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Attachment 5: Holtec International, Appendix D Technical Specifications for the HI-Storm 100 Cask System
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PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX D TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100S VERSION E CASK

TABLE OF CONTENTS 1 Definitions, Use, and Application ...................................................................................... 1-1 1.1 Definitions ................................................................................................................. 1-1 1.2 Logical Connectors ................................................................................................... 1-7 1.3 Completion Times.................................................................................................... 1-10 1.4 Frequency ............................................................................................................... 1-14 2 Approved Contents .......................................................................................................... 2-1 2.1 Fuel Specifications and Loading Conditions .............................................................. 2-1 2.1.1 Fuel To Be Stored In MPC-32M ......................................................................... 2-1 2.1.2 Fuel Loading ...................................................................................................... 2-1 2.2 Decay Heat Limits for ZR-Clad Fuel ........................................................................ 2-10 2.2.1 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for MPC-32M for a VENTILATED OVERPACK ............................................................................................ 2-10 2.2.2 Discrete Loading Pattern Decay Heat Limits for ZR-Clad Fuel in MPC-32M for a VENTILATED OVERPACK ............................................................................................ 2-10 2.2.3 Compliance with Maximum Fuel Storage Location Decay Heat Limits ............. 2-11 2.2.4 Variable Fuel Height for MPC-32M .................................................................. 2-11 2.2.5 Decay Heat Limits for MPC-32M for the UNVENTILATED OVERPACK .......... 2-11 3 Limiting Conditions for Operation (LCOs) and Surveillance Requirements (SRs) ............. 3-1 3.0 Applicability ............................................................................................................... 3-1 3.1 SFSC INTEGRITY .................................................................................................... 3-3 3.1.1 Multi-Purpose Canister (MPC) ........................................................................... 3-3 3.1.2 HI-STORM 100S VERSION E SFSC Heat Removal System ............................. 3-6 3.1.3 MPC Cavity Reflooding ...................................................................................... 3-8 3.1.4 Supplemental Cooling System ......................................................................... 3-10 3.2 SFSC RADIATION PROTECTION. ......................................................................... 3-12 3.2.1 TRANSFER CASK Surface Contamination. ..................................................... 3-12 3.3 SFSC CRITICALITY CONTROL ............................................................................. 3-13 3.3.1 Boron Concentration ........................................................................................ 3-13 4 Administrative Controls .................................................................................................... 4-1 4.1 Radioactive Effluent Control Program for HI-STORM 100S Version E ...................... 4-1 4.2 Cask Transport Evaluation Program ........................................................................... 4-1 4.2.1 Overpacks and the Transfer Cask...................................................................... 4-1 4.3 Radiation Protection Program .................................................................................... 4-2 4.4 Violations of Fuel Specifications or Loading Conditions ............................................ 4-5 Certificate of Compliance No. 1014 Amendment No. 16 Appendix D i

4.4.1 Actions ............................................................................................................... 4-5 4.5 Aging Management Program ..................................................................................... 4-6 4.6 Combustible Gas Monitoring During MPC Lid Welding and Cutting .......................... 4-7 FIGURES Figure 2.1-1: Cell Identification for MPC-32M ...........................................................................2-9 Figure 2.2-1: Discrete Pattern A Per Cell Allowable Heat Loads (kW) - MPC-32M ................2-18 Figure 2.2-2: Discrete Pattern B Per Cell Allowable Heat Loads (kW) - MPC-32M ................2-19 TABLES Table 2.1-1: Fuel Assembly Limits ...........................................................................................2-2 Table 2.1-2: PWR Fuel Assembly Characteristics for MPC-32M ..............................................2-6 Table 2.1-3: MPC-32M Non-Fuel Hardware Cooling and Average Burnup ...............................2-7 Table 2.1-4: Burnup and Cooling Time Fuel Qualification for MPC-32M...................................2-8 Table 2.2-1: Allowable Heat Loads and Soluble Boron Requirements for MPC-32M ..............2-12 Table 2.2-2: Maximum Allowable Decay Heat Loads for MPC-32M .......................................2-13 Table 2.2-3: MPC-32M Fuel Storage Regions ........................................................................2-13 Table 2.2-4: MPC-32M Fuel Storage Quadrants ....................................................................2-14 Table 2.2-5: MPC-32 Heat Load Data for UNVENTILATED OVERPACK...............................2-15 Table 2.2-6: MPC-32M Requirements on Developing Regionalized Heat Load Patterns for UNVENTILATED OVERPACK ........................................................................2-16 Table 2.2-7: Section Heat Load Calculations for MPC-32M for UNVENTILATED OVERPACK .....

............................................................................................................2-17 Table 2.2-8: DFC and DFI Storage Locations with Heat Load Penalties for MPC-32M for UNVENTILATED OVERPACK ........................................................................2-17 Table 3.3-1: MPC Cavity Drying Limits for VENTILATED OVERPACK ..................................3-15 Table 3.3-2: MPC-32M Cavity Drying Limits for UNVENTILATED OVERPACK .....................3-16 Table 3.3-3: MPC Helium Backfill Limits for VENTILATED OVERPACK ................................3-17 Table 3.3-4: MPC Helium Backfill Limits for UNVENTILATED OVERPACK ...........................3-18 Table 3.3-5: Completion Time for Actions to Restore SFSC Heat Removal System Operable ......

............................................................................................................3-19 Table 3.3-6: MPC-32M with up to Sixteen DFIs Soluble Boron Requirements .......................3-20 Certificate of Compliance No. 1014 Amendment No. 16 Appendix D ii

Table 3.3-7: MPC-32M with up to Twelve DFCs Soluble Boron Requirements.......................3-21 Table 3.3-8: MPC-32M with Thirteen to Sixteen DFCs/DFIs Soluble Boron Requirements ....3-21 Table 3.3-9: MPC-32/32F and Version 1 Soluble Boron Requirements ..................................3-23 Certificate of Compliance No. 1014 Amendment No. 16 Appendix D iii

1 DEFINITIONS, USE, AND APPLICATION 1.1 Definitions 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.

CASK TRANSFER FACILITY A CASK TRANSFER FACILITY is an optional (CTF) aboveground or underground system used during the transfer of a loaded MPC between a transfer cask and a storage OVERPACK external to 10 CFR Part 50 controlled structures. The CASK TRANSFER FACILITY includes the following components and equipment: (1) a Cask Transfer Structure used to stabilize the OVERPACK, TRANSFER CASK and/or MPC during lifts involving spent fuel not bounded by the regulations of 10 CFR Part 50, and (2) Either a stationary lifting device or a mobile lifting device used in concert with the stationary structure to lift the OVERPACK, TRANSFER CASK, and/or MPC.

DAMAGED FUEL ASSEMBLY DAMAGED FUEL ASSEMBLIES are fuel assemblies with known or suspected cladding defects, as determined by a review of records, greater than pinhole leaks or hairline cracks, empty fuel rod locations that are not filled with dummy fuel rods, missing structural components such as grid spacers, whose structural integrity has been impaired such that geometric rearrangement of fuel or gross failure of the cladding is expected based on engineering evaluations, or that cannot be handled by normal means.

Fuel assemblies that cannot be handled by normal means due to fuel cladding damage are considered FUEL DEBRIS.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-1

Term Definition DAMAGED FUEL CONTAINER DFCs are specially designed enclosures for DAMAGED (DFC) FUEL ASSEMBLIES or FUEL DEBRIS which permit gaseous and liquid media to escape while minimizing dispersal of gross particulates. DFCs authorized for use in the HI-STORM 100 System are as follows:

1. Holtec Dresden Unit 1/Humboldt Bay design

2. Transnuclear Dresden Unit 1 design

3. Holtec Generic BWR design

4. Holtec Generic PWR design DAMAGED FUEL DFIs are specially designed barriers installed at the top and bottom of the storage cell space which permit flow of ISOLATOR (DFI) gaseous and liquid media while preventing the potential migration of fissile material from fuel assemblies with cladding damage. DFIs are used ONLY with damaged fuel assemblies which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected. Damaged fuel stored in DFIs may contain missing or partial fuel rods and/or fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks.

