Text

Attachment 2: HI-STORM Umax Amendment 3 CoC
	ML23062A665
Person / Time
Site:	HI-STORM 100
Issue date:	03/03/2023
From:	; Holtec
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML23062A662	List: ML23062A663; ML23062A665; ML23062A668;
References
	5021069
	Download: ML23062A665 (1)
	v • d • e

Attachment 2 to Holtec Letter 5021069 U.S. NUCLEAR REGULATORY COMMISSION NRC FORM 651 (10-2004) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Page 1 of 5 The U.S. Nuclear Regulatory Commission is issuing this Certificate of Compliance pursuant to Title 10 of the Code of Federal Regulations, Part 72, "Licensing Requirements for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste" (10 CFR Part 72). This certificate is issued in accordance with 10 CFR 72.238, certifying that the storage design and contents described below meet the applicable safety standards set forth in 10 CFR Part 72, Subpart L, and on the basis of the Final Safety Analysis Report (FSAR) of the cask design. This certificate is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, and the conditions specified below.

Certificate No. Effective Expiration Date Docket No. Amendment No. Amendment Effective Date Package Identification No.

Date 1040 TBD TBD 72-1040 3 USA/72-1040 Issued To: (Name/Address)

Holtec International Holtec Technology Campus One Holtec Blvd Camden, NJ 08104 Commented [KM1]: From Amendment 4 Safety Analysis Report Title Holtec International Final Safety Analysis Report for the HI-STORM UMAX Canister Storage System This certificate is conditioned upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Technical Specifications) and Appendix B (Approved Contents and Design Features), and the conditions specified below:

APPROVED SPENT FUEL STORAGE CASK Model No.: HI-STORM UMAX Canister Storage System DESCRIPTION:

The HI-STORM UMAX Canister Storage System consists of the following components: (1) interchangeable canisters, which contain the fuel; (2) underground Vertical Ventilated Modules (VVMs), which contains the canisters during storage; and (3) a transfer cask (HI-TRAC VW), which contains the canister during loading, unloading and transfer operations. The multi-purpose canister (MPC) stores up to 37 pressurized water reactor fuel assemblies or up to 89 boiling water reactor fuel assemblies. The HI-STORM UMAX may also store a dry shielded canister (DSC) which contains up to 24 pressurized water reactor fuel assemblies.

The HI-STORM UMAX Canister Storage System is certified as described in the UMAX Final Safety Analysis Report (FSAR) supplemented by the information on the analyzed canisters and transfer cask, and in the U. S.

Nuclear Regulatory Commissions (NRC) Safety Evaluation Report (SER) accompanying the Certificate of Compliance (CoC).

The MPC is the confinement system for the stored fuel. It is a welded, cylindrical canister with a honeycombed fuel basket, a baseplate, a lid, a closure ring, and the canister shell. All MPC components that may come into contact with spent fuel pool water or the ambient environment are made entirely of stainless steel or passivated aluminum/aluminum alloys. The canister shell, baseplate, lid, vent and drain port cover plates, and closure ring are the main confinement boundary components. All confinement boundary components are made entirely of stainless steel. The honeycombed basket provides criticality control.

Similarly, the welded DSC provides confinement and criticality control for the storage and transfer of irradiated fuel. The principle component subassemblies of the DSC are the shell with integral bottom cover plate and shield plug, top shield plug, top cover plate, and basket assembly. The DSC confinement boundary consists of stainless steel cylindrical shell and the top and bottom cover plate assemblies. The shell length is fuel specific.

The internal basket assembly for the 24PT1 is composed of guide sleeves, support rods, and spacer disks.

Page 1 of 148

Attachment 2 to Holtec Letter 5021069 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1040 FOR SPENT FUEL STORAGE CASKS Amendment No. 2 Supplemental Sheet Page 2 of 5 DESCRIPTION (continued)

The DSC basket assembly aids in the insertion of the fuel assemblies, enhances subcriticality during loading operations, and provides structural support.

There are two types of MPCs permitted for storage in HI-STORM UMAX VVM: the MPC-37 and MPC-89. The number suffix indicates the maximum number of fuel assemblies permitted to be loaded in the MPC. The MPC-37 also has an alternative design called the MPC-37 Type 1. Both MPC models have the same external Commented [KM2]: From Amendment 4 diameter. The DSC type permitted for storage in the HI-STORM UMAX is the DSC-24PT1. The information in this certificate related to the DSC applies from when the DSC is transferred into the HI-TRAC through storage in the UMAX cavity, and applicability ends when the DSC is removed from the HI-TRAC.

The HI-TRAC VW transfer cask provides shielding and structural protection of the canister during loading, unloading, and movement of the canister from the cask loading area to the VVM. The transfer cask is a multi-walled (carbon steel/lead/carbon steel) cylindrical vessel with a neutron shield jacket attached to the exterior and a retractable bottom lid used during transfer operations. The HI-TRAC VW is also used for transfer of the DSC-24PT1.

The HI-STORM UMAX VVM utilizes a storage design identified as an air-cooled vault or caisson. The HI-STORM UMAX VVM relies on vertical ventilation instead of conduction through the fill material around the VVM, as it is essentially a below-grade storage cavity. Air inlets and an air outlet allow air to circulate naturally through the cavity to cool the canister inside. The subterranean steel structure is seal welded to prevent ingress of any groundwater in the canister storage cavity from the surrounding subgrade, and it is mounted on a stiff foundation. The surrounding subgrade and a top surface pad provide significant radiation shielding. A loaded canister is stored within the HI-STORM UMAX VVM in a vertical orientation.

HI-STORM UMAX Version MSE is a structurally strengthened embodiment of the VVM engineered for deployment at sites with its Design Basis Earthquake with ZPA in excess of 2.12Gs (resultant horizontal) and up to 1.0G (vertical).

CONDITIONS

1. OPERATING PROCEDURES Written operating procedures shall be prepared for handling, loading, movement, surveillance, and maintenance. The users site-specific written operating procedures shall be consistent with the technical basis described in Chapter 9 and canister specific Chapter 9 supplements of the FSAR.

2. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written acceptance tests and a maintenance program shall be prepared consistent with the technical basis described in Chapter 10 and canister specific Chapter 10 supplements of the FSAR.

For the MPCs, at completion of welding the MPC shell to baseplate, an MPC confinement weld helium leak test shall be performed using a helium mass spectrometer. This test shall include the base metals of the MPC shell and baseplate. A helium leakage test shall also be performed on the base metal of the fabricated MPC lid. The confinement boundary welds leakage rate test shall be performed in accordance with ANSI N14.5 to leaktight criterion. If a leakage rate exceeding the acceptance criteria is detected, then the area of leakage shall be determined and the area repaired per ASME Code Section III, Subsection NB, Article NB-4450 requirements. Re-testing shall be performed until the leakage rate acceptance criterion is met.

Page 2 of 148

Attachment 2 to Holtec Letter 5021069 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1040 FOR SPENT FUEL STORAGE CASKS Amendment No. 2 Supplemental Sheet Page 3 of 5 Page 3 of 148

Attachment 2 to Holtec Letter 5021069

3. QUALITY ASSURANCE Activities in the areas of design, purchase, fabrication, assembly, inspection, testing, operation, maintenance, repair, modification of structures, systems and components, and decommissioning that are important-to-safety shall be conducted in accordance with a Commission-approved quality assurance program which satisfies the applicable requirements of 10 CFR Part 72, Subpart G, and which is established, maintained, and executed with regard to the storage system

4. HEAVY LOADS REQUIREMENTS Each lift of an MPC , DSC, or a HI-TRAC VW transfer cask must be made in accordance to the existing heavy loads requirements and procedures of the licensed facility at which the lift is made. A plant-specific review of the heavy load handling procedures (under 10 CFR 50.59 or 10 CFR 72.48, as applicable) is required to show operational compliance with existing plant specific heavy loads requirements. Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 5.2 of Appendix A or Appendix C as applicable.

5. APPROVED CONTENTS Contents of the HI-STORM UMAX Canister Storage System must meet the fuel specifications for each canister in the appendices to this certificate as follows:

Canister Approved Contents Appendix MPC-37 Appendix B MPC-89 Appendix B DSC-24PT1 Appendix D

6. DESIGN FEATURES Features or characteristics for the site or system must be in accordance with the applicable appendix to this certificate, identified in item 5.

7. CHANGES TO THE CERTIFICATE OF COMPLIANCE The holder of this certificate who desires to make changes to the certificate, which includes all the appendices (A through D), shall submit an application for amendment of the certificate.

8. PRE-OPERATIONAL TESTING AND TRAINING EXERCISE - MPCs only A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM UMAX Canister Storage System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the MPC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:

a. Moving the MPC and the transfer cask into the spent fuel pool or cask loading pool.

b. Preparation of the HI-STORM UMAX Canister Storage System for fuel loading.

c. Selection and verification of specific fuel assemblies to ensure type conformance.

d. Loading specific assemblies and placing assemblies into the MPC (using a dummy fuel assembly),

including appropriate independent verification.

e. Remote installation of the MPC lid and removal of the MPC and transfer cask from the spent fuel pool or cask loading pool.

NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1040 FOR SPENT FUEL STORAGE CASKS Amendment No. 2 Supplemental Sheet Page 4 of 5 Page 4 of 148

Attachment 2 to Holtec Letter 5021069

f. MPC welding, NDE inspections, pressure testing, draining, moisture removal (by vacuum drying or forced helium dehydration, as applicable), and helium backfilling. (A mockup may be used for this dry-run exercise.)

g. Transfer of the MPC from the transfer cask to the VVM.

h. HI-STORM UMAX Canister Storage System unloading, including flooding MPC cavity and removing MPC lid welds. (A mockup may be used for this dry-run exercise.)

Any of the above steps can be omitted if the site has already successfully loaded a Holtec MPC System.

PRE-OPERATIONAL TESTING AND TRAINING EXERCISE - DSCs only A dry run training exercise of the handling, unloading and transfer of the DSC in the HI-STORM UMAX Canister Storage System shall be conducted by the licensee prior to the first movement of a loaded DSC into a HI-STORM UMAX VVM. The training exercise shall not be conducted with spent fuel in the DSC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:

a. Transfer of the DSC from the NUHOMS storage module to the HI-TRAC VW.

b. Transfer of the DSC from the HI-TRAC VW to the VVM

c. Unloading of the DSC from storage in the HI-STORM UMAX

9. AUTHORIZATION The HI-STORM UMAX Canister Storage System, which is authorized by this certificate, is hereby approved for general use by holders of 10 CFR Part 50 licenses for nuclear reactors at reactor sites under the general license issued pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR 72.212, this certificate, and the attached Appendices A through D. The HI-STORM UMAX Canister Storage System may be fabricated and used in accordance with any approved amendment to CoC No. 1040 listed in 10 CFR 72.214. Each of the licensed HI-STORM UMAX Canister Storage System components (i.e., the canister, overpack, and transfer cask), if fabricated in accordance with any of the approved CoC Amendments, may be used with one another provided an assessment is performed by the CoC holder that demonstrates design compatibility. .

FOR THE U. S. NUCLEAR REGULATORY COMMISSION DRAFT Dated TBD Attachments:

1. Appendix A

2. Appendix B

3. Appendix C

4. Appendix D Page 5 of 148

Attachment 2 to Holtec Letter 5021069 CERTIFICATE OF COMPLIANCE NO. 1040 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM UMAX CANISTER STORAGE SYSTEM Page 6 of 148

Attachment 2 to Holtec Letter 5021069 TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1-1 1.1 Definitions ............................................................................................ 1.1-1 1.2 Logical Connectors .............................................................................. 1.2-1 1.3 Completion Times ................................................................................ 1.3-1 1.4 Frequency ............................................................................................ 1.4-1 2.0 NOT USED 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY ............ 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............................. 3.0-2 3.1 SFSC INTEGRITY ............................................................................ 3.1.1-1 3.1.1 Multi-Purpose Canister (MPC) ............................................... 3.1.1-1 3.1.2 SFSC Heat Removal System ................................................. 3.1.2-1 3.1.3 MPC Cavity Reflooding .......................................................... 3.1.3-1 3.2 SFSC RADIATION PROTECTION ................................................... 3.2.1-1 3.2.1 TRANSFER CASK Surface Contamination ............................ 3.2.1-1 3.3 SFSC CRITICALITY CONTROL ....................................................... 3.3.1-1 3.3.1 Boron Concentration .............................................................. 3.3.1-1 Table 3-1 MPC Cavity Drying Limits .................................................................... 3.4-1 Table 3-2 MPC Helium Backfill Limits .................................................................. 3.4-4 4.0 NOT USED 4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS ...................................... 5.0-1 5.1 Radioactive Effluent Control Program .................................................. 5.0-1 5.2 Transport Evaluation Program ............................................................. 5.0-2 5.3 Radiation Protection Program .............................................................. 5.0-3 Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.1-i Page 7 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.0 USE AND APPLICATION

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

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

1.1 Definitions 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.

AMBIENT TEMPERATURE AMBIENT TEMPERATURE for Short Term Operations (operations involving use of the HI-TRAC, a Lifting device, and/or an on-site transport device) is defined as the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average of the local temperature as forecast by the National Weather Service.

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.

DAMAGED FUEL CONTAINER DFCs are specially designed enclosures for (DFC) DAMAGED 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 UMAX System are as follows:

1. Holtec Generic BWR design

2. Holtec Generic PWR design Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.1-1 Page 8 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.1 Definitions Term Definition 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.

GROSSLY BREACHED Spent nuclear fuel rod with a cladding defect that SPENT FUEL ROD could lead 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.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on a 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 TRANSFER CASK is suspended from or secured on the transporter. LOADING OPERATIONS does not include MPC TRANSFER.

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

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

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

Axial Power Shaping Rods (APSRs), Wet Annular Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.1-2 Page 9 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.1 Definitions Term Definition 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 For the HI-STORM UMAX, the term OVERPACK is synonyms with the term VVM defined below.

