below:

1. For the DSCs considered for loading, select HLZC(s) appropriate to store the spent fuel.

2. Compute the decay heat of the fuel assemblies considered for loading.

Methods include, but are not limited to, NRC Regulatory Guide 3.54, or the methodology described in the UFSAR (i.e., ORIGEN-ARP).

3. Compute the source term for the fuel assemblies considered for loading. The design basis source terms provided in the UFSAR may be used for site-specific shielding analysis if they are shown to bound the site-specific source terms.

4. Demonstrate computationally that the EOS-HSM or HSM-MX to be loaded meets the dose rate requirements of TS 5.1.2(c). This evaluation may be used as the basis for the dose rate limits established in TS 5.1.2(b).

5. Demonstrate computationally that direct radiation from the ISFSI meets the requirements of 72.104.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-1

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

b. On the basis of the analysis in TS 5.1.2(a), the licensee shall establish a set of HSM dose rate limits which are to be applied to DSCs used at the site. Limits shall establish dose rates for:

i. HSM front face, ii. HSM door centerline, and iii. End shield wall exterior for the EOS-HSM or exterior side wall of the HSM-MX monolith.

c. Notwithstanding the limits established in TS 5.1.2(b), the dose rate limits may not exceed the following values as calculated for a content of design basis fuel as follows:

For EOS-HSM:

i. 25 mrem/hr average over the front face, ii. 10 mrem/hr at the door centerline, and iii. 5 mrem/hr average at the end shield wall exterior.

For HSM-MX:

i. 55 mrem/hr average over the front face, ii. 10 mrem/hr at the door centerline, and iii. 5 mrem/hr average at the exterior side wall of the HSM-MX monolith.

If the measured dose rates do not meet the limits of TS 5.1.2(b) or TS 5.1.2(c),

whichever are lower, the licensee shall take the following actions:

Notify the U.S. Nuclear Regulatory Commission (Director of the Office of Nuclear Material Safety and Safeguards) within 30 days, Administratively verify that the correct fuel was loaded, Ensure proper installation of the HSM door, Ensure that the DSC is properly positioned on the DSC supports, and Perform an analysis to determine that placement of the as-loaded DSC at the ISFSI will not cause the ISFSI to exceed the radiation exposure limits of 10 CFR Part 20 and 10 CFR Part 72 and/or provide additional shielding to assure exposure limits are not exceeded.

d. A monitoring program to ensure the annual dose equivalent to any real individual located outside the ISFSI controlled area does not exceed regulatory limits is incorporated as part of the environmental monitoring program in the Radiological Environmental Monitoring Program of TS 5.1.1.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-2

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

e. When using the EOS-TC108 with a liquid neutron shield (NS), the NS shall be verified to be filled when DSC cavity draining or TC/DSC annulus draining operations are initiated and continually monitored during the first five minutes of the draining evolution to ensure the NS remains filled. The NS shall also be verified to be filled prior to the movement of the loaded TC from the decontamination area.

Observation of water level in the expansion tank or some other means can be used to verify compliance with this requirement.

f. Following completion of the DSC shell assembly at the fabricator facility, the inner bottom cover plate, canister shell and all associated welds are leak-tested to demonstrate that these welds and components meet the leak-tight criterion ( 1.0 x 10-7 reference cm3/sec) as defined in American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment, ANSI N14.5-1997. If the leakage rate exceeds 1.0 x 10-7 reference cm3/sec, check and repair these welds or components.

Following completion of the welding of the DSC shell to the inner top cover and drain port cover and vent plug after fuel loading, these welds and components are leak-tested to demonstrate that they meet the leak-tight criterion ( 1.0 x 10-7 reference cm3/sec) as defined in American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment, ANSI N14.5-1997. If the leakage rate exceeds 1.0 x 10-7 reference cm3/sec, check and repair these welds or components.

5.1.3 HSM Thermal Monitoring Program Two separate programs for the EOS-HSM and MATRIX HSM are described in Technical Specifications 5.1.3.1 and 5.1.3.2, respectively.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-3

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) 5.1.3.1 EOS-HSM Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each EOS-HSM. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria.

Each user must implement either TS 5.1.3.1(a) OR 5.1.3.1(b).

a. Daily Visual Inspection of EOS-HSM Inlets and Outlets (Front Wall and Roof Birdscreens) and Wind Deflectors

i. The user shall develop and implement procedures to perform visual inspection of EOS-HSM inlets and outlets on a daily basis.

Perform a daily visual inspection of the air vents to ensure that EOS-HSM air vents are not blocked for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months . If visual inspection indicates blockage, clear air vents and replace or repair birdscreens if damaged. If the air vents are blocked or could have been blocked for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months , evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

ii. Daily Visual Inspection of Wind Deflectors If wind deflectors are required per TS 5.5, the user shall develop and implement procedures to perform visual inspection of the wind deflectors on a daily basis.

There is a possibility that the wind deflectors could become damaged or lost by extreme winds, tornados, or other accidents. The condition caused by a damaged or lost wind deflector is bounded by the air vent blockage postulated and analyzed in the UFSAR accident analyses. The procedures shall ensure that the duration of a damaged or lost wind deflector will not exceed periods longer than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months as assumed in the UFSAR analyses for vent blockage. If visual inspection indicates a damaged or lost wind deflector, replace or repair the wind deflector. If the wind deflectors are damaged or could have been damaged for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months , evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

b. Daily EOS-HSM Temperature Measurement Program

i. The user shall develop a daily temperature measurement program to verify the thermal performance of each NUHOMS EOS System. The user shall establish administrative temperature limits to (1) detect off-normal and accident blockage conditions before the EOS- HSM components and fuel cladding temperatures would exceed temperature design limits and (2) ensure the EOS-HSM air vents are not blocked for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months . The daily temperature measurements shall include one of the following options:

1. direct measurement of the EOS-HSM concrete temperature

2. direct measurement of inlet and outlet air temperatures (continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-4

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

If the direct measurement of the inlet and outlet air temperatures (option 2) is performed, the measured temperature differences of the inlet and outlet vents of each individual EOS-HSM must be compared to the predicted temperature differences for each individual EOS-HSM during normal operations. The measured temperature difference between the inlet and outlet vents shall not exceed 138 °F.

ii. The user shall establish in the program, measurement locations in the EOS-HSM that are representative of the EOS-HSM thermal performance and directly correlated to the predicted fuel cladding temperatures, air mass flow rates, and NUHOMS EOS System temperature distributions that would occur with the off-normal and accident blockage conditions, as analyzed in the UFSAR. The administrative temperature limits shall employ appropriate safety margins that ensure temperatures would not exceed design basis temperature limits in the UFSAR, and be based on the UFSAR methodologies used to predict thermal performance of the NUHOMS EOS System. If the direct measurement of the inlet and outlet air temperatures (option 2) is performed, the user must develop procedures to measure air temperatures that are representative of inlet and outlet air temperatures, as analyzed in the UFSAR. The user must also consider site-specific environmental conditions, loaded decay heat patterns, and the proximity of adjacent EOS-HSM modules in the daily air temperature measurement program. The user must ensure that measured air temperatures reflect only the thermal performance of each individual module, and not the combined performance of adjacent modules.

iii. The user shall establish in the program the appropriate actions to be taken if administrative temperature criteria are exceeded. If an administrative temperature limit is exceeded during a daily measurement, the user shall inspect the vents, wind deflectors if installed, and implement TS 5.1.3.1(a) for the affected system, until the cause of the excursion is determined and necessary corrective actions are completed under the site corrective action program.

iv. If measurements or other evidence indicate that the EOS-HSM concrete temperatures have exceeded the concrete accident temperature limit of 500

°F for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months , the user shall perform an analysis and/or tests of the concrete in accordance with TS 5.3. The user shall demonstrate that the structural strength of the EOS-HSM has an adequate margin of safety and take appropriate actions to return the EOS-HSM to normal operating conditions.

v. If measurements or other evidence indicate that off-normal or accident temperature limits for fuel cladding have been exceeded, verify that canister confinement is maintained and assess analytically the condition of the fuel.

Additionally, within 30 days, take appropriate actions to restore the spent fuel to a safe configuration.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-5

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) 5.1.3.2 HSM-MX Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each HSM-MX. There are no credible scenarios that could block both the inlet and outlet vents. Therefore, only blockage of inlet vent is considered in the UFSAR. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria. Each user must implement either TS 5.1.3.2(a) OR 5.1.3.2(b).

a. Daily Visual Inspection of HSM-MX Inlets and Outlets (Front Wall and Roof Birdscreens)

The user shall develop and implement procedures to perform visual inspection of HSM-MX inlets and outlets on a daily basis.

Perform a daily visual inspection of the air vents to ensure that HSM-MX air vents are not blocked for more than 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months . If visual inspection indicates blockage, clear air vents and replace or repair birdscreens if damaged. If the air vents are blocked or could have been blocked for more than 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months , evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

b. Daily HSM-MX Temperature Measurement Program

i. The user shall develop a daily temperature measurement program to verify the thermal performance of each HSM-MX System through direct measure of the HSM-MX concrete temperature. The user shall establish administrative temperature limits to (1) detect off-normal and accident blockage conditions before the HSM components and fuel cladding temperatures would exceed temperature design limits and (2) ensure the HSM-MX air vents are not blocked for more than 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months .

ii. The user shall establish in the program measurement locations in the HSM-MX that are representative of the HSM-MX thermal performance and directly correlated to the predicted fuel cladding temperatures, air mass flow rates, and NUHOMS MATRIX System temperature distributions that would occur with the off-normal and accident blockage conditions, as analyzed in the UFSAR. The administrative temperature limits shall employ appropriate safety margins that ensure temperatures would not exceed design basis temperature limits in the UFSAR, and be based on the UFSAR methodologies used to predict thermal performance of the NUHOMS MATRIX System.

iii. The user shall establish in the program the appropriate actions to be taken if administrative temperature criteria are exceeded. If an administrative temperature limit is exceeded during a daily measurement, the user shall inspect the vents and implement TS 5.1.3.2(a) for the affected system, until the cause of the excursion is determined and necessary corrective actions are completed under the site corrective action program.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-6

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) iv. If measurements or other evidence indicate that the HSM-MX concrete temperatures have exceeded the concrete accident temperature limit of 500

°F for more than 32 hours3.703704e-4 days 0.00889 hours 5.291005e-5 weeks 1.2176e-5 months , the user shall perform an analysis and/or tests of the concrete in accordance with TS 5.3. The user shall demonstrate that the structural strength of the HSM-MX has an adequate margin of safety and take appropriate actions to return the HSM-MX to normal operating conditions.

v. If measurements or other evidence indicate that off-normal or accident temperature limits for fuel cladding have been exceeded, verify that canister confinement is maintained and assess analytically the condition of the fuel.

Additionally, within 30 days, take appropriate actions to restore the spent fuel to a safe configuration.

