ML21308A386

Enclosure 3: WSNF-220, Amendment 4, Technical Specifications

ML21308A386
Person / Time
Site:	07201026
Issue date:	11/03/2021
From:	Westinghouse
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML21308A382	List: ML21308A383 ML21308A386 ML21308A387
References
LTR-NRC-21-35 WSNF-220, Amend 4
Download: ML21308A386 (65)

Text

WESTINGHOUSE NON-PROPRIETARY CLASS 3

Page 1 of 65 Our ref: LTR-NRC-21-35 Enclosure 3 November 3, 2021

Enclosure 3:

WSNF-220, Amendment 4, Technical Specifications

TECHNICAL SPECIFICATION

FOR THE FuelSolutions' STORAGE SYSTEM

to be used concurrent with

one of the canister Technical Specifications

Amendment 4 TABLE OF CONTENTS Page

1.0 USE AND APPLICATION............................................ 1.1-1 1.1 Definitions......................................................... 1.1-1 1.2 Logical Connectors.................................................. 1.2-1 1.3 Completion Times................................................... 1.3-1 1.4 Frequency.......................................................... 1.4-1

2.0 FUNCTIONAL AND OPERATING LIMITS............................. 2.0-1

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY........ 3.0-1

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY................ 3.0-2

3.1 CANISTER INTEGRITY............................................. 3.1-1 3.1.1 Canister Helium Backfill Density....................................... 3.1-1 3.1.2 Canister Vacuum Drying Pressure....................................... 3.1-2 3.1.3 Canister Leak Rate................................................... 3.1-3 3.1.4 Hydraulic Ram Force During Horizontal Canister Transfer................... 3.1-4 3.1.5 Canister Vertical Time Limit in Transfer Cask............................. 3.1-6

3.2 CANISTER RADIATION PROTECTION................................ 3.2-1 3.2.1 Canister Surface Contamination........................................ 3.2-1

3.3 STORAGE CASK INTEGRITY........................................ 3.3-1 3.3.1 (Deleted).......................................................... 3.3-1 l 3.3.2 Storage Cask Periodic Monitoring....................................... 3.3-2 l 3.3.3 Storage Cask Temperatures During Horizontal Transfer..................... 3.3-3 l

3.4 TRANSFER CASK INTEGRITY....................................... 3.4-1 3.4.1 Transfer Cask Structural Shell Temperature............................... 3.4-1

3.5 TRANSFER CASK RADIATION PROTECTION......................... 3.5-1 3.5.1 Transfer Cask Surface Contamination.................................... 3.5-1

4.0 DESIGN FEATURES................................................ 4.0-1 4.1 Storage System...................................................... 4.0-1 4.2 Storage Pad........................................................ 4.0-3 4.3 Site Specific Parameters and Analyses................................... 4.0-4

5.0 ADMINISTRATIVE CONTROLS...................................... 5.0-1 5.1 Training Modules.................................................... 5.0-1 5.2 Preoperational Testing and Training Exercises............................. 5.0-2 5.3 Programs.......................................................... 5.0-2 5.4 Special Requirements for First System in Place............................ 5.0-7 l

FuelSolutions' Storage System Amendment 4 TABLE OF CONTENTS Page

LIST OF TABLES

Table 4.1-1 - FuelSolutions' W150 Storage Cask ACI Code Requirement Compliance Summary.......................................... 4.0-5 Table 4.1-2 - FuelSolutions' W100 Transfer Cask ASME Code Requirement Compliance Summary......................................... 4.0-14

FuelSolutions' Storage System Amendment 4 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.

CANISTER The CANISTER is the storage container for SFAs approved for use at the ISFSI.

INDEPENDENT SPENT FUEL The facility within the perimeter fence licensed for STORAGE INSTALLATION (ISFSI) storage of spent fuel within CANISTERs.

INTACT FUEL Fuel assemblies with no known or suspected cladding defects greater than hairline cracks or pinhole leaks.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on a CANISTER while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the CANISTER and end when the CANISTER outer closure plate to shell weld examination is complete.

SPENT FUEL ASSEMBLIES (SFAs) Irradiated nuclear fuel assemblies that are to be placed in a CANISTER for dry storage.

SPENT FUEL STORAGE SYSTEM The storage components including the CANISTER, (SFSS) STORAGE CASK, and TRANSFER CASK.

STORAGE CASK The cask that provides a shielded, ventilated storage environment for the loaded CANISTER. This cask is used for TRANSFER OPERATIONS.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while a CANISTER containing spent fuel is sitting inside a STORAGE CASK on a storage pad within the ISFSI.