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

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

SPENT FUEL STORAGE SFSCs are containers approved for the storage of CASKS (SFSCs) spent fuel assemblies at the ISFSI. The HI-STORM UMAX SFSC System consists of the OVERPACK 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 prior to and during unloading and to transfer the MPC to or from the OVERPACK.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on a 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 TRANSFER CASK is first suspended from or secured on the transporter and end when the TRANSFER CASK is at its destination and no longer secured on or suspended from the transporter. TRANSPORT OPERATIONS includes Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.1-3 Page 10 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.1 Definitions Term Definition MPC TRANSFER.

VERTICAL VENTILATED The VVM is a subterranean type overpack which MODULE (VVM) receives and contains the sealed MPC for interim storage at the ISFSI. The VVM supports the MPC in a vertical orientation and provide gamma and neutron shielding and also provides air flow through cooling passages to promote heat transfer from the MPC to the environs.

UNDAMAGED FUEL UNDAMAGED FUEL ASSEMBLIES are: a) fuel ASSEMBLY assemblies 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 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 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.

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. 1040 Amendment No. 3 Appendix A 1.1-4 Page 11 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 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.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.1-5 Page 12 of 148

Attachment 2 to Holtec Letter 5021069 Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors 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. 1040 Amendment No. 3 Appendix A 1.2-1 Page 13 of 148

Attachment 2 to Holtec Letter 5021069 Logical Connectors 1.2 1.2 Logical Connectors 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. 1040 Amendment No. 3 Appendix A 1.2-2 Page 14 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion 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 UMAX 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 UMAX 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. 1040 Amendment No. 3 Appendix A 1.3-1 Page 15 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

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 AND Completion 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. 1040 Amendment No. 3 Appendix A 1.3-2 Page 16 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

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

associated Completion AND Time not met.

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

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. 1040 Amendment No. 3 Appendix A 1.3-3 Page 17 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

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

Separate Condition entry is allowed for each component.

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

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

associated Completion AND Time not met.

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

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

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis. When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.3-4 Page 18 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

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

TIME Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 1.3-5 Page 19 of 148

Attachment 2 to Holtec Letter 5021069 Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR.

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. 1040 Amendment No. 3 Appendix A 1.4-1 Page 20 of 148

Attachment 2 to Holtec Letter 5021069 Frequency 1.4 1.4 Frequency (continued)

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

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the 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. 1040 Amendment No. 3 Appendix A 1.4-2 Page 21 of 148

Attachment 2 to Holtec Letter 5021069 Frequency 1.4 1.4 Frequency (continued)

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. 1040 Amendment No. 3 Appendix A 1.4-3 Page 22 of 148

Attachment 2 to Holtec Letter 5021069 2.0 2.0 This section is intentionally left blank Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 2.0-1 Page 23 of 148

Attachment 2 to Holtec Letter 5021069 LCO Applicability 3.0 3.0 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. 1040 Amendment No. 3 Appendix A 3.0-1 Page 24 of 148

Attachment 2 to Holtec Letter 5021069 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

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

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.0-2 Page 25 of 148

Attachment 2 to Holtec Letter 5021069 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period and the (continued) 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. 1040 Amendment No. 3 Appendix A 3.0-3 Page 26 of 148

Attachment 2 to Holtec Letter 5021069 Multi-Purpose Canister (MPC) 3.1.1 3.1 SFSC INTEGRITY 3.1.1 Multi-Purpose Canister (MPC)

LCO 3.1.1 The MPC shall be dry and helium filled.

Table 3-1 provides decay heat and burnup limits for forced helium dehydration (FHD) and vacuum drying.

APPLICABILITY: Prior to TRANSPORT OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each MPC.

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

met. AND A.2 Develop and initiate 30 days corrective actions necessary to return the MPC to compliance with Table 3-1.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.1.1-1 Page 27 of 148

Attachment 2 to Holtec Letter 5021069 Multi-Purpose Canister (MPC) 3.1.1 ACTIONS (continued)

B. MPC helium backfill limit B.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 B.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 B.2.2 Develop and initiate corrective actions necessary to demonstrate through analysis, using the models and methods from the HI-STORM UMAX FSAR, that all limits for MPC components and contents will be met.

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

AND C.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. 1040 Amendment No. 3 Appendix A 3.1.1-2 Page 28 of 148

Attachment 2 to Holtec Letter 5021069 Multi-Purpose Canister (MPC) 3.1.1 D. Required Actions and D.1 Remove all fuel assemblies 30 days associated Completion from the SFSC.

Times not met.

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

SR 3.1.1.3 Verify that the helium leak rate through the MPC Once, prior to vent and drain port cover plates (confinement TRANSPORT welds and the base metal)meets the leaktight OPERATIONS criteria of ANSI N14.5-1997.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.1.1-3 Page 29 of 148

Attachment 2 to Holtec Letter 5021069 SFSC Heat Removal System 3.1.2 3.1 SFSC INTEGRITY 3.1.2 SFSC Heat Removal System LCO 3.1.2 The SFSC Heat Removal System shall be operable APPLICABILITY: During STORAGE OPERATIONS after closure lid installed. Commented [KM1]: From Amendment 4 ACTIONS

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

Separate Condition entry is allowed for each SFSC.

COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Heat Removal A.1 Remove blockage. N/A System operable, but partially ( blocked. Commented [KM2]: From Amendment 4 B. SFSC Heat Removal B.1 Restore SFSC Heat 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months System inoperable. Removal System to operable status.

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 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Removal System to operable status.

OR C.2.2 Transfer the MPC into a 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months TRANSFER CASK.

OR C.2.3 Perform an engineering 24hours Commented [KM3]: From Amendment 4 evaluation to demonstrate that component temperatures are within allowable limits Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.1.2-1 Page 30 of 148

Attachment 2 to Holtec Letter 5021069 SFSC Heat Removal System 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all VVM inlets and outlets duct screen are 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months free of blockage from solid debris or floodwater.

OR For VVMs with installed temperature monitoring 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months equipment, verify that the difference between the average VVM air outlet duct temperature and ISFSI ambient temperature is 87oF for VVMs containing MPC-37s and 85oF for VVMs containing MPC-89s.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.1.2-2 Page 31 of 148

Attachment 2 to Holtec Letter 5021069 Fuel Cool-Down 3.1.3 3.1 SFSC INTEGRITY 3.1.3 MPC Cavity Reflooding LCO 3.1.3 The MPC cavity pressure shall be < 100 psig

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 A.1 Stop re-flooding operations Immediately not within limit. until MPC cavity pressure is within limit.

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

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

OR 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. 1040 Amendment No. 3 Appendix A 3.1.3-1 Page 32 of 148

Attachment 2 to Holtec Letter 5021069 TRANSFER CASK Surface Contamination 3.2.1 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.

APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each TRANSFER CASK.

COMPLETION CONDITION REQUIRED ACTION TIME A. TRANSFER CASK or A.1 Restore removable surface 7 days MPC removable surface contamination to within contamination limits not limits.

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. 1040 Amendment No. 3 Appendix A 3.2.1-1 Page 33 of 148

Attachment 2 to Holtec Letter 5021069 Boron Concentration 3.3.1 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 to be stored in the MPC:

MPC-37: Minimum soluble boron concentration as required by the table below.

One or more Damaged Fuel All Undamaged Fuel Assemblies Assemblies or Fuel Debris Array/Class Maximum Initial Maximum Initial Maximum Initial Maximum Initial Enrichment Enrichment 5.0 Enrichment Enrichment 5.0 4.0 wt% 235U wt% 235U 4.0 wt% 235U wt% 235U (ppmb) (ppmb) (ppmb) (ppmb)

All 14x14 and 16x16 1000 1500 1300 1800 All 15x15 and 17x17 1500 2000 1800 2300 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%.

If any undamaged fuel assemblies are stored in DFCs the minimum soluble boron concentration is 1600 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. 1040 Amendment No. 3 Appendix A 3.3.1-1 Page 34 of 148

Attachment 2 to Holtec Letter 5021069 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 entering the through the MPC. Applicability of

this LCO.

SR 3.3.1.1 Verify boron concentration is within the AND 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. 1040 Amendment No. 3 Appendix A 3.3.1-2 Page 35 of 148

Attachment 2 to Holtec Letter 5021069 3.4 Tables Table 3-1 MPC Cavity Drying Limits MPC Type Cell Heat Load Limits Method of Moisture Fuel Burnup (Note 5) Removal (MWD/MTU) (Note 6) (Notes 1 and 2)

MPC-37 Figure 2.3-1, 2.3-2, or 2.3-3 of (Short Fuel) Appendix B MPC-37 Figure 2.3-1, 2.3-2, or 2.3-4 of All Assemblies (Standard Fuel) Appendix B VDS (Notes 3 and 4)

< 45,000 or FHD (Note 4)

MPC-37 Figure 2.3-5, 2.3-6, or 2.3-7 of (Long Fuel) Appendix B MPC-89 Figure 2.3-10 of Appendix B MPC-37 One or more (Short, Standard Figure 2.3-12 of Appendix B VDS (Notes 3 and 4) assemblies and Long Fuel) or FHD (Note 4)

> 45,000 MPC-89 Figure 2.3-13 of Appendix B MPC-37 Figure 2.3-1, 2.3-2, or 2.3-3 of (Short Fuel) Appendix B One or more MPC-37 Figure 2.3-1, 2.3-2, or 2.3-4 of assemblies (Standard Fuel) Appendix B FHD (Note 4)

> 45,000 MPC-37 Figure 2.3-5, 2.3-6, or 2.3-7 of (Long Fuel) Appendix B MPC-89 Figure 2.3-10 of Appendix B MPC-37 with Any allowable 16x16A in DFCs Figure 2.3-14 of Appendix B FHD (Note 4) burnup (Note 7)

Notes:

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

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

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

4. Heat load limits are set for each cell; see Appendix B Section 2.3.

5. The fuel assembly lengths loaded in MPC-37 are catalogued as short, standard and long fuel based on the active fuel lengths specified in Appendix B Table 2.1-4.

6. For additional aggregate heat load limits for storage, see Appendix B Table 2.3-1

7. As stated in Appendix B, Table 2.1-1 Item I.B, this can include undamaged fuel both in DFCs and not, and damaged fuel in DFCs. These heat load limits apply with one or more undamaged fuel assemblies stored in DFCs.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.4-1 Page 36 of 148

Attachment 2 to Holtec Letter 5021069 3.4 Tables Table 3-2 MPC Helium Backfill Limits 1 Helium Backfill Helium Backfill MPC Type Pressure Pressure Range Option (psig) 1 41.0 and 44.2 MPC-37 2 41.0 and 44.5 3 39.0 and 46.0 1 42.0 and 45.2 MPC-89 2 39.0 and 46.0 Note: For Permissible Aggregate Heat Load Limit for each helium backfill pressure option see Appendix B, Table 2.3-1.

1 Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 3.4-2 Page 37 of 148

Attachment 2 to Holtec Letter 5021069 4.0 4.0 This section is intentionally left blank Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 4.0-1 Page 38 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented and maintained.

5.1 Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d).

a. The HI-STORM UMAX Canister Storage System does not create any radioactive materials or have any radioactive waste treatment systems.

Therefore, specific operating procedures for the control of radioactive effluents are not required. Specification 3.1.1, Multi-Purpose Canister (MPC), provides assurance that there are not radioactive effluents from the SFSC.

b. 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.

c. An annual report shall be submitted pursuant to 10 CFR 72.44(d)(3).

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 5.0-1 Page 39 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program

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

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

c. The TRANSFER CASK when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and MPC TRANSFER, provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.

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

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

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

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 5.0-2 Page 40 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program 5.3.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

5.3.2 As part of its evaluation pursuant to 10 CFR 72.212(b)(5)(iii), the licensee Commented [KM4]: From Amendment 4 shall perform an analysis to confirm that the dose limits of 10 CFR 72.104(a) will be satisfied under the actual site conditions and ISFSI configuration, considering the planned number of casks to be deployed and the cask contents.

5.3.3 Based on the analysis performed pursuant to Section 5.3.2, the licensee shall establish individual cask surface dose rate limits for the TRANSFER CASK and the VVM 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 VVM.

b. The side of the TRANSFER CASK

c. The outlet vents on the VVM 5.3.4 Notwithstanding the limits established in Section 5.3.3, the measured dose rates on a loaded VVM or TRANSFER CASK shall not exceed the following values:

a. HI-STORM UMAX Standard Lid: 66mrem/hr (gamma + neutron) on the closure lid of the VVM (see 5.3.8(a) for location description)

HI-STORM UMAX Version B lid: 22 mrem/hr (gamma + neutron) on the closure lid of the VVM (see 5.3.8(a) for location description)

b. 3500 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.3.5 The licensee shall measure the TRANSFER CASK and lid VVM surface Commented [KM5]: From Amendment 4 neutron and gamma dose rates as described in Section 5.3.8 for comparison against the limits established in Section 5.3.3 or Section 5.3.4, whichever are lower.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 5.0-3 Page 41 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.3.3 or Section 5.3.4, 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 a VVM 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.

5.3.7 If the evaluation performed pursuant to Section 5.3.6 shows that the dose limits of 10 CFR 72.104 will be exceeded, the MPC shall not be placed into a VVM or the MPC shall be removed from the VVM until appropriate corrective action is taken to ensure the dose limits are not exceeded.

5.3.8 TRANSFER CASK and VVM 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 top of the VVM. These measurements shall be taken:

HI-STORM UMAX Standard Lid: On the side of the closure lid approximately midheight and approximately 90 degrees apart HI-STORM UMAX Version B lid: On the side of the closure lid approximately midheight and adjacent to the inlet vent. One measurement per each lid side, rotationally symmetric by approximately 90 degrees Commented [KM6]: From Amendment 4

b. A minimum of four (4) dose rate measurements shall be taken adjacent to the outlet vent duct screen of the VVM, approximately 90 degrees apart.