5.2 Lifting Controls 5.2.1 TC/DSC Lifting Height and Temperature Limits The requirements of 10 CFR 72 apply to TC/DSC lifting/handling height limits outside the FUEL BUILDING. The requirements of 10 CFR Part 50 apply to TC/DSC lifting/handling height limits inside the FUEL BUILDING. Confirm the surface temperature of the TC before TRANSFER OPERATIONS of the loaded TC/DSC.

The lifting height of a loaded TC/ DSC is limited as a function of low temperature and the type of lifting/handling device, as follows:

No lifts or handling of the TC/DSC at any height are permissible at TC surface temperatures below 0 °F The maximum lift height of the TC/DSC shall be 65 inches for the EOS-DSCs or 80 inches for the 61BTH Type 2 DSC if the surface temperature of the TC is above 0 °F and a non-single-failure-proof lifting/handling device is used.

No lift height restriction is imposed on the TC/DSC if the TC surface temperature is higher than 0 °F and a single-failure-proof lifting/handling system is used.

The requirements of 10 CFR Part 72 apply when the TC/DSC is in a horizontal orientation on the transfer trailer. The requirements of 10 CFR Part 50 apply when the TC/DSC is being lifted/handled using the cask handling crane/hoist. (This distinction is valid only with respect to lifting/handling height limits.)

5.2.2 Cask Drop Inspection Requirement The TC will be inspected for damage and the DSC will be evaluated after any TC with a loaded DSC side drop of 15 inches or greater.

Background

TC/DSC handling and loading activities are controlled under the 10 CFR Part 50 license until a loaded TC/DSC is placed on the transporter, at which time fuel handling activities are controlled under the 10 CFR Part 72 license.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-7

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

Safety Analysis The analysis of bounding drop scenarios shows that the TC will maintain the structural integrity of the DSC confinement boundary from an analyzed side drop height of 65 inches for the EOS-DSCs and 80 inches for the 61BTH Type 2 DSC. This 65-inch/80-inch drop height envelopes the maximum height from the bottom of the TC when secured to the transfer trailer while en route to the ISFSI.

Although analyses performed for cask drop accidents at various orientations indicate much greater resistance to damage, requiring the inspection of the DSC after a side drop of 15 inches or greater ensures that:

1. The DSC will continue to provide confinement.

2. The TC can continue to perform its design function regarding DSC transfer and shielding.

5.3 Concrete Testing HSM concrete shall be tested during the fabrication process for elevated temperatures to verify that there are no significant signs of spalling or cracking and that the concrete compressive strength is greater than that assumed in the structural analysis. Tests shall be performed at or above the calculated peak temperature and for a period no less than the permissible duration as specified in Technical Specification 5.1.3.

HSM concrete temperature testing shall be performed whenever:

There is a change in the supplier of the cement, or There is a change in the source of the aggregate, or The water-cement ratio changes by more than 0.04.

(continued)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-8

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) 5.4 Hydrogen Gas Monitoring For DSCs, while welding the inner top cover during LOADING OPERATIONS, and while cutting the inner top cover to DSC shell weld when the DSC cavity is wet during UNLOADING OPERATIONS, hydrogen monitoring of the space under the top shield plug in the DSC cavity is required, to ensure that the combustible mixture concentration remains below the flammability limit of 4%. If this limit is exceeded, all welding operations shall be stopped and the DSC cavity purged with helium to reduce hydrogen concentration safely below the limit before welding or cutting operations can be resumed.

5.5 EOS-HSM Wind Deflectors If the heat load of an EOS-37PTH DSC loaded per HLZC 1, 4, 6, 10, or 11 during STORAGE OPERATIONS is greater than 41.8 kW, wind deflectors shall be installed on the EOS-HSM.

If the heat load of a fuel assembly loaded per HLZC 5 in the EOS-37PTH DSC during STORAGE OPERATIONS is greater than 1.625 kW, wind deflectors shall be installed on the EOS-HSM.

If the heat load of an EOS-89BTH DSC during STORAGE OPERATIONS is greater than 41.6 kW, wind deflectors shall be installed on the EOS-HSM.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 5-9

Tables Table 1 Fuel Assembly Design Characteristics for the EOS-37PTH DSC B&W WE CE WE CE WE CE PWR FUEL CLASS 15X15 17X17 15X15 15X15 14X14 14X14 16X16 Fissile Material UO2 UO2 UO2 UO2 UO2 UO2 UO2 Maximum Number of Fuel 208 264 216 204 176 179 236 Rods Maximum Number of 17 25 9 21 5 17 5 Guide/ Instrument Tubes Table 2 Maximum Uranium Loading per FFC for Failed PWR Fuel Maximum Uranium Fuel Assembly Class Loading (MTU)

WE 17x17 0.550 CE 16x16 0.456 BW 15x15 0.492 WE 15x15 0.480 CE 15x15 0.450 CE 14x14 0.400 WE 14x14 0.410 Table 3 Co-60 Equivalent Activity for CCs Stored in the EOS-37PTH DSC Maximum Co-60 Equivalent Activity (2)

Fuel Region per DSC (Curies/DSC)

Active Fuel 32,656 Plenum/Top Region 6,671 Notes:

1. Not Used.

2. NSAs and Neutron Sources shall only be stored in the inner zone of the basket. Figure 3 defines the compartments categorized as the Inner and Peripheral Zones.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-1

Tables Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH (2 Pages)

Maximum Planar Average Initial Enrichment (wt. % U-235) as a Function of Soluble Boron Concentration and Basket Type (Fixed Poison Loading) With and Without CCs Basket Type PWR Fuel Class Minimum A1/A2/A3/A4H/A4L/A5 B1/B2/B3/B4H/B4L/B5 Soluble w/o CCs w/ CCs w/o CCs w/ CCs Boron (ppm) DAMAGED/ DAMAGED/ DAMAGED/ DAMAGED/

INTACT INTACT INTACT INTACT FAILED FAILED FAILED FAILED FUEL (2) FUEL (2) FUEL (3) FUEL (3)

FUEL FUEL FUEL FUEL 2000 4.35 4.20 4.35 4.15 4.50 4.15 4.45 4.25 2100 4.50 4.20 4.45 4.20 4.65 4.25 4.60 4.40 WE 17x17 2200 4.60 4.40 4.55 4.35 4.75 4.45 4.70 4.55 Class 2300 4.70 4.45 4.65 4.50 4.85 4.65 4.85 4.60 2400 4.85 4.45 4.80 4.60 5.00 4.65 4.95 4.75 2500 4.95 4.65 4.90 4.70 5.00 5.00 5.00 4.95 2000 5.00 4.75 5.00 4.70 5.00 5.00 5.00 5.00 2100 5.00 5.00 5.00 5.00 - - - -

CE 16x16 2200 - - - - - - - -

Class 2300 - - - - - - - -

2400 - - - - - - - -

2500 - - - - - - - -

2000 4.25 4.05 4.20 4.00 4.40 4.10 4.35 4.15 2100 4.40 4.10 4.30 4.15 4.55 4.20 4.45 4.25 2200 4.50 4.25 4.45 4.15 4.65 4.35 4.60 4.30 BW 15x15 2300 4.60 4.35 4.55 4.30 4.80 4.40 4.70 4.50 Class 2400 4.75 4.40 4.65 4.45 4.90 4.55 4.85 4.50 2500 4.85 4.55 4.75 4.65 5.00 4.75 4.90 4.75 (1) (1) (1) (1) (1) (1) 2600 5.00 5.00 2000 4.45 4.10 4.40 4.10 4.55 4.30 4.55 4.25 2100 4.60 4.15 4.55 4.15 4.65 4.50 4.65 4.35 2200 4.70 4.25 4.65 4.35 4.80 4.55 4.80 4.45 WE 15x15 2300 4.85 4.35 4.75 4.45 5.00 4.50 4.95 4.50 2400 4.95 4.50 4.90 4.50 5.00 4.90 5.00 4.80 2500 5.00 4.75 5.00 4.65 5.00 5.00 5.00 5.00 2000 4.60 4.25 4.55 4.20 4.75 4.35 4.70 4.30 2100 4.70 4.45 4.65 4.40 4.85 4.50 4.85 4.35 CE 15x15 2200 4.85 4.50 4.80 4.45 5.00 4.60 4.95 4.60 Assembly 2300 5.00 4.55 4.90 4.65 5.00 5.00 5.00 4.80 Class 2400 5.00 5.00 5.00 4.85 5.00 5.00 5.00 5.00 2500 - - 5.00 5.00 - - - -

2000 5.00 5.00 5.00 4.50 5.00 5.00 5.00 4.95 2100 - - 5.00 4.95 - - 5.00 5.00 CE 14x14 2200 - - 5.00 5.00 - - - -

Assembly 2300 - - - - - - - -

Class 2400 - - - - - - - -

2500 - - - - - - - -

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-2

Tables Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH (2 Pages)

Maximum Planar Average Initial Enrichment (wt. % U-235) as a Function of Soluble Boron Concentration and Basket Type (Fixed Poison Loading) With and Without CCs Basket Type PWR Fuel Class Minimum A1/A2/A3/A4H/A4L/A5 B1/B2/B3/B4H/B4L/B5 Soluble w/o CCs w/ CCs w/o CCs w/ CCs Boron (ppm) DAMAGED/ DAMAGED/ DAMAGED/ DAMAGED/

INTACT INTACT INTACT INTACT FAILED FAILED FAILED FAILED FUEL (2) FUEL (2) FUEL (3) FUEL (3)

FUEL FUEL FUEL FUEL 2000 5.00 5.00 5.00 5.00 5.00 5.00 5.00 5.00 2100 - - - - - - - -

WE 14x14 2200 - - - - - - - -

Class 2300 - - - - - - - -

2400 - - - - - - - -

2500 - - - - - - - -

Notes:

1. Not analyzed.

2. May only be stored in basket types A4H and A4L

3. May only be stored in basket types B4H and B4L NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-3

Tables Table 5 Minimum B-10 Content in the Neutron Poison Plates of the EOS-37PTH DSC Minimum B-10 Content Basket Type (areal density) 2 for MMC (mg/cm )

A1/A2/A3/A4H/A4L/A5 28.0 B1/B2/B3/B4H/B4L/B5 35.0 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-4

Tables Table 6 Fuel Assembly Design Characteristics for the EOS-89BTH DSC BWR FUEL BWR Fuel (1)(2)

CLASS ID Example Fuel Designs 7x7 GE-7-A GE-1, GE-2, GE-3 8x8 GE-8-A GE-4, XXX-RCN 8x8 GE-8-B GE-5, GE-Pres GE-Barrier GE-8 Type 1 8x8 GE-8-C GE-8 Type II 8x8 GE-8-D GE-9, GE-10 9x9 GE-9-A GE-11, GE-13 10 x 10 GE-10-A GE-12, GE-14 10 x 10 GE-10-B GNF2 7x7 ENC-7-A ENC-IIIA 7x7 ENC-7-B ENC-III ENC-IIIE ENC-IIIF 8x8 ENC-8-A ENC Va and Vb 8x8 FANP-8-A FANP 8x8-2 9x9 FANP-9-A FANP-9x9-79/2 FANP-9x9-72 FANP-9x9-80 FANP-9x9-81 9x9 FANP-9-B Siemens QFA ATRIUM 9 10 x 10 FANP-10-A ATRIUM 10 ATRIUM 10XM 8x8 ABB-8-A SVEA-64 8x8 ABB-8-B SVEA-64 10 x 10 ABB-10-A SVEA-92 SVEA-96Opt SVEA-100 10 x 10 ABB-10-B SVEA-92 SVEA-96 SVEA-100 10 x 10 ABB-10-C SVEA-96Opt2 Notes:

1. Any fuel channel average thickness up to 0.120 inch is acceptable on any of the fuel designs.

2. Example BWR fuel designs are listed herein and are not all-inclusive.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-5

Tables Table 7A PWR Minimum Enrichments as a Function of Burnup Burnup Range Minimum Enrichment (GWd/MTU) (wt. % U-235) 1-6 0.7 7-16 1.3 17-30 1.8 (1) 31-62 Burnup/16 Notes:

(1) Round enrichment down to the nearest 0.1%. Example: for 62 GWd/MTU, 62/16 = 3.875%,

round down to 3.8%.

