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)


Text

RENEWED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100 CASK SYSTEM AMENDMENT NO. 0

ii 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 Table 5-1 TRANSFER CASK and OVERPACK Lifting Requirements

...............5.0-4 5.6 Aging Management Program.......................................................................5.0-5

Certificate of Compliance No. 1014 Appendix A 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)

Renewed Amendment No. 0

Definitions 1.1 Certificate of Compliance No. 1014 Appendix A 1.1-1 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)

Renewed Amendment No. 0

Definitions 1.1 Certificate of Compliance No. 1014 Appendix A 1.1-2 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.

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 1.2-1 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)

Renewed Amendment No. 0

Logical Connectors 1.2 1.2 Logical Connectors Certificate of Compliance No. 1014 Appendix A 1.2-2 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)

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 1.2-3 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.

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 1.3-1 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 enteringan 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)

Renewed Amendment No. 0

Completion Times 1.3 Certificate of Compliance No. 1014 Appendix A 1.3-2 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 Action and associated Completion Time not met.

B.1 Perform Action B.1 AND B.2 Perform Action B.2 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 36 hours 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)

Renewed Amendment No. 0

Completion Times 1.3 Certificate of Compliance No. 1014 Appendix A 1.3-3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-2 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not within limit.

A.1 Restore system to within limit.

7 days B. Required Action and associated Completion Time not met.

B.1 Complete action B.1.

AND 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 /> 36 hours 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)

Renewed Amendment No. 0

Completion Times 1.3 Certificate of Compliance No. 1014 Appendix A 1.3-4 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 with LCO.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time not met.

B.1 Complete action B.1.

AND B.2 Complete action B.2 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours 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)

Renewed Amendment No. 0

Completion Times 1.3 Certificate of Compliance No. 1014 Appendix A 1.3-5 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 Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 1.4-1 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)

Renewed Amendment No. 0

Frequency 1.4 Certificate of Compliance No. 1014 Appendix A 1.4-2 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)

Renewed Amendment No. 0

Frequency 1.4 Certificate of Compliance No. 1014 Appendix A 1.4-3 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.

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 2.0-1 2.0 2.0 This section is intentionally left blank.

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 3.0-1 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.

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 3.0-2 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)

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 3.0-3 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.

Renewed Amendment No. 0

Multi-Purpose Canister (MPC) 3.1.1 Certificate of Compliance No. 1014 Appendix A 3.1.1-1 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.

CONDITION REQUIRED ACTION COMPLETION TIME A.

MPC cavity vacuum drying pressure limit not met.

A.1 Perform an engineering evaluation to determine the quantity of moisture left in the MPC.

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

7 days 30 days B

MPC helium backfill density limit not met.

B.1 Perform an engineering evaluation to determine the impact of helium differential.

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

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 14 days Renewed Amendment No. 0

Multi-Purpose Canister (MPC) 3.1.1 3.1.1-2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

MPC helium leak rate limit not met.

C.1 Perform an engineering evaluation to determine the impact of increased helium leak rate on heat removal capability and offsite dose.

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

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 7 days D.

Required Actions and associated Completion Times not met.

D.1 Remove all fuel assemblies from the SFSC.

30 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify MPC cavity vacuum drying pressure is within the limit specified in Table 3-1 for the applicable MPC model.

Once, prior to TRANSPORT OPERATIONS SR 3.1.1.2 Verify MPC helium backfill density is within the limit specified in Table 3-1 for the applicable MPC model.

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

Once, prior to TRANSPORT OPERATIONS Certificate of Compliance No. 1014 Appendix A Renewed Amendment No. 0

Multi-Purpose Canister (MPC) 3.1.2 Certificate of Compliance No. 1014 Appendix A 3.1.2-1 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.

CONDITION REQUIRED ACTION COMPLETION TIME A.

SFSC Heat Removal System inoperable.

A.1 Restore SFSC Heat Removal System to OPERABLE status.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> B.

Required Action A.1 and associated Completion Time not met.

B.1 Perform SR 3.2.3.1 AND B.3.1 Restore SFSC Heat Removal System to OPERABLE status.

OR B.3.2 Transfer the MPC into a TRANSFER CASK.