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

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 5.0-4 Page 42 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.9 The Radiation Protection Space (RPS) is the prismatic subgrade buffer zone surrounding the VVMs in a loaded ISFSI. The RPS boundary is indicated in the Licensing Drawings in Section 1.5 of the system FSAR. The RPS boundary shall not be encroached upon during any site construction activity. The jurisdictional boundary of the RPS extends down from the top of the ISFSI pad to the elevation of the Bottom surface of the Support Foundation Pad. The ISFSI design shall ensure that there is no significant loss of shielding in the RPS due to a credible accident or an extreme environment event during construction activity involving excavation adjacent to the RPS boundary.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix A 5.0-5 Page 43 of 148

Attachment 2 to Holtec Letter 5021069 CERTIFICATE OF COMPLIANCE NO. 1040 APPENDIX B APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM UMAX CANISTER STORAGE SYSTEM Page 44 of 148

Attachment 2 to Holtec Letter 5021069 TABLE OF CONTENTS 1.0 DEFINITIONS ........................................................................................................ 1-1 2.0 APPROVED CONTENTS ...................................................................................... 2-1 2.1 Fuel Specifications and loading conditions ........................................................ 2-1 2.2 Violations ........................................................................................................... 2-1 2.3 Decay Heat Limits ........................................................................................... 2-15 Table 2.1-1 Fuel Assembly Limits .......................................................................... 2-2 Table 2.1-2 PWR Fuel Assembly Characteristics .................................................. 2-6 Table 2.1-3 BWR Fuel Assembly Characteristics .................................................. 2-9 Table 2.1-4 Classification of Fuel Assembly for MPC-37 in the HI-STORM UMAX System ...................................................................................................... 2-14 Table 2.3-1 Permissible Heat Load for long term storage .................. 2-16Table 2.3-2 HI-STORM UMAX MPC-37 Type 1 Permissib Figure 2.3-1 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 1 for Long-term Storage for Short and Standard Fuel ........................................ 2-21 Figure 2.3-2 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 2 for Long-Term Storage for Short and Standard Fuel ....................................... 2-22 Figure 2.3-3 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 3 for Long-term Storage for Short Fuel .............................................................. 2-23 Figure 2.3-4 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 3 for Long-term Storage for Standard Fuel ........................................................ 2-24 Figure 2.3-5 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 1 for Long-term Storage for Long Fuel ............................................................... 2-25 Figure 2.3-6 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 2 for Long-term Storage for Long Fuel ............................................................... 2-26 Figure 2.3-7 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 3 for Long-term Storage for Long Fuel ............................................................... 2-27 Figure 2.3-8 HI-STORM UMAX MPC-37 Permissible Heat Load for Short and Standard Fuel for Helium Backfill Option3 in Table 3-2 of Appendix A ....................................................................................... 2-28 Figure 2.3-9 HI-STORM UMAX MPC-37 Permissible Heat Load for Long Fuel for Helium Backfill Option 3 in Table 3-2 of Appendix A ......................... 2-29 Figure 2.3-10 HI-STORM UMAX MPC-89 Permissible Heat Load for Long-Term Storage ............................................................................................ 2-30 Figure 2.3-11 HI-STORM UMAX MPC-89 Permissible Heat Load for Helium Backfill Option 2 in Table 3-2 of Appendix A ................................................ 2-31 Figure 2.3-12 HI-STORM UMAX MPC-37 Permissible Threshold Heat Load for VDS High Burnup Fuel in Table 3-1 of Appendix A and Helium Backfill Option 3 in Table 3-2 of Appendix A............................................................. 2-32 Figure 2.3-13 HI-STORM UMAX MPC-89 Permissible Threshold Heat Load for VDS High Burnup Fuel in Table 3-1 of Appendix A and Helium Backfill Option 2 in Table 3-2 of Appendix A............................................................. 2-33 Certificate of Compliance No. 1040 Amendment No. 3 Appendix B i Page 45 of 148

Attachment 2 to Holtec Letter 5021069 Figure 2.3-14 HI-STORM UMAX MPC-37 Permissible Heat Load for 16x16A Undamaged Fuel with up to Thirty-seven DFCs ................................. 2-3 Figure 2.3-15: HI-STORM UMAX MPC-37 Type 1 Heat Permissible Heat Loads ... 2-35 Commented [KM1]: From Amendment 4 3.0 DESIGN FEATURES ............................................................................................. 3-1 3.1 Site .................................................................................................................... 3-1 3.2 Design Features Important for Criticality Control ............................................... 3-1 3.3 Codes and Standards ........................................................................................ 3-2 3.4 Site Specific Parameters and Analyses ........................................................... 3-10 3.5 Combustible Gas Monitoring During MPC Lid Welding and Cutting ................ 3-16 3.6 Periodic Corrosion Inspections for Underground Systems .............................. 3-16 Figure 3-1 SUBGRADE AND UNDERGRADE SPACE NOMENCLATURE....3-15 Table 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs) .... 3-3 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR HI-STORM UMAX OVERPACK and HI-TRAC VW TRANSFER CASK, PRIMARY LOAD BEARING PARTS .................................................................................. 3-8 Table 3-3 LOAD COMBINATIONS FOR THE TOP SURFACE PAD, ISFSI PAD, AND SUPPORT FOUNDATION PAD PER ACI-318 (2005) ................. 3-12 Table 3-4 Values of Principal Design Parameters for the Underground ISFSI ...... 3-13 Certificate of Compliance No. 1040 Amendment No. 3 Appendix B ii Page 46 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.0 1.0 Definitions Refer to Appendix A for Definitions.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 1-1 Page 47 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 2.0 APPROVED CONTENTS 2.1 Fuel Specifications and Loading Conditions 2.1.1 Fuel to Be Stored in the HI-STORM UMAX Canister Storage System

a. 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 the HI-STORM UMAX Canister Storage System.

b. All BWR fuel assemblies may be stored with or without ZR channels.

2.1.2 Fuel Loading Figures 2.3-1 through 2.3-7 and 2.3-10 define the unique cell numbers for the MPC-37 and MPC-89 models, respectively, and the maximum allowable heat load per fuel assembly for each cell under multiple loading conditions. Fuel assembly decay heat limits are specified in Section 2.3.1.

Fuel assemblies shall meet all other applicable limits specified in Tables 2.1-1 through 2.1-3.

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

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

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

2.2.3 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.1040 Amendment No. 3 Appendix B 2-1 Page 48 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-1 (page 1 of 4)

Fuel Assembly Limits I. MPC MODEL: MPC-37 A. Allowable Contents

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

a. Cladding Type: ZR

b. Maximum Initial Enrichment: 5.0 wt. % U-235 with soluble boron credit per LCO 3.3.1

c. Post-irradiation Cooling Time Cooling Time 3 years and Average Burnup Per Assembly Average Burnup 68.2 GWD/MTU Assembly:

d. Decay Heat Per Fuel Storage As specified in Section 2.3 Location:

e. Fuel Assembly Length: 199.2 inches (nominal design including NON-FUEL HARDWARE and DFC)

f. Fuel Assembly Width: 8.54 inches (nominal design)

g. Fuel Assembly Weight: 2050 lbs (including NON-FUEL HARDWARE and DFC)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-2 Page 49 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-1 (page 2 of 4)

Fuel Assembly Limits I. MPC MODEL: MPC-37 (continued)

B. Quantity per MPC: 37 FUEL ASSEMBLIES with up to twelve (12) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs). DFCs may be stored in fuel storage locations 1, 3, 4, 8, 9, 15, 23, 29, 30, 34, 35, and 37 (see Figures 2.3-1 through 2.3-7). The remaining fuel storage locations may be filled with PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

OR 37 class 16x16A UNDAMAGED FUEL ASSEMBLIES, with up to thirty-seven (37) of these stored in DAMAGED FUEL CONTAINERS, with up to twelve (12)

DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS stored in DAMAGED FUEL CONTAINERS (DFCs). DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS may be stored in fuel storage locations to 1, 3, 4, 8, 9, 15, 23, 29, 30, 34, 35, and 37 (see Figure 2.3-14). UNDAMAGED FUEL ASSEMBLIES, class 16x16A may be stored in DFCs only under loading pattern shown in Figure 2.3.14 OR For MPC-37 Type 1 only, up to 37 PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications under loading pattern shown in Figure 2.3.15 Commented [KM2]: From Amendment 4 C. One (1) Neutron Source Assembly (NSA) is authorized for loading in the MPC-37.

D. Up to thirty (30) BRPAs are authorized for loading in the MPC-37.

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. Fuel assemblies containing APSRs, RCCAs, CEAs, CRAs, or NSAs may only be loaded in fuel storage locations 5 through 7, 10 through 14, 17 through 21, 24 through 28, and 31 through 33 (see Figures 2.3-1 through 2.3-7).

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-3 Page 50 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-1 (page 3 of 4)

Fuel Assembly Limits II. MPC MODEL: MPC-89 A. Allowable Contents

1. Uranium oxide BWR UNDAMAGED FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, and/or FUEL DEBRIS meeting the criteria in Table 2.1-3, with or without channels and meeting the following specifications:

a. Cladding Type: ZR

b. Maximum PLANAR-AVERAGE As specified in Table 2.1-3 for the INITIAL ENRICHMENT(Note 1): applicable fuel assembly array/class.

c. Initial Maximum Rod Enrichment 5.0 wt. % U-235

d. Post-irradiation Cooling Time and Average Burnup Per Assembly

i. Array/Class 8x8F Cooling time 10 years and an assembly average burnup 27.5 GWD/MTU.

ii. All Other Array Classes Cooling Time 3 years and an assembly average burnup 65 GWD/MTU

e. Decay Heat Per Assembly

i. Array/Class 8x8F 183.5 Watts ii. All Other Array Classes As specified in Section 2.3

f. Fuel Assembly Length 176.5 inches (nominal design)

g. Fuel Assembly Width 5.95 inches (nominal design)

h. Fuel Assembly Weight 850 lbs, including a DFC as well as a channel Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-4 Page 51 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-1 (page 4 of 4)

Fuel Assembly Limits II. MPC MODEL: MPC-89 (continued)

B. Quantity per MPC: 89 FUEL ASSEMBLIES with up to sixteen (16) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs). DFCs may be stored in fuel storage locations 1, 3, 4, 10, 11, 19, 29, 39, 51, 61, 71, 79, 80, 86, 87, and 89 (see Figure 2.3-10). The remaining fuel storage locations may be filled with BWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

Note 1: The lowest maximum allowable enrichment of any fuel assembly loaded in an MPC-89, based on fuel array class and fuel classification, is the maximum allowable enrichment for the remainder of the assemblies loaded in that MPC.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-5 Page 52 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-2 (page 1 of 4)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 14x14 A 14x14 B 14x14 C 15x15 B 15x15 C Array/ Class No. of Fuel Rod 179 179 176 204 204 Locations Fuel Clad O.D. (in.) 0.400 0.417 0.440 0.420 0.417 Fuel Clad I.D. (in.) 0.3514 0.3734 0.3880 0.3736 0.3640 Fuel Pellet Dia. (in.)

0.3444 0.3659 0.3805 0.3671 0.3570 (Note 3)

Fuel Rod Pitch (in.) 0.556 0.556 0.580 0.563 0.563 Active Fuel Length 150 150 150 150 150 (in.)

No. of Guide and/or 5 17 17 21 21 Instrument Tubes (Note 2)

Guide/Instrument 0.017 0.017 0.038 0.015 0.0165 Tube Thickness (in.)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-6 Page 53 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-2 (page 2 of 4)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 15x15 D 15x15 E 15x15 F 15x15 H 15x15 I Array/Class No. of Fuel Rod 216 (Note 208 208 208 208 Locations 4)

Fuel Clad O.D. (in.) 0.430 0.428 0.428 0.414 0.413 Fuel Clad I.D. (in.) 0.3800 0.3790 0.3820 0.3700 0.3670 Fuel Pellet Dia. (in.)

0.3735 0.3707 0.3742 0.3622 0.3600 (Note 3)

Fuel Rod Pitch (in.) 0.568 0.568 0.568 0.568 0.550 Active Fuel Length 150 150 150 150 150 (in.)

No. of Guide and/or 17 17 17 17 9 (Note 4)

Instrument Tubes Guide/Instrument 0.0150 0.0140 0.0140 0.0140 0.0140 Tube Thickness (in.)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-7 Page 54 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-2 (page 3 of 4)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 16x16 A 16x16B 16x16C Array and Class No. of Fuel Rod 236 236 236 Locations Fuel Clad O.D. (in.) 0.382 0.374 0.374 Fuel Clad I.D. (in.) 0.3350 0.3290 0.3290 Fuel Pellet Dia. (in.)

0.3255 0.3225 0.3225 (Note 3)

Fuel Rod Pitch (in.) 0.506 0.506 0.485 Active Fuel length 150 150 150 (in.)

No. of Guide and/or 5 5 21 Instrument Tubes (Note 2) (Note 2)

Guide/Instrument 0.0350 0.04 0.0157 Tube Thickness (in.)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-8 Page 55 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-2 (page 4 of 4)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 17x17A 17x17 B 17x17 C 17x17 D 17x17 E Array and Class No. of Fuel Rod 264 264 264 264 265 Locations Fuel Clad O.D. (in.) 0.360 0.372 0.377 0.372 0.372 Fuel Clad I.D. (in.) 0.3150 0.3310 0.3330 0.3310 0.3310 Fuel Pellet Dia. (in.)

0.3088 0.3232 0.3252 0.3232 0.3232 (Note 3)

Fuel Rod Pitch (in.) 0.496 0.496 0.502 0.496 0.496 Active Fuel length 150 150 150 170 170 (in.)

No. of Guide and/or 25 25 25 25 24 Instrument Tubes Guide/Instrument 0.016 0.014 0.020 0.014 0.014 Tube Thickness (in.)

Notes:

1. All dimensions are design nominal values. Maximum and minimum dimensions are specified to bound variations in design nominal values among fuel assemblies within a given array/class.