FuelSolutions' Storage System Amendment 41.1-1 Definitions 1.1 1.1 Definitions

Term Definition TRANSFER CASK The cask that is used for SFA LOADING OPERATIONS and UNLOADING OPERATIONS, and for TRANSFER OPERATIONS.

TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities that are performed on a CANISTER loaded with one or more fuel assemblies when it is being moved to and from the ISFSI.

For movement to the ISFSI, TRANSFER OPERATIONS begin when the CANISTER outer closure plate to shell weld inspection is complete and end when the CANISTER is in the STORAGE CASK in its storage position on the storage pad within the ISFSI.

For movement from the ISFSI, TRANSFER OPERATIONS begin when the STORAGE CASK is moved and end when the CANISTER is moved into a transportation cask or the spent fuel building.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on a CANISTER to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the CANISTER is ready to initiate removal of the CANISTER outer closure plate and end when the last fuel assembly is removed from the CANISTER.

FuelSolutions' Storage System Amendment 41.1-2 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 Require 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 indentations 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 ACTIONTIME A. LCO not met A.1 Verify...

AND A.2 Restore...

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

FuelSolutions' Storage System Amendment 41.2-1 Logical Connectors 1.2 1.2 Logical Connectors

EXAMPLES EXAMPLE 1.2-2 (continued) ACTIONS

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO not met A.1 Stop...

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove...

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

FuelSolutions' Storage System Amendment 41.2-2 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 can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(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.

FuelSolutions' Storage System Amendment 41.3-1 Completion Times 1.3 1.3 Completion Times

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

EXAMPLE 1.3-1 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME B. RequiredB.1 Perform Action12 hours Action and B.1.

associated AND Completion Time not B.2 Perform Action36 hours met. B.2.

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

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> AND complete action B.2 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

A total of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> (not 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) 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 <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

FuelSolutions' Storage System Amendment 41.3-2 Completion Times 1.3 1.3 Completion Times

EXAMPLES EXAMPLE 1.3-2 (continued) ACTIONS

COMPLETION CONDITION REQUIRED ACTION TIME A. One systemA.1 Restore system7 days not within to within limit.

limit.

B. RequiredB.1 Perform Action12 hours Action and B.1.

associated AND Completion Time not B.2 Perform Action36 hours met. B.2.

When it is determined that a system does 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.

FuelSolutions' Storage System Amendment 41.3-3 Completion Times 1.3 1.3 Completion Times

EXAMPLES EXAMPLE 1.3-3 (continued) ACTIONS

NOTE Separate Condition entry is allowed for each component.

COMPLETION CONDITION REQUIRED ACTIONTIME A. LCO notA.1 Restore4 hours met. compliance with LCO.

B. RequiredB.1 Perform Action12 hours Action and B.1.

associated AND Completion Time not B.2 Perform Action36 hours met. B.2.

The Note above the ACTIONS Table is a method of modifying the Completion Time tracking. If this method of modifying the Completion Time tracking were only applicable 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 does not meet the LCO, Condition A is entered and its Completion Time starts. If it is determined that subsequent components do 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 COMPLETION TIME Required Action should be pursued without delay and in a controlled manner.

FuelSolutions' Storage System Amendment 41.3-4 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, 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 an SR satisfied, SR 3.0.4 imposes no restriction.

The use of met or performed in these instances conveys specific meaning. A Surveillance is met only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being performed, constitutes a Surveillance not met.

FuelSolutions' Storage System Amendment 41.4-1 Frequency 1.4 1.4 Frequency

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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when it is determined the equipment does 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 cask 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 unit 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.

FuelSolutions' Storage System Amendment 41.4-2 Frequency 1.4 1.4 Frequency

EXAMPLES EXAMPLE 1.4-2 (continued) SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting activity AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 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.

FuelSolutions' Storage System Amendment 41.4-3 Functional and Operating Limits 2.0

2.0 FUNCTIONAL AND OPERATING LIMITS

See each individual CANISTER Technical Specification for the applicable functional and operating limits.

FuelSolutions' Storage System Amendment 42.0-1 LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

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

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

LCO 3.0.3 Not applicable to an SFSS.

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 CANISTER.

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.

LCO 3.0.6 Not applicable to an SFSS.

LCO 3.0.7 Not applicable to an SFSS.

FuelSolutions' Storage System Amendment 43.0-1 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY

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

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or a 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. 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 LCOs 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 CANISTER.

