ML22331A010

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Attachment 7 - HI-2177597, HI-STORE CTF Thermal Evaluation
ML22331A010
Person / Time
Site: HI-STORE
Issue date: 08/13/2021
From: Varma N
Holtec
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML22331A002 List:
References
5025076 HI-2177597
Download: ML22331A010 (1)


Text

Attachment 7 to Holtec Letter 5025076 Nuclear Power Division 5025 Sponsoring Company Project No.

HI-2177597 2 13 Aug 2021 Company Record Number Revision No. Issue Date Report Non-Proprietary Record Type Proprietary Classification Nuclear No Quality Class Export Control Applicability Record

Title:

HI-STORE CTF THERMAL EVALUATION Prepared by: Reviewed by: Approved by:

N.Varma, 13 Aug 2021 A.Mohammad, 13 Aug 2021 D.Mitra-Majumdar, 13 Aug 2021 Signature histories are provided here for reference only. Company electronic signature records are traceable via the provided Verification QR Code and are available for review within the secure records management system. A valid Verification QR Code and the presence of this covering page indicates this record has been approved and accepted.

Proprietary Classification This is a non-proprietary version of a proprietary report.

Export Control Status Not applicable.

Page 1 of 25

Attachment 7 to Holtec Letter 5025076 PREFACE This section contains quality related information on this document in conformance with the provisions in Holtecs Quality Assurance program docketed with the USNRC (Docket # 71-0784).

This document is classified as Safety Significant under Holtec Internationals quality assurance system. In order to gain acceptance as a safety significant document in the companys quality assurance system, this document is required to undergo a prescribed review and concurrence process that requires the preparer and reviewer(s) of the document to answer a long list of questions crafted to ensure that the document is purged of all errors of any material significance. A record of the review and verification activities is maintained in electronic form within the companys network to enable future retrieval and recapitulation of the programmatic acceptance process leading to the acceptance and release of this document under the companys QA system. Among the numerous requirements that this document must fulfill, as applicable, to muster approval within the companys QA program are:

  • The preparer(s) and reviewer(s) are technically qualified to perform their activities per the applicable Holtec Quality Procedure (HQP).
  • The input information utilized in the work effort is drawn from referenceable sources.

Any assumed input data is so identified.

  • Significant assumptions are stated or provided by reference to another source.
  • The analysis methodology is suitable for the physics of the problem.
  • Any computer code and its specific versions used in the work are formally admitted for use within the companys QA system.
  • The content of the document is in accordance with the applicable Holtec quality procedure.
  • The material content of the calculation package is understandable to a reader with the requisite academic training and experience in the underlying technical disciplines.

Once a safety significant document, such as this calculation package, completes its review and certification cycle, it should be free of any materially significant error and should not require a revision unless its scope of treatment needs to be altered. Except for regulatory interface documents (i.e., those that are submitted to the regulator in support of a license amendment and request), editorial revisions to Holtec safety significant documents are not made unless such editorial changes are deemed necessary by the Holtec Project Manager to prevent erroneous conclusions from being inferred by the reader. In other words, the focus in the preparation of this Report HI-2177597 i Project 5025 Page 2 of 25

Attachment 7 to Holtec Letter 5025076 document is to ensure correctness of the technical content rather than the cosmetics of presentation.

Furthermore, this Calculation Package is focused on providing technical results that demonstrate compliance with the applicable safety limits. Informational material that does not bear upon reaching a safety conclusion is minimized in this document to the extent possible. Because of its function as a repository of all analyses performed on the subject of its scope, this document will require a revision only if an error is discovered in the computations or the equipment design is modified. Additional analyses in the future may be added as numbered supplements to this Package. Each time a supplement is added or the existing material is revised, the revision status of this Package is advanced to the next number and the Table of Contents is amended.

Calculation Packages are Holtec proprietary documents. They are shared with a client only under strict controls on their use and dissemination. This Calculation Package will be saved as a Permanent Record under the companys QA System.

Generic Reports Holtec International maintains a number of so-called generic reports which provide the methodology, computer models and associated modeling assumptions for a specific physical problem. The technical content of a generic report is fully aligned with the System FSAR, Reg.