(2) Fuel below the minimum enrichment defined in this table is classified as LOW-ENRICHED OUTLIER FUEL. Number and location are specified in Section 2.1.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-6

Tables Table 7B EOS-37PTH DSC Fuel Qualification Table, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 1.3 1.8 2.0 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 2.95 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 4.92 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 9.84 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 14.76 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 19.68 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 22.14 2.16 2.12 2.09 2.05 2.04 2.02 2.00 2.00 24.60 2.35 2.31 2.28 2.26 2.24 2.18 2.14 27.06 2.55 2.51 2.49 2.47 2.41 2.35 29.52 2.76 2.75 2.71 2.64 2.58 30.50 2.85 2.82 2.74 2.67 34.10 3.22 3.20 3.11 3.03 Notes:

(1) The minimum cooling time is 2.0 years.

(2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.

(3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.

(4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-7

Tables Table 7C Deleted NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-8

Tables Table 8 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for EOS-89BTH DSC Maximum Lattice Minimum B-10 Areal Density Average Initial 2 (mg/cm )

Basket Type Enrichment (1)

(wt. % U-235) MMC BORAL A1 / A2 / A3 4.10 32.7 39.2 B1 / B2 / B3 4.45 41.3 49.6 C1 / C2 / C3 4.80 Not Allowed 60.0 Note:

1. For ABB-10-C Fuel Designs, the enrichment shall be reduced by 0.25 wt. % U-235 for Types A1 / A2 / A3 and Types C1 / C2 / C3 and reduced by 0.20 wt. % U-235 for Types B1 / B2 /

B3.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-9

Tables Table 9 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Intact Fuel)

Maximum Lattice Minimum B-10 Areal Density, 2

Average Initial (mg/cm )

Basket Type Enrichment Borated (wt. % U-235)

(1) Boral Aluminum/MMC A 3.7 22 27 B 4.1 32 38 C 4.4 42 50 D 4.6 48 58 E 4.8 55 66 (1)

F 5.0 62 75 Note:

1) For ATRIUM 11 fuel assemblies, the U-235 wt. % enrichment is reduced by 0.55%. The ATRIUM 11 fuel assemblies are authorized for storage in the Type F basket only.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-10

Tables Table 10 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Damaged Fuel)

Maximum Lattice Average Initial Minimum B-10 Areal Density, 2

Enrichment (wt. % U-235) (mg/cm )

Basket Up to 4 Five or More Type Damaged Damaged Borated (1) (1) Boral Assemblies Assemblies Aluminum/MMC (16 Maximum)

A 3.7 2.80 22 27 B 4.1 3.10 32 38 C 4.4 3.20 42 50 D 4.6 3.40 48 58 E 4.8 3.50 55 66 (2, 3)

F 5.0 3.60 62 75 Notes:

1) See Figure 5 for the location of damaged fuel assemblies within the 61BTH Type 2 DSC.

2) ATRIUM 11 fuel assemblies are authorized for storage only in the Type F basket only with a maximum of 4 damaged fuel assemblies.

3) For ATRIUM 11 fuel assemblies, the U-235 wt. % enrichment is reduced by 0.55%.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-11

Tables Table 11 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Failed and Damaged Fuel)

Maximum Lattice Average Initial Minimum B-10 Areal 2

Enrichment (wt. % U-235) Density (mg/cm )

Up to 4 Failed Up to 4 Failed Assemblies (Corner Assemblies Locations) and up to 12 Basket (Corner Damaged Assemblies Borated (1, 2) (1, 2)

Type Locations) (Interior Locations) Aluminum/MMC Boral A 3.7 2.8 22 27 B 4.0 3.1 32 38 C 4.4 3.2 42 50 D 4.6 3.4 48 58 E 4.8 3.4 55 66 F 5.0 3.5 62 75 Notes:

1) See Figure 5 for the locations of the failed and damaged assemblies within the 61BTH Type 2 DSC.

2) Failed ATRIUM 11 fuel assemblies are not authorized for storage in the 61BTH Type 2 DSC.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-12

Tables Table 12 Maximum Lattice Average Initial Enrichments and Minimum B-10 Areal Density for the 61BTH Type 2 DSC for > 16 Damaged Fuel Assemblies Up to 57 Damaged Fuel at 3.30 Minimum B-10 Areal Density 2

wt. % U-235 (mg/cm )

Remaining Remaining Four Basket Four Intact Damaged Borated (1) (1)

Type Assemblies Assemblies Aluminum/MMC Boral A - - - -

B - - - -

C - - - -

D 5.00 4.20 48 58 E 5.00 4.20 55 66 F 5.00 4.20 62 75 Note:

1) See Figure 5 for the locations of the damaged assemblies within the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-13

Tables Table 13 BWR Fuel Assembly Design Characteristics for the 61BTH Type 2 DSC Initial Design or BWR FUEL Reload Fuel CLASS (1) (3)

Designation GE1 7x7-GE2 49/0 GE3 8x8-GE4 63/1 GE-5 8x8- GE-Pres 62/2 GE-Barrier GE8 Type I 8x8- GE8 60/4 Type II 8x8- GE9 60/1 GE10 9x9- GE11 74/2 GE13 GE12 10x10-GE14 92/2 GNF2 7x7-ENC-IIIA 49/0 7x7- (2)

ENC-III 48/1Z 8x8- ENC Va 60/4Z ENC Vb 8x8- FANP 62/2 8x8-2 9x9- FANP9 79/2 9x9-2 Siemens 9x9 QFA 10x10- ATRIUM-10 91/1 ATRIUM-10XM 11x11 ATRIUM-11 Notes:

(1) Any fuel channel average thickness up to 0.120 inch is acceptable on any of the fuel designs.

(2) Includes ENC-IIIE and ENC-IIIF.

(3) Initial designs or reload fuel designations belonging to a listed fuel class, but not listed herein may be qualified for storage using the same methodology as documented in the UFSAR.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-14

Tables Table 14 Maximum Uranium Loading per FFC for Failed 61BTH Type 2 Fuel Fuel Maximum Assembly MTU/Assembly Class 7x7 0.198 8x8 0.188 9x9 0.180 10x10 0.187 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-15

Tables Table 15 System Configurations for EOS-37PTH HLZCs HLZC Storage Module Transfer Cask 1 EOS-HSM EOS-TC125 EOS-TC135 2 EOS-HSM EOS-TC108 EOS-TC125 EOS-TC135 3 EOS-HSM EOS-TC108 EOS-TC125 EOS-TC135 4 EOS-HSM EOS-TC108 EOS-TC125 EOS-TC135 5 EOS-HSM EOS-TC108 EOS-TC125 EOS-TC135 6 EOS-HSM EOS-TC108 EOS-TC125 EOS-TC135 7 HSM-MX EOS-TC108 EOS-TC125 EOS-TC135 8 HSM-MX EOS-TC108 EOS-TC125 EOS-TC135 9 HSM-MX EOS-TC108 EOS-TC125 EOS-TC135 10 EOS-HSM EOS-TC125 EOS-TC135 11 EOS-HSM EOS-TC125 HSM-MX EOS-TC135 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-16

Tables Table 16 System Configurations for EOS-89BTH HLZCs HLZC Storage Module Transfer Cask 1 EOS-HSM EOS-TC125 EOS-TC108 2 EOS-HSM EOS-TC125 EOS-HSM EOS-TC108 3

HSM-MX EOS-TC125 NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-17

Tables Table 17 System Configurations for 61BTH Type 2 HLZCs HLZC Storage Module Transfer Cask OS197/OS197H/

1 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

2 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

3 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

4 HSM-MX OS197FC-B/OS197HFC-B 5 HSM-MX OS197FC-B/OS197HFC-B 6 HSM-MX OS197FC-B/OS197HFC-B 7 HSM-MX OS197FC-B/OS197HFC-B 8 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

9 HSM-MX OS197FC-B/OS197HFC-B 10 HSM-MX OS197FC-B/OS197HFC-B NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-18

Tables Table 18 BWR Minimum Enrichments as a Function of Burnup (61BTH Type 2 DSC)

Burnup Range Minimum Enrichment (GWd/MTU) (wt. %)

1-6 0.7 7-19 0.9 (1) 20-35 Burnup/20 (1) 36-62 Burnup/16 Notes:

1) Round down to the nearest 0.1%. Example: for 62 GWd/MTU, 62/16 = 3.875%, round down to 3.8%.

2) Fuel below the minimum enrichment defined in this table is classified as LOW-ENRICHED OUTLIER FUEL. Number and location are specified in Section 2.3.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-19

Tables Table 19 61BTH Type 2 DSC Fuel Qualification Table, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 0.9 1.0 1.5 1.7 2.2 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 1.19 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 1.39 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.97 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 3.76 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 3.96 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 5.94 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 6.93 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 7.13 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 7.92 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 8.91 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 9.90 2.11 2.06 2.01 2.00 2.00 2.00 2.00 10.89 2.29 2.24 2.22 2.19 2.11 2.05 11.88 2.48 2.46 2.43 2.34 2.27 12.28 2.57 2.53 2.44 2.36 Notes:

1) The minimum cooling time is 2.0 years.

2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.

3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.

