ML23068A387

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3. Renewed Certificate of Compliance No. 1014, Amendment No. 0, Appendix a
ML23068A387
Person / Time
Site: Holtec
Issue date: 06/29/2023
From:
Storage and Transportation Licensing Branch
To:
Holtec
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ML23068A384 List: ... further results
References
CAC 001028, EPID L-2020-RNW-0007
Download: ML23068A387 (1)
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RENEWED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100 CASK SYSTEM AMENDMENT NO. 0

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 ......................................................................................................................2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ............3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ...........................3.0-2 3.1 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 Fuel Cool-Down ...................................................................3.1.3-1 3.2 SFSC RADIATION PROTECTION ....................................................3.1-1 3.2.1 TRANSFER CASK Average Surface Dose Rates ................3.2.1-1 3.2.2 TRANSFER CASK Surface Contamination ..........................3.2.2-1 3.2.3 OVERPACK Average Surface Dose Rates ..........................3.2.3-1 Table 3-1 MPC Model-Dependent Limits ...........................................................3.3-1 4.0 ......................................................................................................................4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS ....................................5.0-1 5.1 Training Program ...............................................................................5.0-1 5.2 Pre-Operational Testing and Training Exercise .................................5.0-1 5.3 Special Requirements for First Systems in Place ..............................5.0-2 5.4 Radioactive Effluent Control Program ................................................5.0-3 5.5 Cask Transport Evaluation Program ..................................................5.0-3 5.6 Aging Management Program .......................................................................5.0-5 Table 5-1 TRANSFER CASK and OVERPACK Lifting Requirements ...............5.0-4 i

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

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

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

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

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.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an OVERPACK or TRANSFER CASK while it is being loaded with fuel assemblies.

LOADING OPERATIONS begin when the first fuel assembly is placed in the MPC and end when the OVERPACK or TRANSFER CASK is suspended from or secured on the transporter. LOADING OPERATIONS does not include MPC transfer between the TRANSFER CASK and the OVERPACK.

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.

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A i

Definitions 1.1 1.1 Definitions (continued)

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

SPENT FUEL STORAGE SFSCs are containers approved for the storage of CASKS (SFSCs) spent fuel assemblies at the ISFSI. The HI-STORM 100 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 sitting on a storage pad within the ISFSI perimeter. STORAGE OPERATIONS does not include MPC transfer between the TRANSFER CASK and the OVERPACK.

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

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.1-1

Definitions 1.1 1.1 Definitions (continued)

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on an OVERPACK or TRANSFER CASK loaded with one or more fuel assemblies when it is being moved to and from the ISFSI. TRANSPORT OPERATIONS begin when the OVERPACK or TRANSFER CASK is first suspended from or secured on the transporter and end when the OVERPACK or TRANSFER CASK is at its destination and no longer secured on or suspended from the transporter. TRANSPORT OPERATIONS includes transfer of the MPC between the OVERPACK and the TRANSFER CASK.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SFSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the OVERPACK or TRANSFER CASK is no longer suspended from or secured on the transporter and end when the last fuel assembly is removed from the SFSC.

UNLOADING OPERATIONS does not include MPC transfer between the TRANSFER CASK and the OVERPACK.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.1-2

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

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

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action.

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

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

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.2-1

Logical Connectors 1.2 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. 1014 Renewed Amendment No. 0 Appendix A 1.2-2

EXAMPLES EXAMPLE 1.2-2 (continued)

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

OR A.2.1 Verify . . .

AND A.2.2.1 Reduce . . .

OR A.2.2.2 Perform . . .

OR A.3 Remove. . .

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

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.2-3

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 100 System is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the HI-STORM 100 System is not within the LCO Applicability.

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

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.3-1

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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and associated AND Completion Time not met. B.2 Perform Action B.2 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.3-2

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

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

limit.

B. Required B.1 Complete action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Action and B.1.

associated Completion AND Time not met. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B.2 Complete action 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. 1014 Renewed Amendment No. 0 Appendix A 1.3-3

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

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

Separate Condition entry is allowed for each component.

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

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

associated AND Completion Time not met. B.2 Complete action B.2 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> The Note above the ACTIONS table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

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

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.3-4

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. 1014 Renewed Amendment No. 0 Appendix A 1.3-5

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. 1014 Renewed Amendment No. 0 Appendix A 1.4-1

Frequency 1.4 1.4 Frequency (contiuned)

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

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

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

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.4-2

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

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND"). This type of Frequency does not qualify for the 25%

extension allowed by SR 3.0.2.