FuelSolutions' Storage System Amendment 43.0-2 Canister Helium Backfill Density 3.1.1 3.1 CANISTER INTEGRITY 3.1.1 Canister Helium Backfill Density

See each individual CANISTER Technical Specification for the applicable LCO.

FuelSolutions' Storage System Amendment 43.1-1 Canister Vacuum Drying Pressure 3.1.2 3.1 CANISTER INTEGRITY 3.1.2 Canister Vacuum Drying Pressure

LCO 3.1.2 The CANISTER cavity vacuum pressure following drying shall be

1. 3 torr, maintained for at least 30 minutes.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

NOTE Separate Condition entry is allowed for each CANISTER.

COMPLETION CONDITION REQUIRED ACTIONTIME A. CANISTER cavity A.1 Establish CANISTER cavity 7 days.

vacuum pressure limit not vacuum pressure within the met. limit in accordance with the vacuum drying program.

B. Required Action and B.1 Remove all fuel assemblies 30 days.

Associated Completion from the CANISTER.

Time not met.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify that the CANISTER cavity vacuumPrior to continuing pressure following drying is within the limit. LOADING OPERATIONS.

FuelSolutions' Storage System Amendment 43.1-2 Canister Leak Rate 3.1.3 3.1 CANISTER INTEGRITY 3.1.3 Canister Leak Rate LCO 3.1.3 The CANISTER leak rate for the inner closure plate to CANISTER shell weld, and the inner closure plate to drain and vent port body welds shall not exceed 8.52 x 10 -6 ref-cc/sec.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS NOTE Separate Condition entry is allowed for each CANISTER.

COMPLETION CONDITION REQUIRED ACTIONTIME A. CANISTER leak rate A.1 Establish CANISTER leak 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.

limit is not met. rate within limit.

B. Required Action and B.1 Remove all fuel assemblies 30 days.

associated Completion from CANISTER.

Time are not met.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify CANISTER leak rate is within limit. Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after verifying CANISTER vacuum pressure during drying within limit per LCO 3.1.2.

FuelSolutions' Storage System Amendment 43.1-3 Hydraulic Ram Force During Horizontal Canister Transfer 3.1.4 3.1 CANISTER INTEGRITY 3.1.4 Hydraulic Ram Force During Horizontal Canister Transfer

LCO 3.1.4 The ram force on the CANISTER during horizontal transfer shall not exceed 70,000 pounds pushing or 50,000 pounds pulling.

APPLICABILITY: During TRANSFER OPERATIONS ACTIONS

NOTE Separate Condition entry is allowed for each CANISTER.

COMPLETION CONDITION REQUIRED ACTIONTIME

A. Hydraulic ram force A.1 Initiate action to stop Immediately.

limit on CANISTER is horizontal transfer.

not met. AND

A.2 Move CANISTER back to cask 7 days.

from which it was being transferred.

AND

A.3 Check STORAGE CASK rails Prior to proceeding for proper installation and with TRANSFER damage. OPERATIONS.

AND

A.4 Verify alignment. Prior to proceeding with TRANSFER OPERATIONS.

FuelSolutions' Storage System Amendment 43.1-4 Hydraulic Ram Force During Horizontal Canister Transfer 3.1.4 3.1.4 Hydraulic Ram Force During Horizontal Canister Transfer

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.1.4.1 Verify hydraulic ram force on Continuously during CANISTER is within limit. horizontal TRANSFER OPERATIONS when transferring CANISTER between TRANSFER CASK and STORAGE CASK.

FuelSolutions' Storage System Amendment 43.1-5 Canister Vertical Time Limit in Transfer Cask 3.1.5 3.1 CANISTER INTEGRITY 3.1.5 Canister Vertical Time Limit in Transfer Cask

See each individual CANISTER Technical Specification for the applicable LCO.

FuelSolutions' Storage System Amendment 43.1-6 Canister Surface Contamination 3.2.1 3.2 CANISTER RADIATION PROTECTION 3.2.1 Canister Surface Contamination

LCO 3.2.1 The non-fixed (removable) radioactive contamination for the accessible external surfaces of a CANISTER shall not exceed:

a. 1,000 dpm/100 cm2 for beta-gamma sources.

b. 20 dpm/100 cm2 for alpha sources.

APPLICABILITY: During LOADING OPERATIONS.

ACTIONS

NOTE Separate Condition entry is allowed for each CANISTER.

COMPLETION CONDITION REQUIRED ACTIONTIME A. Surface contamination A.1 Establish CANISTER 7 days.

limits are not met. surface contamination within limit.