2. Each guide tube replaces four fuel rods.

3. Annular fuel pellets are allowed in the top and bottom 12 of the active fuel length.

4. Assemblies have one Instrument Tube and eight Guide Bars (Solid ZR). Some assemblies have up to 8 fuel rods removed or replaced by Guide Tubes.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-9 Page 56 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-3 (page 1 of 4)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly Array 7x7 B 8x8 B 8x8 C 8x8 D 8x8 E and Class Maximum Planar-Average Initial

< 4.8 < 4.8 < 4.8 < 4.8 < 4.8 Enrichment (wt.%

235 U) (Note 14)

No. of Fuel Rod Locations (Full Length 49 63 or 64 62 60 or 61 59 or Total/Full Length)

Fuel Clad O.D. (in.) > 0.5630 > 0.4840 > 0.4830 > 0.4830 > 0.4930 Fuel Clad I.D. (in.) < 0.4990 < 0.4295 < 0.4250 < 0.4230 < 0.4250 Fuel Pellet Dia. (in.) < 0.4910 < 0.4195 < 0.4160 < 0.4140 < 0.4160 Fuel Rod Pitch (in.) < 0.738 < 0.642 < 0.641 < 0.640 < 0.640 Design Active Fuel

< 150 < 150 < 150 < 150 < 150 Length (in.)

No. of Water Rods 1-4 0 1 or 0 2 5 (Note 10) (Note 6)

Water Rod Thickness N/A > 0.034 > 0.00 > 0.00 > 0.034 (in.)

Channel Thickness

< 0.120 < 0.120 < 0.120 < 0.120 < 0.100 (in.)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-10 Page 57 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-3 (2 of 4)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 8x8F 9x9 A 9x9 B 9x9 C 9x9 D Array and Class Maximum Planar-Average Initial < 4.5

< 4.8 < 4.8 < 4.8 < 4.8 Enrichment (wt.% (Note 12) 235 U) (Note 14)

No. of Fuel Rod 74/66 64 72 80 79 Locations (Note 4)

Fuel Clad O.D. (in.) > 0.4576 > 0.4400 > 0.4330 > 0.4230 > 0.4240 Fuel Clad I.D. (in.) < 0.3996 < 0.3840 < 0.3810 < 0.3640 < 0.3640 Fuel Pellet Dia. (in.) < 0.3913 < 0.3760 < 0.3740 < 0.3565 < 0.3565 Fuel Rod Pitch (in.) < 0.609 < 0.566 < 0.572 < 0.572 < 0.572 Design Active Fuel

< 150 < 150 < 150 < 150 < 150 Length (in.)

No. of Water Rods N/A 1 2 1 2 (Note 10) (Note 2) (Note 5)

Water Rod

> 0.0315 > 0.00 > 0.00 > 0.020 > 0.0300 Thickness (in.)

Channel Thickness

< 0.055 < 0.120 < 0.120 < 0.100 < 0.100 (in.)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-11 Page 58 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-3 (page 3 of 4)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 9x9 E 9x9 F 9x9 G 10x10 A 10x10 B Array and Class (Note 2) (Note 2)

Maximum Planar-

< 4.5 < 4.5 Average Initial (Note (Note < 4.8 < 4.8 < 4.8 Enrichment (wt.%

235 12) 12)

U) (Note 14)

No. of Fuel Rod 92/78 91/83 76 76 72 Locations (Note 7) (Note 8)

Fuel Clad O.D. (in.) >0.4170 >0.4430 >0.4240 >0.4040 >0.3957 Fuel Clad I.D. (in.) <0.3640 <0.3860 <0.3640 < 0.3520 < 0.3480 Fuel Pellet Dia. (in.) <0.3530 <0.3745 <0.3565 < 0.3455 < 0.3420 Fuel Rod Pitch (in.) < 0.572 < 0.572 < 0.572 < 0.510 < 0.510 Design Active Fuel

< 150 < 150 < 150 < 150 < 150 Length (in.)

No. of Water Rods 1 1 5 5 2 (Note 10) (Note 5) (Note 5)

Water Rod Thickness

>0.0120 >0.0120 >0.0320 >0.0300 > 0.00 (in.)

Channel Thickness

< 0.120 < 0.120 < 0.120 < 0.120 < 0.120 (in.)

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-12 Page 59 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-3 (page 4 of 4)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly Array and 10x10 C 10x10 F 10x10 G Class Maximum Planar-Average

< 4.7 < 4.6 Initial Enrichment (wt.% 235U) < 4.8 (Note 13) (Note 12)

(Note 14)

No. of Fuel Rod Locations 92/78 96 96/84 (Note 7)

Fuel Clad O.D. (in.) > 0.3780 > 0.4035 > 0.387 Fuel Clad I.D. (in.) < 0.3294 < 0.3570 < 0.340 Fuel Pellet Dia. (in.) < 0.3224 < 0.3500 < 0.334 Fuel Rod Pitch (in.) < 0.488 < 0.510 < 0.512 Design Active Fuel Length (in.) < 150 < 150 < 150 No. of Water Rods (Note 10) 5 5 2

(Note 9) (Note 9)

Water Rod Thickness (in.) > 0.031 > 0.030 > 0.031 Channel Thickness (in.) < 0.055 < 0.120 < 0.060 Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-13 Page 60 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents

2.0 NOTES

1. All dimensions are design nominal values. Maximum and minimum dimensions are specified to bound variations in design nominal values among fuel assemblies within a given array/class.

2. This assembly is known as QUAD+. It has four rectangular water cross segments dividing the assembly into four quadrants.

3. For the SPC 9x9-5 fuel assembly, each fuel rod must meet either the 9x9E or the 9x9F set of limits or clad O.D., clad I.D., and pellet diameter.

4. This assembly class contains 74 total rods; 66 full length rods and 8 partial length rods.

5. Square, replacing nine fuel rods.

6. Variable.

7. This assembly contains 92 total fuel rods; 78 full length rods and 14 partial length rods.

8. This assembly class contains 91 total fuel rods; 83 full length rods and 8 partial length rods.

9. One diamond-shaped water rod replacing the four center fuel rods and four rectangular water rods dividing the assembly into four quadrants.

10. These rods may also be sealed at both ends and contain ZR material in lieu of water.

11. Not used.

12. When loading fuel assemblies classified as DAMAGED FUEL, all assemblies in the MPC are limited to 4.0 wt.% U-235.

13. When loading fuel assemblies classified as DAMAGED FUEL, all assemblies in the MPC are limited to 4.6 wt.% U-235.

14. In accordance with the definition of UNDAMAGED FUEL, certain assemblies may be limited to 3.3 wt.% U-235. When loading these fuel assemblies, all assemblies in the MPC are limited to 3.3 wt.% U-235.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-14 Page 61 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-4 CLASSIFICATION OF FUEL ASSEMBLY FOR MPC-37 IN THE HI-STORM UMAX ISFSI MPC Type Classification Nominal Active Fuel Length Short Fuel 128 inches < L < 144 inches MPC-37 Standard Fuel 144 inches < L < 168 inches Long Fuel L > 168 inches Note 1: L means "nominal active fuel length".

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-15 Page 62 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 2.3 Decay Heat Limits This section provides the limits on fuel assembly decay heat for storage in the HI-STORM UMAX Canister Storage System. The method to verify compliance, including examples, is provided in Chapter 13 of the HI-STORM UMAX FSAR.

2.3.1 Fuel Loading Decay Heat Limits Table 2.3-1 provides the maximum permissible decay heat under long-term storage for MPC-37 and MPC-89. Table 2.3-1 also lists the applicable figures providing the permissible decay heat per fuel storage location, including MPCs using the optional helium backfill pressure ranges permitted in Table 3-2 of Appendix A.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-16 Page 63 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 TABLE 2.3-1 PERMISSIBLE HEAT LOAD FOR LONG-TERM STORAGE Permissible Helium Backfill Permissible Heat Load Aggregate Heat MPC Type Pressure Option Heat Load Per Chart Load, kW (Notes 1,2) Storage Cell (Note 4) 1 1 Figure 2.3-1 33.88 Short Fuel 2 2 Figure 2.3-2 33.70 (Note 3) 3 1 Figure 2.3-3 33.53 Standard 1 1 Figure 2.3-1 33.88 Fuel 2 2 Figure 2.3-2 33.70 (Note 3 and

7) 3 1 Figure 2.3-4 35.30 Commented [KM3]: From Amendment 4 1 1 Figure 2.3-5 35.76 Long Fuel 2 2 Figure 2.3-6 35.57 (Note 3)

MPC-37 3 1 Figure 2.3-7 37.06 Short Fuel 3 Figure 2.3-8 34.28 (Note 3) 3 Figure 2.3-12 33.46 Standard Fuel 3 Figure 2.3-8 34.28 (Note 3) 3 Figure 2.3-12 33.46 3 Figure 2.3-9 36.19 Long Fuel (Note 3) 3 Figure 2.3-12 33.46 16x16A Fuel with up to 32.3 3 Figure 2.3-14 37 DFCs (Note 6) (Note 5) 1 Figure 2.3-10 36.32 MPC-89 2 Figure 2.3-11 36.72 2 Figure 2.3-13 34.75 Notes:

1. For helium backfill pressure option pressure ranges see Appendix A, Table 3-2

2. For the details on the use of VDS to dry High Burnup Fuel see Appendix A, Table Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-17 Page 64 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 3-1

3. See Table 2.1-4 for fuel length data

4. Aggregate heat load is defined as the sum of heat loads of all stored fuel assemblies. The permissible aggregate heat load is set to 80% of the design basis heat load.

5. This aggregate heat load has been calculated with significant margin to fuel cladding limits, and is therefore not subject to the 80% penalty.

6. As stated in Table 2.1-1 Item I.B, this can include undamaged fuel both in DFCs and not, and damaged fuel in DFCs. These heat load limits apply with one or more undamaged fuel assemblies stored in DFCs.

7. For MPC-37 Type 1, the permissible Aggregate Heat Load is given in Table 2.3-2 Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-18 Page 65 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 TABLE 2.3-2 HI-STORM UMAX MPC-37 TYPE 1 PERMISSIBLE HEAT LOADS Fuel Type (Note 1) Helium Backfill Pressure Heat Load Permissible Option (Note 2) per Storage Aggregate Heat Cell Load (Note 3), kW Standard Fuel 1 Figure 2.3-15 32.3 Note 1: See Table 2.1-4 for fuel length data Note 2: For helium backfill pressure option pressure ranges see Appendix A, Table 3-2 Note 3: The aggregate heat load is defined as a sum of all stored fuel assemblies. Commented [KM4]: From Amendment 4 Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-19 Page 66 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 2.3.2 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.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-20 Page 67 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.873 0.873 0.873 4 5 6 7 8 0.873 1.602 1.602 1.602 0.873 9 10 11 12 13 14 15 0.873 1.602 1.017 1.017 1.017 1.602 0.873 16 17 18 19 20 21 22 0.873 1.602 1.017 1.017 1.017 1.602 0.873 23 24 25 26 27 28 29 0.873 1.602 1.017 1.017 1.017 1.602 0.873 30 31 32 33 34 0.873 1.602 1.602 1.602 0.873 35 36 37 0.873 0.873 0.873 Legend Cell ID Heat Load, kW Figure 2.3-1 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 1 for Long-term Storage for Short and Standard Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-21 Page 68 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 1.215 1.215 1.215 4 5 6 7 8 1.215 1.080 1.080 1.080 1.215 9 10 11 12 13 14 15 1.215 1.080 1.080 1.080 1.080 1.080 1.215 16 17 18 19 20 21 22 1.215 1.080 1.080 1.080 1.080 1.080 1.215 23 24 25 26 27 28 29 1.215 1.080 1.080 1.080 1.080 1.080 1.215 30 31 32 33 34 1.215 1.080 1.080 1.080 1.215 35 36 37 1.215 1.215 1.215 Legend Cell ID Heat Load, kW Figure 2.3-2 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 2 for Long-term Storage for Short and Standard Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-22 Page 69 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.922 0.922 0.922 4 5 6 7 8 0.922 1.520 1.520 1.520 0.922 9 10 11 12 13 14 15 0.922 1.710 0.950 0.950 0.950 1.710 0.922 16 17 18 19 20 21 22 0.922 1.520 0.950 0.570 0.950 1.520 0.922 23 24 25 26 27 28 29 0.922 1.710 0.950 0.950 0.950 1.710 0.922 30 31 32 33 34 0.922 1.520 1.520 1.520 0.922 35 36 37 0.922 0.922 0.922 Legend Cell ID Heat Load, kW Figure 2.3-3 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 3 for Long-term Storage for Short Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-23 Page 70 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.970 0.970 0.970 4 5 6 7 8 0.970 1.600 1.600 1.600 0.970 9 10 11 12 13 14 15 0.970 1.800 1.000 1.000 1.000 1.800 0.970 16 17 18 19 20 21 22 0.970 1.600 1.000 0.600 1.000 1.600 0.970 23 24 25 26 27 28 29 0.970 1.800 1.000 1.000 1.000 1.800 0.970 30 31 32 33 34 0.970 1.600 1.600 1.600 0.970 35 36 37 0.970 0.970 0.970 Legend Cell ID Heat Load, kW Figure 2.3-4 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 3 for Long-term Storage for Standard Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-24 Page 71 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.922 0.922 0.922 4 5 6 7 8 0.922 1.691 1.691 1.691 0.922 9 10 11 12 13 14 15 0.922 1.691 1.074 1.074 1.074 1.691 0.922 16 17 18 19 20 21 22 0.922 1.691 1.074 1.074 1.074 1.691 0.922 23 24 25 26 27 28 29 0.922 1.691 1.074 1.074 1.074 1.691 0.922 30 31 32 33 34 0.922 1.691 1.691 1.691 0.922 35 36 37 0.922 0.922 0.922 Legend Cell ID Heat Load, kW Figure 2.3-5 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 1 for Long-term Storage for Long Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-25 Page 72 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 1.283 1.283 1.283 4 5 6 7 8 1.283 1.140 1.140 1.140 1.283 9 10 11 12 13 14 15 1.283 1.140 1.140 1.140 1.140 1.140 1.283 16 17 18 19 20 21 22 1.283 1.140 1.140 1.140 1.140 1.140 1.283 23 24 25 26 27 28 29 1.283 1.140 1.140 1.140 1.140 1.140 1.283 30 31 32 33 34 1.283 1.140 1.140 1.140 1.283 35 36 37 1.283 1.283 1.283 Legend Cell ID Heat Load, kW Figure 2.3-6 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 2 for Long-term Storage for Long Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-26 Page 73 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 1.019 1.019 1.019 4 5 6 7 8 1.019 1.680 1.680 1.680 1.019 9 10 11 12 13 14 15 1.019 1.890 1.050 1.050 1.050 1.890 1.019 16 17 18 19 20 21 22 1.019 1.680 1.050 0.630 1.050 1.680 1.019 23 24 25 26 27 28 29 1.019 1.890 1.050 1.050 1.050 1.890 1.019 30 31 32 33 34 1.019 1.680 1.680 1.680 1.019 35 36 37 1.019 1.019 1.019 Legend Cell ID Heat Load, kW Figure 2.3-7 HI-STORM UMAX MPC-37 Permissible Heat Load Chart 3 for Long-term Storage for Long Fuel Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-27 Page 74 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.785 0.785 0.785 4 5 6 7 8 0.785 1.441 1.441 1.441 0.785 9 10 11 12 13 14 15 0.785 1.441 0.915 0.915 0.915 1.441 0.785 16 17 18 19 20 21 22 0.785 1.441 0.915 0.915 0.915 1.441 0.785 23 24 25 26 27 28 29 0.785 1.441 0.915 0.915 0.915 1.441 0.785 30 31 32 33 34 0.785 1.441 1.441 1.441 0.785 35 36 37 0.785 0.785 0.785 Legend Cell ID Heat Load, kW Figure 2.3-8 HI-STORM UMAX MPC-37 Permissible Heat Load for Short and Standard Fuel for Helium Backfill Option 3 in Table 3-2 of Appendix A Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-28 Page 75 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.829 0.829 0.829 4 5 6 7 8 0.829 1.521 1.521 1.521 0.829 9 10 11 12 13 14 15 0.829 1.521 0.966 0.966 0.966 1.521 0.829 16 17 18 19 20 21 22 0.829 1.521 0.966 0.966 0.966 1.521 0.829 23 24 25 26 27 28 29 0.829 1.521 0.966 0.966 0.966 1.521 0.829 30 31 32 33 34 0.829 1.521 1.521 1.521 0.829 35 36 37 0.829 0.829 0.829 Legend Cell ID Heat Load, kW Figure 2.3-9 HI-STORM UMAX MPC-37 Permissible Heat Load for Long Fuel for Helium Backfill Option 3 in Table 3-2 of Appendix A Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-29 Page 76 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.431 0.431 0.431 4 5 6 7 8 9 10 0.431 0.431 0.431 0.607 0.431 0.431 0.431 11 12 13 14 15 16 17 18 19 0.431 0.431 0.607 0.607 0.607 0.607 0.607 0.431 0.431 20 21 22 23 24 25 26 27 28 0.431 0.607 0.607 0.607 0.607 0.607 0.607 0.607 0.431 29 30 31 32 33 34 35 36 37 38 39 0.431 0.431 0.607 0.607 0.431 0.431 0.431 0.607 0.607 0.431 0.431 40 41 42 43 44 45 46 47 48 49 50 0.431 0.607 0.607 0.607 0.431 0.431 0.431 0.607 0.607 0.607 0.431 51 52 53 54 55 56 57 58 59 60 61 0.431 0.431 0.607 0.607 0.431 0.431 0.431 0.607 0.607 0.431 0.431 62 63 64 65 66 67 68 69 70 0.431 0.607 0.607 0.607 0.607 0.607 0.607 0.607 0.431 71 72 73 74 75 76 77 78 79 0.431 0.431 0.607 0.607 0.607 0.607 0.607 0.431 0.431 80 81 82 83 84 85 86 0.431 0.431 0.431 0.607 0.431 0.431 0.431 87 88 89 0.431 0.431 0.431 Legend Figure 2.3-10 Cell ID HI-STORM UMAX MPC-89 Permissible Heat Load for Long-Term Storage Heat Load, kW Note that this figure shows the per cell heat load limit for storage.

