ML23073A398

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TMI-2 ISFSI Biennial Update Report for 2023
ML23073A398
Person / Time
Site: Three Mile Island, 07200020  Constellation icon.png
Issue date: 03/31/2023
From:
US Dept of Energy, Idaho Operations Office
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML23073A396 List:
References
NLF-RPT-255, CLN230794
Download: ML23073A398 (1)
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Text

TMI-2 ISFSI Biennial Update Report for 2023 Prepared by Idaho Environmental Coalition NRC Licensed Facilities Report: NLF-RPT-255 March 2023

NLF-RPT-255, TMI-2 ISFSI Biennial Update Report for 2023 1.0 PURPOSE AND SCOPE The Department of Energy's Idaho Operations Office (DOE-ID) was issued license SNM-2508 to operate the Three Mile Island Unit 2 (TMI-2) Independent Spent Fuel Storage Installation (ISFSI) by the Nuclear Regulatory Commission (NRC). The date of issuance was March 19, 1999. A renewed license was issued on September 16, 2019. This update report provides the following reports, which were last updated in March 2021.

  • The biennial Safety Analysis Report (SAR) Update Report pursuant to 10 CFR 72.70 (b) and (c). The SAR Update Report is provided in Section 2.0, Description of Changes to the Safety Analysis Report.
  • The biennial 72.48 Evaluations Report pursuant to 10 CFR 72.48(d)(2). This report, comprised of summaries of evaluations of changes made pursuant to 10 CFR 72.48, is provided in Section 3.0, Changes, Tests, and Experiments.
  • The biennial Technical Specifications Bases Evaluations Report pursuant to TS 5.5.1.d. This report is provided in Section 4.0, Changes to the Technical Specification Bases.
  • The biennial Essential Program Evaluations Report pursuant to TS 5.5.2.6. This report covers changes made during this reporting period to the DOE-ID essential programs as described in Section 5.0, Radiological Environmental Monitoring Program Changes, Section 6.0, Training Program Changes, and Section 7.0, Quality Assurance Program Changes.

NOTE: The changes to the Physical Protection Program and the Emergency Response Program are provided separately because of the reporting time frames required by 10 CFR 72.44 (e) and (f), respectively.

This report is provided in a combined format because many of the changes described in the SAR Update are also covered by reviews of changes made without NRC approval pursuant to 10 CFR 72.48, TS 5.5.1, and TS 5.5.2. Technical Specification 5.5.1 requires 72.48 reviews to be performed for any change to the Technical Specification Bases. Technical Specification 5.5.2 requires an evaluation of the change in program effectiveness [similar to the requirements of 10 CFR 72.44(e) and (f)] for changes to the ISFSI Radiological Environmental Monitoring Program, Training Program, and Quality Assurance Program. These three programs are contained in the ISFSI SAR.

2.0 Description of Changes to the Safety Analysis Report The previous update of the TMI-2 ISFSI SAR made pursuant to 10 CFR 72.70 was provided in March 2021 (Revision 12).

Since that time, in March of 2021 changes were made to the TMI-2 ISFSI SAR Chapter 5 and Chapter 9 as described below.

Page 1 of 5

NLF-RPT-255, TMI-2 ISFSI Biennial Update Report for 2023

  • Section 5.1.2.2 HSM Monitoring Operations, was changed to describe visual inspections of the Dry Shielded Canister (DSC) and Horizontal Storage Module (HSM) to include remote inspections which require temporary removal of the HSM door using a portable crane.
  • Section 9.8.6, Aging Management Programs, was revised to include the addition of paragraphs to describe the operation to perform remote inspections by removing the shield door and installing a temporary sample cover to allow for insertion of a borescope camera.

Attached to this report are the replacement pages for the SAR chapters (Chapter 5 and 9) that were revised as required by 10 CFR 72.70.

3.0 Changes, Tests, and Experiments The previous report of changes made pursuant to 10 CFR 72.48 was provided in March 2021.

Eight screens were prepared pursuant to 10 CFR 72.48 during the subsequent 24-month period as described below.

1. In March 2021, a screen was completed of changes made to Chapters 5 and 9 of the FSAR as described in the previous section to describe operations condition to remove the shield door for remote inspections in support of the Aging Management Program
2. In August 2021, a screen was completed for a work order to repair cracks in the existing security tower foundations and seal the foundations with epoxy paint.
3. In December 2021, a screen was completed for a work order to replace the portable Delta Barrier with a new portable barrier.
4. In January 2022, a screen was completed for a Nonconformance Report (NCR) written to address the results of the 2020 Aging Management Program inspections of the DSC steel and coatings directing rework and repair of conditions found as well as accept-as-is conditions.
5. In February 2022, a screen was completed for an NCR written to address the results of the 2020 Aging Management Program direct inspections of the HSM steel and coatings directing rework of identified conditions.
6. In February 2022, a screen was completed for an NCR written to address the results of the 2020 Aging Management Program direct inspections of the HSM-4 and HSM-17 bolt covers directing replacement of the identified condition.

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NLF-RPT-255, TMI-2 ISFSI Biennial Update Report for 2023

7. In February 2022, a screen was completed for a work order to update and renovate the alarm station.
8. In February 2022, a screen was completed for an NCR to address the results of the 2020 Aging Management Program direct inspection of the HSM concrete fillers and sealants directing repair of the identified conditions.

All changes were screened out, and no further 10 CFR 72.48 evaluations were required. Therefore, the changes were made without a license amendment.

4.0 Changes to the Technical Specification Bases The previous update of the Technical Specification Bases made pursuant to TS 5.5.1 was provided in March 2021. There was no change made to the Technical Specification Bases during the subsequent 24-month period.

5.0 Radiological Environmental Monitoring Program Changes The previous update of the Radiological Environmental Monitoring Program made pursuant to TS 5.5.2 was provided in March 2021. There was no change made to the Radiological Environmental Monitoring Program described in the SAR during the subsequent 24-month period.

6.0 Training Program Changes The previous update of the Training Program made pursuant to TS 5.5.2 was provided in March 2021. There were no changes made to the Training Program described in the SAR, Section 9.3 during the subsequent 24-month period.

7.0 Quality Assurance Program Changes The previous update of the Quality Assurance Program made pursuant to TS 5.5.2 was provided in March 2021. There were no changes made to the Quality Assurance Program described in Chapter 11 of the SAR during the subsequent 24-month period.

8.0 Attachments Attachment A, TMI-2 SAR-II-8.4 Chapter 5 Attachment B, TMI-2 SAR-II-8.4 Chapter 9 Page 3 of 5

NLF-RPT-255, TMI-2 ISFSI Biennial Update Report for 2023 Attachment A TMI-2 SAR-II-8.4 Chapter 5 (PDF attached)

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TABLE OF CONTENTS

5. OPERATION SYSTEMS ....................................................................................................... 5.1-1 5.1 Operation Description ...................................................................................................... 5.1-1 5.1.1 Narrative Description of Operations at the TAN Hot Shop ................................... 5.1-1 5.1.2 Operations Conducted at the ISFSI ........................................................................ 5.1-5 5.1.3 Flowsheets ............................................................................................................ 5.1-13 5.1.4 Identification of Subjects for Safety Analysis...................................................... 5.1-14 5.2 Fuel Handling Systems .................................................................................................... 5.2-1 5.2.1 TMI-2 Canister Handling and Transfer.................................................................. 5.2-1 5.2.2 TMI-2 Canister Storage ......................................................................................... 5.2-3 5.3 Other Operating Systems ................................................................................................. 5.3-1 5.3.1 Operating System ................................................................................................... 5.3-1 5.3.2 Component/Equipment Spares ............................................................................... 5.3-1 5.4 Operation Support System ............................................................................................... 5.4-1 5.4.1 Instrumentation and Control System ...................................................................... 5.4-1 5.4.2 System and Component Spares .............................................................................. 5.4-1 5.5 Control Room and/or Control Areas ................................................................................ 5.5-1 5.6 Analytical Sampling ........................................................................................................ 5.6-1 LIST OF TABLES Table 5.1-1 Instrumentation Used for NUHOMS-12T System Operations ............................... 5.1-15 LIST OF FIGURES Figure 5.1-1 Primary Operations for the NUHOMS-12T System ............................................. 5.1-16 Figure 5.2-1 NUHOMS Cask/HSM Alignment Verification ....................................................... 5.2-4 TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page i

Intentionally Blank TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page ii

5. OPERATION SYSTEMS This chapter describes the operations to be performed using the NUHOMS-12T system with the MP-187 transportation cask described in previous chapters and shown on the drawings in Appendix A.

Appendix E describes the operations to be performed using the NRC 10 CFR 72 approved OS-197 Transfer Cask. The major difference between the two transportation approaches is that the NRC 10 CFR 72 approved OS-197 Transfer Cask does not require impact limiters, evacuation and helium backfill of the DSC, leak testing of the DSC closure weld, or installation of the vent/filter housing transportation covers. The operations include preparation of the DSC and fuel loading, closure of the DSC, transport to the ISFSI, DSC transfer into the HSM, monitoring operations, and DSC retrieval from the HSM. The NUHOMS-12T transfer equipment, and the existing systems and equipment are used to accomplish these operations.

As of the effective date of the renewed TMI-2 ISFSI license, a license condition prohibits the use of the MP-187 transfer cask (TC) if that MP-187 cask was fabricated 20 or more years prior to its proposed use at the TMI-2 ISFSI. Unless and until the TMI-2 ISFSI license is amended to remove or suitably modify this license condition, all activities involving the TC described in this FSAR may only be conducted using the OS-197 TC as described in Appendix E of this FSAR. Furthermore, if use of the TC used to retrieve the DSC requires the use of TC spacers, the spacers shall have been fabricated less than 20 years prior to their use at the TMI-2 ISFSI.

Operations are performed in two locations: the TAN Hot Shop and the ISFSI. Handling operations at the TAN Hot Shop are described herein but are not subject to licensing, however certain steps in the TAN procedures implement requirements of the licensed system and these procedure steps are subject to change control under 10 CFR 72.48 (see 9.4.1). Operations at the ISFSI are subject to requirements of 10 CFR Part 72. Procedures are delineated in outline form to describe how these operations are to be performed and are not intended to be limiting. TMI-2 canister and cask handling operations performed at TAN under DOE regulated procedures and operations under the purview of 10 CFR Part 71 are described in less detail. Operational procedures at TAN and procedures for transportation under 10 CFR Part 71 may be revised and new ones may be developed according to INL requirements, provided that the limiting conditions of operation are not exceeded.

5.1 Operation Description The following sections outline the general procedures (sequences of steps) that will be followed to prepare and load TMI-2 canisters into the DSCs, transfer the DSCs from TAN to the ISFSI, and place the DSCs into the HSMs at the ISFSI. Operating procedures will be developed for the NUHOMS-12T system to ensure these sequences are followed to: minimize the amount of time required to complete the subject operations; minimize personnel exposure; and assure that all operations required for DSC loading, closure, transfer, and storage are performed safely. The procedure outlines presented here are provided as a guide for the preparation of the operating procedures and serve to point out how the NUHOMS-12T system operations are to be accomplished. This outline is not intended to be limiting in that DOE-ID may judge that alternate acceptable means are available to accomplish the same operational and safety objectives.

5.1.1 Narrative Description of Operations at the TAN Hot Shop The following steps describe the recommended operating procedures for the NUHOMS-12T system with the MP-187 transportation cask. Figure 5.1-1 provides a TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-1

series of pictorial views of the key loading and transfer operations to help in the description of the operating activities.

5.1.1.1 Preparation of the Cask and DSC

1. Prior to placement in dry storage, the TMI-2 canisters are to be dried to ensure that no free water is contained in the canisters. A verified record of final TMI-2 canister drying will be maintained for each canister.
2. Install lower trunnions on the cask. Place the cask on the turning skid. Install upper trunnions. Upright the cask using a cask handling crane.
3. Place the cask in the vertical position in the TAN Hot Shop using the cask handling crane and the cask rigging.
4. Place scaffolding around the cask so that the top cover plate and surface of the cask are easily accessible to personnel.
5. Remove the cask top cover plate and top spacer. Examine the cask cavity for any physical damage and ready the cask for service.
6. Examine the DSC for any physical damage which might have occurred since the receipt inspection was performed. The DSC is to be cleaned and any loose debris removed Cleaning methods shall not introduce any chemical residues.
7. Verify the unique identification of the DSC and using a crane, lower the DSC into the cask cavity by the internal lifting lugs and rotate the DSC to match the cask and DSC alignment marks.
8. Install temporary covers over the cask/DSC annulus to prevent contamination or debris from entering the annulus.
9. Place the top shield plug onto the DSC. Examine the top shield plug to ensure a proper fit.
10. Remove the top shield plug.