B. Required Action and B.1 Determine the cause for the Prior to TRANSFER associated Completion failure to meet Condition A, OPERATIONS.

Time are not met. initiate actions to correct the cause, and establish the accessible CANISTER surface contamination within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify that the removable contamination on theWithin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> accessible exterior surface of the CANISTER before containing fuel assemblies is within limits. TRANSFER OPERATIONS.

FuelSolutions' Storage System Amendment 43.2-1 (Deleted) l 3.3.1 3.3 STORAGE CASK INTEGRITY 3.3.1 (Deleted) l

l

FuelSolutions' Storage System Amendment 43.3-1 Storage Cask Periodic Monitoring l 3.3.2 3.3 STORAGE CASK INTEGRITY 3.3.2 Storage Cask Periodic Monitoring l

See each individual CANISTER Technical Specification for the applicable LCO.

FuelSolutions' Storage System Amendment 43.3-2 Storage Cask Temperatures During Horizontal Transfer 3.3.3 3.3 STORAGE CASK INTEGRITY 3.3.3 Storage Cask Temperatures During Horizontal Transfer

See each individual CANISTER Technical Specification for the applicable LCO.

FuelSolutions' Storage System Amendment 43.3-3 Transfer Cask Structural Shell Temperature 3.4.1 3.4 TRANSFER CASK INTEGRITY 3.4.1 Transfer Cask Structural Shell Temperature

LCO 3.4.1 The temperature of the TRANSFER CASK, as detected by a permanently installed thermocouple mounted on the TRANSFER CASK structural shell (inside the neutron shield), shall remain above 40°F (4°C) when the ambient air temperature is below 32°F (0°C).

APPLICABILITY: During TRANSFER OPERATIONS.

ACTIONS

COMPLETION CONDITION REQUIRED ACTIONTIME A. TRANSFER CASK A.1 Establish TRANSFER 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

temperature limit is not CASK temperature within met. the limit.

B. Required Action and B.1 Move TRANSFER CASK to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.

associated Completion plants fuel building or other Time are not met. heated area.

AND B.2 If CANISTER loaded with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

fuel is in TRANSFER CASK, fill annulus with water.

AND B.3 Inspect TRANSFER CASK 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

liquid neutron shield and expansion tank for damage.

AND B.4 If TRANSFER CASK is 7 days.

damaged, repair as required.

FuelSolutions' Storage System Amendment 43.4-1 Transfer Cask Structural Shell Temperature 3.4.1 3.4.1 Transfer Cask Structural Shell Temperature

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY SR 3.4.1.1 Verify TRANSFER CASK structural shellOnce after the temperature within the limit. TRANSFER CASK with a CANISTER containing fuel assemblies has been downended on the horizontal transfer skid and moved outside the plants fuel building, or a loaded CANISTER has been retrieved from a STORAGE CASK or transportation cask.

AND Every 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> thereafter during TRANSFER OPERATIONS.

FuelSolutions' Storage System Amendment 43.4-2 Transfer Cask Surface Contamination 3.5.1 3.5 TRANSFER CASK RADIATION PROTECTION 3.5.1 Transfer Cask Surface Contamination

LCO 3.5.1 The non-fixed (removable) radioactive contamination for the accessible surfaces of a TRANSFER CASK when the TRANSFER CASK is outside the plants fuel building for horizontal TRANSFER OPERATIONS shall not exceed:

a. 1,000 dpm/100 cm2 for beta-gamma sources

b. 20 dpm/100 cm2 for alpha sources APPLICABILITY: During TRANSFER OPERATIONS.

ACTIONS

COMPLETION CONDITION REQUIRED ACTIONTIME

A. Surface contaminationA.1 Establish TRANSFER CASK 7 days.

limits are not met. surface contamination within limit.

B. Required Action andB.1 Determine the cause for the Prior to TRANSFER associated Completion failure to meet Condition A, OPERATIONS.

Time are not met. initiate actions to correct the cause, and establish the TRANSFER CASK surface contamination within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

SR 3.5.1.1 Verify that the removable contamination onPrior to moving the the accessible surfaces of the TRANSFER TRANSFER CASK CASK is within limits. outside the fuel building during horizontal TRANSFER OPERATIONS.

FuelSolutions' Storage System Amendment 43.5-1 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 the maintenance of safety margins in the storage system component design. The principal objective of this category is to describe the design envelope which might constrain any physical changes to essential equipment. Included in this category are the site environmental parameters which provide the bases for design, but are not inherently suited for description as LCOs.