The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-30 Page 77 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.387 0.387 0.387 4 5 6 7 8 9 10 0.387 0.387 0.387 0.546 0.387 0.387 0.387 11 12 13 14 15 16 17 18 19 0.387 0.387 0.546 0.546 0.546 0.546 0.546 0.387 0.387 20 21 22 23 24 25 26 27 28 0.387 0.546 0.546 0.546 0.546 0.546 0.546 0.546 0.387 29 30 31 32 33 34 35 36 37 38 39 0.387 0.387 0.546 0.546 0.387 0.387 0.387 0.546 0.546 0.387 0.387 40 41 42 43 44 45 46 47 48 49 50 0.387 0.546 0.546 0.546 0.387 0.387 0.387 0.546 0.546 0.546 0.387 51 52 53 54 55 56 57 58 59 60 61 0.387 0.387 0.546 0.546 0.387 0.387 0.387 0.546 0.546 0.387 0.387 62 63 64 65 66 67 68 69 70 0.387 0.546 0.546 0.546 0.546 0.546 0.546 0.546 0.387 71 72 73 74 75 76 77 78 79 0.387 0.387 0.546 0.546 0.546 0.546 0.546 0.387 0.387 80 81 82 83 84 85 86 0.387 0.387 0.387 0.546 0.387 0.387 0.387 87 88 89 0.387 0.387 0.387 Legend Figure 2.3-11 HI-STORM UMAX MPC-89 Permissible Heat Load for Helium Backfill Cell ID Option 2 in Table 3-2 of Appendix A Heat Load, kW Note that this figure shows the per cell heat load limit for storage.

The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-31 Page 78 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.97 0.97 0.97 4 5 6 7 8 0.97 0.97 0.97 0.97 0.97 9 10 11 12 13 14 15 0.97 0.97 0.7 0.7 0.7 0.97 0.97 16 17 18 19 20 21 22 0.97 0.97 0.7 0.7 0.7 0.97 0.97 23 24 25 26 27 28 29 0.97 0.97 0.7 0.7 0.7 0.97 0.97 30 31 32 33 34 0.97 0.97 0.97 0.97 0.97 35 36 37 0.97 0.97 0.97 Legend Cell ID Heat Load, kW Figure 2.3-12 HI-STORM UMAX MPC-37 Permissible Threshold Heat Load for VDS High Burnup Fuel in Table 3-1 of Appendix A and Helium Backfill Option 3 in Table 3-2 of Appendix A Note that this figure shows the per cell heat load limit for storage. The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-32 Page 79 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.44 0.44 0.44 4 5 6 7 8 9 10 0.44 0.44 0.44 0.35 0.44 0.44 0.44 11 12 13 14 15 16 17 18 19 0.44 0.44 0.35 0.35 0.35 0.35 0.35 0.44 0.44 20 21 22 23 24 25 26 27 28 0.44 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.44 29 30 31 32 33 34 35 36 37 38 39 0.44 0.44 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.44 0.44 40 41 42 43 44 45 46 47 48 49 50 0.44 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.44 51 52 53 54 55 56 57 58 59 60 61 0.44 0.44 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.44 0.44 62 63 64 65 66 67 68 69 70 0.44 0.35 0.35 0.35 0.35 0.35 0.35 0.35 0.44 71 72 73 74 75 76 77 78 79 0.44 0.44 0.35 0.35 0.35 0.35 0.35 0.44 0.44 80 81 82 83 84 85 86 0.44 0.44 0.44 0.35 0.44 0.44 0.44 87 88 89 0.44 0.44 0.44 Legend Figure 2.3-13 Cell ID HI-STORM UMAX MPC-89 Permissible Threshold Heat Load for VDS High Burnup Fuel in Table 3-1 of Appendix A and Helium Backfill Option Heat Load, kW 2 in Table 3-2 of Appendix A Note that this figure shows the per cell heat load limit for storage.

The total permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-1 for corresponding permissible aggregate heat load.

Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-33 Page 80 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 1 2 3 0.80 0.80 0.80 4 5 6 7 8 1.00 1.00 1.40 1.00 1.00 9 10 11 12 13 14 15 0.80 1.00 0.60 0.60 0.60 1.00 0.80 16 17 18 19 20 21 22 0.80 1.40 0.60 0.30 0.60 1.40 0.80 23 24 25 26 27 28 29 0.80 1.00 0.60 0.60 0.60 1.00 0.80 30 31 32 33 34 1.00 1.00 1.40 1.00 1.00 35 36 37 0.80 0.80 0.80 Legend Cell ID Heat Load, kW Figure 2.3-14 HI-STORM UMAX MPC-37 Permissible Heat Load for 16x16A Undamaged Fuel with up to Thirty-seven DFCs Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-34 Page 81 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 0.725 0.865 0.725 0.66 1.075 1.24 1.075 0.66 0.725 1.075 0.775 0.865 0.775 1.075 0.725 0.865 1.24 0.865 0.285 0.865 1.24 0.865 0.725 1.075 0.775 0.865 0.775 1.075 0.725 0.66 1.075 1.24 1.075 0.66 0.725 0.865 0.725 Legend Cell ID Heat Load, kW Figure 2.3-15: HI-STORM UMAX MPC-37 Type 1 Heat Permissible Heat Loads (All storage cell heat loads are in kW)

Note that this figure shows the per cell heat load limit for storage. The permissible aggregate heat load may be less than the sum of each individual cell heat load. See Table 2.3-2 for corresponding permissible aggregate heat load and the helium backfill option. Commented [KM5]: From Amendment 4 Certificate of Compliance No.1040 Amendment No. 3 Appendix B 2-35 Page 82 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 3.0 DESIGN FEATURES 3.1 Site 3.1.1 Site Location The HI-STORM UMAX Canister Storage System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.

3.2 Design Features Important for Criticality Control 3.2.1 MPC-37

1. Basket cell ID: 8.92 in. (min. nominal)

2. Basket cell wall thickness: 0.57 in. (min.nominal )

3. B4C in the Metamic-HT: 10.0 wt % (min. nominal) 3.2.2 MPC-89

1. Basket cell ID: 5.99 in. (min.nominal)

2. Basket cell wall thickness: 0.38 in. (min.nominal)

3. B4C in the Metamic-HT: 10.0 wt % (min. nominal) 3.2.3 Metamic-HT Test Requirements

1. The weight percentage of the boron carbide must be confirmed to be greater than or equal to 10% in each lot of Al/ B4C powder.

2. The areal density of the B-10 isotope corresponding to the 10%

min. weight density in the manufactured Metamic HT panels shall be independently confirmed by the neutron attenuation test method by testing at least one coupon from a randomly selected panel in each lot.

3. If the B- 10 areal density criterion in the tested panel fails to meet the specified minimum, then the manufacturer has the option to reject the entire lot or to test a statistically significant number of panels and perform statistical analysis to show that the minimum areal density in the panels (that comprise the lot) is satisfied with 95% confidence.

4. All test procedures used in demonstrating compliance with the above requirements shall conform to the cask designer's QA program which has been approved by the USNRC under docket number 71-0784.

3.3 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2007, is the governing Code for the HI-STORM UMAX system MPC as Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-1 Page 83 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 clarified in Specification 3.3.1 below, except for Code Sections V and IX. However, the HI-STORM UMAX VVM is structurally qualified per the newer 2010 ASME code. The ASME Code paragraphs applicable to the manufacturing of HI-STORM UMAX VVM and transfer cask are listed in Table 3-2. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the applicable edition (including addenda) specified above, is performed by the certificate holder.

American Concrete Institute ACI-318 (2005) is the governing Code for both plain concrete and reinforced concrete as clarified in Chapter 3 of the Final Safety Analysis Report for the HI-STORM 100 UMAX System.

3.3.1 Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the MPCs of the HI-STORM UMAX Canister Storage System.

3.3.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code,Section III, 2007 Edition, including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternative should demonstrate that:

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

2. Compliance with the specified requirements of the ASME Code,Section III, 2007 Edition, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-2 Page 84 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 3.0 DESIGN FEATURES (continued)

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Subsection General Requirements. Because the MPC is not an ASME Enclosure NCA Requires preparation of a Code stamped vessel, none of the Vessel Design Specification, specifications, reports, certificates, or Design Report, other general requirements specified by Overpressure Protection NCA are required. In lieu of a Design Report, Certification of Specification and Design Report, the Construction Report, Data HI-STORM FSAR includes the design Report, and other criteria, service conditions, and load administrative controls for combinations for the design and an ASME Code stamped operation of the MPCs as well as the vessel. results of the stress analyses to demonstrate that applicable Code stress limits are met. Additionally, the fabricator is not required to have an ASME-certified QA program. All important-to-safety activities are governed by the NRC-approved Holtec QA program.

Because the cask components are not certified to the Code, the terms Certificate Holder and Inspector are not germane to the manufacturing of NRC-certified cask components. To eliminate ambiguity, the responsibilities assigned to the Certificate Holder in the Code, as applicable, shall be interpreted to apply to the NRC Certificate of Compliance (CoC) holder (and by extension, to the component fabricator) if the requirement must be fulfilled. The Code term Inspector means the QA/QC personnel of the CoC holder and its vendors assigned to oversee and inspect the manufacturing process.

MPC NB-1100 Statement of requirements MPC Enclosure Vessel is designed and Enclosure for Code stamping of will be fabricated in accordance with Vessel components. ASME Code,Section III, Subsection NB to the maximum practical extent, but Code stamping is not required.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-3 Page 85 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC basket NB-1130 NB-1132.2(d) requires that The lugs that are used exclusively for supports the first connecting weld of lifting an empty MPC are welded to the and lift lugs a non-pressure retaining inside of the pressure-retaining MPC structural attachment to a shell, but are not designed in component shall be accordance with Subsection NB. The considered part of the lug-to-Enclosure Vessel Weld is component unless the weld required to meet the stress limits of is more than 2t from the Reg. Guide 3.61 in lieu of Subsection pressure retaining portion NB of the Code.

of the component, where t is the nominal thickness of the pressure retaining material.

NB-1132.2(e) requires that the first connecting weld of a welded nonstructural attachment to a component shall conform to NB-4430 if the connecting weld is within 2t from the pressure retaining portion of the component.

MPC NB-2000 Requires materials to be Materials will be supplied by Holtec Enclosure supplied by ASME- approved suppliers with Certified Vessel approved material supplier. Material Test Reports (CMTRs) in accordance with NB-2000 requirements.