FUEL DEBRIS FUEL DEBRIS is ruptured fuel rods, severed rods, loose fuel pellets, containers or structures that are supporting these loose fuel assembly parts, or fuel assemblies with known or suspected defects which cannot be handled by normal means due to fuel cladding damage.

FUEL BUILDING The FUEL BUILDING is the site-specific power plant facility, governed by the regulations of 10 CFR Part 50, where the loaded OVERPACK or TRANSFER CASK is transferred to or from the transporter.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-2

Term Definition GROSSLY BREACHED SPENT Spent nuclear fuel rod with a cladding defect that could lead FUEL ROD to the release of fuel particulate greater than the average size fuel fragment for that particular assembly. A gross cladding breach may be confirmed by visual examination, through a review of reactor operating records indicating the presence of heavy metal isotopes, or other acceptable inspection means.

INTACT FUEL ASSEMBLY INTACT FUEL ASSEMBLIES are fuel assemblies without known or suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means. Fuel assemblies without fuel rods in fuel rod locations shall not be classified as INTACT FUEL ASSEMBLIES unless dummy fuel rods are used to displace an amount of water greater than or equal to that displaced by the fuel rod(s) in the active region. INTACT FUEL ASSEMBLIES may contain integral fuel absorber rods (IFBA) in PWR fuel, or burnable poison rods in BWR fuel.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an OVERPACK or TRANSFER CASK while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the MPC and end when the OVERPACK or TRANSFER CASK is suspended from or secured on the transporter. LOADING OPERATIONS does not include MPC TRANSFER.

MINIMUM ENRICHMENT MINIMUM ENRICHMENT is the minimum assembly average enrichment. Natural uranium and low enrichment blankets are not considered in determining minimum enrichment.

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

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-3

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

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

Control Rod Assemblies (CRAs), Axial Power Shaping Rods (APSRs), Wet Annular Burnable Absorbers (WABAs), Rod Cluster Control Assemblies (RCCAs),

Control Element Assemblies (CEAs), Neutron Source Assemblies (NSAs), water displacement guide tube plugs, orifice rod assemblies, instrument tube tie rods (ITTRs), vibration suppressor inserts, and components of these devices such as individual rods.

OVERPACK OVERPACKs are the casks which receive and contain the sealed MPCs for interim storage on the ISFSI. They provide gamma and neutron shielding, and in some versions, may provide for ventilated air flow to promote heat transfer from the MPC to the environs. The term OVERPACK does not include the TRANSFER CASK.

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

REDUNDANT PORT COVER REDUNDANT PORT COVER DESIGN refers to two DESIGN independent port cover plates per port opening, where each port cover plate contains multiple pass closure welds.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-4

Term Definition REPAIRED/RECONSTITUTED Spent nuclear fuel assembly which contains dummy fuel FUEL ASSEMBLY rod(s) that displaces an amount of water greater than or equal to the original fuel rod(s) and/or which contains structural repairs so it can be handled by normal means.

If irradiated dummy stainless steel rods are present in the fuel assembly, the dummy/replacement rods will be considered in the site specific dose calculations.

SPENT FUEL STORAGE CASKS SFSCs are containers approved for the storage of spent (SFSCs) fuel assemblies at the ISFSI. The HI-STORM 100 SFSC System consists of the OVERPACK/VVM and its integral MPC.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while an SFSC containing spent fuel is situated within the ISFSI perimeter. STORAGE OPERATIONS does not include MPC TRANSFER.

TRANSFER CASK TRANSFER CASKs are containers designed to contain the MPC during and after loading of spent fuel assemblies and to transfer the MPC to or from the OVERPACK/VVM. The HI-STORM 100 System employs either the 125-Ton, the 100-Ton HI-TRAC TRANSFER CASK or the HI-TRAC MS.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on an OVERPACK or TRANSFER CASK loaded with one or more fuel assemblies when it is being moved after LOADING OPERATIONS or before UNLOADING OPERATIONS. TRANSPORT OPERATIONS begin when the OVERPACK or TRANSFER CASK is first suspended from or secured on the transporter and end when the OVERPACK or TRANSFER CASK is at its destination and no longer secured on or suspended from the transporter.

TRANSPORT OPERATIONS includes MPC TRANSFER.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-5

Term Definition UNDAMAGED FUEL ASSEMBLY UNDAMAGED FUEL ASSEMBLY is: a) a fuel assembly without known or suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means; or b) a BWR fuel assembly with an intact channel, a maximum planar average initial enrichment of 3.3 wt% U-235, without known or suspected GROSSLY BREACHED SPENT FUEL RODS, and which can be handled by normal means. An UNDAMAGED FUEL ASSEMBLY may be a REPAIRED/

RECONSTITUTED FUEL ASSEMBLY.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SFSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the OVERPACK or TRANSFER CASK is no longer suspended from or secured on the transporter and end when the last fuel assembly is removed from the SFSC. UNLOADING OPERATIONS does not include MPC TRANSFER.

UNVENTILATED OVERPACK The UNVENTILATED OVERPACK is an aboveground OVERPACK which receives and contains the sealed MPC for interim storage at the ISFSI. The UNVENTILATED OVERPACK design is characterized by its absence of inlet and outlet ventilation passages.

VENTILATED OVERPACK The VENTILATED OVERPACK is an aboveground OVERPACK which receives and contains the sealed MPC for interim storage at the ISFSI. The VENTILATED OVERPACK provides passages for airflow to promote heat transfer from the MPC.

ZR ZR means any zirconium-based fuel cladding or fuel channel material authorized for use in a commercial nuclear power plant reactor.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-6

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.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-7

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME 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.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-8

EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION 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.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-9

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 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 HI-STORM 100 System 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 HI-STORM 100 System 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.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-10

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 B.1 Perform Action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action and associated Completion AND Time not met.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-11

EXAMPLES EXAMPLE 1.3-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system A.1 Restore system to 7 days not within limit. within limit.

B. Required B.1 Complete action B.1. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action and associated Completion AND Time not met.

B.2 Complete action B.2. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a system is determined not to 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, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-12

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 B.1 Complete action B.1. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action and associated Completion AND Time not met.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-13

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

TIME 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.

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.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-14

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 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 the equipment or variables are outside specified limits, or the facility 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)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-15

EXAMPLES (continued) EXAMPLE 1.4-2 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 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 1-16

2 APPROVED CONTENTS 2.1 Fuel Specifications and Loading Conditions 2.1.1 Fuel To Be Stored In MPC-32M 2.1.1.1 UNDAMAGED FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, FUEL DEBRIS, and NON-FUEL HARDWARE meeting the limits specified in Table 2.1-1 and other referenced tables may be stored in MPC- 32M.

2.1.1.2 For MPCs partially loaded with stainless steel clad fuel assemblies, all remaining fuel assemblies in the MPC shall meet the decay heat generation limit for the stainless steel clad fuel assemblies.

2.1.1.3 INTACT FUEL ASSEMBLIES, UNDAMAGED FUEL ASSEMBLIES, DAMAGED FUEL ASEMBLIES, FUEL DEBRIS and NON-FUEL HARDWARE meeting the limits specified in Appendix B Table 2.1-1 and other referenced Appendix B tables for MPC-24/24E/24EF/32/32F/68/68F/68FF/68M may be stored in the applicable MPC in the HI-STORM 100S Version E.

2.1.1.4 INTACT FUEL ASSEMBLIES, UNDAMAGED FUEL ASSEMBLIES, FUEL DEBRIS, DAMAGED FUEL ASSEMBLIES and NON-FUEL HARDWARE meeting the limits specified in Appendix B Table 2.1-1 and other referenced Appendix B tables for the MPC-68 may be stored in the MPC-68 version 1 in the HI-STORM 100S Version E.