4.1 Storage System 4.1.1 Storage Cask 4.1.1.1 Structural Performance The STORAGE CASK has been evaluated for a tip-over during handling (equivalent to a side drop of 28 g) and a bottom end drop resulting in an axial gravitational (g) loading of 89 g.

The STORAGE CASK factors of safety due to Design Basis Earthquake (DBE) and all associated load combinations have been evaluated for all possible modes of failure. The DBE peak accelerations are defined as 0.25 g in two orthogonal horizontal directions and 0.25 g in the vertical direction.

4.1.1.2 Codes and Standards The FuelSolutions' W150 STORAGE CASK is designed in accordance with ACI 349 and fabricated in accordance with ACI 318. Exceptions to these codes are listed in Table 4.1-1.

4.1.1.3 Fabrication Exceptions to Codes, Standards, and Criteria Proposed alternatives to ACI 318, including exceptions allowed by Section 4.1.1.2, 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 ACI 318, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for exception in accordance with this section should be submitted in accordance with 10CFR72.4.

4.1.2 Transfer Cask 4.1.2.1 Structural Performance The TRANSFER CASK has been evaluated for a side drop resulting in a lateral gravitational loading of 60 g.

FuelSolutions' Storage System Amendment 44.0-1 Design Features 4.0 4.0 Design Features

The TRANSFER CASK factors of safety due to Design Basis Earthquake (DBE) and all associated load combinations have been evaluated for all possible modes of failure. The DBE peak accelerations are defined as 0.25 g in two orthogonal horizontal directions and 0.25 g in the vertical direction.

4.1.2.2 Codes and Standards The FuelSolutions' W100 TRANSFER CASK is designed in accordance with Subsection NF of the ASME Code. Exceptions to the code are listed in Table 4.1-2.

4.1.2.3 Fabrication Exceptions to Codes, Standards, and Criteria Proposed alternatives to Subsection NF of the ASME Code, including exceptions allowed by Section 4.1.2.2, 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 ASME Code,Section III, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for exception in accordance with this section should be submitted in accordance with 10CFR72.4.

4.1.3 Canister 4.1.3.1 Criticality See each individual CANISTER Technical Specification Section 4.1.3.1 for discussion of CANISTER criticality control features.

4.1.3.2 Structural Performance See each individual CANISTER Technical Specification Section 4.1.3.2 for discussion of CANISTER structural performance features.

4.1.3.3 Codes and Standards See each individual CANISTER Technical Specification Section 4.1.3.3 for discussion of codes and standards applicable to the CANISTER.

4.1.3.4 Fabrication Exceptions to Codes, Standards, and Criteria See each individual CANISTER Technical Specification Section 4.1.3.4 for discussion of exceptions to codes, standards, and criteria.

FuelSolutions' Storage System Amendment 44.0-2 Design Features 4.0 4.0 Design Features

4.2 Storage Pad 4.2.1 Storage Location for Storage Casks Each STORAGE CASK is designed to radiate sufficient heat when placed on the storage pad in the appropriate location. Thermal analyses of normal STORAGE OPERATIONS (Storage System FSAR, Section 4.4) assume that the casks will be stored in an array that places adjacent casks a minimum of 15 feet apart, center-to-center. This minimum spacing is an important parameter to the proper dissipation of radiant heat energy from the cask.

4.2.2 Pad Properties to Limit Cask Gravitational Loadings Due to Postulated Drops 4.2.2.1 Storage Cask The FuelSolutions' W150 STORAGE CASK has been evaluated for an end drop onto a reinforced concrete pad. The evaluations are based on the following parameters:

Concrete thickness (inches, max.) 24 30 36

Maximum Reinforcing Steel (EWEF) #8 @ 18" #9 @ 18" #8 @ 12"

Nominal concrete 28 day compressive 3,000 3,000 3,000 strength (psi)

Nominal reinforcement yield strength (psi) 60,000 60,000 60,000

Soil effective modulus of elasticity 30,000 20,000 10,000 (psi, max.)

Drop height (inches, max.) 36 36 36

Any site-specific pad design with parameters that differ from those listed must be evaluated by the licensee to confirm that the design basis deceleration loads for the storage cask and canister are not exceeded. This evaluation must be performed using the same methodology as described in WSNF-200 FSAR, Section 3.7.3.1.