MPC NB-3100 Provides requirements for These requirements are subsumed by Enclosure NF-3100 determining design loading the HI-STORM FW FSAR, serving as Vessel conditions, such as the Design Specification, which pressure, temperature, and establishes the service conditions and mechanical loads. load combinations for the storage system.

MPC NB-4120 NB-4121.2 and NF-4121.2 In-shop operations of short duration that Enclosure provide requirements for apply heat to a component, such as Vessel repetition of tensile or plasma cutting of plate stock, welding, impact tests for material machining, and coating are not, unless subjected to heat treatment explicitly stated by the Code, defined as during fabrication or heat treatment operations.

installation.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-4 Page 86 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC NB-4220 Requires certain forming The cylindricity measurements on the Enclosure tolerances to be met for rolled shells are not specifically Vessel cylindrical, conical, or recorded in the shop travelers, as would spherical shells of a vessel. be the case for a Code-stamped pressure vessel. Rather, the requirements on inter-component clearances (such as the MPC-to-transfer cask) are guaranteed through fixture-controlled manufacturing. The fabrication specification and shop procedures ensure that all dimensional design objectives, including inter-component annular clearances are satisfied. The dimensions required to be met in fabrication are chosen to meet the functional requirements of the dry storage components. Thus, although the post-forming Code cylindricity requirements are not evaluated for compliance directly, they are indirectly satisfied (actually exceeded) in the final manufactured components.

MPC NB-4122 Implies that with the MPCs are built in lots. Material Enclosure exception of studs, bolts, traceability on raw materials to a heat Vessel nuts and heat exchanger number and corresponding CMTR is tubes, CMTRs must be maintained by Holtec through markings traceable to a specific on the raw material. Where material is piece of material in a cut or processed, markings are component. transferred accordingly to assure traceability. As materials are assembled into the lot of MPCs being manufactured, documentation is maintained to identify the heat numbers of materials being used for that item in the multiple MPCs being manufactured under that lot. A specific item within a specific MPC will have a number of heat numbers identified as possibly being used for the item in that particular MPC of which one or more of those heat numbers (and corresponding CMTRS) will have actually been used. All of the heat numbers identified will comply with the requirements for the particular item.

MPC Lid and NB-4243 Full penetration welds MPC lid and closure ring are not full Closure Ring required for Category C penetration welds. They are welded Welds Joints (flat head to main independently to provide a redundant shell per NB-3352.3) seal.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-5 Page 87 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Closure NB-5230 Radiographic (RT) or Root (if more than one weld pass is Ring, Vent and ultrasonic (UT) required) and final liquid penetrant Drain Cover examination required. examination to be performed in Plate Welds accordance with NB-5245. The closure ring provides independent redundant closure for vent and drain cover plates.

Vent and drain port cover plate welds are helium leakage tested.

MPC Lid to NB-5230 Radiographic (RT) or Only progressive liquid penetrant (PT)

Shell Weld ultrasonic (UT) examination is permitted. PT examination required. examination will include the root and final weld layers and each approx. 3/8" of weld depth.

MPC NB-6111 All completed pressure The MPC vessel is welded in the field Enclosure retaining systems shall be following fuel assembly loading. After Vessel and Lid pressure tested. the lid to shell weld is completed, the MPC shall then be pressure tested as defined in Chapter 10. Accessibility for leakage inspections precludes a Code compliant pressure test. Since the shell welds of the MPC cannot be checked for leakage during this pressure test, the shop leakage test to 10-7 ref cc/sec provides reasonable assurance as to its leak tightness. All MPC enclosure vessel welds (except closure ring and vent/drain cover plate) are inspected by volumetric examination. The MPC lid-to-shell weld shall be verified by progressive PT examination. PT must include the root and final layers and each approximately 3/8 inch of weld depth.

The inspection results, including relevant findings (indications) shall be made a permanent part of the users records by video, photographic, of other means which provide an equivalent record of weld integrity. The video or photographic records should be taken during the final interpretation period described in ASME Section V, Article 6, T-676. The vent/drain cover plate and the closure ring welds are confirmed by liquid penetrant examination. The inspection of the weld must be performed by qualified personnel and shall meet the acceptance requirements of ASME Code Section III, NB-5350.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-6 Page 88 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC NB-7000 Vessels are required to No overpressure protection is provided.

Enclosure have overpressure Function of MPC enclosure vessel is to Vessel protection. contain radioactive contents under normal, off-normal, and accident conditions of storage. MPC vessel is designed to withstand maximum internal pressure considering 100% fuel rod failure and maximum accident temperatures.

MPC NB-8000 States requirements for The HI-STORM UMAX system is to be Enclosure nameplates, stamping and marked and identified in accordance Vessel reports per NCA-8000. with 10CFR71 and 10CFR72 requirements. Code stamping is not required. QA data package to be in accordance with Holtec approved QA program.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-7 Page 89 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR VVM PRIMARY LOAD BEARING PARTS Item Code Explanation and Applicability Paragraph

[2.6.1]

1. Definition of primary and NF-1215 -

secondary members

2. Jurisdictional boundary NF-1133 The VVMs jurisdictional boundary is defined by the bottom surface of the SFP, the top surface of the ISFSI pad and the SES side surfaces.

3. Certification of NF-2130(b) and Materials shall be certified to material(structural) (c) the applicable Section II of the ASME Code or equivalent ASTM Specification.

4. Heat treatment of material NF-2170 and -

NF-2180

5. Storage of welding material NF-2400 -

6. Welding procedure Section IX -

7. Welding material Section II -

8. Loading conditions NF-3111 -

9. Allowable stress values NF-3112.3 -

10. Rolling and sliding NF-3424 -

supports

11. Differential thermal NF-3127 -

expansion

12. Stress analysis NF-3143 Provisions for stress analysis NF-3380 for Class 3 plate and shell NF-3522 supports and for linear supports NF-3523 are applicable for Closure Lid and Container Shell, respectively.

13. Cutting of plate stock NF-4211 -

NF-4211.1

14. Forming NF-4212 -

15. Forming tolerance NF-4221 Applies to the Container Shell

16. Fitting and Aligning Tack NF-4231 -

Welds NF-4231.1

17. Alignment NF-4232 -

18. Storage of Welding NF-4411 -

Materials

19. Cleanliness of Weld NF-4412 Applies to structural and non-Surfaces structural welds Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-8 Page 90 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR VVM PRIMARY LOAD BEARING PARTS Item Code Explanation and Applicability Paragraph

[2.6.1]

20. Backing Strips, Peening NF-4421 Applies to structural and non-NF-4422 structural welds

21. Pre-heating and Interpass NF-4611 Applies to structural and non-Temperature NF-4612 structural welds NF-4613

22. Non-Destructive NF-5360 InvokesSection V Examination

23. NDE Personnel NF-5522 -

Certification NF-5523 NF-5530 Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-9 Page 91 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 3.0 DESIGN FEATURES (continued) 3.4 Site-Specific Parameters and Analyses Site-specific parameters and analyses that will require verification by the system user are, as a minimum, as follows:

1. The temperature of 80o F is the maximum average yearly temperature.

2. The allowed temperature extremes, averaged over a 3-day period, shall be greater than -40o F and less than 125o F.

3. The resultant zero period acceleration at the top of the grade and at the elevation of the Support Foundation Pad (SFP) at the host site (computed by the Newmarks rule as the sum of A+0.4*B+0.4*C, where A, B, C denote the free field ZPAs in the three orthogonal directions in decreasing magnitude, i.e., A B C) shall be less than or equal to 1.3 and 1.214, respectively.

For HI-STORM UMAX Version MSE, the corresponding Newmark sum of the ZPAs at the top of the Support Foundation Pad is limited to 2.121 Gs and the vertical ZPA is limited to 1.0G.

4. The analyzed flood condition of 15 fps water velocity and a height of 125 feet of water (full submergence of the loaded cask) are not exceeded.

5. The potential for fire and explosion shall be based on site-specific considerations. The user shall demonstrate that the site-specific potential for fire is bounded by the fire conditions analyzed by the Certificate Holder, or an analysis of the site-specific fire considerations shall be performed.

6. The moment and shear capacities of the ISFSI Structures shall meet the structural requirements under the load combinations in Table 3-3.

7. Radiation Protection Space (RPS) as defined in Subsection 5.3.9 of Appendix A, is intended to ensure that the subgrade material in and around the lateral space occupied by the VVMs remains essentially intact under all service conditions including during an excavation activity adjacent to the RPS.

8. The SFP for a VVM array established in any one construction campaign shall be of monolithic construction, to the extent practicable, to maximize the physical stability of the underground installation.

9. Excavation activities contiguous to a loaded UMAX ISFSI on the side facing the excavation can occur down to the depth of the bottom surface of the SFP of the loaded ISFSI (i.e. within the area labeled Space B in Figure 3-1) considering that there may be minor variations in the depth due to normal construction practices. For excavation activities which are contiguous to the loaded ISFSI (within a distance W, see Figure 3-1) and below the depth of the bottom surface of the SFP (i.e. within the area labeled Space D in Figure 3-1), asite-specific seismic analysis will be performed to demonstrate the stability of the RPS boundary and structural Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-10 Page 92 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 integrity of the ISFSI structure. This analysis shall be submitted to Holtec International to be incorporated in an amendment request for NRC review and approval prior to any excavation taking place.

10. In cases where engineered features (i.e., berms and shield walls) are used to ensure that the requirements of 10CFR72.104(a) are met, such features are to be considered important-to-safety and must be evaluated to determine the applicable quality assurance category.

11. LOADING OPERATIONS, TRANSPORT OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area Ambient Temperature 0o F.

12. For those users whose site-specific design basis includes an event or events (e.g., flood) that result in the blockage of any VVM inlet or outlet air ducts for an extended period of time (i.e., longer than the total Completion Time of LCO 3.1.2), an analysis or evaluation may be performed to demonstrate adequate heat removal is available for the duration of the event. Adequate heat removal is defined as fuel cladding temperatures remaining below the short term temperature limit. If the analysis or evaluation is not performed, or if fuel cladding temperature limits are unable to be demonstrated by analysis or evaluation to remain below the short term temperature limit for the duration of the event, provisions shall be established to provide alternate means of cooling to accomplish this objective.

13. Users shall establish procedural and/or mechanical barriers to ensure that during LOADING OPERATIONS and UNLOADING OPERATIONS, either the fuel cladding is covered by water, or the MPC is filled with an inert gas.

14. The entire haul route shall be evaluated to ensure that the route can support the weight of the loaded transfer cask and its conveyance.

15. The loaded transfer cask and its conveyance shall be evaluated to ensure, under the site specific Design Basis Earthquake, that the cask and its conveyance does not tipover or slide off the haul route.

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-11 Page 93 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-3 LOAD COMBINATIONS FOR THE TOP SURFACE PAD, ISFSI PAD, AND SUPPORT FOUNDATION PAD PER ACI-318 (2005)

Load Combination Case Load Combination LC-1 1.4D LC-2 1.2D + 1.6L LC-3 1.2D + E + L where:

D: Dead Load including long-term differential settlement effects.

L: Live Load E: DBE for the Site Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-12 Page 94 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-4 Values of Principal Design Parameters for the Underground ISFSI Thickness of the Support Foundation Pad, inch 33 (nominal)

Thickness of the ISFSI Pad and curb, inch 34 (nominal)

Thickness of the ISFSI Pad, inch (nominal) 30 Rebar Size* and Layout* (nominal) #11 @ 9" each face, each direction Rebar Concrete Cover (top and bottom)*, inch per 7.7.1 of ACI-318 (2005)

Compressive Strength of Concrete at 28 4500 days*, psi Compressive Strength of Self-hardening 1,000 Engineered Subgrade (SES), psi For Version MSE only, the Compressive 3000 Strength of plain concrete, psi Lower Bound Shear Wave Velocity in the 1,300 Subgrade lateral to the VVM (Figure 3-1 Space A), fps**

Depth Averaged Density of subgrade in Space 120 A. (Figure 3-1)1 (lb/ft3)

Depth Averaged Density of subgrade in Space 110 B. (Figure 3-1)1 (lb/ft3)

Depth Averaged Density of subgrade in Space 120 C. (Figure 3-1)2 (lb/ft3)

Depth Averaged Density of subgrade in Space 120 D. (Figure 3-1)3 (lb/ft3)

Lower Bound Shear Wave Velocity in the 485 Subgrade below the Support Foundation Pad (Figure 3-1 Space C & D), fps**

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-13 Page 95 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 Lower Bound Shear Wave Velocity in the 450 Subgrade laterally surrounding the ISFSI (Figure 3-1 Space B), fps**

For Version MSE only, Nominal Strain compatible Shear wave Velocity in Space B, fps 344

Applies to Support Foundation Pad and ISFSI Pad.

- Strain compatible effective shear wave velocities shall be computed using the guidance provided in Section 16 of the International Building Code, 2009 Edition. Users must account for potential variability in the subgrade shear wave velocity in accordance with Section 3.7.2 of NUREG-0800.

Notes:

1. A lower average density value may be used in shielding analysis per FSAR Chapter 5 for conservatism.

2. Not required for shielding, not credited in Version MSE model.

3. This space will typically contain native soil. Not required for shielding, not credited in Version MSE model.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-14 Page 96 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 Figure 3 SUBGRADE AND UNDERGRADE SPACE NOMENCLATURE Note: W is a representative dimension of the ISFSI determined by site-specific layouts Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-15 Page 97 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 3.0 DESIGN FEATURES (continued) 3.5 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.

3.6 Periodic Corrosion Inspections for Underground Systems HI-STORM UMAX VVM ISFSIs not employing an impressed current cathodic protection system shall be subject to visual and UT inspection of at least one representative VVM to check for significant corrosion of the CEC Container Shell and Bottom Plate at an interval not to exceed 20 years. The VVM chosen for inspection is not required to be in use or to have previously contained a loaded MPC. The VVM considered to be most vulnerable to corrosion degradation shall be selected for inspection. If significant corrosion is identified, either an evaluation to demonstrate sufficient continued structural integrity (sufficient for at least the remainder of the licensing period) shall be performed or the affected VVM shall be promptly scheduled for repair or decommissioning. Through wall corrosion shall not be permitted without promptly scheduling for repair or decommissioning. Promptness of repair or decommissioning shall be commensurate with the extent of degradation of the VVM but shall not exceed 3 years from the date of inspection.