5.1.1.2 TMI-2 Canister Loading into the DSC

1. Remotely load the dry TMI-2 canisters from the canister staging area into the DSC in accordance with the TAN procedures. Remove the TMI-2 canister inlet and drain line caps and remove the quick disconnect fittings, if not already done.
2. During the DSC loading process, check, record, and independently verify the identity and location of each TMI-2 canister in the DSC.
3. Install test flanges on vent and purge penetrations on the shield plug.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-2

4. After all the TMI-2 canisters have been placed into the DSC and their identities verified and recorded, position the cask rigging and the top shield plug and lower the shield plug into the DSC.
5. Visually verify that the top shield plug is properly seated onto the DSC.
6. Decontaminate the cask exterior surface if required. Temporary shielding may be installed as necessary to minimize personnel exposure.

5.1.1.3 DSC Shield Plug Sealing

1. Install temporary shielding to minimize personnel exposure throughout the subsequent welding operations as required.
2. Place the automated welding machine onto the cask. As an alternative manual welding is permissible.
3. Check radiation levels along the surface of the shield plug.
4. Verify that the cask/DSC annulus cover is in place to prevent debris from entering the annulus.
5. Take appropriate measures to assure that concentrations of flammable gases are below the flammable limit, or sample the environment in the DSC for flammable gases before welding.
6. Obtain authorization to proceed and then ready the automated welding machine, if installed, and tack weld the shield plug to the DSC shell.

Complete the 360 continuous shield plug weldment and remove the automated welding machine, if installed.

7. Perform surface examination of the shield plug welds (one continuous 360 shield plug to DSC shell weld, one purge penetration weld) in accordance with the Technical Specification requirements.
8. Connect the vacuum drying system (VDS) to the DSC purge port as shown in Figure 4.7.1.
9. Connect the hose from the purge test port to the intake of the vacuum pump.

Connect a hose from the discharge side of the VDS to an off-gas system.

Connect the VDS to a helium source.

10. Open the valve on the suction side of the pump, start the VDS and draw a vacuum on the DSC cavity. When the pressure reaches 10 torr or less, the DSC evacuation is complete. This step is performed to provide an evacuated DSC so that when backfilled with helium, the helium is not diluted with air.
11. Open the valve to the purge port and allow the helium to flow into the DSC cavity.
12. Pressurize the DSC with helium to 22 psia.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-3

13. Helium leak test the shield plug to DSC shell weld for leakage. This leak test is performed for informational purposes prior to welding on the top cover plate.
14. If a leak is found, repair the weld, re-pressurize the DSC and repeat the Step 6 surface examination and the helium leak test.
15. If no leak is detected, release the pressure.

5.1.1.4 DSC Top Cover Installation

1. Disconnect the VDS from the DSC.
2. Place the top cover plate onto the DSC. Verify proper fit up of the top cover plate with the DSC shell. Install the automatic welding system on the cask (as an alternative manual welding is permissible).
3. Tack weld the top cover plate to the DSC shell. Install the top cover plate weld root pass. Perform surface examination of the root pass weld. Weld the top cover plate to the DSC shell and perform surface examination on the weld surface in accordance with the Technical Specification requirements.
4. Remove the automated welding machine from the cask, if installed. Remove vent port test cover and manually seal weld the top cover to the shield plug around the vent and purge penetrations. Perform surface examination of the seal welds in accordance with Technical Specification requirements.
5. Remove temporary shielding from the vent port and purge port penetrations.
6. Install the vent and purge filter assemblies (with transportation covers already installed on the filter assemblies) and the double mechanical seals onto the DSC penetrations.
7. Evacuate and backfill the DSC with helium in accordance with 10 CFR Part 71 requirements. Evacuate and leak test the annulus between the double mechanical seal between the DSC and the vent assembly. Test ports are integral to the filter housings. Testing is done in accordance with 10 CFR Part 71 (10 CFR Part 71 requirements bound), however, only the Technical Specifications requirements are required for the 10 CFR Part 72 license.
8. Remove the temporary cask/DSC annulus cover.
9. Rig the cask top cover plate with top internal spacer attached and lower the cover plate onto the transport cask. Bolt the cask cover plate into place, tightening the bolts to the required torque in a star pattern.
10. Leak test the DSC and cask in accordance with the 10 CFR Part 71 requirements and document on the acceptance form.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-4

5.1.1.5 Cask Downending and Preparation for Transport to ISFSI

1. The transport trailer should be positioned so that the cask support skid is accessible with the trailer supported on the vertical jacks.
2. Re-attach the transport cask rigging to the crane hook. Transfer the cask to the turning skid and then downend the cask. Remove cask upper trunnions.

Return the cask to the transport trailer.

3. Remove the cask lower trunnions. Install top half of transport skid frame.

Install impact limiters. Install personnel barriers.

4. Complete applicable transfer forms for the spent nuclear fuel (SNF) contained in the DSC and attach to the acceptance form.

5.1.2 Operations Conducted at the ISFSI 5.1.2.1 DSC Transfer to the HSM

1. HSM Preparation to Receive DSC: Remove the HSM door using a porta-crane, inspect the cavity of the HSM, removing any debris and ready the HSM to receive a DSC. The doors on adjacent HSMs should remain in place.
2. Prior to transfer activities, verify that DSC temperatures are within the control limits of Technical Specifications of the SAR.
3. Using a suitable heavy haul tractor, transport the cask from the TAN facility to the ISFSI along the designated transfer route.
4. Once at the ISFSI, remove the cask impact limiters and complete the receipt records verification.
5. After removing the impact limiters, move the transport trailer to the HSM.
6. Check the position of the trailer to ensure the centerline of the HSM and cask approximately coincide. If the trailer is not properly oriented, reposition the trailer, as necessary.
7. Set the trailer brakes and disengage the tractor. Drive the tractor clear of the trailer.
8. Connect the skid positioning system hydraulic power unit to the positioning system via the hose connector panel on the trailer, and power it up. Remove the skid tie-down bracket fasteners and use the skid positioning system to bring the cask into approximate vertical and horizontal alignment with the HSM. Using optical survey equipment and the alignment marks on the cask and the HSM, adjust the position of the cask until it is properly aligned with the HSM.
9. Secure the cask restraints to the front wall embedments of the HSM.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-5

10. Unbolt and remove the cask top cover plate and top internal spacer.
11. Using the skid positioning system, fully insert the cask into the HSM access opening docking collar.
12. After the cask is docked with the HSM, verify the alignment of the cask using the optical survey equipment.
13. Install ram front support on base of cask. Position the hydraulic ram behind the cask in approximate horizontal alignment with the cask and level the ram. Remove the ram access cover on the cask. Power up the ram hydraulic power supply and extend the ram through the bottom cask opening into the DSC grapple ring.
14. Activate the hydraulic cylinder on the ram grapple and engage the grapple arms with the DSC grapple ring.
15. Recheck all alignment marks and ready all systems for DSC transfer.
16. Activate the hydraulic ram to initiate insertion of the DSC into the HSM.

Stop the ram when the DSC is fully inserted or if there are indications that the DSC is jammed.

17. Disengage the ram grapple mechanism so that the grapple is retracted away from the DSC grapple ring.
18. Retract and disengage the hydraulic ram system from the cask and move it clear of the cask. Remove the ram support and cask restraints from the HSM.
19. Using the skid positioning system, disengage the cask from the HSM access opening.
20. Install the DSC seismic restraint and record the unique identification number of the DSC and its HSM location.
21. Install the HSM door using a portable crane and secure it in place. Door may be welded for security.
22. Open rear wall access door. Remove transportation covers from the vent and purge assemblies and install the dust covers.
23. Close and lock the rear wall access door.
24. Replace the cask top cover plate and internal spacer. Secure the skid to the trailer, retract the vertical jacks and disconnect the skid positioning system.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-6

25. Reconnect the tractor and tow the trailer and cask to the designated location.

Return the remaining transfer equipment to the designated location.

26. Close and lock the ISFSI access gate and activate the ISFSI security measures.

5.1.2.2 HSM Monitoring Operations

1. Perform routine security surveillance in accordance with the TMI-2 ISFSI physical protection plan.
2. Perform surveillance of the DSC vent system in accordance with the Technical Specification requirements.
3. Perform visual inspection of the DSC and HSM in accordance with the Aging Management Program requirements established in the renewed license to ensure that no aging effects result in a loss of intended function of the structures, systems, and components important to safety.
a. For remote Aging Management Program inspections of the DSC and HSM in the sheltered environment, remove the HSM door using a porta-crane. The doors on adjacent HSMs should remain in place.
b. Perform inspections in accordance with Aging Management Program requirements.
c. Reinstall the HSM door using a porta-crane and secure the door in place.

5.1.2.3 DSC Retrieval from the HSM

1. Ready the cask, transport trailer, and support skid for service and tow the trailer to the HSM.
2. Prior to retrieval activities, verify that DSC temperatures are within the control limits of Technical Specifications.
3. Open the rear wall access door. Remove the vent system dust covers and install the transportation covers on the vent and purge filter assemblies.

Evacuate and backfill the DSC, with helium (if required for 10 CFR Part 71 transportation testing). Install and leak test (if required for transport) the vent and purge assembly seals and vent and purge assembly transportation cover seals.

4. Back the trailer to within a few inches of the HSM, remove the cask top cover plate and top internal spacer.
5. Remove the HSM door using a porta-crane. Remove the seismic restraint.
6. Connect the skid positioning system hydraulic power unit to the positioning system via the hose connector panel on the trailer, and power it up. Remove the skid tie-down bracket fasteners and use the skid positioning system to bring the cask into approximate vertical and horizontal alignment with the HSM. Using optical survey equipment and the alignment marks on the cask TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-7

and the HSM, adjust the position of the cask until it is properly aligned with the HSM.

7. Using the skid positioning system, fully insert the cask into the HSM access opening docking collar.
8. Secure the cask restraints to the front wall embedments of the HSM.
9. After the cask is docked with the HSM, verify the alignment of the cask using the optical survey equipment.
10. Install and align the hydraulic ram with the cask.
11. Extend the ram through the cask into the HSM until it is inserted in the DSC grapple ring.
12. Activate the arms on the ram grapple mechanism with the DSC grapple ring.
13. Retract ram and pull the DSC into the cask.
14. Retract the ram grapple arms.
15. Disengage the ram from the cask.
16. Remove the cask restraints.
17. Using the skid positioning system, disengage the cask from the HSM.
18. Install the internal spacer and cask top cover plate and ready the trailer for transport.
19. Replace the door on the HSM.

5.1.2.4 Removal of TMI-2 Canisters from the DSC If retrieval of the TMI-2 canisters is required, there are two basic options available.

The TMI-2 canisters could be removed from the DSC and reloaded into a shipping cask at a dry transfer facility or at the TAN Hot Shop if available. Procedures for unloading of the TMI-2 canisters into a fuel pool or another cask are presented here. Dry unloading procedures are essentially identical to those of DSC loading through the DSC weld removal. Prior to opening the DSC, the following operations are to be performed.

1. Transfer the cask to the cask handling area inside the TAN or other facility.
2. Position and ready the trailer for access by the crane.
3. Remove the top half of the transportation skid and install lower trunnions.
4. Move cask to turning skid.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-8

5. Install upper trunnions.
6. Move the crane backward in a horizontal motion while simultaneously raising the crane hook vertically and lift the cask off the turning skid.
7. Lower the cask to stand in a vertical position.
8. Clean the cask to remove any dirt which may have accumulated during the loading and transfer operations.
9. Place scaffolding around the cask so that any point on the surface of the cask is easily accessible to handling personnel.
10. Unbolt the cask top cover plate.
11. Connect the rigging cables to the cask top cover plate and lift the cover plate and internal spacer from the cask. Set the cask cover plate and internal spacer aside and disconnect the lid lifting cables.
12. Install temporary shielding to reduce personnel exposure as required.

The process of DSC unloading is similar to that used for DSC loading. DSC opening operations described below are to be carefully controlled in accordance with DSC unloading procedures. This operation is to be performed under established safety and radiological control procedures for welding, grinding, and handling of potentially highly contaminated equipment.

Following opening of the DSC, TMI-2 canisters will be removed using unloading procedures governed by the TAN or other facility operating procedures. The general sequence for these operations are as follows:

13. Place an exhaust hood or tent over the DSC, if necessary. The exhaust should be filtered or routed to the site radwaste system.
14. Vent and purge the gas inside the DSC through the vent port to the facility off-gas system and backfill the DSC with an inert gas such as argon.
15. Remove the DSC vent and purge assemblies and install the vent test penetration and purge port quick disconnect to prevent the spread of contamination.
16. Place welding blankets around the cask and scaffolding.
17. Using plasma arc-gouging, a mechanical cutting system, or other suitable means, remove the seal welds from between the top cover and the shield plug at the vent and purge penetrations. Then remove the weld between the top cover plate and DSC shell. A fire watch should be placed on the TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-9

scaffolding, as appropriate. The exhaust system should be operating at all times.