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

New intervals start upon preparing to restart the specified activity.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 1.4-3

2.0 2.0 This section is intentionally left blank.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 2.0-1

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

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

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

LCO 3.0.3 Not applicable.

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

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

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.0-1

SR 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 <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

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

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.0-2

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 (continued) When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

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

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.0-3

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.

APPLICABILITY: During TRANSPORT OPERATIONS and STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

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

AND A.2 Develop and initiate 30 days corrective actions necessary to return the MPC to an analyzed condition.

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

AND B.2 Develop and initiate 14 days corrective actions necessary to return the MPC to an analyzed condition.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.1.1-1

Multi-Purpose Canister (MPC) 3.1.1 ACTIONS (continued)

COMPLETION CONDITION REQUIRED ACTION TIME C. MPC helium leak rate C.1 Perform an engineering 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> limit not met. evaluation to determine the impact of increased helium 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 an analyzed condition.

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 MPC cavity vacuum drying pressure is Once, prior to within the limit specified in Table 3-1 for the TRANSPORT applicable MPC model. OPERATIONS SR 3.1.1.2 Verify MPC helium backfill density is within the Once, prior to limit specified in Table 3-1 for the applicable TRANSPORT MPC model. OPERATIONS SR 3.1.1.3 Verify that the total helium leak rate through the Once, prior to MPC lid confinement weld and the drain and TRANSPORT vent port confinement welds is within the limit OPERATIONS specified in Table 3-1 for the applicable MPC model.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.1.1-2

Multi-Purpose Canister (MPC) 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.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Heat Removal A.1 Restore SFSC Heat 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> System inoperable. Removal System to OPERABLE status.

B. Required Action A.1 and B.1 Perform SR 3.2.3.1 Immediately and associated Completion every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Time not met. AND thereafter B.3.1 Restore SFSC Heat 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Removal System to OPERABLE status.

OR B.3.2 Transfer the MPC into a 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> TRANSFER CASK.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.1.2-1

Multi-Purpose Canister (MPC) 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify all OVERPACK inlet and outlet air ducts 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> are free of blockage.

OR For OVERPACKS with temperature monitoring 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> equipment, verify the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is < 99o F (for the MPC-24) and < 105o F (for the MPC-68 and MPC-68F).

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.1.2-2

Fuel Cool-Down 3.1.3 3.1 SFSC INTEGRITY 3.1.3 Fuel Cool-Down LCO 3.1.3 The MPC helium exit temperature shall be < 200o F

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

The LCO is only applicable to wet UNLOADING OPERATIONS.

APPLICABILITY: UNLOADING OPERATIONS prior to re-flooding.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

COMPLETION CONDITION REQUIRED ACTION TIME A. MPC helium gas exit A.1 Establish MPC helium gas Prior to initiating temperature not within exit temperature within limit. MPC re-flooding limit. operations AND A.2 Ensure adequate heat 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> transfer from the MPC to the environment SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify MPC helium gas exit temperature within Prior to MPC re-limit. flooding operations.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.1.3-1

TRANSFER CASK Average Surface Dose Rates 3.2.1 3.2 SFSC RADIATION PROTECTION 3.2.1 TRANSFER CASK Average Surface Dose Rates LCO 3.2.1 The average surface dose rates of each TRANSFER CASK shall not exceed:

a. 125 Ton TRANSFER CASK
i. 130 mrem/hour (neutron + gamma) on the side; ii. 40 mrem/hour (neutron + gamma) on the top
b. 100 Ton TRANSFER CASK
i. 890 mrem/hour (neutron + gamma) on the side; ii. 170 mrem/hour (neutron + gamma) on the top APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each TRANSFER CASK.

COMPLETION CONDITION REQUIRED ACTION TIME A. TRANSFER CASK A.1 Administratively verify 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> average surface dose correct fuel loading.

rate limits not met.