Guides, NUREGs, etc., as applicable. In other words, the generic report contains Holtecs standardized analysis approach, method and model to analyze a technical problem. Developed under Holtecs self-funded R&D program, the generic reports are treated as vital intellectual property of the Company and are accordingly prohibited from dissemination to any external entity. The generic reports are subject to inspection by the NRCs staff at Holtecs corporate headquarters during NRCs triennial inspection of Holtec. The Calculation Package can invoke a Generic Report in whole or in part (see table below) to improve conciseness and to enable it to be submitted un-redacted to the Companys clients.

Holtec Approved Computer Program List (ACPL)

Holtec International maintains an active list of QA validated computer codes on the Companys network that are approved for use in Safety significant projects. The table below identifies the Codes and applicable versions (listed in the ACPL) that have been used in this work effort.

Generic Report & ACPL Information Generic Report # invoked in this Calc Package, HI-2167374 if applicable Code(s) name(s) (must be listed in the ACPL) FLUENT Code(s) version # (must be approved in the 14.5.7 ACPL)

[PROPRIETARY INFORMATION [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390] WITHHELD PER 10CFR2.390]

Report HI-2177597 ii Project 5025 Page 3 of 25

Attachment 7 to Holtec Letter 5025076

[PROPRIETARY INFORMATION [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390] WITHHELD PER 10CFR2.390]

Quality Validation Questionnaire The questionnaire below is a distilled version of the vast number of questions that the preparer and reviewer of a Holtec safety-significant report must answer and archive in the Companys network to gain a VIR number (the identifier of QA pedigree in Holtecs electronic configuration control system).

An affirmative answer (unless the question is not applicable or NA) to each of the following questions by the preparer of the report (or editor of a multi-author document) is an essential condition for this document to merit receiving a QA validated status.

Response

Criterion Yes or No Are you qualified per HQP 1.0 to perform the analysis 1 Yes documented in this report?

Are you aware that you must be specifically certified if you 2 use any Category A computer code (as defined in HQP 2.8 in Yes the preparation of this document?

Are you fully conversant with the pertinent sections of the 3 Yes applicable Specification invoked in this report?

Is the input data used in this work fully sourced (i.e.,

4 Yes references are provided)?

Are you fully conversant with the user manual and validation 5 Yes manual of the code(s) used in this report, if any?

Is (Are) Category A computer code(s) (if used) listed in the 6 Yes Companys Approved Computer program list?

Are the results clearly set down and do they meet the 7 Yes acceptance criteria set down in the governing Specification?

Are you aware that you must observe all internal requirements on needed margins of safety published in Holtecs internal 8 Yes memos, if applicable (which may exceed those in the reference codes and standards or the specification)?

Have you performed numerical convergence checks to ensure 9 Yes that the solution is fully converged?

Is it true that you did not receive more than 10 quality 10 Yes infraction points in the past calendar year or thus far this year?

Report HI-2177597 iii Project 5025 Page 4 of 25

Attachment 7 to Holtec Letter 5025076 TABLE OF CONTENTS 1.0 PURPOSE AND SCOPE ..................................................................................................... 1 2.0 METHODOLOGY AND ASSUMPTIONS ........................................................................ 2 3.0 INPUT DATA ...................................................................................................................... 5 4.0 ACCEPTANCE CRITERIA ................................................................................................ 7 5.0 COMPUTER CODES AND FILES .................................................................................... 8 6.0 RESULTS AND DISCUSSIONS ........................................................................................ 9

7.0 REFERENCES

.................................................................................................................. 17 Summary of Revisions Revision 0: Original Issue Revision 1: Report is revised to provide additional information per regulator comments. All changes are marked by revision bars on the right margin.

Revision 2: Report is revised to address USNRCs 2nd round of RAIs. Specifically:

- Hypothetical CTB collapse event is removed as the event is deemed non-credible.

- Radial differential thermal expansion between HI-STAR 190 cask and CTF structure is computed.

All changes are marked by revision bars on the right.