2.1.1.5 INTACT FUEL ASSEMBLIES, UNDAMAGED FUEL ASSEMBLIES, FUEL DEBRIS, DAMAGED FUEL ASSEMBLIES and NON-FUEL HARDWARE meeting the limits specified in Appendix B Table 2.1-1 and other referenced Appendix B tables for the MPC-32 may be stored in the MPC-32 version 1 in the HI-STORM 100 Version E.

2.1.2 Fuel Loading Fuel assembly decay heat limits and other restrictions related to DAMAGED FUEL, FUEL DEBRIS, and NON-FUEL HARDWARE are specified in Section 2.2. Cell identification for MPC-32M is in Figure 2.1-1.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-1

Table 2.1-1 (page 1 of 4)

Fuel Assembly Limits I. MPC MODEL: MPC-32M A. Allowable Contents

1. Uranium oxide, PWR UNDAMAGED FUEL ASSEMBLIES listed in Table 2.1-2, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type: ZR for all fuel assembly array/class except, Stainless Steel (SS) for 14x14D and 15x15G fuel assembly array/class

b. Maximum Initial Enrichment: 5.0 wt. % U-235

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. All Array/Classes Zr clad: Cooling time 1 year and average burnup 68,200 MWD/MTU.

SS clad: Cooling time 9 years and 30,000 MWD/MTU or 20 years and 40,000MWD/MTU ii. NON-FUEL HARDWARE As specified in Table 2.1-3.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-2

Table 2.1-1 (page 2 of 4)

Fuel Assembly Limits I. MPC MODEL: MPC-32M stored in HI-STORM 100S Version E SFSC (contd)

A. Allowable Contents (contd)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D and 500 Watts.

15x15G ii. All Other Array/Classes As specified in Section 2.2.

e. Fuel Assembly Weight 2,050 lbs (including NON-FUEL HARDWARE)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-3

Table 2.1-1 (page 3 of 4)

Fuel Assembly Limits I. MPC MODEL: MPC-32M (contd)

A. Allowable Contents (contd)

2. Uranium oxide, PWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS, with or without NON-FUEL HARDWARE, placed in DAMAGED FUEL CONTAINERS.

Uranium oxide PWR DAMAGED FUEL ASSEMBLIES whose damage is limited such that the fuel assembly is able to be handled by normal means and whose structural integrity remains intact to the extent that geometric rearrangement of fuel is not expected, may be placed in basket cell locations containing top and bottom DAMAGED FUEL ISOLATORS. Uranium oxide PWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS shall meet the criteria specified in Table 2.1-2 and meet the following specifications (Note 1):

a. Cladding Type: ZR for all fuel assembly array/class except, Stainless Steel (SS) for 14x14D and 15x15G fuel assembly array/class

b. Maximum Initial Enrichment: 5.0 wt. % U-235

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. All Array/Classes Zr clad: Cooling time 1 year and average burnup 68,200 MWD/MTU.

SS clad: Cooling time 9 years and 30,000 MWD/MTU or 20 years and 40,000MWD/MTU ii. NON-FUEL HARDWARE As specified in Table 2.1-3.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-4

Table 2.1-1 (page 4 of 4)

Fuel Assembly Limits I. MPC MODEL: MPC-32M stored in HI-STORM 100S Version E SFSC (contd)

A. Allowable Contents (contd)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D and 500 Watts.

15x15G ii. All Other Array/Classes As specified in Section 2.2.

e. Fuel Assembly Weight 2,050 lbs (including NON-FUEL HARDWARE and DFC)

B. Quantity per MPC: Up to sixteen (16) DAMAGED FUEL ASSEMBLIES stored using DAMAGED FUEL ISOLATORS or DAMAGED FUEL CONTAINERS and/or FUEL DEBRIS in DAMAGED FUEL CONTAINERS, stored in fuel storage locations in Table 2.2-1. The remaining fuel storage locations may be filled with PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

C. One NSA is permitted for loading.

Note 1: Fuel assemblies containing BPRAs, TPDs, WABAs, water displacement guide tube plugs, orifice rod assemblies, or vibration suppressor inserts, with or without ITTRs, may be stored in any fuel storage location.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-5

Table 2.1-2 PWR FUEL ASSEMBLY CHARACTERISTICS FOR MPC-32M No. of Guide and/or Fuel Assembly Array/Class No. of Fuel Rod Locations Instrument Tubes 14x14A 179 17 14x14B 179 17 14x14C 176 5 (Note 1) 14x14D 180 16 15x15A 204 21 15x15B 204 21 15x15C 204 21 15x15D 208 17 15x15E 208 17 15x15F 208 17 15x15G 204 21 15x15H 208 17 15x15I 216 9 (Note 2) 16x16A 236 5 (Note 1) 16x16B 236 5 (Note 1) 16x16C 235 21 17x17A 264 25 17x17B 264 25 17x17C 264 25 Notes:

1. Each guide tube replaces four fuel rods.

2. One Instrument Tube and eight Guide Bars (Solid ZR)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-6

Table 2.1-3 MPC-32M NON-FUEL HARDWARE COOLING AND AVERAGE BURNUP (Notes 1 and 2)

Post-irradiation Inserts (Note TPD Control Component (Note Cooling 3) Burnup Burnup (Note 4) 5), NSA Time (MWD/MTU) (MWD/MTU) Burnup (MWD/MTU)

(years) 1 60,000 225,000 NA (Note 6) 2 - - 630,000 Notes: 1. Burnups for NON-FUEL HARDWARE are to be determined based on the burnup and uranium mass of the fuel assemblies in which the component was inserted during reactor operation.

2. Non-fuel hardware burnup and cooling times are not applicable to ITTRs since they are installed post irradiation.

3. Includes Burnable Poison Rod Assemblies (BPRAs), Wet Annular Burnable Absorbers (WABAs), and vibration suppressor inserts.

4. Includes Thimble Plug Devices (TPDs), water displacement guide tube plugs and orifice rod assemblies.

5. Includes Axial Power Shaping Rods (APSRs), Control Rod Assemblies (CRAs), Control Element Assemblies (CEAs) and Rod Cluster Control Assemblies (RCCAs).

6. NA means not authorized for loading at this cooling time.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-7

Table 2.1-4 BURNUP AND COOLING TIME FUEL QUALIFICATION FOR MPC-32M Cell Decay Heat Load Polynomial Coefficients, see Paragraph 2.II.1.5.2 Limit (kW)

(Notes 1, 2, 3) A B C D 0.83 6.57083E-14 -4.02593E-09 1.47107E-04 8.01647E-01 0.83 < decay heat 1.25 4.11020E-14 -4.62813E-09 2.17444E-04 -5.55545E-01 1.25 < decay heat 1.46 1.21147E-14 -1.08013E-09 8.66361E-05 4.04455E-01 1.46 < decay heat 1.81 3.82652E-15 -2.38729E-10 4.75134E-05 6.36443E-01 1.81 < decay heat 3.26 3.76103E-16 4.83486E-11 1.74805E-05 6.53455E-01 The burnup and cooling time for every fuel loaded into the MPC-32M must satisfy the following equation:

= 3 + 2 + +

where, Ct = Minimum cooling time (years),

Bu = Assembly-average burnup (MWd/mtU),

A, B, C, D = Polynomial coefficients listed in Table 2.1-4 Notes:

1. Decay heat per fuel assembly is presented

2. A decay heat value that is equal to or greater than the appropriate decay heat load limit

3. The polynomial coefficients associated for decay heat load 1.81 < decay heat 3.26 are applied to the UNVENTILATED OVERPACK MPC-32M decay heat load range of 0.83 < decay heat 3.26 Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-8

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Figure 2.1-1: Cell Identification for MPC-32M Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-9

2.2 Decay Heat Limits for ZR-Clad Fuel For MPC-24/24E/24EF/32/32F/68/68F/68FF/68M decay heat, burnup, and cooling time limits from Appendix B Section 2.2 apply for ZR clad fuel. Decay heat limits from Appendix B Table 2.1-1 apply for SS clad fuel.