4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-20

Tables Table 20 61BTH Type 2 DSC Fuel Qualification Table, HLZC 2, 4, 5, 6, 7, and 8, Peripheral Locations (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 0.9 1.0 1.5 1.7 2.2 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 1.19 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 1.39 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.97 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 3.76 2.35 2.33 2.23 2.20 2.12 2.09 2.06 2.03 2.01 2.00 2.00 2.00 2.00 2.00 3.96 2.41 2.31 2.28 2.20 2.16 2.13 2.10 2.08 2.06 2.05 2.04 2.02 2.00 5.94 3.13 3.09 2.98 2.93 2.88 2.83 2.79 2.75 2.74 2.72 2.67 2.63 6.93 3.55 3.43 3.36 3.29 3.24 3.18 3.14 3.12 3.10 3.03 2.98 7.13 3.52 3.45 3.39 3.33 3.27 3.22 3.21 3.18 3.11 3.06 7.92 3.87 3.79 3.71 3.64 3.58 3.57 3.53 3.45 3.38 8.91 4.39 4.29 4.20 4.12 4.10 4.05 3.94 3.85 9.90 5.03 4.91 4.80 4.77 4.70 4.56 4.43 10.89 5.86 5.70 5.65 5.56 5.35 5.18 11.88 6.97 6.89 6.75 6.45 6.19 12.28 7.53 7.36 7.00 6.70 Notes:

1) The minimum cooling time is 2.0 years.

2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.

3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.

4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.

5) The peripheral locations are defined in Figure 6.

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 T-21

Figures Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 2.0 1.3125 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 50.0 Figure 1A Heat Load Zone Configuration 1 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-1

Figures Zone Number 1 2 3 Maximum Decay Heat, (H), (kW/FA plus CCs, if included) 1.0 1.5 1.05 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 41.8 Figure 1B Heat Load Zone Configuration 2 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-2

Figures Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus CCs, if included) 0.95 1.0 1.0 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 36.35 Figure 1C Heat Load Zone Configuration 3 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-3

Figures Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.625 1.6 Maximum Number of Fuel Assemblies 13 8 16 (1)

Maximum Decay Heat per DSC (kW) 50.0 Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1D Heat Load Zone Configuration 4 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-4

Figures Zone Number 1 2 3 4 Maximum Decay Heat (kW/FA plus CCs, if included) 0.7 0.5 2.4 0.85 Maximum Number of Fuel Assemblies 5 6 8 18 Maximum Decay Heat per DSC (kW) 41.0 Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1E Heat Load Zone Configuration 5 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-5

Figures Z3 Z3** Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3** Z1 Z1 Z1 Z1 Z1 Z3**

Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z3** Z3

(*) denotes location where INTACT or DAMAGED FUEL can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

(1) (1)

Zone Number 1 2 3 (2)

Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.5 1.3125 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 46.00

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

2. The maximum allowable heat load per FAILED FUEL compartment is 0.8 kW.

Figure 1F Heat Load Zone Configuration 6 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-6

Figures Zone Number 1 2 3 Maximum Number of Fuel Assemblies 13 8 16 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.60 1.3125 (1)

Maximum Decay Heat per DSC (kW) 41.8 Lower Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.9 1.60 1.60 (1)

Maximum Decay Heat per DSC (kW) 50.0 Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1G Heat Load Zone Configuration 7 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-7

Figures Z3 Z3** Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3** Z1 Z1 Z1 Z1 Z1 Z3**

Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z3** Z3

(*) denotes location where INTACT or DAMAGED FUEL can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

(2) (2)(3)

Zone Number 1 2 3 Maximum Number of Fuel Assemblies 13 8 16 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.8 1.50 1.50 (1)(4)

Maximum Decay Heat per DSC (kW) 41.8 Lower Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.8 1.50 1.50 (1)

Maximum Decay Heat per DSC (kW) 46.4 Notes:

1. The maximum decay heat per DSC is limited to 41.8 kW when DAMAGED or FAILED FUEL is loaded.

2. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

3. The maximum allowable heat load per FAILED FUEL is 0.8 kW.

4. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1H Heat Load Zone Configuration 8 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-8

Figures Z5 Z4 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z3 Z2 Z1 Z2 Z3 Z4 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z4 Z3 Z2 Z1 Z2 Z3 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z4 Z5 Zone Number 1 2 3 4 5 Maximum Decay Heat (kW/FA plus CCs, if 0.50 0.70 2.0 0.75 2.4 included)

Maximum Number of Fuel Assemblies 5 6 4 18 4 Maximum Decay Heat per DSC (kW) 37.80 Figure 1I Heat Load Zone Configuration 9 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-9

Figures Z2* Z1 Z2*

Z3 Z3 Z3 Z3 Z3

/ /

Z2* ** Z3 Z1 Z1 Z1 Z3 Z2* **

Z1 Z3 Z1 Z1 Z1 Z3 Z1 Z2* Z3 Z1 Z1 Z1 Z3 Z2*

Z3 Z3 Z3 Z3 Z3 Z2 Z1 Z2

(*) denotes location where INTACT or DAMAGED FUEL ASSEMBLY can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

(1)

Zone Number 1 2 3 (2)

Max Decay Heat (kW/ plus CCs, if included) 0.5 3.5 0.7 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 45.7 Notes:

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

2. The maximum allowable heat load per FAILED FUEL is 0.8 kW.

Figure 1J Heat Load Zone Configuration 10 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-10

Figures Z4* Z1 Z4*

Z3 Z3 Z3 Z3 Z3

/ /

Z4* ** Z3 Z1 Z1 Z1 Z3 Z4* **

Z1 Z3 Z1 Z1 Z1 Z3 Z1 Z2* Z3 Z1 Z1 Z1 Z3 Z2*

Z3 Z3 Z3 Z3 Z3 Z2 Z1 Z2

(*) denotes location where INTACT or DAMAGED FUEL ASSEMBLY can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

(1) (1)

Zone Number 1 2 3 4 Maximum Number of Fuel Assemblies 13 4 16 4 Upper Compartment (2)

Maximum Decay Heat (kW/FA plus CCs, if included) 0.5 3.0 0.7 3.0 Maximum Decay Heat per DSC (kW) 41.8 Lower Compartment (2)

Maximum Decay Heat (kW/FA plus CCs, if included) 0.5 3.5 0.7 3.2 Maximum Decay Heat per DSC (kW) 44.5 Notes:

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

2. The maximum allowable heat load per FAILED FUEL is 0.8 kW.

Figure 1K Heat Load Zone Configuration 11 for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-11

Figures Heat Load Zone Configuration 1 for the EOS-89BTH DSC Zone Number 1 2 3 (1)

Maximum Decay Heat (kW/FA plus channel, if included) 0.4 0.6 0.5 Maximum Number of Fuel Assemblies 29 20 40 Maximum Decay Heat per DSC (kW) 43.6 Figure 2 EOS-89BTH DSC Heat Load Zone Configurations and Fuel Qualification (2 Pages)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-12

Figures Heat Load Zone Configuration 2 for the EOS-89BTH DSC in the EOS-TC108/125 Stored in the EOS-HSM (1)

Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus channel, if included) 0.4 0.5 0.5 Maximum Number of Fuel Assemblies 29 20 40 Maximum Decay Heat per DSC (kW) 41.6 Heat Load Zone Configuration 3 for the EOS-89BTH DSC in the EOS-TC108/125 Stored in the EOS-HSM or HSM-MX (2)

Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus channel, if included) 0.36 0.4 0.4 Maximum Number of Fuel Assemblies 29 20 40 Maximum Decay Heat per DSC (kW) 34.44 Note:

1. The minimum cooling time for HLZC 2 for Zone 3 in the EOS-TC108 is 9.7 years.

2. The minimum cooling time for HLZC 3 Zone 3 in the EOS-TC108 is 9.0 years.

Figure 2 EOS-89BTH DSC Heat Load Zone Configurations and Fuel Qualification (2 Pages)

NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-13

Figures P P P P I I I P P I I I I I P P I I I I I P P I I I I I P P I I I P P P P Figure 3 Peripheral (P) and Inner (I) Fuel Locations for the EOS-37PTH DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-14

Figures Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA NA 0.393 NA NA NA Maximum Decay Heat per Zone (kW) NA NA 22.0 NA NA NA Maximum Decay Heat per DSC (kW) 22.0 Figure 4A Heat Load Zone Configuration 1 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-15

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) NA 8.75 NA 11.52 6.48 NA (1)

Maximum Decay Heat per DSC (kW) 22.0 (1)

Adjust payload to maintain total DSC heat load within the specified limit Figure 4B Heat Load Zone Configuration 2 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-16

Figures Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 NA NA NA NA Maximum Decay Heat per Zone (kW) NA 19.4 NA NA NA NA Maximum Decay Heat per DSC (kW) 19.4 Figure 4C Heat Load Zone Configuration 3 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-17

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) 0.22 0.35 NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) 1.98 5.60 NA 11.52 6.48 NA (1)

Maximum Decay Heat per DSC (kW) 19.4 (1)

Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4D Heat Load Zone Configuration 4 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-18

Figures Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 NA NA 0.54 NA Maximum Decay Heat per Zone (kW) NA 3.15 NA NA 28.08 NA (1)

Maximum Decay Heat per DSC (kW) 31.2 (1)

Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4E Heat Load Zone Configuration 5 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-19

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z6 Z6 Z6 Z6 Z6 Z4 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z4 Z6 Z6 Z6 Z6 Z6 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) 0.22 NA NA 0.48 0.54 0.70 Maximum Decay Heat per Zone (kW) 1.98 NA NA 11.52 6.48 11.20 (1)

Maximum Decay Heat per DSC (kW) 31.2 (1)

Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4F Heat Load Zone Configuration 6 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-20

Figures Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA NA NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) NA NA NA 12.00 19.44 NA (1)

Maximum Decay Heat per DSC (kW) 31.2 (1)

Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4G Heat Load Zone Configuration 7 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-21

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 0.393 0.48 0.54 NA Maximum Decay Heat per Zone (kW) NA 3.15 6.288 11.52 6.48 NA (1)

Maximum Decay Heat per DSC (kW) 27.4 (1)

Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4H Heat Load Zone Configuration 8 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-22

Figures Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Zone 1 Zone 2 Zone 3 Zone 4 Maximum Decay Heat 0.393 0.48 0.35 0.35 (kW/FA)

Maximum Decay Heat per 3.54 7.68 4.2 8.4 Zone (kW)

Maximum Decay Heat per (1) 22.0 DSC (kW)

Note 1: Adjust payload to maintain total canister heat load within the specified limit.

Figure 4I Heat Load Zone Configuration 9 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-23

Figures Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Zone 1 Zone 2 Zone 3 Zone 4 Maximum Decay Heat (2) (2) (2) 0.393 0.48 1.20 0.48 (kW/FA)

Maximum Decay Heat per 3.54 7.68 14.4 11.52 Zone (kW)

Maximum Decay Heat per (1) 31.2 DSC (kW)

Note 1: Adjust payload to maintain total canister heat load within the specified limit.

Note 2: If the maximum decay heat per FA in Zone 3 is greater than 0.9 kW, the maximum decay heat per FA in Zone 2 and Zone 4 shall be less than or equal to 0.393 kW.