18. The material or waste from the cutting or grinding process should be treated and handled in accordance with the plant's low level waste procedures unless determined otherwise.
19. Remove the top of the tent, if necessary.
20. Remove the exhaust hood, if necessary.
21. Remove the DSC top cover plate.
22. Reinstall tent and temporary shielding, as required. Remove the shield plug to DSC weld. Remove any remaining excess material on the inside shell surface by grinding.
23. Clean the cask surface of dirt and any debris which may be on the cask surface as a result of the weld removal operation.
24. Lift the top shield plug from the DSC.
25. Remove the TMI-2 canisters from the DSC and place the TMI-2 canisters into an authorized location or other cask.

5.1.2.5 DSC Transfer to the DSC Overpack The need to transfer a DSC to the HSM with an integral overpack could arise as a result of damage or deterioration that occurs unexpectedly or due to loading difficulties. The following procedural steps accommodate this condition with the initial condition of the DSC already in the transfer cask.

As of the effective date of the renewed TMI-2 ISFSI license, a license condition prohibits the use of HSM-15 and its pre-installed DSC overpack for spent fuel storage operations. Unless and until the TMI-2 ISFSI license is amended to remove or suitably modify this license condition, all activities involving the use of HSM-15 and its pre-installed DSC overpack described in this FSAR are prohibited.

1. Prior to positioning the cask close to the DSC overpack, remove the HSM door using a porta-crane. Inspect the cavity of the DSC overpack, removing any debris, and ready the DSC overpack to receive a DSC. The doors on adjacent HSMs, if any, must remain in place. Verify that the overpack vent and purge filters are in place and the filter housing seals have been leak tested.
2. Prior to transfer operations verify that DSC temperatures are within the control limits of Technical Specifications.
3. Using a suitable heavy haul tractor, move the cask to the ISFSI overpack HSM location.

TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-10

4. Check the position of the trailer to ensure the centerline of the DSC overpack and cask approximately coincide. If the trailer is not properly oriented, reposition the trailer as necessary.
5. Set the trailer brakes and disengage the tractor. Drive the tractor clear of the trailer.
6. Unbolt and remove the cask top cover plate and top internal spacer.
7. Using the skid positioning system, fully insert the cask into the DSC overpack access opening docking collar.
8. Connect the skid positioning system hydraulic power unit to the positioning system via the hose connector panel on the trailer, and power it up. Remove the skid tie-down bracket fasteners and use the skid positioning system to bring the cask into approximate vertical and horizontal alignment with the DSC overpack. Using optical survey equipment and the alignment marks on the cask and the DSC overpack, adjust the position of the cask until it is properly aligned with the DSC overpack. Just prior to inserting the DSC into the overpack, pull a vacuum on the DSC, release the vacuum and remove the filters.
9. After the cask is docked with the DSC overpack, verify the alignment of the cask using the optical survey equipment.
10. Secure the cask trunnions to the front wall embedments of the DSC overpack using the cask restraints.
11. Install ram front support on the base of the cask and position the hydraulic ram behind the cask in approximate horizontal alignment with the cask and level the ram. Power up the ram hydraulic power supply and extend the ram through the bottom cask opening into the DSC grapple ring.
12. Activate the hydraulic cylinder on the ram grapple and engage the grapple arms with the DSC grapple ring.
13. Recheck all alignment marks used in the Step 11 operation and ready all systems for DSC transfer.
14. Activate the hydraulic ram to initiate insertion of the DSC into the DSC overpack. Stop the ram when the DSC reaches the support rail stops at the back of the DSC overpack.
15. Disengage the ram grapple mechanism so that the grapple is retracted away from the DSC grapple ring.
16. Retract and disengage the hydraulic ram system from the cask and move it clear of the cask. Remove the ram support and cask restraints.

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17. Using the skid positioning system, disengage the cask from the DSC overpack access opening.
18. Install the DSC overpack cover including surface examination of the root and final pass of the weld in accordance with Technical Specification requirements.
19. Install the HSM door using a portable crane and secure it in place. Door may be welded for security.
20. Replace the cask top cover plate. Secure the skid to the trailer, retract the vertical jacks and disconnect the skid positioning system.
21. Tow the trailer and cask to the designated location. Return the remaining transfer equipment to the designated location.
22. Close and lock the ISFSI access gate and activate the ISFSI security measures.

5.1.2.6 DSC Overpack Monitoring Operations

1. Perform routine security surveillance in accordance with the TMI-2 ISFSI physical protection plan.
2. Perform surveillance of the DSC overpack vent system in accordance with the Technical Specification requirements for a standard HSM/DSC vent system.

5.1.2.7 DSC Retrieval from the Overpack

1. Ready the cask, transport trailer, and support skid for service and tow the trailer to the DSC overpack.
2. Evacuate and backfill the overpack and DSC with fresh air or an inert gas.
3. Cut any welds from the door and remove the HSM door using a porta-crane.

Remove the DSC seismic restraint.

4. Place scaffolding, a containment tent with exhaust system, and welding blankets around appropriate end of the overpack.
5. Using plasma arc-gouging, a mechanical cutting system, or other suitable means, remove the seal weld from the DSC overpack. A fire watch should be present, as appropriate. The exhaust system should be operating, as necessary.
6. The material or waste from the cutting or grinding process should be treated and handled in accordance with the facilities low level waste procedures unless determined otherwise.

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7. Remove the tent and exhaust system.
8. Remove the DSC overpack cover plate.
9. Prior to retrieval activities, verify that DSC temperatures are within the control limits of Technical Specifications.
10. Back the trailer to within a few inches of the DSC overpack.
11. Using the skid positioning system, align the cask with the HSM and position the skid until the cask is docked with the HSM access opening.
12. Using optical survey equipment, verify alignment of the cask with respect to the DSC overpack. Install the cask restraints.
13. Install rear cask ram support and align the hydraulic ram with the cask, as necessary.
14. Extend the ram through the cask into the DSC overpack until it is inserted in the DSC grapple ring.
15. Activate the arms on the ram grapple mechanism with the DSC grapple ring.
16. Retract ram and pull the DSC into the cask.
17. Retract the ram grapple arms.
18. Disengage the ram from the cask.
19. Remove the cask restraints.
20. Using the skid positioning system, disengage the cask from the DSC overpack.
21. Install vent and purge port filter/transportation cover assemblies, if required.

Install and leak test (if required for transport) the vent assembly transportation covers.

22. Install the cask internal spacer and top cover plate.
23. Replace the door on the overpack.

5.1.3 Flowsheets The NUHOMS-12T is a passive storage system and requires no operating system other than those systems/operations used in loading and transfer. A description and sequence of operations is provided in Section 5.1.1. A series of pictorial views of operations is also shown in Figure 5.1-1.

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5.1.4 Identification of Subjects for Safety Analysis 5.1.4.1 Criticality Control The criticality analyses and controls for the NUHOMS-12T system are described in Section 3.3.4.

5.1.4.2 Chemical Safety There are no hazardous chemicals used in the NUHOMS-12T system that require special precautions. Material control procedures at the TAN facility will ensure that no hazardous chemicals or surface contaminants are introduced.

5.1.4.3 Operation Shutdown Modes NUHOMS-12T is a totally passive system, including DSC venting, and has no operational shutdown modes.

5.1.4.4 Instrumentation Table 5.1-1 shows the typical instruments which might be used to measure conditions or control the operations during the DSC loading, closure, transfer, and storage operations. The instruments are standard industry equipment, which is readily available.

5.1.4.5 Maintenance Techniques The NUHOMS-12T system does not require maintenance during storage except when sampling of the DSCs indicates that filter replacement and DSC purging is required. When required by Technical Specification limits, the DSC would be purged and the HEPA grade filters replaced. HEPA grade filter replacement would be performed using conventional radioactive contamination control practices.

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Table 5.1-1 Instrumentation Used for NUHOMS-12T System Operations Instruments Function

1. Gross Gamma/Beta/Neutron Measure dose rate at DSC top cover plates Detectors
2. Pressure and Vacuum Gauges Measure helium, air and vacuum pressures inside DSC. Measure the pressure drop across the HEPA filters.
3. Hydraulic Pressure Gauges Measure and limit hydraulic and Ram Pressure Relief ram force applied to DSC Valves
4. Optical Survey Equipment Align cask and ram with HSM
5. Gas Sampling Equipment Measure hydrogen concentration during vent system surveillance activities
6. Air Particulate Measuring Equipment Measure air samples outside of filters for airborne activity.

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Figure 5.1-1 Primary Operations for the NUHOMS-12T System TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.1-16

Figure 5.1-1 Primary Operations for the NUHOMS-12T System (continued)

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Figure 5.1-1 Primary Operations for the NUHOMS-12T System (continued)

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Figure 5.1-1 Primary Operations for the NUHOMS-12T System (continued)

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Figure 5.1-1 Primary Operations for the NUHOMS-12T System (concluded)

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5.2 Fuel Handling Systems 5.2.1 TMI-2 Canister Handling and Transfer NUHOMS-12T is a modular storage system which provides for the dry storage of TMI-2 canisters in a horizontal orientation. NUHOMS-12T is a system designed to be installed at the INL INTEC site. It utilizes the existing systems at the TAN for handling TMI-2 canisters and casks. This section describes the TMI-2 canister handling systems that are unique to NUHOMS-12T and used during the DSC loading, closure, and transfer operations. The transfer system is described in this section to illustrate the hardware and procedures required for operation of the NUHOMS-12T system.

5.2.1.1 Function Description Figure 5.1-1 illustrates the DSC loading, closure, and transfer operations.

Transfer System: The transfer system is composed of the cask, lifting device, support skid, skid positioning system, transport trailer, hydraulic ram, and auxiliary equipment as described in Section 1.3.2.

Cask: The cask is used to transfer a loaded DSC to and from the HSM. The cask provides biological shielding during the transfer, loading, and retrieval operations. During transfer of the DSC to the HSM, the top end of the cask is docked within the HSM access opening sleeve. A description of the cask design criteria and capabilities are provided in Chapters 3, 4, and 8.

Cask Transportation Skid: The purpose of the cask transportation skid, shown in Figure 4.7-7, is to transport the cask in a horizontal position to the ISFSI and maintain the cask alignment during the loading and retrieval operations. The skid is mounted on bearing plates and secured to the transport trailer during transport. These bearings permit the skid to be moved in the longitudinal and transverse directions with respect to the trailer. The skid positioning system shown in Figure 4.7-5, allows the DSC to be precisely aligned with the DSC support structure inside the HSM. Section 3.1.2.1 establishes the criteria for design of the cask transportation skid.

Transport Trailer: The function of the transport trailer is two-fold: 1) to transport the loaded cask in the horizontal position to the ISFSI, and 2) to approximately align the cask with the HSM opening. The trailer shown in Figure 4.7-3 is a standard heavy haul trailer capable of handling a 125 ton payload.

Optical Survey Equipment: After the loaded trailer has been backed up to the HSM, the cask is aligned with the HSM. Alignment is achieved using a transit and optical alignment marks on the cask and HSM as shown in Figure 5.2-1. Once the cask is aligned with the HSM, the trailer jacks and cask restraints ensure that alignment is maintained throughout the DSC transfer or retrieval operations.

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Jack Support System: The tires on the trailer are pneumatic. As the DSC is being transferred into or out of the HSM, the transfer of the load may cause the alignment to be altered or cause the DSC to bind in the cask or HSM. To ensure that the alignment is maintained throughout the DSC transfer or retrieval operations, jacks at four locations on the trailer are used as shown in Figure 4.7-3. The design criteria for the jack support system are established in Section 3.1.2.

Cask Restraints: During the DSC transfer or retrieval operations, the resistance of the DSC could cause the cask to move in its axial direction. This motion could cause the alignment to be altered or the shielding by the HSM and cask to be jeopardized. To ensure that the cask does not move in the axial direction, cask restraints join the HSM front wall embedments to the cask.

Ram and Grappling Apparatus: The ram is a hydraulic cylinder which extends from the back of the cask through the length of the cask as shown in Figure 4.7-

6. The grappling apparatus is mounted on the front of the ram as shown in Figure 4.7-6. The hydraulics for the grappling apparatus are activated, causing the arms to engage the DSC grapple ring. Once the arms are engaged, the ram is extended, pushing the DSC out of the cask and into the HSM. For retrieval of the cask, the process is reversed. The DSC slides along the cask inner liner rails and onto the support rails inside the HSM.