For MPC-32 Version 1 decay heat, burnup and cooling time limits for MPC-32 from Appendix B Section 2.2 apply for ZR clad fuel. Decay heat limits for MPC-32 from Appendix B Table 2.1-1 apply for SS clad fuel.

For MPC-68 Version 1 decay heat, burnup and cooling time limits for MPC-68 from Appendix B Section 2.2 apply for ZR clad fuel. Decay heat limits for MPC-68 from Appendix B Table 2.1-1 apply for SS clad fuel.

Decay heat limits for ZR clad for storage in MPC-32M in HI-STORM 100S Version E are provided in the following subsections. Burnup and cooling time limits for the MPC-32M are provided in Table 2.1-4.

2.2.1 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for MPC-32M for a VENTILATED OVERPACK The maximum allowable decay heat per fuel storage location for intact or undamaged fuel assemblies in regionalized loading is determined using the following equations:

Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:

Q0 = Maximum uniform storage MPC decay heat (38 kW)

X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.2-3.

n2 = Number of storage locations in outer region from Table 2.2-3.

Allowable heat loads for Damaged Fuel and Fuel Debris are shown in Table 2.2-1. Allowable storage locations for Damaged Fuel in DFIs and Damaged Fuel or Fuel Debris in DFCs are shown in Table 2.2-1. Cell heat load limits and total heat load limits may need to be adjusted in accordance with Section 2.2.4.

2.2.2 Discrete Loading Pattern Decay Heat Limits for ZR-Clad Fuel in MPC-32M for a VENTILATED OVERPACK Discrete decay heat loading patterns (Patterns A and B) for MPC-32M are shown in Figures 2.2-1 and 2.2-2. Figures 2.2-1 and 2.2-2 provide the maximum allowable decay heat loads per fuel Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-10

storage location. Table 2.1-2 provides the maximum total allowable decay heat load and maximum allowable quadrant decay heat load for Figures 2.2-1 and 2.2-2. Cell heat load limits, quadrant heat load limits and total heat load limit may need to be adjusted in accordance with Section 2.2.4.

2.2.3 Compliance with Maximum Fuel Storage Location Decay Heat Limits When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.

2.2.4 Variable Fuel Height for MPC-32M 2.2.4.1 For fuel with a longer active fuel length than the reference fuel (144 in), the total heat load, quadrant heat load limits and specific heat load limits in each cell, may be increased by the ratio SQRT(L/144), where L is the active length of the fuel in inches.

2.2.4.2 For fuel with a shorter active fuel length than the reference fuel (144 in), the total heat load, quadrant heat load limits and specific heat load limits in each cell, shall be reduced linearly by the ratio L/144, where L is the active fuel length of the fuel in inches.

2.2.5 Decay Heat Limits for MPC-32M for the UNVENTILATED OVERPACK Tables 2.2-5 and 2.2-6 provide the maximum allowable decay heat per fuel storage location for MPC-32M for UNVENTILATED OVERPACK.

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

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-11

Table 2.2-1: Allowable Heat Loads and Soluble Boron Requirements for MPC-32M Number Penalty on per Locations/Storage Min. Soluble of storage cell DFC/DFI Cell Numbers (Note Boron Row No. DFC/DFI heat load limit (Note 1) 2) Content Locations (Note 3) 2, 11, 22, 31 1 4 0% Table 3.3-8 (NOTE 4) 1, 4, 5, 10, 23, 28, 2 8 5% Table 3.3-7 29, 32 1, 2, 4, 5, 10, 16, 3 12 17, 23, 28, 29, 31, 5% Table 3.3-7 DFC 32 1, 2, 3, 4, 5, 10, 11, 16, 17, 22, 23, 28, 4 16 0% Table 3.3-8 29, 30, 31, 32 (NOTE 4) 1, 2, 3, 4, 5, 10, 11, 5 16 16, 17, 22, 23, 28, 5% Table 3.3-8 29, 30, 31, 32 6 4 2, 11, 22, 31 10% Table 3.3-6 1, 2, 4, 5, 10, 16, 7 DFI 12 17, 23, 28, 29, 31, 40% Table 3.3-6 32 1, 2, 3, 4, 5, 10, 11, 16 16, 17, 22, 23, 28, 40% Table 3.3-6 8

29, 30, 31, 32 1, 2, 3, 4, 5, 10, 11, DFI or DFCs - 5%

9 16 16, 17, 22, 23, 28, Table 3.3-8 DFC DFIs - 40%

29, 30, 31, 32 Note 1: Damaged fuel assemblies or fuel debris can be loaded in DFCs while only damaged fuel assemblies that can be handles by normal means can be loaded in DFIs.

Note 2: DFCs/DFIs are allowed for storage in certain basket peripheral locations as defined herein. Basket storage cell numbers are identified in Figure 2.1-1.

Note 3: Heat load penalties are applicable to ONLY those cells where DFCs/DFIs are located and are applied to the allowable undamaged fuel assembly decay heat limit in that storage cell location. The penalties remain the same for all regionalized patterns and discrete loading patterns.

Note 4: Storage cell locations 6, 9, 24, 27 all must remain empty.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-12

Table 2.2-2: Maximum Allowable Decay Heat Loads for MPC-32M (Note 2)

Heat Load Pattern Maximum Total Decay Maximum Quadrant Heat Load (Note 1)

(kW)

Decay heat Load (kW)

Figure 2.2-1 (Discrete 40.0 10.0 Loading Pattern A)

Figure 2.2-2 (Discrete 39.0 9.75 Loading Pattern B)

Regionalized Loading per 41.2 N/A Section 2.2.1 Notes:

1. Figure 2.1-1 identifies cell locations. Table 2.2-4 lists cell locations in each quadrant.

2. Quadrant heat load limits and total heat load limits may need to be adjusted in accordance with Section 2.2.4.

Table 2.2-3: MPC-32M Fuel Storage Regions Number of Storage Cells Storage Cell IDs (Note 1)

MPC Inner Region Outer Region Inner Region Outer Region (n1) (n2) 7, 8, 12 through 15, 18 All other MPC-32M 12 20 through 21, 25 locations and 26 Note:

1. See Figure 2.1-1 for storage cell numbering for MPC-32M.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-13

Table 2.2-4: MPC-32M Fuel Storage Quadrants Quadrant Storage Cell IDs (Note 1) 1 3, 4, 8, 9, 10, 14, 15, 16 20, 21, 22, 26, 27, 28, 31, 2

32 17, 18, 19, 23, 24, 25, 29, 3

30 4 1, 2, 5, 6, 7, 11, 12, 13 Note:

1. See Figure 2.1-1 for storage cell numbering for MPC-32M.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-14

Table 2.2-5: MPC-32 Heat Load Data for UNVENTILATED OVERPACK Number of Regions: 2 Number of Storage Cells: 32 Maximum Total Heat Load (kW): 25 Maximum Section Heat Load (kW): 3.125 Region No. Decay Heat Limit per Number of Cells Decay Heat Limit per (Note 1) Cell, kW (Note 2) per Region Region, kW 1 (Inner) 0.781 12 9.375 2 (Outer) 0.781 20 15.625 Note 1: Figure 2.1-1 identifies the cell locations. The inner region consists of cells 7, 8,12 through 15,18 through 21, 25 and 26. The outer region is maintained by all other cell locations.