Figure 4J Heat Load Zone Configuration 10 for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-24

Figures C C C A B C C C B A B B C C C B B C C C C C C C C C C C C C C C C C C C C C C C C C C C B B C C C B B A B C C C B A C C C Corner Locations Interior Locations A B See Note 1 See Note 2 Interior/Edge Locations C

See Note 3 Note 1: When loading up to 4 damaged or 4 failed assemblies, these must be placed in corner A locations, and the remaining locations B and C shall be loaded with intact fuel. If fewer than 4 damaged or 4 failed assemblies are to be stored, the remaining A locations may be loaded with intact fuel provided they meet the respective damaged or failed enrichment limits of Table 10 or Table 11. Damaged and failed fuel shall not be mixed, i.e., up to four damaged assemblies may be stored, or up to four failed assemblies may be stored in A locations.

Note 2: If loading more than four damaged assemblies, place first four damaged assemblies in the corner A locations per Note 1, and up to 12 additional damaged assemblies in these interior B locations, with the remaining intact in a 61BTH Type 2 Basket. The maximum lattice average initial enrichment of assemblies (damaged or intact stored in the 2x2 cells) is limited to the Five or More Damaged Assemblies column of Table 10. For the 61BTH Type 2 DSC containing both damaged and failed fuel assemblies, this enrichment is limited to the and up to 12 Damaged Assemblies column of Table 11.

Note 3: If loading more than 16 damaged assemblies, place the first 57 damaged assemblies in the interior/edge "C" and the interior B locations. Place the remaining four intact or damaged assemblies in the corner "A" locations. The maximum lattice average initial enrichments of assemblies is limited to the Remaining Four Intact Assemblies or Remaining Four Damaged Assemblies column of Table 12.

Figure 5 Location of Damaged and Failed Fuel Assemblies inside the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-25

Figures P P P P P I I I P P P I I I I I P P I I I I I I I P P I I I I I I I P P I I I I I I I P P I I I I I P P P I I I P P P P P Figure 6 Peripheral (P) and Inner (I) Fuel Locations for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-26

Figures RECONSTITUTED FUEL ASSEMBLIES with 5 irradiated stainless steel rods may be loaded into all peripheral locations (i.e., not restricted). See Figure 6 for peripheral locations.

A RECONSTITUTED FUEL ASSEMBLY with > 5 and 10 irradiated stainless steel rods may be loaded in any peripheral location, with additional restrictions in accordance with Section 2.3. Examples:

If Location B contains a RECONSTITUTED FUEL ASSEMBLY with > 5 irradiated stainless steel rods, peripherally adjacent Locations A and C shall contain fuel assemblies that do not contain irradiated stainless steel rods.

If Locations E and G contain RECONSTITUTED FUEL ASSEMBLIES with > 5 irradiated stainless steel rods, peripherally adjacent Locations D, F, and H shall contain fuel assemblies that do not contain irradiated stainless steel rods.

Figure 7 Peripheral Location Restrictions for Reconstituted Fuel with Irradiated Stainless Steel Rods for the 61BTH Type 2 DSC NUHOMS EOS System Amendment 2 Proposed Technical Specifications - Revision 7 F-27 All Indicated Changes are in response to Revised RAI 6-4

Enclosure 6 to E-58012 CoC 1042 Amendment 2, Revision 7 UFSAR Changed Pages Withheld Pursuant to 10 CFR 2.390

Enclosure 7 to E-58012 CoC 1042 Amendment 2, Revision 7 UFSAR Changed Pages (Public Version)

Proprietary and Security Related Information for Drawing EOS01-1000-SAR, Rev. 4B Withheld Pursuant to 10 CFR 2.390

Proprietary and Security Related Information for Drawing EOS01-1005-SAR, Rev. 3B Withheld Pursuant to 10 CFR 2.390

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 3.9.1 DSC SHELL STRUCTURAL ANALYSIS The purpose of this appendix is to present the structural evaluation of the shell assembly of the EOS-37PTH dry shielded canister (DSC) and the EOS-89BTH DSC under all applicable normal, off-normal and accident loading conditions during storage in the EOS horizontal storage module (HSM) and during transfer in the EOS transfer cask (TC). The EOS system consists of the EOS-HSM, the EOS-TC, the dual-purpose (transportable/storage) EOS-37PTH and EOS-89BTH DSC, and associated ancillary equipment.

The design of the DSC includes five design options: EOS-37PTH (short, medium and long) and EOS-89BTH (short and medium). The longest and heaviest EOS-37PTH DSC, which uses TC135 for transfer operations, is analyzed to bound all DSC design options in the NUHOMS EOS System.

3.9.1.1 General Description The DSC consists of a fuel basket and a shell assembly. The DSC pressure boundary consists of DSC shell with two cover plates at each end. Non-pressure boundary shield plugs are included at each end of the assembly. The inner bottom shield (IBS) is confined between the inner bottom cover plate (IBCP) and outer bottom cover plate (OBCP). The top shield plug (TSP) is confined by the inner top cover plate (ITCP) and four lifting lugs, which are welded to the inside of the DSC shell. Alternatively, the TSP and ITCP may be replaced by an integrated plate fabricated by a single forging. The grapple ring support is welded to the OBCP using full penetration weld. The ITCP is welded along the top perimeter with partial penetration weld. The IBCP is welded using a full penetration weld. Grapple ring assembly connections are all made using full penetration welds.

The DSC shell thickness is 0.50 inch, and the top and bottom closure assemblies are 10.0 inches and 8.0 inches, respectively. The DSC shell is constructed entirely from stainless steel or duplex steel. There are no penetrations through the pressure boundary. The draining and venting systems are covered by the port plugs. The outer top cover plate (OTCP) and the ITCP are welded to the cylindrical shell with multilayer welds. The DSC cavity is pressurized above atmospheric pressure with helium. The DSC shell assembly geometry and the materials used for its analysis and fabrication are shown on drawings EOS01-1000-SAR, EOS01-1001-SAR, EOS01-1005-SAR and EOS01-1006-SAR included in Chapter 1.

3.9.1.2 DSC Shell Assembly Stress Analysis An enveloping technique of combining various individual loads in a single analysis is used in this evaluation for several load combinations. This approach reduces the number of computer runs, while remaining conservative. For some load combinations, stress intensities under individual loads are added to obtain January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-1 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 resultant stress intensities for the specified combined loads. This addition at the stress intensity level for the combined loads, instead of at component stress level, is also a conservative method for reducing the number of analysis runs.

The stresses of all components are assessed by means of elastic analysis methodology for all load combinations, except for accident loading conditions.

Elastic-plastic analysis methodology is used to assess the stresses for Service Level D load combinations.

A detailed description of each load combination is provided in Section 3.9.1.2.8.

3.9.1.2.1 Material Properties For elastic analysis, temperature dependent material properties used for each component of DSC shell assembly are obtained from the American Society of Mechanical Engineers (ASME) code [3.9.1-2], and are summarized in Chapter

8. Material properties used for stress evaluations are conservatively taken at 500 °F under normal loading conditions. For the partial penetration welds and grapple assembly, 350 °F allowable stresses are used for comparison to load induced stresses as these components remain below this lower temperature under normal loading conditions.

For plastic analysis, a bilinear stress-strain curve with a 5% tangent modulus is used for steel components. The non-linear material properties at 500 °F for side drop analysis are shown in Table 3.9.1-3. Steel material (except shield plugs) is modeled by bilinear kinematic hardening method (TB, BKIN - [3.9.1-9]).

3.9.1.2.2 DSC Shell Stress Criteria The calculated stresses in the DSC shell assembly structural components are compared with the allowable stresses set forth by ASME Boiler and Pressure Vessel (B&PV) Code,Section III, Subsection NB [3.9.1-3] under normal (Level A), and off-normal (Level B) loading conditions. Appendix F of the ASME B&PV Code is used to evaluate the calculated stresses in the DSC shell assembly under accident (Level D) loading conditions. Allowable stress limits for Levels A, B and D service loading conditions, as appropriate, are summarized in Table 3-1, and the corresponding allowable stress values at different temperatures are summarized in Table 3.9.1-5 and Table 3.9.1-5a.

The OTCP-to-DSC shell weld and the ITCP-to-DSC shell weld, which are both partial penetration welds, are to be evaluated using a joint efficiency factor of 0.8. Per NUREG-1536 [3.9.1-7], the minimum inspection requirement for end closure welds is multi-pass dye penetrant testing (PT) using a stress (allowable) reduction factor of 0.8. The allowable weld stresses are summarized in Table 3.9.1-4 and Table 3.9.1-4a.

January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-2 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 The alternate option of the integrated TSP and ITCP is not considered in the FEM as the stresses resulting from the FEM with the separate TSP and ITCP are determined to be conservative and will remain valid for the integrated TSP and ITCP option.

Contact is not modeled between the cover plates and the shell. This modeling approach is conservative as it forces all loads to be transferred through the welds.

Figure 3.9.1-1 through Figure 3.9.1-4 depict the components and meshed model of the DSC. Table 3.9.1-1 lists the major dimensions of the bounding model and Table 3.9.1-2 lists the material designations of each modeled component.

A description of the FEM for the DSC components is shown below.

DSC Shell The DSC shell is modeled using 3D solid elements (ANSYS element SOLID185) and has five elements through the thickness of the component. The shell is connected to the OTCP, ITCP, and OBCP with partial penetration welds and is connected to the IBCP using a full penetration weld.

Outer Top Cover Plate The OTCP is modeled using 3D solid elements (ANSYS element SOLID185) and has 15 elements through the thickness of the component. The plate is connected to the DSC shell with partial penetration welds.

Inner Top Cover Plate The ITCP is modeled using 3D solid elements (ANSYS element SOLID185) and has 15 elements through the thickness of the component. The plate is connected to the DSC shell with partial penetration welds.

Top Shield Plug The TSP is modeled using 3D solid elements (ANSYS element SOLID185) and has 11 elements through the thickness of the component. The TSP is confined by the ITCP and four lifting lugs, which are welded to the inside of the DSC shell.

January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-4 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 For DSCs supported by the DSC support structure, the maximum ratio of induced load to allowable load for a confinement boundary area is 0.82, in the weld between the ITCP and the DSC shell during a side drop event. The maximum overall ratio of 0.92 occurs in the grapple ring support, seconded by a ratio of 0.85 in the non-confinement area of the DSC shell during a grapple pull/accident scenario.

For DSCs supported by the FPS DSC support structure, the maximum ratio of induced load to allowable load for a confinement boundary area is 0.74 and occurs in the confinement boundary area of the DSC shell while the DSC is in horizontal position as described in LC9. The maximum overall stress ratio is 0.92 and occurs in the grapple ring support, seconded by a ratio of 0.85 in the non-confinement area of the DSC shell during a grapple pull/accident scenario.

The above evaluations, specifically the closure welds, are supplemented with additional limit load and strain criteria analyses. These analyses are presented in Section 3.9.1.2.6. The results of the limit load analysis show that there is sufficient margin compared to the design loads. The results of the strain criteria analysis show a maximum equivalent plastic strain of 0.065 in/in during a side drop event, compared to the allowable uniform strain limit of 0.17 in/in, demonstrating a minimum factor of safety of 2.6 in the design. The factor of safety is calculated by dividing the maximum allowable strain by the maximum equivalent plastic strain, and must be greater than 1.