DSC Support Rails: During the transfer operation, the DSC slides out of the cask on hard surfaced rails and onto the support rails inside the HSM as shown in Figure 4.2-3. The support rails in the HSM serve as both the sliding surfaces during the transfer operation as well as supports during DSC storage. The support rail surface that comes into contact with the surface of the DSC, is coated with a lubricant.

5.2.1.2 Safety Features Except for the transfer of the DSC from the cask to the HSM, the loaded DSC is always seated inside the cask cavity. The safety features used in handling the cask at the TAN facility are described in the facility safety procedures.

To ensure that the minimum amount of force is applied to the DSC during the transfer operation, the cask cavity rails and the HSM support rails are coated with a lubricant. A low coefficient of friction minimizes the amount of force applied to the DSC, thus minimizing the possibility of damage to the DSC.

If the motion of the DSC is impeded during the transfer operation and the ram continues to travel, the force exerted by the ram on the DSC will increase. To indicate the occurrence of such an event, the amount of force which the ram may exert is limited by the ram control system and monitored by the operator. The stresses which develop in the DSC due to the maximum loading force are less than the allowable limits of the DSC material and, therefore, the integrity of the canister shell and closure welds is not jeopardized.

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5.2.2 TMI-2 Canister Storage Descriptions of the operations used for the transfer and retrieval of the DSC from the HSM are presented in Section 5.1.

5.2.2.1 Safety Features The features, systems, and special techniques which provide for safe loading and retrieval operations are described in Section 5.2.1.2.

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Figure 5.2-1 NUHOMS Cask/HSM Alignment Verification TMI-2 SAR-II-8.4 3/31/21 Chapter 5 Rev. 6 Page 5.2-4

5.3 Other Operating Systems 5.3.1 Operating System NUHOMS-12T is a passive storage system and requires no operating systems other than those systems used in transferring the DSC to and from the HSM.

5.3.2 Component/Equipment Spares As discussed in Section 8.2, the TMI-2 ISFSI is designed to withstand all postulated design basis events. Therefore, no storage component or equipment spares are required for the standardized NUHOMS-12T system, with the exception of changeout of the HEPA filters.

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5.4 Operation Support System NUHOMS-12T is a self-contained passive system and requires no effluent processing systems during storage conditions.

5.4.1 Instrumentation and Control System There are no instrumentation and control systems included in the system design. The instrumentation and controls necessary during DSC loading, closure, transfer and periodic testing during storage are described in Section 5.1.4.4.

5.4.2 System and Component Spares There are no instrumentation or control systems used during storage conditions; thus, no other system and component spare parts are required.

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5.5 Control Room and/or Control Areas There are no control room or control areas for the NUHOMS-12T system.

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5.6 Analytical Sampling Periodic DSC sampling is performed for the NUHOMS-12T system in accordance with the Technical Specification surveillance and monitoring requirements. The objective of this sampling is to ensure that the hydrogen gas remains at safe levels and the vent system and HEPA filters are functioning properly.

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NLF-RPT-255, TMI-2 ISFSI Biennial Update Report for 2023 Attachment B TMI-2 SAR-II-8.4 Chapter 9 (PDF attached)

Page 5 of 5

Table of Contents

9. CONDUCT OF OPERATIONS ..................................................................................... 9.1-1 9.1 Organizational Structure ......................................................................................................... 9.1-1 9.1.1 Corporate Organization ........................................................................................... 9.1-1 9.1.2 Corporate Functions, Responsibilities, and Authorities.......................................... 9.1-1 9.1.3 Operating Organization, Management, and Administrative Control System .......... 9.1-5 9.1.4 Personnel Qualification Requirements .................................................................... 9.1-7 9.1.5 Liaison with Outside Organizations...................................................................... 9.1-10 9.2 Preoperational Testing and Operation .................................................................................... 9.2-1 9.2.1 Administrative Procedures for Conducting Test Programs ..................................... 9.2-1 9.2.2 Test Program Description ....................................................................................... 9.2-1 9.2.3 Test Discussion ....................................................................................................... 9.2-2 9.3 Training Program.................................................................................................................... 9.3-1 9.3.1 Administration ........................................................................................................ 9.3-1 9.3.2 Records ................................................................................................................... 9.3-1 9.3.3 Instructor Qualifications and Development ............................................................ 9.3-1 9.3.4 Development of Training Material.......................................................................... 9.3-2 9.3.5 Training Improvement............................................................................................. 9.3-2 9.3.6 Waivers of Training Requirements ......................................................................... 9.3-2 9.3.7 Frequency of Training ............................................................................................. 9.3-2 9.3.8 General Employee Training .................................................................................... 9.3-2 9.3.9 Certified ISFSI Operator Training........................................................................... 9.3-3 9.3.10 Technical Support Positions .................................................................................... 9.3-5 9.4 Normal Operations ................................................................................................................. 9.4-1 9.4.1 Procedures ............................................................................................................... 9.4-1 9.4.2 Records ................................................................................................................... 9.4-1 9.5 Emergency Planning ............................................................................................................... 9.5-1 9.6 Decommissioning Plan ........................................................................................................... 9.6-1 9.6.1 Decommissioning Program ..................................................................................... 9.6-1 9.6.2 Cost of Decommissioning ....................................................................................... 9.6-1 9.6.3 Decommissioning Facilitation ................................................................................. 9.6-1 9.6.4 Recordkeeping for Decommissioning ..................................................................... 9.6-2 9.7 Physical Protection Program ................................................................................................... 9.7-1 9.8 Aging Management................................................................................................................. 9.8-1 9.8.1 Scoping Evaluation Methodology ........................................................................... 9.8-1 9.8.2 Results of Aging Management Scoping Evaluation - Major Components ............ 9.8-2 9.8.3 Results of Aging Management Scoping Evaluation - Subcomponents .................. 9.8-3 9.8.4 Aging Management Reviews - Materials and Environments ................................. 9.8-4 9.8.5 Results of Aging Management Reviews ................................................................. 9.8-6 9.8.6 Aging Management Programs .............................................................................. 9.8-12 9.8.7 Time-Limited Aging Analyses ............................................................................. 9.8-13 9.8.8 Tollgate Assessments ............................................................................................ 9.8-14 9.9 References .............................................................................................................................. 9.9-1 TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page i

LIST OF FIGURES Figure 9.1-1 TMI-2 ISFSI Organization ............................................................................ 9.1-9 LIST OF TABLES Table 9.8-1 Results of Component-Level and Contents Scoping Evaluation ................. 9.8-14 Table 9.8-2 In-Scope Subcomponents for Aging Management ...................................... 9.8-15 Table 9.8-3 Materials and Environments for DSC AMRs .............................................. 9.8-25 Table 9.8-4 Materials and Environments for HSM AMRs.............................................. 9.8-26 Table 9.8-5 Materials and Environments for TMI-2 Canister AMRs ............................. 9.8-30 Table 9.8-6 TMI-2 ISFSI Tollgates ................................................................................. 9.8-33 Table 9.8-7 DSC Aging Management Program............................................................... 9.8-34 Table 9.8-8 HSM Aging Management Program .............................................................. 9.8-36 Table 9.8-9 OS197 Transfer Cask Aging Management Program ................................... 9.8-39 TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page ii

9. CONDUCT OF OPERATIONS This chapter describes the organization and general plans for operating the TMI-2 ISFSI. The organization section includes a brief description of the responsibilities of key personnel. The preoperational testing program is described. The training program for the facility staff is described.

Procedures that govern routine operations and maintenance and the records developed as a result of those operations are also discussed.

9.1 Organizational Structure 9.1.1 Corporate Organization The Deputy Manager for Idaho Cleanup Project (DM/ICP), Office of Environmental Management (EM) is authorized to be the license holder for the TMI-2 ISFSI (License SNM-2508). This authority was delegated and responsibility was assigned to the DM/ICP by the Secretary of Energy pursuant to 10 CFR 72.16(b) in a delegation order. As the facility owner and licensee, DOE retains ultimate responsibility for the safe operation of the facility and for compliance with all license conditions.

9.1.2 Corporate Functions, Responsibilities, and Authorities The DM/ICP Manager is the authorized DOE representative having direct authority and responsibility for compliance with the TMI-2 ISFSI License. The DM/ICP is responsible for overall executive management of the NRC-licensed ISFSIs, has signature authority for the TMI-2 ISFSI license, and is the person ultimately responsible for compliance with the facilitys license conditions and overall facility nuclear safety. The DM/ICP shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure nuclear safety and compliant operations. The responsibilities of the personnel reporting directly to the DM/ICP, as depicted in Figure 9.1-1, are described below.

The actual day-to-day execution of programs and operations associated with the NRC-licensed ISFSIs is performed by a contractor. The DM/ICP and staff provide management direction and oversight of contractor performance in accordance with DOE-ID's Quality Assurance (QA) Program and commitments herein.

ISFSI support services are provided by the DOE-ID Office of Nuclear Engineering (NE).

The DOE-ID Office of Operations Support (NE) is independent of the facility line management and is responsible for environmental protection, safety, health, quality assurance, and security. This Office provides DOE-ID oversight of the contractor for licensed activities independent of the ICP organization. The DOE-ID Office of Administration Support has responsibility for developing appropriate revisions to the contract.

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9.1.2.1 Applicant's In-House Organization This section contains the description of DOE-ID's organization, as depicted in Figure 9.1-1. The responsibility for DOE-IDs role of providing direction to the contractor for spent fuel management lies with the DM/ICP.

The ICP NRC Licensed Facilities Program (NLFP) Team supports and coordinates directly with the DM/ICP as the license holder on all license activities. The NLFP team is managed administratively by the Assistant Manager for Facility and Material Disposition (AM/FMD). The AM/FMD is a senior line manager charged, among other responsibilities unrelated to the license, with NLFP personnel management and budgetary oversight of NLFP ensuring the availability of an adequate number of trained/certified federal staff and resources to support the management and oversight of license activities.

The NLFP Supervisor is the formal liaison with the DM/ICP (License Holder) on all matters pertaining to the TMI-2 ISFSI License and the contractors execution of its requirements. The NLFP Supervisor is also accountable to the AM/FMD for funds management and personnel performance. The NLFP Supervisor leads a team of subject matter experts overseeing the NLFP contractors execution of license requirements. The team consists of a Facility Director as a work lead, a License Manager, a Physical Security Manager and an Information Security Manager, all of whom have direct access to the DM/ICP (License Holder) on issues affecting the safety and surety of TMI-2 ISFSI operations.

The NLFP Supervisor is accountable for the programmatic and operational oversight of the TMI-2 ISFSI, the maintenance of license requirements in the contract (delegated by the DM/ICP), the supervision and mentoring of NLFP Managers, and ensuring the incorporation of an Integrated Safety Management System (ISMS) into the activities. The Supervisor is the primary point of contact between the federal staff and the DM/ICP, the NRC, and the contractor organizations. The NLFP Supervisor provides senior management with independent critical assessments and technical evaluations of licensing activity and program progress. The NLFP Supervisor is the Contracting Officer Representative (COR)

Alternate, accountable to the COR for meeting License requirements and maintaining regulatory compliance. The NLFP Supervisor is also tasked with the management of stakeholder interactions at the request and direction of the DM/ICP.

The NLFP Facility Director, as the work lead for the NLFP, reports to the NLFP Supervisor and ensures the day-to-day compliance with safety, quality, regulatory and environmental compliance requirements through a full complement of oversight, on-site inspections and visits, federal support staff coordination, and daily facility and contractor interface. The NLFP Facility Director serves in an ex officio capacity on the TMI-2 ISFSI Safety Review Committee. The NLFP Facility Director develops the facility oversight plans, schedules and staffs the surveillances and assessments, and reviews and integrates the results reporting outcomes and trending to the Supervisor in close cooperation with the NLFP License Manager.

The NLFP Facility Director ensures that on-the-ground implementation of emergency response plans, physical protection plans, and other management processes are consistent with NLFP plans through close coordination with other TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-2

NLFP Managers. As needed, an alternate for the NLFP Facility Director, authorized to act in the NLFP Facility Directors absence, is designated in writing and meets the training and qualification requirements specified below for the NLFP Facility Director.

The NLFP License Manager reports to the NLFP Supervisor and ensures contractor compliance with and overall maintenance of the TMI-2 ISFSI License. The NLFP License Manager coordinates the preparation of required routine, formal and informal program documents, license applications (and amendments) and other communications for the Supervisors clearance and transmittal to the NRC, and prepares timely responses to NRC requests for the Supervisor. The NLFP License Manager works closely with the NLFP Facility Director, ensuring mutual interpretation and application of license requirements in the field. The NLFP License Manager leads the development and execution of the master oversight program for the entire team ensuring timely execution and documentation of oversight activities by all staff.