Note 2: Heat load limits provided in this table are for reference length fuel assemblies (144 in. active length). Maximum total heat load, maximum quadrant heat load and specific cell heat load limits may need to be adjusted in accordance with Section 2.2.4.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-15

Table 2.2-6: MPC-32M Requirements on Developing Regionalized Heat Load Patterns for UNVENTILATED OVERPACK (see Figure 2.1-1)

1. Total MPC aggregate Heat Load must be equal to 25 kW

2. Maximum Section Heat Load must be equal to 3.125 kW, calculated as defined in Table 2.2-7, and pattern must be 1/8th symmetric

3. Maximum Heat Load per Cell in Region 1 is 0.781 kW

4. Maximum Heat Load per Cell in Region 2 is 1.562 kW

5. Pattern-specific Heat Loads in a storage cell may need to be adjusted to meet items 1 and 2

6. Pattern-specific Heat Load for storage cells may be determined by reducing the allowable heat load in any Region 1 cell in Table 2.2-5 by a certain amount () and adding the same to a single cell or distributed amongst multiple cells in Region 2.

i.e. Any reduction of total allowable heat load in Region 1 must be compensated by an equivalent addition in Region 2.

General Notes -

1. Any assembly with a Heat Load less than the limits defined above can be loaded in the applicable cell, provided it meets all other CoC requirements.

2. DFCs/DFIs are permitted in locations denoted in Table 2.2-8 with the applicable heat load penalties identified therein.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-16

Table 2.2-7: Section Heat Load Calculations for MPC-32M for UNVENTILATED OVERPACK Section Equation for Section Heat Load (Note 1)

Section 1 Q3 + Q4 + Q8 + 1/2Q9 + 1/2Q14 Section 2 Q10 + Q15 + Q16 + 1/2Q9 + 1/2Q14 Section 3 Q21 + Q22 + Q28 + 1/2Q20 + 1/2Q27 Section 4 Q31 + Q32 + Q26 + 1/2Q20 + 1/2Q27 Section 5 Q29 + Q30 + Q25 + 1/2Q19 + 1/2Q24 Section 6 Q17 + Q18 + Q23 + 1/2Q19 + 1/2Q24 Section 7 Q11 + Q12 + Q5 + 1/2Q6 + 1/2Q13 Section 8 Q1 + Q2 + Q7 + 1/2Q6 + 1/2Q13 Notes 1.) QX-Y is the heat load in kW in cell ID (X-Y), identified in Figure 2.1-1 Table 2.2-8: DFC and DFI Storage Locations with Heat Load Penalties for MPC-32M for UNVENTILATED OVERPACK Locations/Storage Cell Heat Load DFC/DFI Min. Soluble MPC Type Numbers Penalty (Note 1) Boron Content (Note 2) (Note 3)

DFI 40% Table 3.3-6 1, 2, 3, 4, 5, 10, 11, 16, DFC 5%

MPC-32M 17, 22, 23, 28, 29, 30, DFCs - 5% Table 3.3-8 DFC or DFI 31, 32 DFIs - 40%

Note 1: Damaged fuel assemblies or fuel debris can be loaded in DFCs while only damaged fuel assemblies that can be handled by normal means can be loaded in DFIs.

Note 2: DFCs/DFIs are allowed for storage in certain basket peripheral locations as defined herein. Basket storage cell numbers are identified in Figure 2.1-1 for the MPC-32M.

Note 3: Heat load penalties are applicable to ONLY those cells where DFCs/DFIs are located and are applied to the allowable undamaged fuel assembly decay heat limit in that storage cell location. The penalties remain the same for all regionalized patterns and discrete loading patterns.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-17

Quadrant Quadrant No.4 No. 1 1 2 3 4 3.000 0.775 0.775 3.000 5 6 7 8 9 10 3.000 0.825 1.025 1.025 0.825 3.000 11 12 13 14 15 16 0.775 1.025 1.400 1.400 1.025 0.775 17 18 19 20 21 22 0.775 1.025 1.400 1.400 1.025 0.775 23 24 25 26 27 28 3.000 0.825 1.025 1.025 0.825 3.000 Quadrant 29 30 31 32 No. 3 3.000 0.775 0.775 3.000 Cell No.

Heat Quadrant Load No. 2 (KW)

Figure 2.2-1: Discrete Pattern A Per Cell Allowable Heat Loads (kW) - MPC-32M

Notes: 1. This figure provides per cell allowable heat loads for MPC-32M with all UNDAMAGED FUEL assemblies.

2. Location of DFCs/ DFIs, applicable cell heat load penalties, and the soluble boron requirements are provided in Table 2.2-1.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-18

Quadrant Quadrant No.4 No. 1 1 2 3 4 3.255 0.745 0.745 3.255 5 6 7 8 9 10 3.255 0.375 0.990 0.990 0.375 3.255 11 12 13 14 15 16 0.745 0.990 1.275 1.275 0.990 0.745 17 18 19 20 21 22 0.745 0.990 1.275 1.275 0.990 0.745 23 24 25 26 27 28 3.255 0.375 0.990 0.990 0.375 3.255 Quadrant 29 30 31 32 No. 3 3.255 0.745 0.745 3.255 Cell No.

Heat Quadrant Load No. 2 (KW)

Figure 2.2-2: Discrete Pattern B Per Cell Allowable Heat Loads (kW) - MPC-32M

Notes: 1. This figure provides per cell allowable heat loads for MPC-32M with all UNDAMAGED FUEL assemblies.

2. Location of DFCs/ DFIs, applicable cell heat load penalties, and the soluble boron requirements are provided in Table 2.2-1.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-19

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 2-20

3 LIMITING CONDITIONS FOR OPERATION (LCOS) AND SURVEILLANCE REQUIREMENTS (SRS) 3.0 Applicability Limiting Conditions 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.

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 an SFSC.

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.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-1

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 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 an SFSC.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-2

3.1 SFSC INTEGRITY 3.1.1 Multi-Purpose Canister (MPC)

LCO 3.1.1 The MPC shall be dry and helium filled.

Tables 3.3-1 and 3.3-2 provide decay heat and burnup limits for forced helium dehydration (FHD) and vacuum drying. FHD is not subject to time limits. Vacuum drying of MPCs may be subject to time limits, from the end of bulk water removal until the start of helium backfill, as shown in Tables 3.3-1 and 3.3-2.

APPLICABILITY: During TRANSPORT OPERATIONS and STORAGE OPERATIONS.

ACTIONS

NOTES---------------------------------------------------------

Separate Condition entry is allowed for each MPC.

COMPLETION CONDITION REQUIRED ACTION TIME A. MPC cavity vacuum A.1 Perform an engineering 7 days drying pressure or evaluation to determine the demoisturizer exit gas quantity of moisture left in the temperature limit not met. MPC.

AND A.2 Develop and initiate corrective 30 days actions necessary to return the MPC to compliance with Tables 3.3-1 and 3.3-2.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-3

ACTIONS (continued)

B. MPC cavity vacuum drying B.1 Backfill the MPC cavity with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months acceptance criteria not helium to a pressure of at least met during allowable time. 0.5 atm.

C. MPC helium backfill limit C.1 Perform an engineering 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months not met. evaluation to determine the impact of helium differential.

AND C.2.1 Develop and initiate 14 days corrective actions necessary to return the MPC to an analyzed condition by adding helium to or removing helium from the MPC.

OR C.2.2 Develop and initiate corrective actions necessary to demonstrate through analysis, using the models and methods from the HI-STORM FSAR, that all limits for cask components and contents will be met.

D. MPC helium leak rate limit D.1 Perform an engineering 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for vent and drain port evaluation to determine the cover plate welds or cover impact of increased helium plate base metal not met. leak rate on heat removal capability and offsite dose.

AND D.2 Develop and initiate 7 days corrective actions necessary to return the MPC to compliance with SR 3.1.1.3.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-4

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

Times not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify that the MPC cavity has been dried in Once, prior to accordance with the applicable limits in Tables TRANSPORT 3.3-1 and 3.3-2, within the specified vacuum drying OPERATIONS time limits as applicable.