The structural integrity of the DSC shell, including closure welds, is maintained since the maximum stress ratio is less than 1 and the limit load and strain criteria analyses results were lower than their respective limits.

Convergence/Sensitivity Studies The base model and mesh used to evaluate the EOS DSC is validated by three sensitivity studies focused on gap modeling methodology, radial and longitudinal element size in an axisymmetric internal pressure environment, and circumferential element sizes in a lateral load side drop environment. A model with midside nodes was added to the axisymmetric model and showed lower stresses than the other models, and thus these midside nodes were conservatively excluded from the analytical model. No significant difference in results were observed between the employed model and the refined models, therefore the employed model is producing accurate results.

It is on these bases that the EOS DSC assembly is determined to be, as designed, structurally adequate under all anticipated load conditions for service during storage and transfer.

January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-32 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-1 EOS37PTH DSC Major Dimensions Component Dimensions Outer Diameter of DSC Shell 75.50 inches DSC Shell Thickness 0.5 inch DSC Length 219 inches(1)

OTCP Thickness 2 inches ITCP Thickness 2 inches TSP Thickness 6 inches OBCP Thickness 2 inches IBCP Thickness 2 inches IBS 4 inches Alternate Integrated TSP/ITCP Thickness 8 inches (1) Indicated length is for longest EOS-37PTH DSC Table 3.9.1-2 Material of EOS DSC Components (Analysis)

DSC Shell ASME SA-240 Type 304 OTCP ASME SA-240 Type 304 ITCP ASME SA-240 Type 304 TSP ASTM A36 OBCP ASTM A240 Type 304 IBCP ASME SA-240 Type 304 IBS ASTM A36 Grapple Ring Support ASTM A240 Type 304 Grapple Ring ASTM A240 Type 304 Lifting Lug Plate ASME SA-240 Type 304 Lifting Lug ASTM A240 Type 304 ASME SA-182 Type F304 > 5" or Alternate Integrated TSP/ITCP ASME SA-965 Type F304 January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-34 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-4a Allowable Weld Stresses for Pressure Boundary Partial Penetration Welds, Material SA-182 Type F304/SA-965 Type F304 (Thickness > 5)

Allowable Stress Value at Service Level Stress Region / Category Stress Criteria 350 °F [ksi]

Primary Local Membrane PL = 0.8 [1.5 Sm] 23.2 Stress, PL Level A / Primary Local Membrane +

PL + Pb = 0.8 [1.5 Sm] 23.2 Level B Bending Stress, PL + Pb Primary + Secondary Stress, PL + Pb + Q = 0.8 [3.0 Sm] 46.3 P+Q Primary Local Membrane 0.8 [Min(3.6 Sm, Su)] 48.60 Level D Stress, PL (Elastic) Primary Local Membrane +

0.8 [Min(3.6 Sm, Su)] 48.60 Bending Stress, PL + Pb Primary Local Membrane 0.8 [0.9 Su] 43.74 Level D Stress, PL (Elastic Plastic) Primary Local Membrane +

0.8 [0.9 Su] 43.74 Bending Stress, PL + Pb January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-37 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-5 SA-240/SA-479 304 & SA-182 F304 -Stress Allowables Level A/B Level D (Elastic) Level D (Plastic)

Temp Sm Sy Su Pm + Pm + Pm + Pm +

(°F) (ksi) (ksi) (ksi) Pm Pb Pb + Q Pm Pb Pm Pb 70 20 30 75 20.0 30.0 60.0 48.0 72.0 52.5 67.5 200 20 25 71 20.0 30.0 60.0 48.0 71.0 49.7 63.9 300 20 22.4 66.2 20.0 30.0 60.0 46.3 66.2 46.3 59.6 400 18.6 20.7 64 18.6 27.9 55.8 44.6 64.0 44.8 57.6 500 17.5 19.4 63.4 17.5 26.3 52.5 42.0 63.0 44.4 57.1 600 16.6 18.4 63.4 16.6 24.9 49.8 39.8 59.8 44.4 57.1 700 15.8 17.6 63.4 15.8 23.7 47.4 37.9 56.9 44.4 57.1 750 15.5 17.2 63.3 15.5 23.3 46.5 37.2 55.8 44.3 57.0 Table 3.9.1-5a SA-182/SA-965 Type F304 (Thickness 5) - Stress Allowables Level A/B Level D (Elastic) Level D (Plastic)

Temp Sm Sy Su Pm + Pb

(°F) (ksi) (ksi) (ksi) Pm Pm + Pb +Q Pm Pm + Pb Pm Pm + Pb 70 20.0 30.0 70.0 20.0 30.0 60.0 48.00 70.00 49.00 63.00 200 20.0 25.0 66.3 20.0 30.0 60.0 46.41 66.30 46.41 59.67 300 20.0 22.4 61.8 20.0 30.0 60.0 43.26 61.80 43.26 55.62 400 18.6 20.7 59.7 18.6 27.9 55.8 41.79 59.70 41.79 53.73 500 17.5 19.4 59.2 17.5 26.3 52.5 41.44 59.20 41.44 53.28 600 16.6 18.4 59.2 16.6 24.9 49.8 39.84 59.20 41.44 53.28 700 15.8 17.6 59.2 15.8 23.7 47.4 37.92 56.88 41.44 53.28 January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-38 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-9 ITCP Stress Results - Load Combinations 3 Pages Load Stress Allowable Service DSC Stress Comb Stress Category Loads intensity Stress Level Orientation Ratio No. (ksi) (ksi) 6 D Horizontal(2) Pm DWh + 135 kips + PI(20) 0.54 41.44 0.01 Pm+Pb DWh + 135 kips + PI(20) 4.18 53.28 0.08 PL DWh + 135 kips + PI(20) 0.89 53.28 0.02 Pm (or PL)+Pb+Q DWh + 135 kips + PI(20) NA (2) 7A D Horizontal Pm DWh + max.(SD_AWAY, SD_RAIL_EP,SD_TOP_RAIL_EP)+ PI(20) 7.33 41.44 0.18 Pm+Pb DWh + max.(SD_AWAY_EP, SD_RAIL_EP)+ PI(20) 20.14 53.28 0.38 PL DWh + max.(SD_AWAY, SD_RAIL_EP,SD_TOP_RAIL_EP)+ PI(20) 13.28 53.28 0.25 Pm (or PL)+Pb+Q DWh + max.(SD_AWAY_EP, SD_RAIL_EP)+ PI(20) NA 7B D Vertical Pm DWv + max.(ED_TOP, ED_BOT)+ PI(20) 3.40 41.44 0.08 Pm+Pb DWv + max.(ED_TOP, ED_BOT)+ PI(20) 18.01 53.28 0.34 PL DWv + max.(ED_TOP, ED_BOT)+ PI(20) 4.09 53.28 0.08 Pm (or PL)+Pb+Q DWv + max.(ED_TOP, ED_BOT)+ PI(20) NA (2) 8 D Horizontal Pm DWh + PI(130) 2.46 41.44 0.06 Pm+Pb DWh + PI(130) 25.82 53.28 0.48 PL DWh + PI(130) 3.07 53.28 0.06 Pm (or PL)+Pb+Q DWh + PI(130) NA 9 A Horizontal(3) Pm DWh + PI(20) 0.74 17.50 0.04 Pm+Pb DWh + PI(20) 4.55 26.25 0.17 PL DWh + PI(20) 1.31 26.25 0.05 Pm (or PL)+Pb+Q DWh + PI(20) 4.51 52.50 0.09 Pm (or PL)+Pb+Q+Pe DWh + PI(20) + TH 14.73 52.50 0.28 January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-59 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-9 ITCP Stress Results - Load Combinations 3 Pages Load Stress Allowable Service DSC Stress Comb Stress Category Loads intensity Stress Level Orientation Ratio No. (ksi) (ksi) 10 D Horizontal(3) Pm DWh + max.(HS_TOP, HS_BOT)+PI(20) 2.05 41.44 0.05 Pm+Pb DWh + max.(HS_TOP, HS_BOT)+PI(20) 4.60 53.28 0.09 PL DWh + max.(HS_TOP, HS_BOT)+PI(20) 3.73 53.28 0.07 Pm (or PL)+Pb+Q DWh + max.(HS_TOP, HS_BOT)+PI(20) NA 11 Test Vertical Pm max. (PI(23)+155 kips, PE(14.7)+155 kips) NA Pm+Pb max. (PI(23)+155 kips, PE(14.7)+155 kips) NA PL max. (PI(23)+155 kips, PE(14.7)+155 kips) NA Pm (or PL)+Pb+Q max. (PI(23)+155 kips, PE(14.7)+155 kips) NA Notes:

(1) DSC in transfer cask in vertical orientation. Only inner top cover is installed.

(2) DSC in TC with TC in a horizontal orientation.

(3) DSC in EOS-HSM supported on the steel rails.

January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-60 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-9a ITCP Stress Results- Load Combinations (Supported by FPS DSC Support Structure) 3 Pages Load Stress Service DSC Allowable Stress Comb Stress Category Loads intensity Level Orientation Stress (ksi) Ratio No. (ksi) 6 D Horizontal(2) Pm DWh + 135 kips + PI(20) 0.54 41.44 0.01 Pm+Pb DWh + 135 kips + PI(20) 4.18 53.28 0.08 PL DWh + 135 kips + PI(20) 0.89 53.28 0.02 Pm (or PL)+Pb+Q DWh + 135 kips + PI(20) NA (2) 7A D Horizontal Pm DWh + max.(SD_AWAY, SD_RAIL_EP,SD_TOP_RAIL_EP)+ PI(20) 7.33 41.44 0.18 Pm+Pb DWh + max.(SD_AWAY_EP, SD_RAIL_EP)+ PI(20) 20.14 53.28 0.38 PL DWh + max.(SD_AWAY, SD_RAIL_EP,SD_TOP_RAIL_EP)+ PI(20) 13.28 53.28 0.25 Pm (or PL)+Pb+Q DWh + max.(SD_AWAY_EP, SD_RAIL_EP)+ PI(20) NA 7B D Vertical Pm DWv + max.(ED_TOP, ED_BOT)+ PI(20) 3.40 41.44 0.08 Pm+Pb DWv + max.(ED_TOP, ED_BOT)+ PI(20) 18.01 53.28 0.34 PL DWv + max.(ED_TOP, ED_BOT)+ PI(20) 4.09 53.28 0.08 Pm (or PL)+Pb+Q DWv + max.(ED_TOP, ED_BOT)+ PI(20) NA (2) 8 D Horizontal Pm DWh + PI(130) 2.46 41.44 0.06 Pm+Pb DWh + PI(130) 25.82 53.28 0.48 PL DWh + PI(130) 3.07 53.28 0.06 Pm (or PL)+Pb+Q DWh + PI(130) NA (3) 9 A Horizontal Pm DWh + PI(20) 0.57 17.50 0.03 Pm+Pb DWh + PI(20) 4.24 26.25 0.16 PL DWh + PI(20) 1.13 26.25 0.04 Pm (or PL)+Pb+Q DWh + PI(20) 4.04 52.50 0.08 Pm (or PL)+Pb+Q+Pe DWh + PI(20) +TH 14.42 52.50 0.27 January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-62 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-9a ITCP Stress Results- Load Combinations (Supported by FPS DSC Support Structure) 3 Pages Load Stress Service DSC Allowable Stress Comb Stress Category Loads intensity Level Orientation Stress (ksi) Ratio No. (ksi) 10 D Horizontal(3) Pm DWh + max.(HS_TOP, HS_BOT)+PI(20) 1.90 41.44 0.05 Pm+Pb DWh + max.(HS_TOP, HS_BOT)+PI(20) 4.70 53.28 0.09 PL DWh + max.(HS_TOP, HS_BOT)+PI(20) 3.96 53.28 0.07 Pm (or PL)+Pb+Q DWh + max.(HS_TOP, HS_BOT)+PI(20) NA 11 Test Vertical Pm max. (PI(23)+155 kips, PE(14.7)+155 kips) NA Pm+Pb max. (PI(23)+155 kips, PE(14.7)+155 kips) NA PL max. (PI(23)+155 kips, PE(14.7)+155 kips) NA Pm (or PL)+Pb+Q max. (PI(23)+155 kips, PE(14.7)+155 kips) NA Notes:

(1) DSC in transfer cask in vertical orientation. Only inner top cover is installed.