If the representative VVM is determined to require repair or decommissioning, the next most vulnerable VVM shall be selected for inspection. This inspection process shall conclude when a VVM is found that does not require repair or decommissioning. Since the last VVM inspected is considered more prone to corrosion than the remaining un-inspected VVMs, the last VVM inspected becomes the representative VVM for the remaining VVMs.

Inspections Visual Inspection: Visual inspection of the inner surfaces of the CEC Container Shell and Bottom Plate for indications of significant or through wall corrosion (i.e.,

holes).

UT Inspection: The UT inspection or an equivalent method shall be used to measure CEC shell wall thickness to determine the extent of metal loss from corrosion. A minimum of 16 data points shall be obtained, 4 near the top, 4 near the mid-height and 4 near the bottom of the CEC Container Shell all approximately 0, 90, 180, and 270 degrees apart; and 4 on the CEC Bottom Plate near the CEC Container Shell approximately 0, 90, 180, and 270 degrees apart. Locations where visual inspection has identified potentially significant corrosion shall also receive UT inspection. Locations suspected of significant corrosion may receive further UT inspection to determine the extent of corrosion.

Inspection Criteria Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-16 Page 98 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 General wall thinning exceeding 1/8 in depth and local pitting exceeding 1/4" in depth are conditions of significant corrosion.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix B 3-17 Page 99 of 148

Attachment 2 to Holtec Letter 5021069 CERTIFICATE OF COMPLIANCE NO. 1040 APPENDIX C TECHNICAL SPECIFICATIONS FOR THE STORAGE OF 24PT1-DSC IN HI-STORM UMAX CANISTER STORAGE SYSTEM Page 100 of 148

Attachment 2 to Holtec Letter 5021069 TABLE OF CONTENTS 1.0 USE AND APPLICATION ............................................................................. 1.1-1 1.1 Definitions ............................................................................................ 1.1-1 1.2 Logical Connectors .............................................................................. 1.2-1 1.3 Completion Times ................................................................................ 1.3-1 1.4 Frequency ............................................................................................ 1.4-1 2.0 NOT USED 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY ............ 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............................. 3.0-2 3.1 SFSC INTEGRITY ............................................................................ 3.1.1-1 3.1.1 SFSC Heat Removal System ................................................. 3.1.1-1 4.0 NOT USED .................................................................................................. 4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS ...................................... 5.0-1 5.1 Radioactive Effluent Control Program .................................................. 5.0-1 5.2 Transport Evaluation Program ............................................................. 5.0-2 5.3 Radiation Protection Program .............................................................. 5.0-3 5.4 DSC Verification Requirements ........................................................... 5.0-5 Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-i Page 101 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.0 USE AND APPLICATION

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

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

1.1 Definitions 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.

AMBIENT TEMPERATURE AMBIENT TEMPERATURE for Short Term Operations (operations involving use of the HI-TRAC, a Lifting device, and/or an on-site transport device) is defined as the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average of the local temperature as forecast by the National Weather Service.

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

DAMAGED FUEL ASSEMBLY DAMAGED FUEL ASSEMBLY is a fuel assembly with (for 24PT1-DSC only) known or suspected cladding defects greater than pinhole leaks or hairline cracks or an assembly with partial or missing rods.

DRY SHIELDED CANISTER DSC is a welded pressure vessel that provides confinement of INTACT or DAMAGED FUEL (DSC)

ASSEMBLIES in an inert atmosphere FAILED FUEL CAN A FAILED FUEL CAN confines any loose material and gross fuel particles to a known, subcritical volume during normal, off-normal and accident conditions and facilitates handling and retrievability.

FUEL DEBRIS (24PT1) An intact or partial fuel rod not contained in a fuel assembly grid or an individual intact or partial fuel pellet not contained in a fuel rod. FUEL DEBRIS may be inserted in a ROD STORAGE BASKET.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-1 Page 102 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.1 Definitions Term Definition 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.

INTACT FUEL ASSEMBLY Spent nuclear fuel assemblies without known or (24PT1) suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means.

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

STORAGE INSTALLATION (ISFSI)

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

OVERPACK For the HI-STORM UMAX, the term OVERPACK is synonyms with the term VVM defined below.

RECONSTITUED FUEL RECONSTITUTED FUEL ASSEMBLIES include ASSEMBLY (24PT1) assemblies in which leaking fuel rods are replaced with either stainless steel rods or intact fuel rods, and which could undergo further irradiation ROD STORAGE BASKET A 9x9 array of tubes in a lattice that has approximately the same dimensions as a standard fuel assembly SPENT FUEL STORAGE SFSCs are containers approved for the storage of CASKS (SFSCs) spent fuel assemblies at the ISFSI. The HI-STORM UMAX SFSC System consists of the OVERPACK and its integral canister.

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 CANISTER TRANSFER.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.1-2 Page 103 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.1 1.1 Definitions Term Definition TRANSFER CASK TRANSFER CASKs are containers designed to contain the canister during and after loading of spent fuel assemblies, and prior to and during unloading and to transfer the canister to or from the OVERPACK.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on a 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 TRANSFER CASK is first suspended from or secured on the transporter and end when the TRANSFER CASK is at its destination and no longer secured on or suspended from the transporter. TRANSPORT OPERATIONS includes DSC TRANSFER.

VERTICAL VENTILATED The VVM is a subterranean type overpack which MODULE (VVM) receives and contains the sealed canister for interim storage at the ISFSI. The VVM supports the MPC in a vertical orientation and provide gamma and neutron shielding and also provides air flow through cooling passages to promote heat transfer from the MPC to the environs.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SFSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the 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.

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. 1040 Amendment No. 3 Appendix C 1.1-3 Page 104 of 148

Attachment 2 to Holtec Letter 5021069 Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

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

BACKGROUND Several levels of logic may be used to state Required Actions.

These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

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

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.2-1 Page 105 of 148

Attachment 2 to Holtec Letter 5021069 Logical Connectors 1.2 1.2 Logical Connectors (continued)

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. 1040 Amendment No. 3 Appendix C 1.2-0 Page 106 of 148

Attachment 2 to Holtec Letter 5021069 Logical Connectors 1.2 1.2 Logical Connectors 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. 1040 Amendment No. 3 Appendix C 1.2-1 Page 107 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion 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 UMAX 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 UMAX 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. 1040 Amendment No. 3 Appendix C 1.3-1 Page 108 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

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 AND Completion 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. 1040 Amendment No. 3 Appendix C 1.3-2 Page 109 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

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

associated Completion AND Time not met.

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

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. 1040 Amendment No. 3 Appendix C 1.3-3 Page 110 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

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

Separate Condition entry is allowed for each component.

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

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

associated Completion AND Time not met.

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

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

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis. When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-4 Page 111 of 148

Attachment 2 to Holtec Letter 5021069 Completion Times 1.3 1.3 Completion Times (continued)

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

TIME Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 1.3-5 Page 112 of 148

Attachment 2 to Holtec Letter 5021069 Frequency 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR.

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. 1040 Amendment No. 3 Appendix C 1.4-1 Page 113 of 148

Attachment 2 to Holtec Letter 5021069 Frequency 1.4 1.4 Frequency (continued)

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

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the 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. 1040 Amendment No. 3 Appendix C 1.4-2 Page 114 of 148

Attachment 2 to Holtec Letter 5021069 Frequency 1.4 1.4 Frequency (continued)

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. 1040 Amendment No. 3 Appendix C 1.4-3 Page 115 of 148

Attachment 2 to Holtec Letter 5021069 2.0 2.0 This section is intentionally left blank Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 2.0-1 Page 116 of 148

Attachment 2 to Holtec Letter 5021069 LCO Applicability 3.0 3.0 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. 1040 Amendment No. 3 Appendix C 3.0-1 Page 117 of 148

Attachment 2 to Holtec Letter 5021069 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

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

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.0-2 Page 118 of 148

Attachment 2 to Holtec Letter 5021069 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period and the (continued) 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. 1040 Amendment No. 3 Appendix C 3.0-3 Page 119 of 148

Attachment 2 to Holtec Letter 5021069 Fuel Cool-Down 3.1.3 3.1 SFSC INTEGRITY 3.1.1 SFSC Heat Removal System LCO 3.1.1 The SFSC Heat Removal System shall be operable APPLICABILITY: During STORAGE OPERATIONS after closure lid installed. Commented [KM1]: Made to align with Amendment 4 ACTIONS

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

Separate Condition entry is allowed for each SFSC.

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

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

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 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months Removal System to operable status.

OR C.2.2 Transfer the DSC into a 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months TRANSFER CASK.

OR C.2.3 Perform an engineering 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months Commented [KM3]: Made to align with Amendment 4 evaluation to demonstrate that component temperatures are within allowable limits Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.1.1-1 Page 120 of 148

Attachment 2 to Holtec Letter 5021069 Fuel Cool-Down 3.1.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all VVM inlets and outlets duct screen are 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months free of blockage from solid debris or floodwater.

OR For VVMs with installed temperature monitoring 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months equipment, verify that the difference between the average VVM air outlet duct temperature and ISFSI ambient temperature is 49oF for VVMs containing 24PT1-DSCs.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 3.1.1-2 Page 121 of 148

Attachment 2 to Holtec Letter 5021069 4.0 4.0 This section is intentionally left blank Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 4.0-1 Page 122 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented and maintained.

5.1 Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d).

a. The HI-STORM UMAX Canister Storage System does not create any radioactive materials or have any radioactive waste treatment systems.

Therefore, specific operating procedures for the control of radioactive effluents are not required.

b. 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.

c. An annual report shall be submitted pursuant to 10 CFR 72.44(d)(3).

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-1 Page 123 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program

a. For lifting of the loaded CHA or TRANSFER CASK using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.

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

c. The TRANSFER CASK when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and CANISTER TRANSFER, provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.

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

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

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

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-2 Page 124 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program 5.3.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

5.3.2 As part of its evaluation pursuant to 10 CFR 72.212(b)(5(iii), the licensee Commented [KM4]: Made to align with Amendment 4 shall perform an analysis to confirm that the dose limits of 10 CFR 72.104(a) will be satisfied under the actual site conditions and ISFSI configuration, considering the planned number of casks to be deployed and the cask contents.

5.3.3 Based on the analysis performed pursuant to Section 5.3.2, the licensee shall establish individual cask surface dose rate limits for the TRANSFER CASK and the VVM 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 VVM.

b. The side of the TRANSFER CASK

c. The outlet vents on the VVM 5.3.4 Notwithstanding the limits established in Section 5.3.3, the measured dose rates on a loaded VVM or TRANSFER CASK shall not exceed the following values:

a. HI-STORM UMAX Standard Lid: 66 mrem/hr (gamma + neutron) on the closure lid of the VVM (see 5.3.8(a) for location description)

HI-STORM UMAX Version B lid: 22 mrem/hr (gamma + neutron) on the closure lid of the VVM (see 5.3.8(a) for location description) Commented [KM5]: Made to align with Amendment 4

b. 3500 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.3.5 The licensee shall measure the TRANSFER CASK and VVM surface neutron and gamma dose rates as described in Section 5.3.8 for comparison against the limits established in Section 5.3.3 or Section 5.3.4, whichever are lower.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-3 Page 125 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.3.3 or Section 5.3.4, 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 a VVM at the ISFSI containing the as-loaded DSC 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.

5.3.7 If the evaluation performed pursuant to Section 5.3.6 shows that the dose limits of 10 CFR 72.104 will be exceeded, the DSC shall not be placed into a VVM or the DSC shall be removed from the VVM until appropriate corrective action is taken to ensure the dose limits are not exceeded.

5.3.8 TRANSFER CASK and VVM 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 top of the VVM. These measurements shall be taken: HI-STORM UMAX Standard Lid: On the side of the closure lid approximately midheight and approximately 90 degrees apart HI-STORM UMAX Version B lid: On the side of the closure lid approximately midheight and adjacent to the inlet vent. One measurement per each lid side, rotationally symmetric by approximately 90 degrees. Commented [KM6]: Made to align with Amendment 4

b. A minimum of four (4) dose rate measurements shall be taken adjacent to the outlet vent duct screen of the VVM, approximately 90 degrees apart.

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

5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-4 Page 126 of 148

Attachment 2 to Holtec Letter 5021069 Programs 5.0 5.3 Radiation Protection Program (continued) 5.3.9 The Radiation Protection Space (RPS) is the prismatic subgrade buffer zone surrounding the VVMs in a loaded ISFSI. The RPS boundary is indicated in the Licensing Drawings in Section 1.5 of the system FSAR. The RPS boundary shall not be encroached upon during any site construction activity. The jurisdictional boundary of the RPS extends down from the top of the ISFSI pad to the elevation of the Bottom surface of the Support Foundation Pad. The ISFSI design shall ensure that there is no significant loss of shielding in the RPS due to a credible accident or an extreme environment event during construction activity involving excavation adjacent to the RPS boundary.

5.4 DSC Verification Requirements Prior to storage in the HI-STORM UMAX System the following records verifications must be performed:

5.4.1 Verify through review of records that the DSC has been fabricated and loaded in accordance with the applicable limits in CoC 72-1029, including but not limited to helium backfill requirements and heat load limits.

5.4.2 Verify through review of records that the loaded DSC is within its initial 20 year license life. Canisters that have been in service longer than 20 years are not acceptable for storage in the HI-STORM UMAX System.