SR 3.1.1.2 Verify MPC helium backfill quantity is within the limit Once, prior to specified in Tables 3.3-3 and 3.3-4 for the applicable TRANSPORT MPC model. Re-performance of this surveillance is OPERATIONS not required upon successful completion of Action C.2.2.

SR 3.1.1.3 Verify that the helium leak rate through the MPC vent Once, prior to and drain port cover plates (confinement welds and TRANSPORT the base metal) meets the leaktight criteria of ANSI OPERATIONS N14.5-1997. This surveillance does not need to be performed in the MPC utilizing the REDUNDANT PORT COVER DESIGN.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-5

3.1.2 HI-STORM 100S VERSION E SFSC Heat Removal System LCO 3.1.2 The HI-STORM 100S VERSION E SFSC Heat Removal System shall be operable

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

The SFSC Heat Removal System is operable when 50% or more of the inlet and outlet vent areas are unblocked and available for flow or when air temperature requirements are met. This LCO only applies to the VENTILATED OVERPACKs.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Heat Removal A.1 Remove blockage N/A operable but partially (<

50%) blocked B. SFSC Heat Removal B.1 Restore SFSC Heat Table 3.3-5 System inoperable. Removal System to operable status.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-6

C. Required Action B.1 and C.1 Measure SFSC dose rates Immediately and associated Completion in accordance with the once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Time not met. Radiation Protection thereafter Program.

AND C.2.1 Restore SFSC Heat Table 3.3-5 Removal System to operable status.

OR C.2.2 Transfer the MPC into a Table 3.3-5 TRANSFER CASK.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlet area are free Table 3.3-5 of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature Table 3.3-5 monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is <

142oF (MPC-32M), or < 163oF (MPC-32 Version 1/MPC-68 Version 1), or < 155oF (MPC-24/24E/24EF/32/32F), or < 137oF (MPC-68/68F/68FF) or < 164oF (MPC-68M)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-7

3.1.3 MPC Cavity Reflooding LCO 3.1.3 The MPC cavity pressure shall be:

< 110 psig (MPC-32M/32 Version 1/68 Version 1), or

< 100 psig for (MPC-24/24E/24EF/32/32F/68/68F/68FF/68M)

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

The LCO is only applicable to wet UNLOADING OPERATIONS.

APPLICABILITY: UNLOADING OPERATIONS prior to and during re-flooding.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

COMPLETION CONDITION REQUIRED ACTION TIME A. MPC cavity pressure not A.1 Stop re-flooding operations Immediately within limit.

until MPC cavity pressure is within limit.

AND A.2 Ensure MPC vent port is not Immediately closed or blocked.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-8

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Ensure via analysis or direct measurement that MPC Once, prior to cavity pressure is within limit. MPC re-flooding operations.

AND Once every 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months thereafter when using direct measurement.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-9

3.1.4 Supplemental Cooling System LCO 3.1.4 A supplemental cooling system (SCS) shall be operable

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

Upon reaching steady state operation, the SCS may be temporarily disabled for a short duration

(< 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ) to facilitate necessary operational evolutions, such as movement of the TRANSFER CASK through a door way, or other similar operation.

APPLICABILITY: This LCO is not applicable to the MPC-68M. This LCO is not applicable to the HI-TRAC MS TRANSFER CASK. For all other MPCs and TRANSFER CASKs, this LCO is applicable when the loaded MPC is in the TRANSFER CASK and:

a. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the completion of MPC drying operations in accordance with LCO 3.1.1 or within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of transferring the MPC into the TRANSFER CASK if the MPC is to be unloaded AND

b. The MPC contains one or more fuel assemblies with an average burnup

> 45,000 MWD/MTU AND c1. MPC backfilled to higher helium backfill limits in Appendix B Tables 3.3-3 and 3.3-4 AND any storage cell decay heat load exceeds 90% of maximum allowable storage cell heat load defined in Appendix B, Section 2.2.1 or 2.2.2 and FSAR Section 2.1.9.1 procedures.

OR c2. MPC backfilled to lower helium backfill limits in Appendix B Tables 3.3-3 and 3.3-4 AND any storage cell heat load exceeds 90% of storage cell heat load limits defined in Appendix B Table 2.2-11 or 2.2-12.

OR c3. MPC-32 Version 1/MPC-68 Version 1 where any storage cell heat load exceeds 90% of storage cell heat load limits defined in Section 2.2.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-10

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Supplemental A.1 Restore SFSC Supplemental 7 days Cooling System Cooling System to operable inoperable. status.

B. Required Action A.1 and B.1 Remove all fuel assemblies 30 days associated Completion from the SFSC.

Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify SCS is operable. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-11

3.2 SFSC RADIATION PROTECTION.

3.2.1 TRANSFER CASK Surface Contamination.

LCO 3.2.1 Removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC shall each not exceed:

a. 1000 dpm/100 cm2 from beta and gamma sources

b. 20 dpm/100 cm2 from alpha sources.

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

This LCO is not applicable to the TRANSFER CASK if MPC TRANSFER operations occur inside the FUEL BUILDING.

APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each TRANSFER CASK.

COMPLETION CONDITION REQUIRED ACTION TIME A. TRANSFER CASK or MPC A.1 Restore removable surface 7 days removable surface contamination to within limits.

contamination limits not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify that the removable contamination on the Once, prior to exterior surfaces of the TRANSFER CASK and TRANSPORT accessible portions of the MPC containing fuel is OPERATIONS within limits.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-12

3.3 SFSC CRITICALITY CONTROL 3.3.1 Boron Concentration LCO 3.3.1 The concentration of boron in the water in the MPC shall meet the following limits for the applicable MPC model and the most limiting fuel assembly array/class and classification to be stored in the MPC:

a. MPC-32M: Minimum soluble boron concentration as required by the Tables 3.3-6 through 3.3-8, per configurations in Table 2.2-1.

b. MPC-32/32F and MPC-32 Version 1: Minimum soluble boron concentration as required by Table 3.3-9

c. MPC-24 with one or more fuel assemblies having an initial enrichment greater than the value in Appendix B Table 2.1-2 for no soluble boron credit and < 5.0 wt% 235U: > 400 ppmb

d. MPC-24E or MPC-24EF (all INTACT FUEL ASSEMBLIES) with one or more fuel assemblies having an initial enrichment greater than the value in Appendix B Table 2.1-2 for no soluble boron credit and < 5.0 wt% 235U: > 300 ppmb

e. MPC-24E or MPC-24EF (one or more DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS) with one or more fuel assemblies having an initial enrichment > 4.0 wt% 235U and

< 5.0 wt% 235U: > 600 ppmb APPLICABILITY: During PWR fuel LOADING OPERATIONS with fuel and water in the MPC AND During PWR fuel UNLOADING OPERATIONS with fuel and water in the MPC.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-13

Boron Concentration 3.3.1 COMPLETION CONDITION REQUIRED ACTION TIME A. Boron concentration not A.1 Suspend LOADING Immediately within limit. OPERATIONS or UNLOADING OPERATIONS.

AND A.2 Suspend positive reactivity Immediately additions.

AND A.3 Initiate action to restore Immediately boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY NOTE Once, within 4 This surveillance is only required to be performed if the MPC is hours prior to submerged in water or if water is to be added to, or recirculated through entering the the MPC. Applicability of this LCO.