(2) DSC in transfer cask, TC is in horizontal orientation.

(3) DSC in EOS-HSM-FPS supported by FPS DSC support structure.

(4) Maximum value with and without internal pressure.

(5) Only load combinations 9 and 10 have results that differ from Table 3.9.1-9.

January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-63 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-11 ITCP-DSC Shell Weld Stress Results - Load Combinations 2 Pages Load Stress Service DSC Allowable Stress Comb Stress Category Loads intensity Level Orientation Stress Ratio No. (ksi)

PL DWv + max(PI(20),BD,VD) 8.60 23.20 0.37 1 A Vertical(1)

PL+Pb+Q+Pe DWv + max(PI(20),BD,VD) + TH 34.48 46.30 0.74 PL DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) 5.95 23.20 0.26 2 A Horizontal(2)

PL+Pb+Q+Pe DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) + TH 27.93 46.30 0.60 PL DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) 5.95 23.20 0.26 3 A Horizontal(2)

PL+Pb+Q+Pe DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) + TH 27.93 46.30 0.60 PL DWh + 135kips + PI(20) 6.02 23.20 0.26 4 A/B Horizontal(2)

PL+Pb+Q+Pe DWh + 135kips + PI(20) + TH 29.44 46.30 0.64 PL DWh + 80 kips + PI(20) 6.50 23.20 0.28 5 A/B Horizontal(2)

PL+Pb+Q+Pe DWh + 80 kips + PI(20) + TH 29.11 46.30 0.63 PL DWh + 135 kips + PI(20) 6.74 43.74 0.15 6 D Horizontal(2)

PL+Pb+Q+Pe DWh + 135 kips + PI(20) + TH NA PL DWh + max.(SD_AWAY, SD_RAIL_EP,SD_TOP_RAIL_EP)+ PI(20) 35.77 43.74 0.82 7A D Horizontal(2)

PL+Pb+Q+Pe DWh + max.(SD_AWAY_EP, SD_RAIL_EP)+ PI(20) + TH NA PL DWv + max.(ED_TOP, ED_BOT)+ PI(20) 13.22 43.74 0.30 7B D Vertical PL+Pb+Q+Pe DWv + max.(ED_TOP, ED_BOT)+ PI(20) + TH NA PL DWh + PI(130) 16.41 43.74 0.38 8 D Horizontal(2)

PL+Pb+Q+Pe DWh + PI(130) + TH NA PL DWh + PI(20) 8.27 23.20 0.36 9 A Horizontal(3)

PL+Pb+Q+Pe DWh + PI(20) + TH 31.18 46.30 0.67 January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-70 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-11 ITCP-DSC Shell Weld Stress Results - Load Combinations 2 Pages Load Stress Service DSC Allowable Stress Comb Stress Category Loads intensity Level Orientation Stress Ratio No. (ksi)

PL DWh + max.(HS_TOP, HS_BOT)+PI(20) 18.93 43.74 0.43 10 D Horizontal(3)

PL+Pb+Q+Pe DWh + max.(HS_TOP, HS_BOT)+PI(20) + TH NA PL max. (PI(23)+155 kips, PE(14.7)+155 kips) NA 11 Test Vertical PL+Pb+Q+Pe max. (PI(23)+155 kips, PE(14.7)+155 kips) + TH NA Notes:

(1) DSC in transfer cask in vertical orientation. Only inner top cover is installed.

(2) DSC in TC with TC in a horizontal orientation.

(3) DSC in EOS-HSM supported on the steel rails January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-71 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-11a ITCP-DSC Shell Weld Stress Results - Load Combinations (Supported by FPS DSC Support Structure) 2 Pages Load Stress Service DSC Allowable Stress Comb Stress Category Loads intensity Level Orientation Stress (ksi) Ratio No. (ksi)

PL DWv + max(PI(20),BD,VD) 8.60 23.20 0.37 1 A Vertical(1)

PL+Pb+Q+Pe DWv + max(PI(20),BD,VD)+TH 34.48 46.30 0.74 PL DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) 5.95 23.20 0.26 2 A Horizontal(2)

PL+Pb+Q+Pe DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) +TH 27.93 46.30 0.60 PL DWh + 1g axial + 1g transverse + 1g Vertical + PI(20) 5.95 23.20 0.26 3 A Horizontal(2)

PL+Pb+Q+Pe DWh + 1g axial + 1g transverse + 1g Vertical + PI(20)+TH 27.93 46.30 0.60 PL DWh + 135kips + PI(20) 6.02 23.20 0.26 4 A/B Horizontal(2)

PL+Pb+Q+Pe DWh + 135kips + PI(20) +TH 29.44 46.30 0.64 PL DWh + 80 kips + PI(20) 6.50 23.20 0.28 5 A/B Horizontal(2)

PL+Pb+Q+Pe DWh + 80 kips + PI(20) +TH 29.11 46.30 0.63 PL DWh + 135 kips + PI(20) 6.74 43.74 0.15 6 D Horizontal(2)

PL+Pb+Q+Pe DWh + 135 kips + PI(20) +TH NA PL DWh + max.(SD_AWAY, SD_RAIL_EP,SD_TOP_RAIL_EP)+ PI(20) 35.77 43.74 0.82 7A D Horizontal(2)

PL+Pb+Q+Pe DWh + max.(SD_AWAY_EP, SD_RAIL_EP)+ PI(20) +TH NA PL DWv + max.(ED_TOP, ED_BOT)+ PI(20) 13.22 43.74 0.30 7B D Vertical PL+Pb+Q+Pe DWv + max.(ED_TOP, ED_BOT)+ PI(20) +TH NA PL DWh + PI(130) 16.41 43.74 0.38 8 D Horizontal(2)

PL+Pb+Q+Pe DWh + PI(130) +TH NA PL DWh + PI(20) 7.64 23.20 0.33 9 A Horizontal(3)

PL+Pb+Q+Pe DWh + PI(20) +TH 31.40 46.30 0.68 January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-72 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 3.9.1-11a ITCP-DSC Shell Weld Stress Results - Load Combinations (Supported by FPS DSC Support Structure) 2 Pages Load Stress Service DSC Allowable Stress Comb Stress Category Loads intensity Level Orientation Stress (ksi) Ratio No. (ksi)

PL DWh + max.(HS_TOP, HS_BOT)+PI(20) 19.98 43.74 0.46 10 D Horizontal(3)

PL+Pb+Q+Pe DWh + max.(HS_TOP, HS_BOT)+PI(20) +TH NA PL max. (PI(23)+155 kips, PE(14.7)+155 kips) NA 11 Test Vertical PL+Pb+Q+Pe max. (PI(23)+155 kips, PE(14.7)+155 kips) +TH NA Notes:

(1) DSC in transfer cask in vertical orientation. Only inner top cover is installed.

(2) DSC in transfer cask, TC is in horizontal orientation.

(3) DSC in EOS-HSM-FPS supported by FPS DSC support structure.

(4) Only load combinations 9 and 10 have results that differ from Table 3.9.1-11.

January 2021 Revision 7 72-1042 Amendment 2 Page 3.9.1-73 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 8-1 DSC Materials Shell Assembly Subcomponents Material Cylindrical Shell, Inner Top Cover Plate, Inner Bottom Stainless steel ASME SA-240 Type 304, Cover Plate (Confinement Boundary), Outer Top Cover 316, 2205 or UNS S31803 Plate, Lifting Lug Plate Drain Port Cover Plate (Confinement Boundary) ASME SA-240 Type 304 Vent Port Plug (Confinement Boundary) ASME SA-240 Type 304 or SA-479 Type 304 Outer Bottom Cover Plate, Lifting Lug Stainless steel ASTM A240 Type 304, 316, or 2205 or UNS S31803 Grapple Ring, Grapple Ring Support Stainless steel ASTM A240 Type 304, 316, or 2205 or UNS S31803, or ASTM A182 Gr F304, F316, F51, or F60 Siphon Bracket, Basket Key Stainless steel ASTM A240 Type 304 or 316 Test Port Plug ASTM A240, A276, or A479, Type 304, 316, UNS S31803, or UNS S32205 Top and Bottom Shield Plugs Carbon steel ASTM A36 Miscellaneous parts (Drain Tube, Siphon Block, Port Stainless Steel Adapter, Quick Connect, Reducing Bushing)

Integrated Top Shield Plug and Inner Top Cover Plate ASME SA-182 Type F304 (>5 inches (Optional; replaces individual Top Shield Plug and Inner thick) / SA-965 Type F304 Top Cover Plate if used)

Basket Assembly Subcomponents Material Basket Steel Plates Low-alloy high strength steel such as ASTM A829 Gr 4130 Basket Aluminum Plates Aluminum ASTM B209 Alloy 1100 or 1060, or alloy 1050 (EN AW-1050A) per EN485-2 and EN573-3 Transition Rails:

R90 and R45 Aluminum Extrusions ASTM B221 or B209 Alloy 6061 R45 Angle Plates ASTM A516 Gr 70 Tie Rod/Flat Head Screws A 564 Type 630 H1100 Hex Nuts ASTM A194 Gr 7 Miscellaneous Washers SA-302 Gr C Neutron absorber plates MMC or BORAL (89BTH only)

Fuel Spacers Stainless steel ASTM A240 Type 304 or Aluminum ASTM B209, Type 6061 or 1100 January 2021 Revision 7 72-1042 Amendment 2 Page 8-25 All Indicated Changes are a result of Enclosure 8, Item 3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 3, 06/20 Table 8-5a Material Properties, SA-182 Type F304 (> 5 thk.) lSA-965 Type F304 Temp E Sm Sy Su AVG K Cp