Report HI-2177597 iv Project 5025 Page 5 of 25

Attachment 7 to Holtec Letter 5025076 1.0 PURPOSE AND SCOPE At New Mexico consolidated interim storage facility, the loaded MPCs are transferred from HI-STAR 190 [1] to HI-TRAC CS [2] using Canister Transfer Facility (CTF) [3]. This report documents evaluations to demonstrate compliance of all short-term operations involving HI-STAR 190 to the thermal requirements in Chapter 4 of HI-STORE SAR [4].

Before the HI-STAR 190 cask is placed into the CTF, the impact limiters are removed and the cask cavity is evacuated and backfilled with nitrogen. After the HI-STAR 190 cask is placed into the CTF, the HI-TRAC CS alignment plate is installed on top of the CTF. A thermal evaluation is performed for the thermally limiting short-term operation condition of HI-STAR 190 inside the CTF as described below:

(1) HI-STAR 190 with MPC is placed inside the CTF. The HI-TRAC CS alignment plate is installed on the CTF.

(2) The HI-STAR 190 cask closure lid is in place. The HI-TRAC CS cask is not placed in the stack-up position above the CTF.

(3) The cask cavity is filled with nitrogen.

The closure lid of the HI-STAR 190 cask is then removed. The HI-TRAC CS cask is placed on the alignment plate with its bottom shield gates open. After the MPC is lifted into the HI-TRAC CS cask, the HI-TRAC CS shield gates are closed and the MPC is rested on the shield gates.

The HI-TRAC CS cask is then lifted and placed at a location on the floor that is accessible to the VCT.

After the closure lid is removed, the HI-STAR 190 cask cavity is filled with air. The thermal conductivity of nitrogen is slightly lower than that of air. Therefore, the thermal performance of the HI-STAR 190 cask after its closure lid is removed and before the MPC is lifted into the HI-TRAC CS cask is bounded by that under the short-term operation condition described above.

Once the MPC is lifted into the HI-TRAC CS cask, the thermal performance is bounded by those evaluated in Ref. [7].

Report HI-2177597 1 Project 5025 Page 6 of 25

Attachment 7 to Holtec Letter 5025076 2.0 METHODOLOGY AND ASSUMPTIONS To accommodate all BWR and all PWR canisters, the HI-STAR 190 cask is available in two discrete lengths: Version SL (standard length) and Version XL (extended length) [1]. The HI-STAR 190 Version XL has a larger external surface for heat dissipation than that of HI-STAR 190 Version SL, and thus the thermal performance of HI-STAR 190 Version XL is bounded by that of HI-STAR 190 Version SL. According to Ref. [8], the bounding configuration of MPC in vertical orientation is MPC-37 loaded with [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]. Therefore, the HI-STAR 190 Version SL containing MPC-37 loaded with

[PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]is adopted to yield bounding results. It bounds the configurations below.

(1) Short fuel in MPC-37 within HI-STAR 190 Version SL (2) Standard fuel in MPC-37 within HI-STAR 190 Version SL (3) Long fuel in MPC-37 within HI-STAR 190 Version XL (4) MPC-89 within HI-STAR 190 Version SL In Appendix F of Ref. [9], HI-STAR 190 Version SL in an open space (without the CTF) containing MPC-37 loaded [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390] is evaluated. This model is the same as that provided in Section 3.3 of HI-STAR 190 SAR [5]. The 3D quarter-symmetric model of HI-STAR 190 in Appendix F of Ref. [9] is adopted and modified as follows:

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

Report HI-2177597 2 Project 5025 Page 7 of 25

Attachment 7 to Holtec Letter 5025076

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

The HI-STAR 190 Version SL is placed on a pedestal inside CTF [3]. The 3D quarter-symmetric model of HI-STAR 190 Version SL inside CTF is illustrated in Figure 2.1 and a 2D cross-section of the CTF cavity is presented in Figure 2.2. The CTF geometry added to the HI-STAR 190 model includes [

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

Report HI-2177597 3 Project 5025 Page 8 of 25

Attachment 7 to Holtec Letter 5025076

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

Following Ref. [8], the thermal evaluations are performed for the bounding heat load pattern, i.e.

heat load pattern 1 presented in Table 1.1 of Ref. [8]. The MPC is initially backfilled with helium in the pressure range specified in Table 1.3 of Ref. [8]. Inside the CTF, the MPC cavity pressure increases with the MPC cavity temperature. Using the minimum backfill pressure specified in Table 1.3 of Ref. [8] and the MPC cavity average temperature predicted in Section 6.0, the minimum MPC cavity pressure under the operation conditions is computed by ideal gas law. The MPC cavity pressure adopted in the simulations is slightly lower than the calculated minimum MPC cavity pressure, which understates the thermo-siphon effect inside the MPC cavity and thereby overestimates the peak cladding temperature.