AND SR 3.3.1.1 Verify boron concentration is within the applicable limit using two independent measurements. Once per 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-14

Table 3.3-1: MPC Cavity Drying Limits for VENTILATED OVERPACK (Note 7)

Method of Moisture Fuel Burnup MPC Heat Load (kW)

Removal (MWD/MTU) (Note 12)

(Notes 1, 2, and 3) 26 (MPC-32 Version 1, MPC-68 VDSNote 5 or FHDNote 6 Version 1) 36.9 (MPC-32 Version 1, MPC-68 VDSNote 8 or FHD All Assemblies < 45,000 Version 1)Note 6 41.2 (MPC-32M)Note 9 VDS or FHD 40 (MPC-32M)Note 10 27 (MPC-32M) VDSNote 4 36.9 (MPC-32 Version 1, MPC-68 One or more assemblies VDSNote 8 or FHD Version 1)Note 6

> 45,000 41.2 (MPC-32M)Note 9 VDSNote 8,11 or FHD 40 (MPC-32M)Note 10 Notes:

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

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

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

4. The maximum allowable decay heat per fuel storage location is 0.843 kW for MPC-32M.

5. Maximum allowable storage cell heat load is 0.812 kW (MPC-32 Version 1) and 0.382 kW (MPC-68 Version 1).

6. Maximum per assembly allowable heat loads under uniform or regionalized storage defined in Appendix B, Section 2.2.1 or 2.2.2.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-15

7. For limits applicable to MPC-24/24E/24EF/32/32F/68/68F/68FF/68M see Appendix B Tables 3.3-1 and 3.3-2.

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

9. Maximum per assembly allowable heat loads defined in Section 2.2.1.

10. Maximum per assembly allowable heat loads defined in Figures 2.2-1 and 2.2-2.

11. Applies when any one storage cell heat load is greater than 0.843kW.

12. For MPC-32M, these heat load limits may need to be modified based on fuel height, in accordance with Section 2.2.4.

Table 3.3-2: MPC-32M Cavity Drying Limits for UNVENTILATED OVERPACK Method of Moisture Fuel Burnup MPC Heat Load (kW) Removal (MWD/MTU)

(Notes 1 and 2)

All burnups 25 (MPC-32M)Note 4 VDS or FHD Notes:

1. VDS means a vacuum drying system. The acceptance criterion when using a VDS is MPC cavity pressure shall be < 3 torr for > 30 minutes.

2. FHD means a forced helium dehydration system. The acceptance criterion when using an FHD system is the gas temperature exiting the demoisturizer shall be

< 21oF for > 30 minutes or the gas dew point exiting the MPC shall be < 22.9oF for > 30 minutes.

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

4. Maximum per assembly allowable heat loads under uniform or regionalized storage defined in Section 2.2.5.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-16

Table 3.3-3: MPC Helium Backfill Limits for VENTILATED OVERPACK (Notes 1 and 3)

MPC MODEL LIMIT MPC-32M (Note 4)

i. Cask Heat Load 41.2 kW 43.0 psig and 46.0 psig Regionalized Loading per Section 2.2.1 ii. Cask Heat Load 40.0 kW Note 2 and 46.8 psig Discrete Loading Patterns per Section 2.2.2 MPC-32 Version 1/ MPC-68 Version 1

i. All allowable heat loads per Section 2.2 49.5 psig and 52.5 psig Notes:

1. Helium used for backfill of MPC shall have a purity of 99.995%.

Pressure range is at a reference temperature of 70oF.

2. Minimum permitted helium backfill is equal to: 43.8(Q/Q)

Where:

Q = aggregate heat load for MPC at time of fuel loading (kW)

Q = allowable maximum heat load for the canister Table 2.2-3 For any scenario where Q/Q 0.9, 0.9 shall be used.

3. For limits applicable to MPC-24/24E/24EF/32/32F/68/68F/68FF/68M see Appendix B Table 3.3-3.

4. These heat load limits may need to be modified based on fuel height, in accordance with Section 2.2.4.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-17

Table 3.3-4: MPC Helium Backfill Limits for UNVENTILATED OVERPACK (Note 1)

MPC MODEL LIMIT MPC-32MNote 2

i. Cask Heat Load 25 kW -

uniformly distributed per Section 2.2.5 0.1218 +/-10% g-moles/l or OR regionalized loading per Section 2.2.5 40.0 psig and 43.0 psig Notes:

1. Helium used for backfill of MPC shall have a purity of 99.995%.

Pressure range is at a reference temperature of 70oF.

2. These heat load limits may need to be modified based on fuel height, in accordance with Section 2.2.4.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-18

Table 3.3-5: Completion Time for Actions to Restore SFSC Heat Removal System Operable (Note 1)

Condition A Condition B Decay Heat Limits per Surveillance MPC Material MPC Type Completion Completion Storage Location Frequency Time Time Alloy X MPC-32 Version 1/

Section 2.2 8 hrs 24 hrs 24 hrs Except MPC-68 Version 1 Duplex Note3 MPC-32 Version 1/

Alloy X Section 2.2 8 hrs 16 hrs 16 hrs MPC-68 Version 1 MPC-32 Version 1 0.5 kW MPC-68 Version 1 0.264 kW 24 hrs 64 hrs 30 days Alloy X MPC-32M 0.75 kWNote 2 SectionNote 2 2.2.1 Alloy X Except MPC-32M OR 8 hrs 24 hrs 24 hrs Duplex Note 3 Note 2 Section 2.2.2 SectionNote 2 2.2.1 Alloy X MPC-32M OR 8 hrs 24 hrs 24 hrs SectionNote 2 2.2.2 Notes:

1. For limits applicable to MPC-24/24E/24EF/32/32F/68/68F/68FF/68M see Appendix B Table 3.3-5.

2. For MPC-32M, heat load limits may need to be modified based on fuel height, in accordance with Section 2.2.4.

3. If any component of the MPC is made of duplex, these completion times are not applicable.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-19

Table 3.3-6: MPC-32M with up to Sixteen DFIs Soluble Boron Requirements (Note 1)

All UNDAMAGED FUEL ASSEMBLIES OR Thirteen to Sixteen DAMAGED FUEL ASSEMBLIES using DFIs Up to Twelve DAMAGED FUEL Array/Class ASSEMBLIES using DFI Maximum Initial Maximum Initial Maximum Initial Maximum Initial Enrichment Enrichment 5.0 Enrichment Enrichment 4.0 wt% 235U wt% 235U 4.0 wt% 235U 5.0 wt% 235U (ppmb) (ppmb) (ppmb) (ppmb) 14x14A/B/C/D, 1000 1500 1100 1600 16x16A/B/C 15x15A/B/C/D/E/ 1500 2100 1600 2200 F/G/H/I, 17x17A/B/C Notes: 1. For maximum initial enrichments between 4.0 wt% and 5.0 wt% 235U, the minimum soluble boron concentration may be determined by linear interpolation between the minimum soluble boron concentrations at 4.0 wt% and 5.0 wt%.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-20

Table 3.3-7: MPC-32M with up to Twelve DFCs Soluble Boron Requirements (Note 1)

All UNDAMAGED FUEL ASSEMBLIES Nine to Twelve DAMAGED FUEL OR ASSEMBLIES or FUEL DEBRIS Up to Eight DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS Maximum Initial Maximum Initial Maximum Initial Maximum Initial Enrichment Enrichment 5.0 Enrichment Enrichment 4.0 wt% 235U wt% 235U 4.0 wt% 235U 5.0 wt% 235U (ppmb) (ppmb) (ppmb) (ppmb) 14x14A/B/C/D, 1000 1500 1100 1600 16x16A/B/C 15x15A/B/C/D/E/ 1500 2100 1500 2200 F/G/H/I, 17x17A/B/C Notes: 1. For maximum initial enrichments between 4.0 wt% and 5.0 wt% 235U, the minimum soluble boron concentration may be determined by linear interpolation between the minimum soluble boron concentrations at 4.0 wt% and 5.0 wt%.