4.2.2.2 Transfer Cask The FuelSolutions' W100 Transfer Cask has been evaluated for a side drop onto a reinforced concrete pad. The evaluations are based on the following parameters:

Concrete thickness (inches, max.) 24 Minimum pad size 30' x 50' Maximum Reinforcing Steel (EWEF) #8 @ 18"

FuelSolutions' Storage System Amendment 44.0-3 Design Features 4.0 4.0 Design Features

Nominal concrete 28 day compressive strength (psi) 3,000 Nominal reinforcement yield strength (psi) 60,000 Soil effective modulus of elasticity (psi, max.) 15,000 Drop height (inches, max.) 72

Any site-specific pad design with parameters that differ from those listed must be evaluated by the licensee to confirm that the design basis deceleration loads for the transfer cask and canister are not exceeded. This evaluation must be performed using the same methodology as described in WSNF-200 FSAR, Section 3.7.5.1.

4.3 Site Specific Parameters and Analyses The minimum site-specific parameters and analyses that will need verification by the system user are:

4.3.1 Fire and Explosion The potential for fire and explosion shall be addressed, based on site-specific considerations.

This includes the condition that the on-site transporter fuel tank will contain no more than 70 gallons of fuel.

For the purpose of providing the licensee with design basis loading criteria for comparison to site-specific hazards, a postulated explosion is taken to be the same as the tornado wind pressure load defined in Section 2.3.4.2 of the Storage System FSAR (WSNF-200).

4.3.2 Engineered Features In cases where engineered features (i.e., berms, shield walls) are used to ensure that the requirements of 10CFR72.104(a) are met, such features are to be considered important to safety and must be evaluated to determine the applicable Quality Assurance Category.

FuelSolutions' Storage System Amendment 44.0-4

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS

5.1 Training Modules Training modules shall be developed under the general licensees training program as required by 10CFR72.212(b)(6). Training modules shall require a comprehensive program for the operation and maintenance of the FuelSolutions' spent fuel storage system and the independent spent fuel storage installation (ISFSI). The training modules shall include the following elements, at a minimum:

< FuelSolutions' SFSS design (overview)

< ISFSI facility design (overview)

< Systems, structures, and components important to safety (overview)

< FuelSolutions' SFSS and CANISTER storage Safety Analysis Report (overview)

< NRC Safety Evaluation Report (overview)

< Certificate of Compliance conditions

< FuelSolutions' Technical Specifications

< Applicable regulatory requirements (e.g., 10CFR72, Subpart K, 10CFR20, 10CFR73)

< Required instrumentation and use

< Operating experience reviews

< FuelSolutions' operating and maintenance procedures, including:

• Fuel qualification and loading

• Rigging and handling

• LOADING OPERATIONS as described in Chapter 8 of the FSAR

• UNLOADING OPERATIONS including reflooding as described in Chapter 8 of the FSAR

• Auxiliary equipment operations and maintenance (i.e., vacuum drying, helium backfilling, leak testing, reflooding)

• Transfer operations including loading and unloading of the transport vehicle

• ISFSI surveillance operations

• Radiation protection

• Maintenance

• Security

• Off-normal and accident conditions, responses, and corrective actions

FuelSolutions' Storage System Amendment 45.0-1 Administrative Controls 5.0 5.0 Administrative Controls

5.2 Preoperational Testing and Training Exercises A preoperational training exercise of the Fuel Solutions' Storage System is to be conducted prior to the first use of any system component or conduct of any specific operation that may include, but is not limited to, the following:

< Moving a transfer cask/canister into the spent fuel pool.

< Loading an SNF assembly. This includes operations associated with selecting, loading, and independent verification of a dummy SNF assembly.

< Placing the top shield plug and removal of transfer cask/canister from the spent fuel pool.

< Canister sealing, vacuum drying, and cover gas backfill operations using a mock-up canister subassembly.

< Transfer cask upending/downending on the horizontal transfer trailer.

< Storage cask upending/downending.

< Horizontal canister transfer from the transfer cask to and retrieval from the storage cask.

< Horizontal canister transfer from the transfer cask to and retrieval from the transportation cask.

< Horizontal canister transfer from the transportation cask to and retrieval from the storage cask.

< Vertical canister transfer from the transfer cask to and retrieval from the storage cask.

< Vertical canister transfer from the transfer cask to and retrieval from the transportation cask.

< Canister reflood and opening using a mock-up canister subassembly.

Subsequent training will be in accordance with site-specific procedures.

5.3 Programs The following programs shall be established, implemented, and maintained:

5.3.1 Cask Sliding Evaluation The FuelSolutions' W150 STORAGE CASK has been evaluated for sliding in the unlikely events of a seismic event. A sliding coefficient of friction of 0.3 is used in these analyses. This program provides a means for evaluating the coefficient of friction to assure that the cask will not slide significantly during the seismic event.