The NLFP Physical Security Manager reports to the NLFP Supervisor and provides physical security oversight and management of the contractor for maintenance of security plans and requirements, working with both the NLFP contractor and the DOEs Idaho Site contractors to ensure continuity of operations. As the lead for emergency management, the Physical Security Manager is responsible for the oversight of design, development, execution, and assessment of surveys, drills, exercises and events related to security and emergency management.

The NLFP Information Security Manager reports to the NLFP Supervisor and, as the Classification Officer for the NLFP, ensures all information developed, used, and/or transmitted by the federal and contractor staff is appropriately managed.

The Information Security Manager serves as the communications technology requirements point-of-contact and subject matter expert for federal and contractor personnel. The NLFP Information Security Manager serves as the lead for all training from the NLFP team.

The responsibility for oversight of the contractors Quality Assurance (QA)

Program for the NRC-licensed ISFSIs as well as the DOE-ID QA oversight program of the ISFSI operations is delegated through the DOE-ID Deputy Manager for Operations Support to the DOE-ID Director, Quality and Safety Division, and from there, to the Supervisor, QA Program, who serves as the NLFP QA Manager. The roles and responsibilities of the NLFP QA Manager are further described in Chapter 11 of this SAR. As with the NLFP Team, the NLFP QA Manager has direct access to the DM/ICP on issues related to the safety and surety of ISFSI operations.

9.1.2.2 Interrelationships with Contractors and Suppliers The DOE utilizes a contractor for the TMI-2 ISFSI activities. The authority for the management and operation of the facility is contractually delegated and the responsibility for compliance with license requirements and applicable regulations is contractually assigned to the contractor. To exercise DOE's ultimate responsibility, DOE will: (1) retain responsibility for and perform independent audits of the contractors TMI-2 ISFSI QA Program (both the TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-3

achievement of quality by contractor management and the verification of quality by contractor QA personnel), (2) ensure the license requirements for the facility are included in the contract, (3) assess the performance of the contractor against the terms of the contract, (4) retain the responsibility to budget funds necessary and sufficient to safely operate the facility, and (5) retain the authority to revise the contract in the event contract deficiencies are found relative to proper implementation of license requirements.

The key relationships between the NLFP Team, NLFP QA Manager, and the contractor are also depicted in Figure 9.1-1.

9.1.2.2.1 ISFSI Oversight Program The NLFP Facility Director is the day-to-day management DOE-ID employee responsible for the compliance of TMI-2 ISFSI operations. The NLFP Facility Director shall verify or audit the TMI-2 ISFSI for compliance with regulatory requirements and license basis commitments and apprise DOE-ID management of TMI-2 ISFSI status based on observations.

The NLFP Facility Director or alternate shall perform surveillances of the contractor's ALARA Committee and the ISFSI Safety Review Committee and shall be an ex officio member (and is a quorum requirement) of these committees when they meet to review ISFSI matters to ensure these committees' functions are satisfactory and to report to DOE-ID management as needed. (See Section 9.1.3.1.1 for the duties of the ISFSI Safety Review Committee.)

The NLFP Facility Director or alternate shall review the results of management assessments performed for the following contractors' programs: training, security, emergency, quality assurance, and radiation protection.

The NLFP Facility Director or alternate shall review and concur with all of the following:

  • All 72.48 evaluations and TS Basis evaluations (TS 5.5.1) for the TMI-2 ISFSI
  • Changes to TS Bases
  • All changes to the SAR
  • Nuclear Material Status Reports (submitted electronically)
  • Annual environmental report
  • Other reports which may be submitted to NRC in response to conditions or events which are not submitted by the DM/ICP.

9.1.2.3 Applicant's Technical Staff TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-4

The DOE Idaho Operations Office has a technical staff representing several areas of expertise with the wide variety of projects and activities at the INL.

This staff is available to assist the management and oversight of the DOE activities at the TMI-2 ISFSI. Staff assigned to assist the management and oversight in the areas of security, radiation protection, emergency preparedness, and QA are trained and qualified in accordance with Licensing Management Procedures, or perform work directly under the supervision of the NLFP Team.

9.1.3 Operating Organization, Management, and Administrative Control System The operating organization, line management, and administrative control systems are provided by DOEs contractor personnel. The DOE and its contractor commit to provide the NRC with ready access to the TMI-2 ISFSI, personnel, and records that NRC considers necessary to carry out its responsibilities.

DOE-ID (EM) has assigned responsibility and delegated authority for the management and operation of the facility to the contractor. DOE-ID policy requirements for operating the TMI-2 ISFSI are assigned to the contractor through the contract. Specifically, the contract requires the contractor to manage and operate the TMI-2 ISFSI in compliance with all applicable:

  • Human health and safety regulations,
  • Environmental regulations,
  • NRC regulations and license conditions, and
  • Quality assurance requirements.

DOE-ID (EM) commits to providing a contractor with management and staff for routine operation and maintenance of the TMI-2 ISFSI and support organizations to implement DOE's program commitments in QA, security, training, radiological protection, environmental monitoring, and spent fuel accountability.

9.1.3.1 Onsite Organization The contractor corporate structure provides the necessary organizations for managing and operating the TMI-2 ISFSI. The following organizational descriptions document the organizations necessary to manage the TMI-2 ISFSI.

The contractor's Chief Executive Officer (CEO) is responsible for overall management of contractor activities and is accountable for complying with the contract conditions. The contractor CEO delegates authorities for daily management to the Program Manager. Authorities are delegated and resources are provided to manage the TMI-2 ISFSI in the areas of emergency preparedness, engineering, environmental management, operations, maintenance, QA, radiological control, safety and health, security, training, and transportation. In addition to the interfaces shown on Figure 9.1-1, personnel assigned to the above functions maintain interfaces with their functional counterparts at DOE-ID.

The TMI-2 ISFSI Manager reports to the ISFSI Program Manager. Support staff for essential positions within the contractors NRC Licensed Facilities organization report to the General Services Manager for services (e.g., Engineering, Document Control, Records Management, Training, Licensing, etc.) provided for the TMI-2 TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-5

ISFSI. The ISFSI Program Manager also reports to the DOE-ID NLFP Facility Director. This interface is the primary operations interface between DOE-ID (EM) and its contractor for the TMI-2 ISFSI.

The contractors QA Manager assigned to the TMI-2 ISFSI reports to a level equal to or above the reporting level of the ISFSI Program Manager. The QA Manager assigned to the TMI-2 ISFSI also interfaces with the DOE-ID ISFSI QA Manager who is responsible for the TMI-2 ISFSI QA Program (see Chapter 11).

9.1.3.1.1 ISFSI Safety Review Committee Reporting to and chartered by the contractors CEO is the ISFSI Safety Review Committee. This committee is comprised of senior technical personnel and management personnel with extensive nuclear experience in various areas.

The purpose of this committee is to evaluate the performance of staff level safety review committees, to review performance indicators (such as audit findings, reportable events and conditions, Technical Specification violations); to review 10 CFR 72.48 evaluations (and associated procedure or design changes); to review changes to the Technical Specification Bases, SAR, Emergency Response Plan, and Physical Protection Plan; to approve license amendment requests; and to review preparations for major changes in operation (such as removing fuel from the ISFSI). The ISFSI Safety Review Committee shall also perform special reviews at the direction of the DOE-ID NLFP Facility Director.

Core members, appointed in writing by the chartering senior executive, provide the needed technical expertise in engineering, radiological safety, criticality safety, nuclear facility operations, and nuclear quality assurance; their technical qualifications are described in section 9.1.4.1 below. Other members may be appointed as considered appropriate by the chartering senior executive.

A quorum shall include 3 core members, the technical disciplines appropriate for the matters under review, and the DOE-ID NLFP Facility Director. The DOE-ID NLFP Facility Director is informed of all appointments to the Safety Review Committee.

9.1.3.2 Personnel Functions, Responsibilities, and Authorities The daily management of the ISFSI operation is provided by the TMI-2 ISFSI Manager. The TMI-2 ISFSI Manager reports to the ISFSI Program Manager.

Assuring requirements are satisfied in the operation of the ISFSI is the responsibility of the TMI-2 ISFSI Manager.

Personnel assigned to TMI-2 ISFSI operations report to the TMI-2 ISFSI Manager. Other personnel from the INL that may be assigned to work at the ISFSI will report to the TMI-2 ISFSI Manager while at the ISFSI site. The TMI-2 ISFSI Manager is responsible for maintaining the Operations log. This log will TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-6

be used to note the performance of all significant on-site activities and conditions.

TMI-2 staff-level committees include an ALARA Committee and staff level safety review committee(s) or board(s) responsible to review changes to license basis documents and any associated evaluations.

9.1.4 Personnel Qualification Requirements The following DOE-ID positions require minimum qualifications and training for the management and oversight of the TMI-2 ISFSI:

  • NLFP QA Manager
  • NLFP Facility Director and designated alternate.

The following contractor positions require minimum qualifications and training for the operation of the TMI-2 ISFSI:

  • ISFSI Safety Review Committee members
  • TMI-2 ISFSI Manager and designated alternate
  • TMI-2 Facility Safety Officer and designated alternate
  • QA Manager 9.1.4.1 Minimum Qualification Requirements In all of the positions below where an academic degree is required, the requirement for a degree may be replaced with an additional five years experience in the technical area (but not necessarily at supervisory level) specified for that position (for a total of ten years experience).

The DOE-ID NLFP QA Manager shall have a minimum of a Baccalaureate degree in an engineering or physical science field and five years experience in nuclear QA and certification as lead auditor. The minimum training for this position shall include 72.48 process, QA program indoctrination, NRC requirements, and the TMI-2 ISFSI License Basis (consisting of the identification of and orientation to the license and design basis documents).

The DOE-ID NLFP Facility Director shall have a minimum of a Baccalaureate degree in an engineering or physical science field and five years experience in nuclear facility operations. The minimum training for this position shall include 72.48 process, QA Program indoctrination, Technical Specifications, NRC requirements, and the TMI-2 ISFSI License Basis. The designated alternate for the NLFP Facility Director shall meet the same minimum qualifications and training requirements.

The Chair, Members, and Alternates of the ISFSI Safety Review Committee (SRC) shall have a minimum of a Baccalaureate degree in an engineering or physical science field and five years experience in one or more of the following technical areas at nuclear facilities:

  • Radiological Safety TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-7
  • Nuclear Safety (with at least two years experience in criticality safety analysis)
  • Nuclear Facility Operations
  • Nuclear QA
  • Engineering The minimum training for the Chair, Members, and Alternates of the ISFSI SRC shall include the 72.48 process, QA program indoctrination, Technical Specifications, NRC requirements, and the TMI-2 ISFSI License Basis.

The ISFSI Program Manager shall have a minimum of a Baccalaureate degree in an engineering or physical science field and five years supervisory experience in nuclear facility operations. No minimum training requirements are associated with this position.

The TMI-2 ISFSI Manager shall have a minimum of a Baccalaureate degree in an engineering or physical science field and five years supervisory experience in nuclear facility operations or equivalent for education and experience as approved by the ISFSI Program Manager, and written concurrence from the NLFP Facility Director. The minimum training for this position shall include 72.48 process, TMI-2 ISFSI License Basis, Radiation Worker, Emergency Response, and TMI-2 Facility Qualification training. The designated alternate for the TMI-2 ISFSI Manager shall meet the same minimum qualifications and training requirements.

The TMI-2 Facility Safety Officer shall have a minimum of a Baccalaureate degree in an engineering or physical science field and five years supervisory experience in radiation protection for nuclear facility operations. The minimum training for this position shall include the ISFSI Radiation Protection Program.

The designated alternate for the TMI-2 Facility Safety Officer shall meet the same minimum qualifications and training requirements.

The minimum qualifications for the position of Certified ISFSI Operators are successful completion of the biennial medical examination and training and certification in accordance with the requirements in section 9.3.

The minimum qualifications for the QA Manager assigned to the TMI-2 ISFSI are a Baccalaureate degree in an engineering or physical science field and five years experience in nuclear operations QA. No minimum training requirements are associated with this position.

9.1.4.2 Qualifications of Personnel The resumes or other appropriate documentation of personnel occupying the positions listed in section 9.1.4.1 will be kept on file to demonstrate compliance with the minimum requirements described in section 9.1.4.1.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-8

Figure 9.1-1. TMI-2 ISFSI Organization TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-9

9.1.5 Liaison with Outside Organizations Despite the fact that the TMI-2 ISFSI is a DOE-owned facility located on the INL with several other DOE-owned facilities and DOE-managed programs, the external regulation of the TMI-2 ISFSI by the NRC sets this facility apart in some respects. The INL is a large, remotely located site and has its own large security police force, a fire department, medical staff, emergency response teams, and full-time INTEC shift plant supervision. Thus, the INL infrastructure will be considered to serve equivalent functions as independent local agencies (similar to local city or county) do for typical commercial licensed sites.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.1-10

9.2 Preoperational Testing and Operation Prior to loading the ISFSI with the TMI-2 canisters, a series of preoperational, startup and performance tests will be developed and implemented. The tests will include functional tests of the in-plant operations, the on-site transport operations, and DSC insertion and retrieval (operations at the ISFSI). These tests are intended to verify that the storage system components (e.g., DSC, HSM, transfer cask, transfer equipment, etc.)

operate safely and effectively.