Report HI-2177597 4 Project 5025 Page 9 of 25

Attachment 7 to Holtec Letter 5025076 3.0 INPUT DATA The principal geometric parameters for HI-STAR 190, CTF, MPC-37 and basket are taken from design drawings [1], [3], [12] and [13]. Materials present in the HI-STAR 190 cask include

((PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]. The physical properties of these materials are obtained from HI-STAR 190 SAR [5]. The properties of air are also obtained from HI-STAR 190 SAR [5]. The properties of nitrogen are obtained from Ref.

[14] and presented in Table 3.1.

The surface emissivities are obtained from HI-STAR 190 SAR [5]. For the HI-STAR 190 cask cavity surface, the emissivity of carbon steel without paint is assumed for conservatism.

[

[PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]

]

The CTF is inside the cask transfer building and thus there is no insolation. The ambient temperature adopted in the evaluations is 32.8oC (91oF), as specified in HI-STORE SAR [4]. The ambient pressure adopted in the evaluations is [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390], which is conservatively lower than the actual ambient pressure at the site elevation specified in HI-STORE SAR [4]. The limiting heat load pattern and the corresponding MPC backfill pressure range as descried in Section 2.0 are adopted to yield bounding results.

Report HI-2177597 5 Project 5025 Page 10 of 25

Attachment 7 to Holtec Letter 5025076 Table 3.1 Properties of Nitrogen [14]

Thermal Viscosity Temperature Conductivity 10-6 N-s/m

°C (°F) W/m-°C (Micropoise)

(Btu/ft-hr-oF) 76.85 0.0293 20.00 (170.33) (0.0169) (200.0) 126.85 0.0327 22.04 (260.33) (0.0189) (220.4) 226.85 0.0389 25.77 (440.33) (0.0225) (257.7) 326.85 0.0446 29.08 (620.33) (0.0258) (290.8)

Density (Ideal Gas Law) kg/m3 (lbm/ft3)

Specific Heat 1041 (0.249)

J/kg-oC (Btu/lbm-°F)

Report HI-2177597 6 Project 5025 Page 11 of 25

Attachment 7 to Holtec Letter 5025076 4.0 ACCEPTANCE CRITERIA The thermal evaluation acceptance criteria are listed below:

1. The fuel cladding temperature during short-term operations must be below the ISG-11 Revision 3 temperature limit [6].
2. The component temperatures of basket, MPC and HI-STAR 190 must be below their respective design temperature limits specified in Ref. [4] for short-term operations.
3. The MPC cavity pressure (MNOP) must be below the design pressure specified in Ref.

[4] for short-term operations.

4. The CTF component temperatures must be below the design temperature limits specified in Ref. [4] for short-term operations.

Report HI-2177597 7 Project 5025 Page 12 of 25

Attachment 7 to Holtec Letter 5025076 5.0 COMPUTER CODES AND FILES The computer code FLUENT Version 14.5 [11] is employed in all thermal calculations involving fluid motion. A list of computer files is provided below.

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

Report HI-2177597 8 Project 5025 Page 13 of 25

Attachment 7 to Holtec Letter 5025076 6.0 RESULTS AND DISCUSSIONS 6.1 Thermal Evaluation of Short-Term Operation A steady state simulation is performed for the short-term operation scenario described in Section 1.0. Simulation is continued until peak cladding temperature and numerical residuals are stabilized and convergence is verified by ensuring that the MPC heat balance and mass balance through the domain is close to 100%. The scaled residuals are shown in Figure 6.1. The evaluation is performed for most limiting thermal configuration under the bounding heat load pattern, as described in Section 2.0. The predicted fuel temperature and component temperatures are presented in Table 6.1. The fuel temperature and component temperatures are below their limits specified in Section 4.0 for short-term operation.