AND A.2 Perform written evaluation 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to verify compliance with the ISFSI offsite radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.1-1

TRANSFER CASK Average Surface Dose Rates 3.2.1 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and B.1 Remove all fuel assemblies 30 days associated Completion from the TRANSFER CASK Time not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify average surface dose rates of the Once, prior to TRANSFER CASK loaded with an MPC TRANSPORT containing fuel assemblies are within limits. OPERATIONS Dose rates shall be measured at the locations shown in Figure 3.2.1-1.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.2-2

TRANSFER CASK Average Surface Dose Rates 3.2.1 Figure 3.2.1-1 HI-TRAC Transfer Cask Dose Rate Measurement Locations Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.3-3

TRANSFER CASK Surface Contamination 3.2.2 3.2 SFSC RADIATION PROTECTION 3.2.2 TRANSFER CASK Surface Contamination LCO 3.2.2 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 1.01 TRANSFER CASK A.1 Restore removable surface 7 days or MPC removable contamination to within surface limits.

contamination limits not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify that the removable contamination on the Once, prior to exterior surfaces of the TRANSFER CASK and TRANSPORT accessible portions of the MPC containing fuel is OPERATIONS within limits.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.2-1

OVERPACK Average Surface Dose Rates 3.2.3 3.2 SFSC RADIATION PROTECTION 3.2.3 OVERPACK Average Surface Dose Rates LCO 3.2.3 The average surface dose rates of each OVERPACK shall not exceed:

a. 40 mrem/hour (neutron + gamma) on the side
b. 10 mrem/hour (neutron + gamma) on the top
c. 16 mrem/hour (neutron + gamma) at the inlet and outlet vent ducts APPLICABILITY: During TRANSPORT OPERATIONS AND STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

COMPLETION CONDITION REQUIRED ACTION TIME A. OVERPACK average A.1 Administratively verify 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surface dose rate limits correct fuel loading.

not met.

AND A.2 Perform analysis to verify 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> compliance with the ISFSI offsite radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

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

Completion Time not met.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.3-1

OVERPACK Average Surface Dose Rates 3.2.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify average surface dose rates of the Once, within 24 OVERPACK loaded with an MPC containing fuel hours after assemblies are within limits. Dose rates shall be beginning measured at the locations shown in Figure STORAGE 3.2.3-1 OPERATIONS Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.3-2

OVERPACK Average Surface Dose Rates 3.2.3 Figure 3.2.3-1 HI-STORM OVERPACK Dose Rate Measurement Locations Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.2.3-3

MPC Model-Dependent Limits Table 3-1 Table 3-1 MPC Model-Dependent Limits MPC MODEL LIMITS

1. MPC-24
a. MPC Cavity Vacuum Drying Pressure < 3 torr for > 30 min
b. MPC Helium Backfill Density1 0.1212 +0/-10% g-moles/l
c. MPC Helium Leak Rate < 5.0E-6 atm cc/sec (He)
2. MPC-68
a. MPC Cavity Vacuum Drying Pressure < 3 torr for > 30 min
b. MPC Helium Backfill Density1 0.1218 +0/-10% g-moles/l
c. MPC Helium Leak Rate < 5.0E-6 atm cc/sec (He)
3. MPC-68F
a. MPC Cavity Vacuum Drying Pressure < 3 torr for > 30 min
b. MPC Helium Backfill Density1 0.1218 +0/-10% g-moles/l
c. MPC Helium Leak Rate < 5.0E-6 atm cc/sec (He) 1 Helium used for backfill of MPC shall have a purity of > 99.995%.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 3.3-1

4.0 4.0 This section is intentionally left blank.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 4.0-1

Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented, and maintained.

5.1 Training Program A training program for the HI-STORM 100 Cask System shall be developed under the general licensee's systematic approach to training (SAT). Training modules shall include comprehensive instructions for the operation and maintenance of the HI-STORM 100 Cask System and the independent spent fuel storage installation (ISFSI).

5.2 Pre-Operational Testing and Training Exercise A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM 100 Cask 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 TRANSFER CASK into the spent fuel pool.
b. Preparation of the HI-STORM 100 Cask System for fuel loading.
c. Selection and verification of specific fuel assemblies to ensure type conformance.
d. Locating 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.
f. MPC welding, NDE inspections, hydrostatic testing, draining, vacuum drying, helium backfilling, and leakage testing. (A mock-up may be used for this dry-run exercise.)

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 5.0-1

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.2 Pre-Operational Testing and Training Exercise (continued)

g. TRANSFER CASK upending/downending on the horizontal transfer trailer or other transfer device, as applicable to the site's cask handling arrangement.
h. Transfer of the MPC from the TRANSFER CASK to the OVERPACK.
i. Placement of the HI-STORM 100 SFSC System at the ISFSI.
j. HI-STORM 100 Cask System unloading, including cooling fuel assemblies, flooding MPC cavity, removing MPC lid welds. (A mock-up may be used for this dry run exercise.)