9.2.1 Administrative Procedures for Conducting Test Programs Test procedures will be developed as part of the spent fuel storage system.

Approval of procedures, performance of tests, evaluation of test results, and incorporation of any needed system modifications or procedure changes (based on the results of the tests) will be performed by the contractor using administrative controls existing at the INL.

9.2.2 Test Program Description The testing program to be conducted utilizes a DSC loaded with mock-up fuel, the transfer cask and associated transfer equipment, and an HSM. The tests will simulate, as nearly as possible, the actual operations involved in preparing a DSC for storage and ensure that they can be performed safely during actual emplacement of TMI-2 core debris in the ISFSI. Verification of ALARA practices, which are not completely achievable during dry runs, will take place during the initial fuel loading. Guidelines for such tests are provided in the following paragraphs.

1. An actual DSC will be utilized for preoperational testing. The DSC will be loaded into the transfer cask to verify fit and adequacy of the cask/DSC annulus seal. Additionally, the DSC may be used in operational testing of the transfer equipment and HSM.
2. Functional testing is to be performed with the transfer cask and lifting devices. These tests are to ensure that the transfer cask can be safely lifted from the trailer, to the upending skid, to the cask work area.
3. The transfer cask will be placed on the transport trailer, which will then be transported to the ISFSI along a predetermined route and aligned with an HSM. Compatibility of the transport trailer with the transfer cask, verification of the transfer route to the ISFSI, and maneuverability within the confines of the ISFSI will be verified.
4. The transfer trailer will be aligned and docked with the HSM. The hydraulic ram will be functionally tested and then used to insert a DSC loaded with test weights into the HSM, and then retrieve it. A weighted DSC will also be loaded into and retrieved from the HSM with the DSC overpack. This testing will be completed after initiation of the loading operations, but prior to the shutdown of the TAN Hot Shop. Until such time, the TAN Hot Shop will be used for recovery of a challenged DSC. Transfer of the DSC to the HSM should verify that the support skid positioning system and the hydraulic ram system operate safely for both insertion and retrieval of a DSC.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.2-1

In addition, since a vented system is proposed to address concerns over radiolysis in the TMI-2 canisters, monitoring will be performed at three phases of the loading and storage campaign. First, a representative sample of canisters will be monitored in their current storage location in the TAN pool for generation of off-gases. Second, a sample of actual TMI-2 core debris will be dried and tested for potential release of fissile material. This will aid in the design of the canister dewatering and drying system. Third, each individual DSC (containing up to 12 TMI-2 canisters) will be monitored during storage at the ISFSI for internal build-up of hydrogen and radiological releases in accordance with the corresponding Technical Specifications.

The HEPA filter design for the DSCs will also be tested prior to operation of the ISFSI. This testing will be done in accordance with typical industry testing and acceptance methods for HEPA filters.

9.2.3 Test Discussion Implementation of the test program is discussed in the paragraphs which follow.

1. The purpose of the preoperational tests is to ensure that a DSC can be properly and safely placed in the TAN hot cell, loaded with TMI-2 fuel, transported to the ISFSI, inserted in the HSM, and retrieved from the HSM.

Proper operation of the DSC, transfer cask, and transfer equipment, as well as the associated auxiliary equipment (e.g., automatic welding equipment and vacuum drying system), provides such assurance.

The purpose of the TMI-2 canister demonstration test program is to ensure that the TMI-2 canisters can be properly and safely dried and stored in the ISFSI.

2. Detailed procedures will be developed and implemented by contractor personnel who are responsible for ensuring that the test requirements are satisfied.
3. The expected results of the preoperational tests are the successful completion of the following: placement of a DSC into the transfer cask, loading of the DSC with TMI-2 canisters, transporting the transfer cask loaded with a DSC and test weights to the ISFSI, and transfer of a DSC to/from the HSM.

The tests are deemed successful if the expected results are achieved safely and without damage to any of the components or associated equipment. The expected results of the TMI-2 canister demonstration test program are the successful completion of canister drying and successful ongoing DSC vent performance.

4. Should any equipment or components require modification in order to achieve the expected results, it will be retested to confirm that the modification is adequate. Should any preoperational procedures change in order to achieve the expected results, the changes will be incorporated into the appropriate operating procedures.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.2-2

5. INTEC operations are not affected by testing of the ISFSI. Testing operations can generally be conducted concurrently with plant operation. All normal prerequisites for safe handling of components will be satisfied, and normal safety and radiological practices will be employed.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.2-3

9.3 Training Program This section of the SAR comprises DOE's TMI-2 ISFSI Training Program and is submitted pursuant to Subpart I of 10 CFR Part 72. The requirements of this TMI-2 ISFSI Training Program are implemented by contractor procedures providing for the administration of training programs. A management assessment of the contractor's implementation of this training program shall be performed biennially. Changes which do not decrease the effectiveness of this program will be documented with biennial SAR updates.

The objective of this TMI-2 ISFSI Training Program is to use a systematic approach to training to provide competent contractor personnel to perform all functions related to the operation of the TMI-2 ISFSI. The application of the systematic approach to training will use a graded approach, with the training of Certified ISFSI Operators subject to the most rigorous application.

This training program ensures that qualified individuals will be available to perform planned and unplanned tasks while protecting the health and safety of plant personnel and the public. DOE, through its contractor, commits to maintain additional training to support the emergency plan, physical protection plan, quality assurance plan, and administrative and safety requirements, as required. Procedures and lesson plans used to implement this training program will be developed and maintained by the contractor.

9.3.1 Administration The Training Supervisor is responsible for the administration of training programs and for maintaining up-to-date records on the status of contractor trained personnel, training of new employees, and refresher or upgrade training of present personnel.

The TMI-2 ISFSI Manager is responsible for ensuring that training requirements are specified for personnel assigned to support the TMI-2 ISFSI. In this role, the ISFSI Manager or designee will approve all TMI-2 specific lesson plans.

The TMI-2 ISFSI Manager is responsible for ensuring that training requirements have been satisfied for personnel assigned to the TMI-2 ISFSI.

9.3.2 Records The following records on the status of trained personnel will be maintained for a minimum of five years in accordance with Section 9.4.2 below:

  • Results of each Certified ISFSI Operators biennial medical examination.
  • The completed records of certification.

9.3.3 Instructor Qualifications and Development The contractor shall provide for and document the qualification and training of Training Staff.

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9.3.4 Development of Training Material The contractor shall maintain procedures providing for the analysis of jobs, design of initial and continuing training, development of instructional material, implementation (conduct of training), and evaluation (examinations, boards, performance demonstration, etc.) The development of training material shall be performed by qualified and trained staff. The contractor shall maintain all training materials, both academic lesson plans and On-the-Job training (OJT) guides, developed in accordance with this training program.

9.3.5 Training Improvement The contractor shall provide for and document the evaluation of training programs in order to ensure the continued improvement of training material and the conduct of training.

9.3.6 Waivers of Training Requirements Applications for waivers of training requirements shall be approved by the TMI-2 ISFSI Manager. Successful completion of equivalent training programs may be used as a basis for waiver from academic training requirements. This training should be comparable in content, performance criteria, and duration. Any information used in the evaluation for a waiver should be verified. Previous work experience may be used as a basis for waiver from OJT requirements.

9.3.7 Frequency of Training Training requirements must be completed within the period specified in the sections below for General Employee Training and Certified ISFSI Operator Training; however, a grace period of 25% is allowed. Not completing the retraining requirements within the specified frequency will require completion of the initial training course in order to have qualification reinstated.

9.3.8 General Employee Training General employee training will be provided to all qualified or certified ISFSI operators and their direct supervision. Topics required for certified operators may be included in the generalized training.

The GET training program is composed of an initial training course and required annual retraining.

A score of <80% on the examination will require a retest. Individuals who write or review lesson plans or tests are excused from taking GET exams.

The GET course shall consist of material dealing with:

  • Physical description of the TMI-2 ISFSI (Structural characteristics)
  • Heat transfer design characteristics, including engineering principles of passive cooling
  • Applicable regulations and standards
  • Radiological shielding
  • General ISFSI information on access control
  • 10 CFR 19.12 TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.3-2

The annual retraining for GET will be composed of the topics covered in the initial GET course. Additional topics may be added as needed.

9.3.9 Certified ISFSI Operator Training Operations such as DSC preparation and handling, fuel loading, transfer cask preparation and handling, and transfer trailer loading are performed under DOE authorization. Procedures and training for these operations are governed by DOE requirements.

The training for Certified ISFSI Operators and supervisor shall provide for initial training and testing of personnel who operate equipment identified as important to safety and will also provide for retraining, proficiency testing, and requalification as required. Certified ISFSI Operators will be actively maintained during transport and HSM loading and unloading operations. During the extended storage period, qualifications will be required for HSM and DSC monitoring activities. During periods when Certified ISFSI Operators are not required, the appropriate lesson plans will be retained as records.

TMI-2 ISFSI equipment and controls that have been identified as important to safety in this SAR and in the license shall be operated by either personnel who have been trained and certified in accordance with this section or who are under the direct visual supervision of a trained, certified individual. Only qualified individuals will operate equipment, machinery, and cranes.

Instructors designated to teach the Certified ISFSI Operator Program shall possess subject matter expertise for a particular subject or topic. Instructors initially qualified will maintain qualifications by instructing classes, and administering or grading examinations and OJT guides, and preparing, reviewing, or revising Certified ISFSI Operator instructional material.

Each individual will be given instructions regarding the hazards and safety precautions applicable to the type of work to be performed, general workplace hazards, and the procedures for protecting themselves from injury. These instructions are normally given during pre-job briefs prior to operations.

The Certified ISFSI Operator Training Program will consist of lesson plans and associated examinations in, but not limited to, the following topics, as applicable to personnel job functions:

A. Fuel Characteristics

  • configuration of TMI-2 Canisters (3 types)
  • contents of TMI-2 Canisters
  • condition of TMI-2 core debris TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.3-3

B. Equipment, Component, and Design Description

  • Dry Shielded Canister (DSC)
  • Horizontal Storage Module (HSM)
  • Transfer Cask (TC)
  • alignment of the cask skid with the HSM
  • assembly of the hydraulic ram system
  • normal and off-normal operation of the hydraulic ram
  • maintenance of the vent and purge system C. Major Licensed Operations D. Regulations, Procedures, and Limitations
  • administrative control of Certified ISFSI Operator actions
  • description of events and sequence of operations (ISFSI Overview)
  • Technical Specifications E. Safety Concepts
  • accident analysis from the TMI-2 ISFSI SAR for off normal operations and accidents
  • confinement barriers/systems
  • criticality prevention The Certified ISFSI Operator Training Program will include operational training (OJT) involving actual and/or mock control manipulations of the following, as applicable. Manipulations will include Certified ISFSI Operator responses, instrumentation, indications, abnormal situations and corrective measures, prerequisites, and procedures. Actual manipulation and operations are preferred to mock manipulations to the extent practicable based upon equipment availability.
  • transfer trailer
  • hydraulic ram
  • vent and purge system.

Biennial retraining applicable to active and ongoing TMI-2 ISFSI operations will be conducted as necessary for ISFSI operators and supervisory personnel who operate equipment or controls that have been identified as important to safety in this SAR and in the license. Any OJT required for recertification will be repeated biennially. The classroom material and written examinations associated with the OJT will be presented and completed prior to the OJT. Additionally, classroom material will be presented as needed in order to convey pertinent modifications, procedure changes, regulatory changes, or other significant material in a timely manner.

Certification as a TMI-2 ISFSI Certified ISFSI Operator is contingent upon meeting the following criteria: obtaining a score of >80% on all Certified ISFSI Operator academic examinations; and satisfactory performance of all OJT practical evaluations. A score of < 80% on any certification academic examination will require retesting. A score of < 80% on the retest will constitute TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.3-4

cause for dismissal from the Certified ISFSI Operator or Supervisor Training Program. A score of < 80% on any three initial academic examinations will constitute cause for dismissal from the Certified ISFSI Operator or Supervisor Training Program. Failure to demonstrate satisfactory performance of the OJT practical examinations will require retesting. Failure to demonstrate satisfactory performance of a second OJT practical examination will constitute cause for dismissal from the Certified ISFSI Operator Training Program.

The evaluation criterion for initial certification of Certified ISFSI Operators shall not be waived; nor shall the evaluation criterion be waived for two or greater consecutive recertification cycles.