Immediately and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> 48 hours Renewed Amendment No. 0

Multi-Purpose Canister (MPC) 3.1.2 Certificate of Compliance No. 1014 Appendix A 3.1.2-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify all OVERPACK inlet and outlet air ducts are free of blockage.

OR For OVERPACKS with temperature monitoring 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).

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours Renewed Amendment No. 0

Fuel Cool-Down 3.1.3 Certificate of Compliance No. 1014 Appendix A 3.1.3-1 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.

CONDITION REQUIRED ACTION COMPLETION TIME A.

MPC helium gas exit temperature not within limit.

A.1 Establish MPC helium gas exit temperature within limit.

AND A.2 Ensure adequate heat transfer from the MPC to the environment Prior to initiating MPC re-flooding operations 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify MPC helium gas exit temperature within limit.

Prior to MPC re-flooding operations.

Renewed Amendment No. 0

TRANSFER CASK Average Surface Dose Rates 3.2.1 Certificate of Compliance No. 1014 Appendix A 3.2.1-1 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.

CONDITION REQUIRED ACTION COMPLETION TIME A.

TRANSFER CASK average surface dose rate limits not met.

A.1 Administratively verify correct fuel loading.

AND A.2 Perform written evaluation to verify compliance with the ISFSI offsite radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours (continued)

Renewed Amendment No. 0

TRANSFER CASK Average Surface Dose Rates 3.2.1 TRANSFER CASK Average Surface Dose Rates 3.2.1 Certificate of Compliance No. 1014 Appendix A 3.2.2-2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

Required Action and associated Completion Time not met.

B.1 Remove all fuel assemblies from the TRANSFER CASK 30 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify average surface dose rates of the TRANSFER CASK loaded with an MPC containing fuel assemblies are within limits.

Dose rates shall be measured at the locations shown in Figure 3.2.1-1.

Once, prior to TRANSPORT OPERATIONS Renewed Amendment No. 0

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

TRANSFER CASK Surface Contamination 3.2.2 Certificate of Compliance No. 1014 Appendix A 3.2.2-1 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.

CONDITION REQUIRED ACTION COMPLETION TIME 1.01 TRANSFER CASK or MPC removable surface contamination limits not met.

A.1 Restore removable surface contamination to within limits.

7 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify that the removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC containing fuel is within limits.

Once, prior to TRANSPORT OPERATIONS Renewed Amendment No. 0

OVERPACK Average Surface Dose Rates 3.2.3 Certificate of Compliance No. 1014 Appendix A 3.2.3-1 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.

CONDITION REQUIRED ACTION COMPLETION TIME A.

OVERPACK average surface dose rate limits not met.

A.1 Administratively verify correct fuel loading.

AND A.2 Perform analysis to verify compliance with the ISFSI offsite radiation protection requirements of 10 CFR Part 20 and 10 CFR Part 72.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours 1.02 Required Action and associated Completion Time not met.

B.1 Remove all fuel assemblies from the SFSC.

30 days Renewed Amendment No. 0

OVERPACK Average Surface Dose Rates 3.2.3 OVERPACK Average Surface Dose Rates 3.2.3 Certificate of Compliance No. 1014 Appendix A 3.2.3-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.3.1 Verify average surface dose rates of the OVERPACK loaded with an MPC containing fuel assemblies are within limits. Dose rates shall be measured at the locations shown in Figure 3.2.3-1 Once, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after beginning STORAGE OPERATIONS Renewed Amendment No. 0

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

MPC Model-Dependent Limits Table 3-1 1 Helium used for backfill of MPC shall have a purity of > 99.995%.

Certificate of Compliance No. 1014 Appendix A 3.3-1 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)

Renewed Amendment No. 0

Certificate of Compliance No. 1014 Appendix A 4.0-1 4.0 4.0 This section is intentionally left blank.

Renewed Amendment No. 0

Programs 5.0 Certificate of Compliance No. 1014 Appendix A 5.0-1 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)

Renewed Amendment No. 0

Programs 5.0 Certificate of Compliance No. 1014 Appendix A 5.0-2 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)

Renewed Amendment No. 0

Programs 5.0 Certificate of Compliance No. 1014 Appendix A 5.0-3 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)

Renewed Amendment No. 0

Programs 5.0 Certificate of Compliance No. 1014 Appendix A 5.0-4 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.

Renewed Amendment No. 0

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