6.2 (Deleted) 6.3 Maximum Normal Operation Pressure (MNOP)

For heat load pattern 1 presented in Table 1.1 of Ref. [8], the MPC is initially backfilled with helium in the pressure range specified in Table 1.3 of Ref. [8]. Inside CTF, the MPC cavity pressure increases as the MPC cavity temperature increases. Using the maximum backfill pressure specified in Table 1.3 of Ref. [8] and the MPC cavity average temperatures predicted in Sections 6.1 and 6.2, the maximum MPC cavity pressures are determined by ideal gas law and presented in Table 6.3.

6.4 Differential Thermal Expansion In this section, thermal expansion of components inside HI-STAR 190 in the radial and axial directions is computed. The calculations address the following thermal expansions:

a) Basket-to-MPC Radial Growth b) Basket-to-MPC Axial Growth c) Fuel-to-MPC Axial Growth d) MPC-to-Cask Radial Growth e) MPC-to-Cask Axial Growth (a) Basket-to-MPC Radial Growth The radial growth of the fuel basket relative to MPC cavity upon heating from a 21oC (70oF) reference temperature (To) to hot operation temperatures is computed as follows:

Report HI-2177597 9 Project 5025 Page 14 of 25

Attachment 7 to Holtec Letter 5025076

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

(b) Basket-to-MPC Axial Growth The axial growth of the fuel basket relative to MPC cavity upon heating from a 21oC (70oF) reference temperature to hot operation temperatures is computed as follows:

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

(c) Fuel Axial Growth The axial growth of the fuel relative to MPC cavity upon heating from a 21oC (70oF) reference temperature to hot operation temperatures is computed as follows:

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

Report HI-2177597 10 Project 5025 Page 15 of 25

Attachment 7 to Holtec Letter 5025076

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

(d) MPC-to-Cask Radial Growth The radial growth of MPC relative to HI-STAR 190 cask cavity upon heating from a 21oC (70oF) reference temperature to hot operation temperatures is computed as follows:

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

(e) MPC-to-Cask Axial Growth The axial growth of MPC relative to HI-STAR 190 cask cavity upon heating from a 21oC (70oF) reference temperature to hot operation temperatures is computed as follows:

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

Report HI-2177597 11 Project 5025 Page 16 of 25

Attachment 7 to Holtec Letter 5025076 (f) Cask-to-CTF Pedestal Radial Growth The smallest clearance between the HI-STAR cask and the CTF occurs near the bottom of the cask where the cask bottom forging is in the proximity of CTF pedestal shims. The radial growth of HI-STAR 190 cask with respect to the CTF pedestal shims upon heating from 21oC (70oF) reference temperature to hot operating temperatures is computed as follows:

[

PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390

]

6.5 Discussion and Conclusion Based on the results presented in Sections 6.1 thru 6.4, the following conclusions are drawn:

1. During short-term operation inside CTF, the fuel cladding temperature and the MPC and cask component temperatures remain below their short-term temperature limits indefinitely. The MPC cavity pressure also remains below its short-term pressure limit.

Thermal evaluations in Section 3.3.5 of HI-STAR 190 SAR [5] demonstrate that the predicted temperatures and cavity pressures under sub-design basis heat loads is bounded by design maximum heat load scenario. Therefore, the above conclusions remain applicable to sub-design basis heat loads also.