5.3.1.1 Pursuant to 10CFR72.212, this program shall evaluate the site-specific ISFSI pad configurations/conditions to assure that the cask would not slide significantly during the postulated design basis earthquake. The program shall conclude that the surface sliding friction coefficient of friction is greater than or equal to 0.3.

FuelSolutions' Storage System Amendment 45.0-2 Administrative Controls 5.0 5.0 Administrative Controls

5.3.1.2 Alternatively, for site-specific ISFSI pad configuration/conditions with a lower sliding coefficient of friction than 0.3, the program shall evaluate the site-specific conditions to assure that the FuelSolutions' W150 STORAGE CASK will not slide significantly during the postulated design basis earthquake. The program shall also evaluate storm winds, missile impacts and flood forces to assure that the cask will not slide such that it could result in impact with other casks or structures at the ISFSI. The program shall assure that these alternative analyses are documented and controlled.

5.3.2 Cask Transport Evaluation Program This program provides a means for evaluating va rious transport configurations and transport route conditions to assure that the design basis drop limits are met.

5.3.2.1 Pursuant to 10CFR72.212, this program shall evaluate the site-specific transport conditions. To demonstrate compliance with Technical Specification 4.2.2, the program shall conclude that the expected lift height above the transport surface shall be less than or equal to that described by Technical Specification 4.2.2.

Also, the program shall conclude that the transport route conditions (e.g., surface hardness and pad thickness) are equivalent to or less limiting than those prescribed for the typical pad surfaces which form the basis for Technical Specification 4.2.2.

5.3.2.2 Alternatively, for site-specific transport conditions which are not encompassed by those of Technical Specification 4.2.2, the program shall evaluate the site-specific conditions to assure that the STORAGE CASK end-drop loading does not exceed 88.5 g and the TRANSFER CASK side drop loading does not exceed 60 g. This alternative analysis shall be commensurate with the analysis which forms the basis of Technical Specification 4.2.2 (Reference FuelSolutions' Storage System FSAR, Section 3.7). The program shall assure that these alternative analyses are documented and controlled.

5.3.2.3 This program shall establish administrative controls and procedures to assure that cask transport operations are conducted within the limits imposed by the Technical Specification or the alternative analysis described above.

5.3.3 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications.

5.3.3.1 Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

FuelSolutions' Storage System Amendment 45.0-3 Administrative Controls 5.0 5.0 Administrative Controls

5.3.3.2 Licensees may make changes to Bases without prior NRC approval provided the changes do not involve either of the following:

• A change in the TS incorporated in the license

• A change to the FSAR or Bases that involves an unreviewed safety question, a significant increase in occupational exposure, or a significant unreviewed environmental impact as defined in 10CFR72.48.

5.3.3.3 The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the FSAR.

5.3.3.4 Proposed changes that do not meet the criteria of 5.3.3.2 above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10CFR72.48(b)(2).

5.3.4 Radioactive Effluent Control Program This program implements the requirements of 10CFR72.44(d).

5.3.4.1 The FuelSolutions' Storage System does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents are not required. Specification 3.1.3, CANISTER Leak Rate, provides assurance that there are essentially no radioactive effluents from the CANISTERs.

5.3.4.2 This program includes an environmental monitoring program. The FuelSolutions' Storage System may be included in a site environmental monitoring program.

5.3.4.3 An annual report shall be submitted pursuant to 10CFR72.44(d)(3) specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during th e previous calendar year of operation.

5.3.5 Cask Surface Dose Rate Evaluation Program This program provides a means for ensuri ng that ISFSIs using FuelSolutions' STORAGE CASKS do not violate the requirements of 10CFR72 and 10CFR20 regarding radiation doses and dose rates.

5.3.5.1 As part of its evaluation pursuant to 10CFR72.212, the licensee shall perform an analysis to confirm that the limits of 10CFR20 and 10CFR72.104 will be satisfied under the actual site conditions and configurations considering the planned number of casks to be used and the planned fuel loading conditions.

5.3.5.2 On the basis of the analysis in 5.3.5.1, the licensee shall establish a set of cask surface dose rate limits which are to be applied to FuelSolutions' STORAGE CASKS used at the site. Limits shall establish average gamma-ray and neutron dose rates for:

FuelSolutions' Storage System Amendment 45.0-4 Administrative Controls 5.0 5.0 Administrative Controls

• The outside vertical surface of the STORAGE CASK at approximately 6 feet above the base.

• The inlet or outlet vent screen surfaces.

• The top lid.