5.3 Special Requirements For First Systems In Place The heat transfer characteristics of the cask system will be recorded by temperature measurements for the first HI-STORM 100 SFSC Systems (MPC-24, MPC-68, and MPC-68F) placed into service with a heat load equal to or greater than 10 kW. An analysis shall be performed that demonstrates the temperature measurements validate the analytic methods and predicted thermal behavior described in Chapter 4 of the SAR.

Validation tests shall be performed for each subsequent cask system that has a heat load that exceeds a previously validated heat load by more than 2 kW. (e.g.,

if the initial test was conducted at 10 kW, then no additional testing is needed until the heat load exceeds 12 kW). No additional testing is required for a system after it has been tested at a heat load equal to or greater than 16 kW.

Letter reports summarizing the results of each validation test shall be submitted to the NRC in accordance with 10 CFR 72.4. Cask users may satisfy these requirements by referencing validation test reports submitted to the NRC by other cask users.

(continued)

Certificate of Compliance No. 1014 Appendix A 5.0-2 Renewed Amendment No. 0

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.4. Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d).

a. The HI-STORM 100 Cask System does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents are not required.

Specification 3.1.1, Multi-Purpose Canister (MPC), provides assurance that there are no 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 program for 10 CFR Part 50 operations.
c. An annual report shall be submitted pursuant to 10 CFR 72.44(d)(3).

5.5 Cask Transport Evaluation Program This program provides a means for evaluating various transport configurations and transport route conditions to ensure that the design basis drop limits are met. For lifting of the loaded TRANSFER CASK or OVERPACK using devices which are integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply. This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by a device providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc.).

Pursuant to 10 CFR 72.212, this program shall evaluate the site-specific transport route conditions.

a. The lift height above the transport surface prescribed in Section 3.4.6 of Appendix B to Certificate of Compliance No. 1014 shall not exceed the limits in Table 5-1. Also, the program shall ensure that the transport route conditions (i.e., surface hardness and pad thickness) are equivalent to or less limiting than those prescribed for the reference pad surface which forms the basis for the values cited in Section 3.4.6 of Appendix B to Certificate of Compliance No. 1014.

(continued)

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 5.0-3

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.5 Cask Transport Evaluation Program (continued)

b. For site-specific transport conditions which are not bounded by the surface characteristics in Section 3.4.6 of Appendix B to Certificate of Compliance No. 1014, the program may evaluate the site-specific conditions to ensure that the impact loading due to design basis drop events does not exceed 45
g. This alternative analysis shall be commensurate with the drop analyses described in the Topical Safety Analysis Report for the HI-STORM 100 Cask System. The program shall ensure that these alternative analyses are documented and controlled.
c. The TRANSFER CASK and MPC, when loaded with spent fuel, may be lifted to those heights necessary to perform cask handling operations, including MPC transfer, provided the lifts are made with structures and components designed in accordance with the criteria specified in Section 3.5 of Appendix B to Certificate of Compliance No. 1014, as applicable.

Table 5-1 TRANSFER CASK and OVERPACK Lifting Requirements ITEM ORIENTATION LIFTING HEIGHT LIMIT (in.)

TRANSFER CASK Horizontal 42 (Note 1)

TRANSFER CASK Vertical None Established (Note 2)

OVERPACK Horizontal Not Permitted OVERPACK Vertical 11 Notes: 1. To be measured from the lowest point on the TRANSFER CASK (i.e., the bottom edge of the transfer lid).

1.01 See Technical Specification 5.5c.

Certificate of Compliance No. 1014 Renewed Amendment No. 0 Appendix A 5.0-4

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.6 Aging Management Program (AMP)

Each general licensee shall have a program to establish, implement, and maintain written procedures for each applicable AMP described in the FSAR.

The program shall include provisions for changing AMP elements, as necessary, and within the limitations of the approved design bases to address new information on aging effects based on inspection findings and/or industry operating experience. Each procedure shall contain a reference to the specific aspect of the AMP element implemented by that procedure, and that reference shall be maintained even if the procedure is modified.

The general licensee shall establish and implement these written procedures prior to entering the period of extended operation or no later than 365 days after the effective date of the renewal of the CoC, whichever is later. The general licensee shall maintain these written procedures for as long as the general licensee continues to operate HI-STORM 100 Cask Systems in service for longer than 20 years.

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

Certificate of Compliance No. 1014 5.0-5 Renewed Amendment No. 0 Appendix A

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