(°F) (103 ksi) (ksi) (ksi) (ksi) (10-6 °F -1) (lb/in3) (Btu/hr-ft-°F) (Btu/lb-°F)

-20 20.0 30.0 70.0 70 28.3 20.0 30.0 70.0 8.5 8.6 0.114 100 20.0 30.0 70.0 8.6 8.7 0.114 150 26.7 8.8 9.0 0.117 200 27.5 20.0 25.0 66.3 8.9 9.3 0.119 250 23.6 9.1 9.6 0.121 300 27.0 20.0 22.4 61.8 9.2 9.8 0.122 350 9.4 10.1 0.124 400 26.4 18.6 20.7 59.7 9.5 10.4 0.126 450 9.6 10.6 0.127 500 25.9 17.5 19.4 59.2 9.7 0.29 10.9 0.129 550 9.8 11.1 0.129 600 25.3 16.6 18.4 59.2 9.9 11.3 0.130 650 16.2 18.0 9.9 11.6 0.131 700 24.8 15.8 17.6 59.2 10.0 11.8 0.132 750 15.5 17.2 59.0 10.0 12.0 0.132 800 24.1 15.2 16.9 58.6 10.1 12.3 0.133 850 16.5 57.9 10.2 12.5 0.134 900 23.5 16.2 56.8 10.2 12.7 0.134 950 15.9 55.4 10.3 12.9 0.135 1000 22.8 15.5 53.6 10.3 13.1 0.135 Table 5A, Table Y- 1 Table TM-1 Table U, Line 7 Table TE-1, Table PRD, Calculated based on Table ASME Lines 25 and Lines 23 and Group G p.738 and 14. P.493 P.711, Group 3 P.744 TCD, P.727, Group J

25. P.408 30, P. 610-611 ASME Section II, Part D - Properties, 2011a Edition January 2021 Revision 7 72-1042 Amendment 2 Page 8-30 All Indicated Changes are a result of Enclosure 8, Item 3

Enclosure 8 to E-58012 Additional Change 3 Not Associated with the RAIs Change 3: Integrated Inner Top Cover Plate and Shield Plug Note: This item, along with several other non-RAI related items, was originally submitted with Amendment 2, Revision 5, dated June 29, 2020 (ML20190A135), and as part of this item, UFSAR Section 1.2.1 was revised to include a discussion to clarify the option of using a top shield plug integrated with the inner top cover plate. That change remained valid and unchanged from the previous submittal, Amendment 2, Revision 6, dated October 29, 2020 (ML20315A417). This item has been completed revised for this submittal, but did not have any change to the discussion added to UFSAR Section 1.2.1 as part of the Amendment 2, Revision 5 submittal. The other non-RAI items (numbers 1, 2, 4, and 5) remain valid and unchanged from the previous submittals listed above.

==

Description:==

This change clarifies the terminology as well as providing the dimensions and material specifications for the option of an integrated inner top cover plate and top shield plug for the EOS-37PTH and EOS-89BTH DSCs. This option is called Alternate 1 -

Integrated Top Shield Plug and Inner Top Cover Plate as shown on drawings EOS01-1000-SAR and EOS01-1005-SAR.

Section 3.9.1.1 of the UFSAR has been revised to include the integrated piece in the general description. Since the combined thickness of the integrated top cover plate (ITCP) and top shield plug (TSP) are greater than 5 in., the Integrated TSP and ITCP material of construction is required to be SA-965 Type F304 or SA-182 Type F304 greater than 5 in.,

which have been added to Table 8-1. Material properties for ASME SA-965 Type F304 and ASME SA-182 Type F304 for forgings greater than 5 in. have also been added in Table 8-5a. Since the ultimate strength values for ASME SA-965 Type F304 and ASME SA-182 Type F304 is greater than 5 in., are lower compared to SA-240 Type 304 values, the Level D allowable stresses for the ITCP and ITCP-DSC weld stresses which are dependent on the ultimate strength are evaluated based on the material properties for the integrated option.

Table 3.9.1-4a and Table 3.9.1-5a in Section 3.9.1.2.2 have been added to provide allowable stresses for the ITCP-DSC weld and the ITCP based on the forged material properties in Table 8-5a.

The integrated TSP and ITCP are not separately evaluated in the finite element model (FEM), as the stresses resulting from the FEM with the composite TSP and ITCP are determined to be conservative and will remain valid for the integrated TSP and ITCP option as described in Section 3.9.1.2.3. Therefore, the stress ratios for the ITCP and ITCP-DSC weld stresses have been revised based on the allowable stresses for the ITCP and ITCP-DSC welds in Table 3.9.1-9, Table 3.9.1-9a, Table 3.9.1-11, and Table 3.9.1-11a. As a result, the maximum stress ratio for a confinement boundary area increased from 0.76 to 0.82, as summarized in Section 3.9.1.6. All load combinations were concluded to be structurally adequate for storage and transfer loading conditions.

Table 3.9.1-1 of the UFSAR has been revised to add the major dimensions for the integrated TSP and ITCP, and Table 3.9.1-2 has been revised to add the material specifications for the integrated TSP and ITCP. It is also noted that items forged from SA-182 Type F304 thickness greater than 5 in. are limited to a weight of 10,000 lb. The weight of the ITCP is 2,530 lb, and the weight of the TSP is 7,340 lb. With these item weights combined, the integrated piece comes out to a total of 9,870 lb. Though the integrated piece slightly widens the chamfer between the combined ITCP and TSP, and Page 1 of 2

Enclosure 8 to E-58012 Additional Change 3 Not Associated with the RAIs adds a small amount of material to compensate for the removal of the item 11 port adapter cup, these changes are marginal and there remains sufficient margin between the total weight of the integrated piece and the 10,000-lb weight limit prescribed by ASME B&PV Code Section II Part D. Therefore, use of SA-182 Type F304 is acceptable.

TS Impact: None UFSAR Impact:

o Drawing EOS01-1000-SAR and Drawing EOS01-1005-SAR have been revised to add drawing details that include dimensions and material specifications for the option of using top shield plug integrated with the inner top cover plate for both the EOS-37PTH and EOS-89BTH DSCs. Note 21 regarding raw material tensile strength has been removed from sheet 1 for each drawing. The UFSAR has been revised to address material tensile strength requirements. Note 16 for each drawing has been revised to include item 4A, Alternate 1.

o UFSAR Sections 1.2.1, 3.9.1.1, 3.9.1.2, and 3.9.1.6 have been revised as discussed above.

o Table 3.9.1-4a and Table 3.9.1-5a, and Table 8-5a have been added as discussed above.

o Table 3.9.1-1, Table 3.9.1-2, Table 3.9.1-9, Table 3.9.1-9a, Table 3.9.1-11, Table 3.9.1-11a, and Table 8-1 have been revised as discussed above.

Page 2 of 2

Enclosure 9 to E-58012 Listing of Package Accession Numbers Associated with the CoC 1042 Amendment 2 Application Submittals Below is a listing of the submittals to-date associated with Amendment 2 NRC ADAMS NRC ADAMS Accession Description Amendment Accession Number(s) for Number and (NRC ADAMS Accession Number for the RSI or Number for the FSAR Revision RAI Enclosure included where applicable) the Package Changed Pages Amendment 2, ML19114A227 ML19112A106 Initial Application for Amendment 2 Revision 0 Amendment 2, Response to Request for Supplemental Information ML19225C845 ML19225C810 Revision 1 (Enclosure 2 [RSIs]; ML19225C798)

Amendment 2, Supplemental Information; FSAR and TS Revision; ML19282A518 ML19282A510 Revision 2 Incorporation of FQT Information.

Amendment 2, Supplemental Information; FSAR Revision; ML19311C551 ML19311C556 Revision 3 Incorporation of Thermal Model Information.

Amendment 2, N/A N/A Supplemental Information; Portable Hard Drive Revision 4 Amendment 2 Response to Request for Additional Information ML20190A135 ML20190A147 Revision 5 (RAI) (Enclosure 2); ML20190A146 Amendment 2 Revised Response to Request for Additional ML20315A417 ML20315A432 Revision 6 Information (RAI) (Enclosure 2); ML20315A431 Page 1 of 1

v t e Letter Sequence Response to RAI
CAC:001028, (Approved, Closed) EPID:L-2019-LLA-0078, Package: Acceptance Review of Tn Americas LLC Application for Certificate of Compliance No. 1042, Amendment No. 2 Nuhoms Eos System (Dkt: 72-1042, CAC: 001028, EPID: L-2019-LLA-0078) Request for Supplemental Information (Open)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results\|Request]] Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting Questions 25 August 2021 20 February 2020 6 March 2020 31 March 2020 31 March 2020 10 April 2020 28 May 2020 28 May 2020 4 August 2020 31 August 2020 30 September 2020 28 September 2020 6 October 2020 20 November 2020 10 December 2020 16 December 2020 14 January 2021 14 January 2021 22 January 2021 23 March 2021 23 March 2021 3 March 2021 20 May 2021 15 June 2021 30 August 2021 28 October 2021 28 October 2021 18 October 2021 3 November 2021 21 December 2021 21 December 2021 8 December 2021 8 December 2021 20 January 2022 20 January 2022 6 May 2022 23 March 2022 31 March 2022 1 July 2022 31 October 2022 31 October 2022 8 December 2022 4 January 2023 6 March 2023 6 March 2023 25 July 2023 25 July 2023 20 June 2023 4 October 2023 4 October 2023 28 August 2023 ... further results Answers 31 March 2020 5 June 2020 10 July 2020 11 September 2020 11 November 2020 27 January 2021 9 February 2021 19 November 2021 30 November 2021 25 February 2022 7 June 2022 11 July 2022 13 July 2022 29 July 2022 31 August 2022 31 August 2022 9 September 2022 3 October 2022 3 October 2022 1 December 2022 21 December 2022 6 January 2023 27 January 2023 17 March 2023 8 May 2023 30 June 2023 Results Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, ... further results\|Approval]] Other: L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML19276D398, ML20014E677, ML20049A082, ML20065N277, ML20065N278, ML20065N280, ML20065N281, ML20065N285, ML20071F156, ML20076D696, ML20094G482, ML20099A180, ML20104C015, ML20104C016, ML20104C018, ML20104C019, ML20105A135, ML20105A136, ML20105A137, ML20105A138, ML20105A139, ML20105A173, ML20111A240, ML20115E377, ML20121A272, ML20136A049, ML20136A050, ML20136A051, ML20150A300, ML20150A335, ML20150A421, ML20155K741, ML20155K742, ML20155K743, ML20155K744, ML20160A040, ML20161A088, ML20163A702, ML20163A703, ML20163A704, ML20181A211, ML20181A212, ML20192A328, ML20192A329, ML20212L768, ML20212L769, ML20212L878, ML20223A036, ML20224A287... further results
MONTHYEAR2020-03-03 [Table View]

ML21027A324

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