Report HI-2177597 12 Project 5025 Page 17 of 25

Attachment 7 to Holtec Letter 5025076 Table 6.1 Maximum Temperatures of HI-STAR 190 and MPC-37 during Short-Term Operation inside CTF Temperature Material/Components oC (°F)

Fuel Cladding 380 (716)

Fuel Basket 353 (667)

Basket Shims 292 (558)

MPC Shell 262 (504)

MPC Baseplate (Section Average) 202 (396)

MPC Lid (Section Average) 257 (495)

Containment Shell 196 (385)

Lead Shield 194 (381)

Intermediate Shell 192 (378)

Holtite-B Shield 191 (376)

Enclosure Shell 169 (336)

Bottom Forging (Maximum) 199 (390)

Bottom Forging (Volumetric Average) 160 (320)

Bottom Forging Lead Shield 197 (387)

Bottom Forging Holtite-B Shield 157 (315)

Bottom Forging Cover Plate 154 (309)

Bottom Holtite-B Shield 196 (385)

Top Forging (Maximum) 144 (291)

Top Forging (Volumetric Average) 129 (264)

Top Forging Holtite-B Shield 142 (288)

Spacer Ring 208 (406)

Closure Lid Spacer 148 (298)

Closure Lid (Maximum) 128 (262)

Closure Lid (Section Average) 122 (252)

CTF Structures 147 (297)

Report HI-2177597 13 Project 5025 Page 18 of 25

Attachment 7 to Holtec Letter 5025076 Table 6.2 (Removed)

Report HI-2177597 14 Project 5025 Page 19 of 25

Attachment 7 to Holtec Letter 5025076 Table 6.3 MNOP of Helium in MPC and HI-STAR 190 inside CTF Cavity Average Gauge Pressure Condition Temperature kPa (psig) oC (oF)

Short-term Operation 705.3 (102.3) 294 (561)

Report HI-2177597 15 Project 5025 Page 20 of 25

Attachment 7 to Holtec Letter 5025076 Table 6.4

[PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]

Report HI-2177597 16 Project 5025 Page 21 of 25

Attachment 7 to Holtec Letter 5025076

7.0 REFERENCES

[1] HI-STAR 190 Cask Assembly, Holtec Drawing 9841, Revision 0.

[2] HI-TRAC CS, Holtec Drawing 10868, Revision 0.

[3] Canister Transfer Facility (CTF), Holtec Drawing 10895, Revision 1.

[4] Licensing Report on the HI-STORE CIS Facility, Holtec Report HI-2167374, Revision 0.

[5] Safety Analysis Report on the HI-STAR 190 Package, Holtec Report HI-2146214, Latest Revision.

[6] Cladding considerations for the Transportation and Storage of Spent Fuel, Interim Staff Guidance-11, Revision 3, USNRC, Washington, DC

[7] Thermal Analysis for HI-TRAC CS Transfer Cask, Holtec Report HI-2177553, Revision 0.

[8] Thermal Evaluations of HI-STORM UMAX at HI-STORE CIS Facility, Holtec Report HI-2177591, Revision 0.

[9] Thermal Evaluations of HI-STAR 190 System, Holtec Report HI-2146286, Revision 3.

[10] Flow of Fluids through Valves, Fittings, and Pipe, Crane Co., 1988.

[11] FLUENT Computational Fluid Dynamics Software, ANSYS Inc.

[12] MPC 37 Enclosure Vessel, Holtec Drawing 6505, Revision 17.

[13] Assembly, MPC 37 Fuel Basket, Holtec Drawing 6506, Revision 12.

[14] F. P. Incropera and D. P. DeWitt, Fundamentals of Heat and Mass Transfer, 4th edition, John Wiley & Sons, New York, 1996

[15] Final Safety Analysis Report on the HI-STORM FW MPC Storage System, Holtec Report HI-2114830, Latest Revision.

[16] Final Safety Analysis Report on the HI-STORM UMAX Canister Storage System, Holtec Report HI-2115090, Latest Revision.

[17] Effective Thermal Properties of PWR Fuel to Support Thermal Evaluation of HI-STORM FW, Holtec Report HI-2094356, Revision 5.

Report HI-2177597 17 Project 5025 Page 22 of 25

Attachment 7 to Holtec Letter 5025076 Figure 2.1: [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]

Report HI-2177597 18 Project 5025 Page 23 of 25

Attachment 7 to Holtec Letter 5025076 Figure 2.2: [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]

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Attachment 7 to Holtec Letter 5025076 Figure 6.1. [PROPRIETARY INFORMATION WITHHELD PER 10CFR2.390]

Report HI-2177597 20 Project 5025 Page 25 of 25