5.3.5.3 Notwithstanding the limits established in TS 5.3.5.2, the dose rate limits may not exceed the following values:

• 50 mrem/hr on the side.

• 510 mrem/hr at the inlet or outlet vent screen surfaces.

• 50 mrem/hr on the top lid.

5.3.5.4 Within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following placement of the loaded STORAGE CASK on the ISFSI pad, the licensee shall measure the cask surface dose rates and calculate average values as described in 5.3.5.7 and 5.3.5.8.

The measured average dose rates shall be compared to the limits established in TS 5.3.5.2 or the limits in 5.3.5.3, whichever are lower.

5.3.5.5 If the measured average surface dose rates do not meet the limits of TS 5.3.5.2 or TS 5.3.5.3, 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.

• Perform an analysis to determine that placement of the as-loaded cask at the ISFSI will not cause the ISFSI to exceed the radiation exposure limits of 10CFR20 and 10CFR72.

5.3.5.6 If the analysis in 5.3.5.5 shows that placement of the as-loaded cask at the ISFSI will cause the ISFSI to exceed the radiation exposure limits of 10CFR20 and 10CFR72, the licensee shall remove all fuel assemblies from the cask within 30 days of the time of cask loading.

5.3.5.7 The surface dose rates shall be measured at the following points:

• At least eight readings taken at equal spacing around the outside vertical surface of the STORAGE CASK at approximately 6 feet above the base.

• The inlet or outlet vent screen surfaces.

• At least five readings taken on the top lid, with one reading from the center and the other four taken at equal spacing 30 inches from the center.

5.3.5.8 The average dose rates shall be determined as follows:

In each of the three measurement zones in 5.3.5.7, the sum of the dose rate measurements is divided by the number of measurements to determine the

FuelSolutions' Storage System Amendment 45.0-5 Administrative Controls 5.0 5.0 Administrative Controls

average for that zone. The neutron and gamma-ray dose rates are averaged separately. Uniformly spaced dose rate measurement locations are chosen such that each point in a given zone represents approximately the same surface area.

5.3.6 Vacuum Drying Program See the CANISTER Technical Specifications for the applicable information.

5.3.7 Cladding Oxide Thickness Measurement Program See the CANISTER Technical Specifications for the applicable information.

5.3.8 Storage Cask Periodic Monitoring Program l The STORAGE CASK containing a CANISTER loaded with fuel has been evaluated for the l unlikely event of full blockage of all STORAGE CASK inlet and outlet vent screens during l STORAGE OPERATIONS. Transient thermal analyses have been performed for the blocked l vent accident condition to determine the time at which the limiting short-term allowable l temperature is reached in the STORAGE CASK. Periodic monitoring is required at intervals l that are less than the time required to reach the limiting short-term temperature limit. l This program shall establish administrative controls and procedures to assure that the licensee l will be able to determine when corrective action needs to be taken to maintain safe storage l conditions. The required surveillance frequency for a STORAGE CASK containing a l CANISTER loaded with fuel is as follows: l l

Total Heat Load (Q) Surveillance Frequency l Q > 20 kW 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (1 day) l 15 kW < Q #20 kW 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> (2 days) l 10 kW < Q #15 kW 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> (4 days) l 5 kW < Q #10 kW 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> (1 week) l Q #5 kW 336 hours0.00389 days <br />0.0933 hours <br />5.555556e-4 weeks <br />1.27848e-4 months <br /> (2 weeks) l l

Acceptable means of monitoring the STORAGE CASK include periodic visual inspection of all l STORAGE CASK inlet and outlet vent screens OR periodic STORAGE CASK liner l thermocouple temperature readings. When the STORAGE CASK liner thermocouple l temperature measurements are used as the means of monitoring, the following limits shall be l met: l l

FuelSolutions' Storage System Amendment 45.0-6 Administrative Controls 5.0 5.0 Administrative Controls

Measured Thermocouple Temperature (°F) l Total Heat Load (Q) Normal Ambient (#100°F) Off-Normal Ambient (#125°F) l Q > 20 kW 163 192 l 15 kW < Q #20 kW 156 181 l 10 kW < Q #15 kW 146 171 l 5 kW < Q #10 kW 136 161 l Q #5 kW 126 151 l l

Alternatively, the program may establish other suitable surveillance frequencies and liner l thermocouple temperature limits to maintain the concrete temperature below the short-term l allowable temperature of 350°F for a specific CANISTER heat load. l 5.4 Special Requirements for First System in Place See the CANISTER Technical Specifications for the applicable information.

FuelSolutions' Storage System Amendment 45.0-7