The physical condition and general health of certified personnel will be verified by physical examination before initial certification and biennially thereafter. These physical examinations consider conditions which might cause impaired judgement or motor coordination. In addition, if an employee's behavior or condition creates a hazard to health or safety, then stop work may be imposed.

9.3.10 Technical Support Positions Training for the applicable support positions will include the administrative and management controls associated with ensuring compliance with the TMI-2 ISFSI license conditions.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.3-5

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9.4 Normal Operations The ISFSI provides for independent storage of TMI-2 core debris separate from the existing INL facilities. With the exception of some limited physical monitoring, maintenance of the DSC vent systems, and security systems, the ISFSI functions as a passive system once the TMI-2 core debris has been placed in dry storage. Placement of TMI-2 core debris in the ISFSI requires specific procedures that are separate from those of normal operations.

9.4.1 Procedures Detailed written procedures will be developed and maintained for the applicable ISFSI operations, maintenance, surveillance, and testing and are described in Sections 5.1.1 and 5.1.2. Procedure changes in Section 5.1.1 are subject to DOE Unreviewed Safety Question analysis as they are conducted under the parameters and cognizance of the TAN SAR under DOE regulation.

However, any procedure changes that could have an impact or bearing on the design basis or the safety basis of TMI ISFSI components, performance specifications, or requirements in the TMI SAR or Technical Specifications shall also be subject to 10 CFR 72.48. Such applicable activities will be clearly denoted in the Section 5.1.1 procedures. The procedures listed in Section 5.1.2 shall be subject to 10 CFR 72.48. All TMI ISFSI procedures will be developed, reviewed, revised, approved, and controlled by the contractor in accordance with approved administrative procedures.

The format and content of written procedures include:

  • Introduction (includes purpose and scope)
  • precautions and limitations
  • prerequisites
  • instructions (sequence, forms to be completed, acceptable conditions, actions if conditions aren't acceptable, approvals)
  • records Maintenance of the written procedures shall be in accordance with Sections 11.5 and 11.6 as implemented by established contractor procedures. The contractor document control system provides written requirements for review, approval, revision, and controlled distribution of the written procedures.

9.4.2 Records The following TMI-2 ISFSI records will be maintained:

  • QA records relating to design, construction, testing, surveillance, operation, and maintenance of the ISFSI
  • Decommissioning records (1) Records of spills or other unusual occurrences involving the spread of contamination in and around the facility, equipment, or site (2) As-built drawings and modifications of structures and equipment in restricted or inaccessible areas (3) A list contained in a single document of all areas designated and formerly TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.4-1

designated as restricted areas and all areas outside of restricted areas that require documentation due to spread of contamination (4) Records of the cost estimate performed for decommissioning

  • Training records as specified in the TMI-2 ISFSI Training Plan (Section 9.3.2)
  • Changes, Tests and Experiments made without prior NRC approval, including the safety evaluations
  • Spent fuel material records, including current inventory and material control and accountability procedures
  • ISFSI Safety Review Committee records
  • Records required by the operating, maintenance, and testing procedures described in Section 9.4.1.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.4-2

9.5 Emergency Planning The TMI-2 ISFSI Emergency Planning requirements are maintained in the TMI-2 ISFSI Emergency Response Plan (ERP). The ERP does not cover detailed security related planning for the ISFSI. These events are accounted for in the TMI-2 ISFSI Physical Protection Plan.

The TMI-2 ISFSI ERP describes the overall process developed to respond to and mitigate any consequences of emergencies that might arise at the TMI-2 ISFSI. The plan incorporates a number of emergency elements, including: (a) demonstrating hazards and credible events that could result in emergency situations; (b) preparing for those situations with a trained emergency response organization; (c) maintaining emergency equipment and facilities; (d) determining protective actions; (e) maintaining standards and techniques for notifications, classification, consequence assessment, reentry, medical support, and program administration; (f) providing timely and accurate public information; and (g) identifying the diverse elements involved in recovery and reentry.

All emergency assistance off site with respect to the TMI-2 ISFSI is obtained from DOE-ID and contractor personnel at the INL. There are no credible accidents at the TMI-2 ISFSI which would require emergency assistance off site with respect to the INL site boundary.

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9.6 Decommissioning Plan The Conceptual Plan for Decommissioning the TMI-2 ISFSI is included as an enclosure to the TMI-2 ISFSI License Application. This decommissioning plan describes the proposed program (approaches, elements, and cost estimates) for decommissioning the TMI-2 ISFSI.

9.6.1 Decommissioning Program The tentative selection of decommissioning alternatives is based on providing decontamination and removal of radioactivity from the site and leaving the basemat intact for unlimited use. DECON is the preferred decommissioning alternative. The program includes preparation (engineering and planning, filing a decommissioning plan with the NRC, and site preparation), decommissioning operations and license termination, and site restoration. The program is described in more detail in the Conceptual Plan for Decommissioning the TMI-2 ISFSI.

Near the end of operations at the TMI-2 ISFSI, a decommissioning plan will be developed to provide specific details of decommissioning based on the technologies that exist at that time. The DOE expects to develop decommissioning and decontamination technologies during the ISFSI license period and will select and define the appropriate approaches at the time of decommissioning.

9.6.2 Cost of Decommissioning The Conceptual Plan for Decommissioning the TMI-2 ISFSI contains cost estimates for decommissioning the TMI-2 ISFSI. The DOE Office of Environmental Management has included the TMI-2 ISFSI decommissioning program in its overall cost estimate for the Environmental Management Program at the INL. DOE will request appropriate funding from Congress at the time of decommissioning.

9.6.3 Decommissioning Facilitation Decommissioning of a NUHOMS ISFSI can be performed in a manner consistent with that for decommissioning other INL facilities. The NUHOMS 12T DSCs can be retrieved from the HSMs and transferred to an on-site facility where the TMI-2 canisters will be unloaded and placed in a 10 CFR Part 71 licensed transportation cask for shipment off-site to a federal facility.

All components of the NUHOMS system are manufactured of materials similar to those found at existing plants (e.g., reinforced concrete, carbon steel, and stainless steel). These components can, therefore, be decommissioned by the same methods in place to handle those materials at the INL. Any of the components that may be contaminated can be cleaned and/or disposed of using the decommissioning technologies available at the time of decommissioning.

The NUHOMS system is a dry containment system that effectively confines all contamination within the DSC. When the DSC is removed from the HSM, the freestanding HSM can be manually decontaminated for any radioactive material, dismantled, and removed from the site. It is possible that a thin layer of material comprising the inner wall of the HSM could become activated by the neutron flux TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.6-1

after an extended period of time. The specific activity of the HSM inner wall surfaces may be measured at the time of decommissioning and compared with the existing guidelines to determine whether the values are below those acceptable for free release. Disposal procedures can be developed which comply with existing requirements at the time of decommissioning.

The NUHOMS DSCs are manufactured from carbon and stainless-steel material which can be decontaminated. If the activity levels are reduced below the level for free release of the material, the steel could be sold for scrap and shipped off-site. If the activity levels cannot be reduced, the steel material can be disposed of in accordance with requirements existing at the time of decommissioning. Other NUHOMS components (transfer equipment, vacuum drying equipment, etc.) are expected to be decontaminated and made available for use at other NUHOMS facilities.

Removal of the TMI-2 canisters from the DSC can be accomplished as described in Chapter 5. The transfer of the TMI-2 canisters from the DSC can be made by use of an existing fuel pool or dry cask transfer in a hot cell.

9.6.4 Recordkeeping for Decommissioning Records that support decommissioning will be treated as quality assurance records. The Conceptual Plan for Decommissioning the TMI-2 ISFSI identifies the types of records that will be maintained to facilitate the ISFSI decommissioning.

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9.7 Physical Protection Program The purpose of the TMI-2 ISFSI physical protection program is to establish and maintain a physical protection program that has the capabilities for the protection of spent fuel stored in the TMI-2 ISFSI, in accordance with Subpart H, "Physical Protection," of 10 CFR Part 72 and applicable portions of 10 CFR Part 73.

The TMI-2 ISFSI physical protection program is described in the Physical Protection Plan for the TMI-2 ISFSI. This plan includes, as appendices, the TMI-2 ISFSI Security Training and Qualification Plan and the TMI-2 ISFSI Safeguards Contingency Plan.

This Physical Protection Plan for the TMI-2 ISFSI contains Safeguards Information, is controlled and protected in accordance with 10 CFR 73.21 and 10 CFR 2.790, and has been submitted for NRC review under separate cover.

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Intentionally Blank TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.7-2

9.8 Aging Management To provide reasonable assurance that the structures, systems, and components (SSCs) of the TMI-2 ISFSI will continue to perform their intended functions for the period of extended operation (PEO), DOE-ID performed certain aging management activities (AMAs) in support of the renewal of the ISFSI license. These activities involved performing a scoping evaluation to identify those SSCs that required an aging management review (AMR) and performance of those AMRs. The result of the AMRs determined whether in-scope SSCs required a time-limited aging analysis (TLAA) or an aging management program (AMP) to provide reasonable assurance of functionality through the PEO. The process used to perform these AMAs is described in NUREG-1927, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel [9.1] and NEI 14-03, Format, Content, and Implementation Guidance for Dry-Cask Storage Operations-Based Aging Management

[9.2]. DOE-IDs license renewal application (LRA) [9.3] provides additional details, including technical bases for the AMAs at the TMI-2 ISFSI.

The first activity in addressing aging management for an ISFSI is to identify the in-scope SSCs based on safety classification and function, as described in NUREG-1927, Section 2.0. Once the TMI-2 ISFSI SSCs that were in-scope for aging management were identified, an AMR was performed to identify the aging effects and aging mechanisms requiring management for each SSC, as described in Section 3.0 of NUREG-1927, augmented by the information in Section 3 of NEI 14-03.

The first step of the AMR for each SSC was to identify the applicable materials subject to aging, along with their service environments. Then, the aging effects and mechanisms requiring management for each SSC were identified. Lastly, either a TLAA or an AMP was developed for each in-scope SSC. The subsections below describe the performance and results of the scoping evaluation, AMRs, TLAAs, and AMPs applicable to the TMI-2 ISFSI SSCs.

9.8.1 Scoping Evaluation Methodology The scoping evaluation performed for the TMI-2 ISFSI license renewal followed the guidance in NUREG-1927, Section 2.0. An SSC is in-scope for aging management if it meets either of the following two criteria:

1. The SSC is classified as Important to Safety (ITS).
2. The SSC is classified as Not-Important-To-Safety (NITS) but, according to the design bases, its failure could prevent fulfillment of a function that is ITS.

NUREG-1927, Section 2.4.2.1 also addresses scoping as it relates to fuel assemblies and other contents stored in the dry storage system (DSS). For simplicity, the TMI-2 LRA used Section 2.4.2.1 of NUREG-1927 to identify a third scoping criterion to address spent nuclear fuel (SNF) assemblies and other contents stored in the DSS (i.e., the payload):

3. Payload contents, including the TMI-2 canisters and the TMI-2 core debris, if relied upon in the safety analysis to maintain geometric configuration.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-1

The scoping evaluation was performed in two phases. The first phase of the scoping evaluation was performed at the SSC major component level based on a review of safety classifications and design bases functions described herein, as well as design documents such as drawings. DSS contents were also considered in this phase. A major component was considered in-scope if it met one of the three scoping criteria. The second phase of the scoping evaluation was performed on an SSC subcomponent level using the Updated Final Safety Analysis Report (UFSAR) and design drawings to make a final determination on in-scope SSCs that would require AMRs. SSC subcomponents not meeting one of the three scoping criteria were scoped out for the AMR.

9.8.2 Results of Aging Management Scoping Evaluation - Major Components The results of the first phase of the scoping evaluation are shown in Table 9.8-1, which shows both in-scope and out-of-scope major components and DSS contents.

The major in-scope components for aging management and the scoping criterion met are as follows:

  • The Dry Shielded Canisters (DSCs) - Criterion 1
  • The Horizontal Storage Modules (HSMs), except HSM Criterion 1
  • The Transfer Cask (TC) - Criterion 1
  • The ISFSI Basemat and Approach Slab - Criterion 2
  • The TMI-2 Canisters - Criterion 3.

9.8.2.1 Dry Shielded Canister (DSC)

The DSC is scoped in as a major component because it performs or supports the following intended functions throughout the PEO:

  • Confinement
  • Radiation shielding
  • Heat-removal capability
  • Structural integrity
  • Retrievability.

Detailed descriptions of the specific design functions performed by the DSC in the above areas may be found in Sections 3.1 through 3.4 of this UFSAR (Section 3.4.1, in particular) and Chapter 8.