5.4.3 Verify through review of records that the DSC has not undergone transportation under Part 71.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix C 5.0-5 Page 127 of 148

Attachment 2 to Holtec Letter 5021069 CERTIFICATE OF COMPLIANCE NO. 1040 APPENDIX D APPROVED CONTENTS AND DESIGN FEATURES FOR THE 24PT1-DSC IN HI-STORM UMAX CANISTER STORAGE SYSTEM Page 128 of 148

Attachment 2 to Holtec Letter 5021069 TABLE OF CONTENTS 1.0 DEFINITIONS ........................................................................................................ 1-1 2.0 APPROVED CONTENTS ...................................................................................... 2-1 2.1 Fuel Specifications and loading conditions ........................................................ 2-1 2.2 Violations ........................................................................................................... 2-1 2.3 Decay Heat Limits ............................................................................................. 2-5 Table 2.1-1 Fuel Assembly Limits .......................................................................... 2-2 Table 2.1-2 PWR Fuel Assembly Characteristics .................................................. 2-4 Table 2.3-1 Permissible Heat Load for long term storage ...................................... 2-5 3.0 DESIGN FEATURES ............................................................................................. 3-1 3.1 Site .................................................................................................................... 3-1 3.2 Design Features Important for Criticality Control ............................................... 3-1 3.3 Codes and Standards ........................................................................................ 3-1 3.4 Site Specific Parameters and Analyses ............................................................. 3-7 3.5 Periodic Corrosion Inspections for Underground Systems .............................. 3-14 Figure 3-1 Subgrade and Undergrade Space Nomenclature ................................ 3-12 Figure 3-2 Minimum Spacer Disc Ligament Widths for 24PT ................................ 3-13 Table 3-1 List of ASME Code Alternatives for 24PT1-DSC .................................... 3-3 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR HI-STORM UMAX OVERPACK and HI-TRAC VW TRANSFER CASK, PRIMARY LOAD BEARING PARTS .................................................................................. 3-5 Table 3-3 LOAD COMBINATIONS FOR THE TOP SURFACE PAD, ISFSI PAD, AND SUPPORT FOUNDATION PAD PER ACI-318 (2005) ................... 3-9 Table 3-4 Values of Principal Design Parameters for the Underground ISFSI ...... 3-10 Certificate of Compliance No. 1040 Amendment No. 2 Appendix D i Page 129 of 148

Attachment 2 to Holtec Letter 5021069 Definitions 1.0 1.0 Definitions Refer to Appendix C for Definitions.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 1-1 Page 130 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 2.0 APPROVED CONTENTS 2.1 Fuel Specifications and Loading Conditions

a. Fuel shall be INTACT FUEL ASSEMBLIES or DAMAGED FUEL ASSEMBLIES. DAMAGED FUEL ASSEMBLIES shall be placed in screened confinement cans (FAILED FUEL CANS) inside the 24PT1-DSC guidesleeves. DAMAGED FUEL ASSEMBLIES shall be stored in outermost guidesleeves located at the 45, 135, 225, and 315 degree azimuth locations.

b. Fuel stored in a 24PT1-DSC must meet the requirements in Tables 2.1-1 and 2.1-2.

C 24PT1-DSCs must meet the DSC verification requirements in Appendix C, 5.4.

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

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

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

2.2.3 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.1040 Amendment No. 3 Appendix D 2-1 Page 131 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-1 (page 1 of 2)

Fuel Assembly Limits I. CANISTER MODEL: 24PT1-DSC A. Allowable Contents

1. Uranium oxide or Mixed Oxide (MOX) PWR INTACT FUEL ASSEMBLIES, and/or DAMAGED FUEL ASSEMBLIES meeting the criteria in Table 2.1-2, with or without Control Components and meeting the following specifications (Note 1,2):

a. Cladding Type: ZR or stainless steel

b. Maximum Initial Enrichment: As specified in Table 2.1-2

c. Post-irradiation Cooling Time Cooling Time 20 years (fuel assembly and and Average Burnup Per control components)

Assembly: Assembly Average Burnup 45 GWD/MTU

d. Decay Heat Per Fuel Storage As specified in Section 2.3 Location:

e. Fuel Assembly Length: 138.5 inches (unirradiated length)

f. Fuel Assembly Width: 7.76 inches (nominal design)

g. Fuel Assembly Weight: 1320 lbs (including Control Components)

Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-2 Page 132 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-1 (page 2 of 2)

Fuel Assembly Limits I. MPC MODEL: 24PT1-DSC (continued)

B. Quantity per DSC:

1. A maximum of 24 INTACT WE 14x14 MOX or stainless steel clad FUEL ASSEMBLIES OR

2. Up to four WE 14x14 stainless steel clad DAMAGED FUEL ASSEMBLIES , with the balance INTACT WE 14x14 stainless steel clad FUEL ASSEMBLIES OR

3. One MOX DAMAGED FUEL ASSEMBLY with the balance INTACT WE 14x14 stainless steel clad FUEL ASSEMBLIES A 24PT1-DSC containing less than 24 fuel assemblies may contain dummy fuel assemblies in fuel assembly slots. The dummy fuel assemblies are unirradiated, stainless steel encased structures that approximate the weight and center of gravity of a fuel assembly. No more than two empty fuel assembly slots are allowed in each DSC. They must be located at symmetrical locations about the 0-180o and 90-270o axes.

No more than 14 fuel pins in each assembly may exhibit damage.

Note 1: Control Components stored integral to WE 14x14 Assemblies in a 24PT1-DSC, shall be limited to Rod Cluster Control Assemblies (RCCAs), Thimble Plug Assemblies (TPAs), and Neutron Source Assemblies (NSAs).

Note 2: Location of Control Components within a 24PT1-DSC shall be selected based on criteria which do not change the radial center of gravity by more than 0.1 inches.

Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-3 Page 133 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 Table 2.1-2 PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly WE 14x14 (UO2) with or WE 14x14 (MOX)

Array/ Class without IFBA fuel rods Cladding Material Stainless Steel ZR No. of Fuel Rod 180 180 Locations Fuel Clad O.D. (in.) 0.422 0.422 Fuel Clad Thickness.

0.0165 0.0243 (in.)

Fuel Pellet Dia. (in.)

0.3835 0.3659 (Note 2)

Fuel Rod Pitch (in.) 0.556 0.556 Maximum Planar 2.84 wt.% Fissile Pu - 64 rods Average Initial 3.10 wt.% Fissile Pu - 92 rods 4.05 wt. % U-235 Enrichment 3.31 wt.% Fissile Pu - 24 rods (Note 2)

Theoretical Density (%) 93-95 91 Active Fuel Length (in.) 120 119.4 Maximum Burnup 45,000 25,000 (MWd/MTU)

Minimum Cooling Time 20 20 (years)

Assembly Weight (lb) 1210 1150 No. of Guide and/or 16 16 Instrument Tubes Notes:

1. All dimensions are design nominal values. Maximum and minimum dimensions are specified to bound variations in design nominal values among fuel assemblies within a given array/class.

2. Mixed oxide assemblies contain 0.71 wt.% U-235.

Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-4 Page 134 of 148

Attachment 2 to Holtec Letter 5021069 Approved Contents 2.0 2.3 Decay Heat Limits This section provides the limits on fuel assembly decay heat for storage in the HI-STORM UMAX Canister Storage System.

2.3.1 Canister Decay Heat Limits Table 2.3-1 provides the maximum permissible decay heat under long-term storage for 24PT1-DSC in the HI-STORM UMAX System.

TABLE 2.3-1 PERMISSIBLE HEAT LOAD FOR LONG-TERM STORAGE Permissible Heat Permissible Aggregate Heat Load Fuel Type Load per Storage Cell (kW) (Note 1)

(kW)

WE 14x14 (UO2) with or without IFBA fuel 0.583 14.0 rods WE 14x14 (MOX) 0.294 13.706 Notes:

1. Aggregate heat load is defined as the sum of heat loads of all stored fuel assemblies, including integral control components.

2.3.2 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.

Certificate of Compliance No.1040 Amendment No. 3 Appendix D 2-5 Page 135 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 3.0 DESIGN FEATURES 3.1 Site 3.1.1 Site Location The HI-STORM UMAX Canister Storage System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.

3.3 Codes and Standards The 24PT1-DSC is designed, fabricated, and inspected to the maximum practical extent in accordance with ASME Boiler and Pressure Vessel Code Section III, Division 1, 1992 Edition with Addenda through 1994, including exceptions allowed by Code Case-595-1, Subsections NB, NF, and NG for Class 1 components and supports, as clarified in Specification 3.3.1.

The HI-STORM UMAX VVM is structurally qualified per the newer 2010 ASME code.

The ASME Code paragraphs applicable to the manufacturing of HI-STORM UMAX VVM and transfer cask are listed in Table 3-2. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the applicable edition (including addenda) specified above, is performed by the certificate holder.

American Concrete Institute ACI-318 (2005) is the governing Code for both plain concrete and reinforced concrete as clarified in Chapter 3 of the Final Safety Analysis Report for the HI-STORM UMAX System.

3.3.1 Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the 24PT1-DSC within the HI-STORM UMAX Canister Storage System.

3.3.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code, including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternative should demonstrate that:

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

2. Compliance with the specified requirements of the ASME Codes listed in Section 3.3, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

(continued)

Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-1 Page 136 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 3.0 DESIGN FEATURES (continued)

TABLE 3-1 List of ASME Code Alternatives for 24PT1-DSC Reference Component ASME Code Code Requirement Alternative, Justification & Compensatory Measures Section/Article NCA All Not compliant with NCA NB-1100 Requirements for Code The DSC shell is designed & fabricated in accordance Stamping of Components with the ASME Code,Section III, Subsection NB to the maximum extent practical. However, Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp, or to be ASME Certified.

NB-2130 Material must be supplied All materials designated as ASME on the UFSAR by ASME approved drawings are obtained from ASME approved MM or material suppliers MS supplier(s) with ASME CMTRs. Material is certified to meet all ASME Code criteria but is not eligible for certification or Code Stamping if a non-NB-4121 Material Certification by ASME fabricator is used. As the fabricator is not Certificate Holder required to be ASME certified, material certification to NB-2130 is not possible. Material traceability &

certification are maintained in accordance with an NRC approved QA program NB-6111 All completed pressure The shield plug support ring and vent and siphon block DSC Shell retaining systems shall be are not pressure tested due to the manufacturing Assembly pressure tested sequence. The support ring is not a pressure-retaining item and the siphon block weld is helium leak tested after fuel is loaded and the inner top closure plate installed in accordance with Code Case N-595-1.

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

The function of the DSC is to contain radioactive materials under normal, off-normal and hypothetical accident conditions postulated to occur during transportation and storage. The DSC s designed to withstand the maximum internal pressure considering 100% fuel rod failure at maximum accident temperature. The DSC is pressure tested to 120% of normal operating design pressure. An overpressure protection report is not prepared for the DSC.

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

Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-2 Page 137 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 TABLE 3-1 List of ASME Code Alternatives for 24PT1-DSC Reference Component ASME Code Code Requirement Alternative, Justification & Compensatory Measures Section/Article NCA All Not compliant with NCA.

NG/NF-1100 Requirements for Code The DSC baskets are designed & fabricated in Stamping of Components accordance with the ASME Code,Section III, Subsection NG/NF to the maximum extent practical as described in the UFSAR, but Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp or be ASME Certified.

NG/NF-2130 Material must be supplied All materials designated as ASME on the UFSAR by ASME approved drawings are obtained from ASME approved MM or material suppliers MS supplier with ASME CMTRs. Material is certified to meet all ASME Code criteria but is not eligible for NG/NF-4121 Material Certification by certification or Code Stamping if a non-ASME Certificate Holder fabricator is used. As the fabricator is not required to be ASME certified, material certification to NG/NF-2130 is not possible. Material traceability & certification are maintained in accordance with an NRC approved QA 24PT1 program.

Basket Table NG- Permissible Joint Efficiency Joint efficiency (quality) factor of 1 is assumed for the 3352-1 Factors guidesleeve longitudinal weld. Table NG-3352 permits a quality factor of 0.5 for full penetration weld with visual inspection. Inspection of both faces provides n=(2*0.5)=1. This is justified by this gauge of material (0.12 inch) with visual examination of both surfaces which ensures that any significant deficiencies would be observed and corrected.

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

N/A N/A Oversleeve to guidesleeve welds are non-code welds which meet the requirements of AWS D1.3-98, the Structural Welding Code-Sheet Steel.

Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-3 Page 138 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR VVM PRIMARY LOAD BEARING PARTS Item Code Explanation and Applicability Paragraph

[2.6.1]

1. Definition of primary and NF-1215 -

secondary members

2. Jurisdictional boundary NF-1133 The VVMs jurisdictional boundary is defined by the bottom surface of the SFP, the top surface of the ISFSI pad and the SES side surfaces.

3. Certification of NF-2130(b) and Materials shall be certified to material(structural) (c) the applicable Section II of the ASME Code or equivalent ASTM Specification.

4. Heat treatment of material NF-2170 and -

NF-2180

5. Storage of welding material NF-2400 -

6. Welding procedure Section IX -

7. Welding material Section II -

8. Loading conditions NF-3111 -

9. Allowable stress values NF-3112.3 -

10. Rolling and sliding NF-3424 -

supports

11. Differential thermal NF-3127 -

expansion

12. Stress analysis NF-3143 Provisions for stress analysis NF-3380 for Class 3 plate and shell NF-3522 supports and for linear supports NF-3523 are applicable for Closure Lid and Container Shell, respectively.

13. Cutting of plate stock NF-4211 -

NF-4211.1

14. Forming NF-4212 -

15. Forming tolerance NF-4221 Applies to the Container Shell

16. Fitting and Aligning Tack NF-4231 -

Welds NF-4231.1

17. Alignment NF-4232 -

18. Storage of Welding NF-4411 -

Materials

19. Cleanliness of Weld NF-4412 Applies to structural and non-Surfaces structural welds Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-4 Page 139 of 148

Attachment 2 to Holtec Letter 5021069 Design Features 3.0 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR VVM PRIMARY LOAD BEARING PARTS Item Code Explanation and Applicability Paragraph

[2.6.1]

20. Backing Strips, Peening NF-4421 Applies to structural and non-NF-4422 structural welds

21. Pre-heating and Interpass NF-4611 Applies to structural and non-Temperature NF-4612 structural welds NF-4613

22. Non-Destructive NF-5360 InvokesSection V Examination

23. NDE Personnel NF-5522 -

Certification NF-5523 NF-5530 Certificate of Compliance No. 1040 Amendment No. 3 Appendix D 3-5 Page 140 of 148