Table 3.3-8: MPC-32M with Thirteen to Sixteen DFCs/DFIs Soluble Boron Requirements (Note 1)

Thirteen to Sixteen DAMAGED Up to Sixteen DAMAGED FUEL FUEL ASSEMBLIES or FUEL ASSEMBLIES or FUEL DEBRIS DEBRIS and Empty Cell Locations Note 2 Maximum Initial Maximum Initial Maximum Initial Maximum Initial Enrichment Enrichment 5.0 Enrichment Enrichment 4.0 wt% 235U wt% 235U 4.0 wt% 235U 5.0 wt% 235U (ppmb) (ppmb) (ppmb) (ppmb) 14x14A/B/C/D, 1300 1700 1000 1500 16x16A/B/C 15x15A/B/C/D/E/ 1700 2300 1500 2100 F/G/H/I, 17x17A/B/C Notes: 1. For maximum initial enrichments between 4.0 wt% and 5.0 wt% 235U, the minimum soluble boron concentration may be determined by linear interpolation between the minimum soluble boron concentrations at 4.0 wt% and 5.0 wt%.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-21

2. Cell locations 6, 9, 24 and 27 in Figure 2.1-1 MUST ALL remain empty.

Table 3.3-9: MPC-32/32F and Version 1 Soluble Boron Requirements (Notes 1 and 2)

All UNDAMAGED FUEL One or more DAMAGED FUEL ASSEMBLIES ASSEMBLIES or FUEL DEBRISNote2 Array/Class Maximum Initial Maximum Initial Maximum Initial Maximum Initial Enrichment Enrichment 5.0 Enrichment Enrichment 4.1 wt% 235U wt% 235U 4.1 wt% 235U 5.0 wt% 235U (ppmb) (ppmb) (ppmb) (ppmb) 14x14A/B/C/D/E 1,300 1,900 1,500 2,300 15x15A/B/C/G/I 1,800 2,500 1,900 2,700 15x15D/E/F/H 1,900 2,600 2,100 2,900 16x16A/B/C 1,400 2,000 1,500 2,300 17x17A 1,600 2,200 1,800 2,600 17x17B/C 1,900 2,600 2,100 2,900 Notes: 1. For maximum initial enrichments between 4.1 wt% and 5.0 wt% 235U, the minimum soluble boron concentration may be determined by linear interpolation between the minimum soluble boron concentrations at 4.1 wt% and 5.0 wt%.

2. In locations allowed in Appendix B Table 2.1-1.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 3-22

4 ADMINISTRATIVE CONTROLS 4.1 Radioactive Effluent Control Program for HI-STORM 100S Version E

4.1.1 The HI-STORM 100 Version E Cask 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.

4.1.2 This program includes an environmental monitoring program. Each general license user may incorporate SFSC operations into their environmental monitoring programs for 10 CFR Part 50 operations.

4.2 Cask Transport Evaluation Program For lifting of the loaded MPC, TRANSFER CASK, or OVERPACK using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.

This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by equipment providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...).

The TRANSFER CASK or OVERPACK, when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and MPC TRANSFER, provided the lifting equipment is designed in accordance with items a, b, and c below.

4.2.1 Overpacks and the Transfer Cask 4.2.1.1 The metal body and any vertical columns of the lifting equipment shall be designed to comply with stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. All vertical compression loaded primary members shall satisfy the buckling criteria of ASME Section III, Subsection NF.

4.2.1.2 The horizontal cross beam and any lifting attachments used to connect the load to the lifting equipment shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with applicable sections and guidance of NUREG-0612, Section 5.1. This includes applicable stress limits from ANSI N14.6.

4.2.1.3 The lifting equipment shall have redundant drop protection features which prevent uncontrolled lowering of the load.

4.2.1.4 For existing handling equipment which does not meet the above criteria, a cask drop analysis may be performed utilizing the site conditions and will be addressed as part of the 10 CFR72.212 report.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-1

4.3 Radiation Protection Program 4.3.1.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded OVERPACK or TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

4.3.1.2 Based on the analysis performed pursuant to 10 CFR 72.212(b)(5)(iii), the licensee shall establish individual cask surface dose rate limits for the HI-TRAC TRANSFER CASK and the HI-STORM OVERPACK to be used at the site. Total (neutron plus gamma) dose rate limits shall be established at the following locations:

a. The top of the OVERPACK.

b. The side of the TRANSFER CASK and OVERPACK

c. The inlet and outlet ducts on the OVERPACK (applicable only for VENTILATED OVERPACKs)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-2

4.3.1.3 Notwithstanding the limits established in Section 4.3.1.2, the measured dose rates on a loaded OVERPACK shall not exceed the following values:

a. 20 mrem/hr (gamma + neutron) on the top of the OVERPACK

b. 200 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts

c. 4000 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 4.3.1.4 The licensee shall measure the TRANSFER CASK and OVERPACK surface neutron and gamma dose rates as described in Section 4.3.1.7 for comparison against the limits established in Section 4.3.1.2 or Section 4.3.1.3, whichever are lower.

4.3.1.5 If the measured surface dose rates exceed the lower of the two limits established in Section 4.3.1.2 or Section 4.3.1.3, the licensee shall:

a. Administratively verify that the correct contents were loaded in the correct fuel storage cell locations.

b. Perform a written evaluation to verify whether an OVERPACK at the ISFSI containing the as-loaded MPC will cause the dose limits of 10 CFR 72.104 to be exceeded.

c. Perform a written evaluation within 30 days to determine why the surface dose rate limits were exceeded.

4.3.1.6 If the evaluation performed pursuant to Section 4.3.1.5 shows that the dose limits of 10 CFR 72.104 will be exceeded, the MPC shall not be placed into storage or, in the case of the OVERPACK loaded at the ISFSI, the MPC shall be removed from storage until appropriate corrective action is taken to ensure the dose limits are not exceeded.

4.3.1.7 TRANSFER CASK and OVERPACK surface dose rates shall be measured at approximately the following locations:

a. A minimum of four (4) dose rate measurements shall be taken on the side of the TRANSFER CASK approximately at the cask mid-height plane. The measurement locations shall be approximately 90 degrees apart around the circumference of the cask. Dose rates shall be measured between the radial ribs.

b. A minimum of twelve (12) dose rate measurements shall be taken on the side of the OVERPACK in three sets of four measurements. One measurement set shall be taken approximately at the cask mid-height plane, 90 degrees apart around the circumference of the cask. The second and third measurement sets shall be taken approximately 60 inches above and below the mid-height plane, respectively, also 90 degrees apart around the circumference of the cask.

c. A minimum of five (5) dose rate measurements shall be taken on the top of the OVERPACK. One dose rate measurement shall be taken at approximately the center of the lid and four measurements shall be taken at locations on the top concrete shield, approximately half way between the center and the edge of the top concrete shield, approximately 90 degrees apart around the circumference of the lid.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-3

d. A dose rate measurement shall be taken on contact at the surface of each inlet and four (4) locations approximately 90 degrees apart around the circumference of the outlet vent of the OVERPACK (applicable only for VENTILATED OVERPACKs).

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-4

4.4 Violations of Fuel Specifications or Loading Conditions 4.4.1 Actions If any Fuel Specifications or Loading Conditions of 2.1 are violated, the following actions shall be completed:

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

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

4.4.1.3 Within 30 days, submit a special report which describes the cause of the violation, and actions taken to restore compliance and prevent recurrence.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-5

4.5 Aging Management Program Each general licensee shall have a program to establish, implement, and maintain written procedures for each AMP described in the FSAR. The program shall include provisions for changing AMP elements, as necessary, and within the limitations of the approved licensing bases to address new information on aging effects based on inspection findings and/or industry operating experience provided to the general licensee during the renewal period.

The general licensee shall establish and implement these written procedures within 365 days after the effective date of the renewal of the CoC or 365 days of the 20th anniversary of the loading of the first dry storage system at its site, whichever is later.

Each general licensee shall perform tollgate assessments as described in Chapter 9 of the FSAR.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-6

4.6 Combustible Gas Monitoring During MPC Lid Welding and Cutting During MPC lid-to-shell welding and cutting operations, combustible gas monitoring of the space under the MPC lid is required, to ensure that there is no combustible mixture present.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix D 4-7

ML22028A377

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