9.8.2.2 Horizontal Storage Module (HSM)

The HSM is scoped in as a major component because it performs or supports the following intended functions throughout the PEO:

  • Radiation shielding
  • Heat-removal capability
  • Structural integrity
  • Retrievability.

Detailed descriptions of the specific design functions performed by the HSM in the above areas may be found in Sections 3.1 through 3.4 of this UFSAR (Section 3.4.2, in particular) and Chapter 8.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-2

9.8.2.3 Transfer Cask (TC)

The TC is scoped in as a major component because it is classified as an ITS component and supports retrieval of the DSC from the HSM. The TC is not used during normal storage operations and has no other storage intended function, besides retrievability throughout the PEO. However, it is used for both structural support (protecting the DSC) and radiation shielding during transfer operations.

Detailed descriptions of the specific design functions performed by the TC may be found in Sections 3.1 through 3.4 of this UFSAR (Section 3.4.4, in particular), Chapter 5, and Appendix E.

9.8.2.4 ISFSI Basemat and Approach Slabs The ISFSI basemat and approach slabs are scoped in because they support retrievability of the DSC from the HSM. Detailed descriptions of the specific design functions performed by the ISFSI basemat and approach slabs may be found in Section 3.4.3 of this UFSAR.

9.8.2.5 TMI-2 Canister The TMI-2 Canister is scoped in because it performs or supports the following intended functions throughout the PEO:

  • Shielding
  • Criticality prevention
  • Structural integrity.

Detailed descriptions of the specific design functions performed by the three types of TMI-2 Canisters may be found in Sections 3.1 through 3.4 of this UFSAR (Section 3.1.1, in particular) and Chapter 8.

9.8.3 Results of Aging Management Scoping Evaluation - Subcomponents In the second phase of the scoping evaluation, the design functions performed or supported by each of the subcomponents of the major components were evaluated.

Subcomponent SSCs were scoped in if they performed or supported one or more of the intended functions performed by the associated major component. This phase of the scoping evaluation was primarily conducted from a review of the fabrication drawings and bill of materials.

Table 9.8-2 lists the in-scope subcomponent SSCs for each in-scope major component and the intended function performed or supported by the subcomponent. Subcomponents of in-scope major components not listed in Table 9.8-2 are out of scope for aging management.

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9.8.4 Aging Management Reviews - Materials and Environments 9.8.4.1 Materials The major components and subcomponents of SSCs that are in-scope for aging management are fabricated from the following materials:

  • Reinforced concrete
  • Stainless steel
  • Carbon/boron steel
  • Alloy steel
  • Ferritic steel
  • Inconel 625
  • BORAL
  • E70XX weld filler
  • Polyurethane plastic
  • Elastomeric (neoprene) seal material
  • Zinc-rich inorganic coating
  • Silicone sealant (Chemical grout)
  • Lightweight concrete (LICON).

9.8.4.2 Environments The ambient environment at the TMI-2 ISFSI is described in detail in Chapter 2. A review of the information presented in Chapter 2 was performed to assess the environmental conditions to which the in-scope SSCs are normally exposed. The environments to which the TMI-2 ISFSI in-scope SSCs are exposed depend on the characteristics of the TMI-2 ISFSI site environment, as well as the SSC location within the DSS.

The environments considered in the AMR are the environments that the TMI-2 ISFSI in-scope SSCs and associated subcomponent SSCs normally experience. Environmental stressors that are conditions not normally experienced (such as extreme heat or cold), or that may be caused by a design or fabrication condition, are considered event driven and are not aging related. Such event-driven situations would be evaluated and corrective actions, if any, implemented at the time of the event.

The HSMs contain the DSCs, which are ventilated to the HSM internal space through HEPA filters. The DSCs contain the TMI-2 Canisters, which are ventilated to the DSC internal space.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-4

The five service environments for the major components of SSCs that are in-scope for aging management include:

1. Outdoor - An environment exposed to all local ambient weather conditions at the INL Site, including seasonal and daily temperature and humidity variations, exposure to sunlight, wind, and precipitation. The HSM exterior surfaces, including hardware, access doors, roof bolt protective covers, etc. are exposed to the Outdoor Environment.
2. Sheltered - This is a protected ambient environment with no direct exposure to sunlight, wind, or precipitation. The sole source of moisture is natural humidity and small amounts of wind-blown rain entering through the vent holes in the rear access door. Temperature inside the Sheltered Environment is a function of outdoor temperature and, to a lesser extent, any heat produced by the TMI-2 core debris inside the DSCs. The DSC exterior surfaces are exposed to the Sheltered Environment. The Sheltered Environment on the DSC shell exterior surface may range from ambient air temperature to slightly above ambient. SSCs located in the Sheltered Environment are also exposed to neutron and gamma radiation fields. However, sources of heat and radiation inside the DSC will decrease over the PEO due to radioactive decay of the TMI-2 core debris.
3. Internal DSC - The Internal DSC Environment is that located within the DSC cylindrical storage cavity. The TMI-2 Canister exterior surfaces, the inside surfaces of the DSC shell and interior shell assembly subcomponents (e.g., inner top and bottom cover plates and top shield plug) are exposed to the Internal DSC Environment. This environment communicates with the Sheltered Environment via a combination of four HEPA filters on the DSC vent port and a single HEPA filter on the DSC purge port. The ventilation and off gas system for the NUHOMS-12T storage system is completely passive and is designed to allow diffusion of small amounts of hydrogen generated inside the DSC through the HEPA filter vents. This environment experiences neutron and gamma fluence higher than the Sheltered Environment. The environment inside the DSC is nearly ambient since it is vented, and decay heat levels are low.
4. Internal TMI-2 Canister - The Internal TMI-2 Canister Environment is that located within the TMI-2 Canister storage cavity. This environment is even more protected from outdoor ambient conditions than either the Sheltered or Internal DSC Environments. The TMI-2 Canister interior structure, the inside surfaces of the TMI-2 Canister shell and interior TMI-2 Canister subcomponents are exposed to the Internal TMI-2 Canister Environment. It is a similar environment to the Internal DSC Environment, except that it is exposed to slightly higher temperatures and higher neutron and gamma fluence.

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5. Embedded or Encased - This environment applies for materials that are embedded or encased (sealed) inside another material. This includes, but is not limited to, items such as concrete reinforcing bars, anchorages, and shield plugs between the inner and outer DSC cover plates. In addition, it includes the BORAL neutron poison material enclosed between the inner and outer skin on the TMI-2 Fuel Canister, and Boron Carbide pellets encased in the TMI-2 Knockout and TMI-2 Filter Canister poison rod tubes. Embedded or Encased Environments are exposed to radiation.

The heat load source decreases over the PEO.

Tables 9.8-3 through 9.8-5 provide the combinations of materials and environments considered in the AMR for each in-scope subcomponent SSC, except for the TC. See FSAR Section 9.8.5.3 for additional information on aging management of the TC.

9.8.5 Results of Aging Management Reviews After the materials and environments for in-scope major component and subcomponent SSCs were identified, the potential applicable aging effects and mechanisms requiring management for each were determined. Those aging effects and mechanisms were then reviewed with respect to the materials and service conditions for each subcomponent to determine which required aging management at the TMI-2 ISFSI during the PEO. Then, a determination as to whether a TLAA or other engineering evaluation or alternately an AMP was employed to address or manage the aging effect. The subsections below summarize the results of the AMRs for each major component.

9.8.5.1 Results of AMR - DSC The potential aging effects and related aging mechanisms that were evaluated in the AMR for the in-scope DSC subcomponent SSCs are:

a) Potential Aging Effect: Loss of material Associated Potential Aging Mechanisms:

  • General corrosion
  • Crevice corrosion
  • Pitting corrosion
  • Galvanic corrosion
  • Microbiologically induced corrosion
  • Adhesive, abrasive, and erosive wear b) Potential Aging Effect: Cracking Associated Potential Aging Mechanisms:
  • Hydrogen damage c) Potential Aging Effect: Change in material properties TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-6

Associated Potential Aging Mechanisms:

  • Intergranular corrosion
  • Creep
  • Thermal aging
  • Irradiation embrittlement
  • Hydrogen damage The AMR conducted for the DSC evaluated the likelihood of the above potential aging mechanisms to cause the related potential aging effect for the DSC subcomponent SSCs and determined that the following aging effect and causative aging mechanisms required a TLAA or AMP for the DSC:

Aging Effect: Loss of material Aging Mechanisms:

  • General, crevice, pitting, and galvanic corrosion
  • Adhesive wear In addition, as a defense-in-depth aging management function, the zinc-rich primer on the Sheltered Environment steel SSCs is included to assess loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage.

See Sections 9.8.6.1 and 9.8.7 for summary descriptions of the TMI-2 ISFSI DSC AMPs and TLAAs, respectively.

9.8.5.2 Results of AMR - HSM The potential aging effects and related aging mechanisms that were evaluated during the AMR for the in-scope HSM subcomponents are:

a) Potential Aging Effect: Loss of concrete material via spalling or scaling Associated Potential Aging Mechanisms:

  • Freeze-thaw cycles
  • Aggressive chemical attack
  • Fatigue
  • Irradiation
  • Reaction with aggregates
  • Shrinkage b) Potential Aging Effect: Concrete cracking Associated Potential Aging Mechanisms:
  • Freeze-thaw cycles
  • Aggressive chemical attack
  • Fatigue TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-7
  • Irradiation
  • Reaction with aggregates
  • Shrinkage
  • Elevated temperatures c) Potential Aging Effect: Reduction of concrete strength and modulus Associated Potential Aging Mechanisms:
  • Irradiation
  • Aggressive chemical attack
  • Reaction with aggregates
  • Leaching of calcium hydroxide
  • Elevated temperatures
  • Creep d) Potential Aging Effect: Loss of material of embedded SSCs Associated Potential Aging Mechanism:
  • Corrosion e) Potential Aging Effect: Increase in concrete porosity and permeability Associated Potential Aging Mechanism:
  • Leaching of calcium hydroxide f) Potential Aging Effect: Reduction of concrete pH Associated Potential Aging Mechanisms:
  • Aggressive chemical attack
  • Leaching of calcium hydroxide g) Potential Aging Effect: Premature degradation of concrete repair chemical grout fillers and sealants Associated Potential Aging Mechanism:
  • Ultra-violet (UV) exposure
  • Irradiation In addition, as a defense-in-depth aging management function, the silane water repellent coating on the concrete is included to assess for physical damage on the steel coatings and inhibition of moisture penetration on HSM concrete SSCs and rebar corrosion on HSM steel SSCs.

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h) Potential Aging Effect: Loss of material in HSM steel SSCs Associated Potential Aging Mechanisms:

  • General corrosion
  • Crevice corrosion
  • Pitting corrosion i) Potential Aging Effect: Loss of strength in HSM steel SSCs Associated Potential Aging Mechanisms:
  • Irradiation
  • Fatigue j) Potential Aging Effect: Cracking in HSM steel SSCs Associated Potential Aging Mechanisms:
  • Irradiation
  • Fatigue
  • Stress corrosion cracking In addition, as a defense-in-depth aging management function, the zinc-rich primer on the coated steel HSM SSCs is included to assess loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage.

The AMR conducted for the HSM evaluated the likelihood of the above potential aging mechanisms to cause the related potential aging effect for the HSM SSCs and determined that the following aging effects and aging mechanisms required a TLAA or AMP for the HSM:

a) Aging Effect: Loss of concrete material via spalling or scaling Associated Aging Mechanisms:

  • Freeze-thaw cycles
  • Shrinkage b) Aging Effect: Concrete cracking Associated Aging Mechanisms:
  • Freeze-thaw cycles
  • Shrinkage c) Aging Effect: Reduction of concrete strength and modulus Associated Aging Mechanism:
  • Leaching of calcium hydroxide TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-9

d) Aging Effect: Loss of material from embedded SSCs Associated Aging Mechanism:

  • Corrosion e) Aging Effect: Increase in concrete porosity and permeability Associated Aging Mechanism:
  • Leaching of calcium hydroxide f) Aging Effect: Reduction of concrete pH Associated Aging Mechanism:
  • Leaching of calcium hydroxide g) Aging Effect: Premature degradation of concrete repair chemical grout fillers and sealants Associated Aging Mechanisms:
  • Ultra-violet (UV) exposure
  • Irradiation In addition, as a defense-in-depth aging management function, the silane water repellent coating on the concrete is included to assess for physical damage on the steel coatings and inhibition of moisture penetration on HSM concrete SSCs and rebar corrosion on HSM steel SSCs.

h) Aging Effect: Loss of material in HSM steel SSCs Associated Aging Mechanism:

  • General, crevice, and pitting corrosion In addition, as a defense-in-depth aging management function, the zinc-rich primer on the coated steel HSM SSCs is included to assess loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage.

See Sections 9.8.6.2 and 9.8.7 for summary descriptions of the TMI-2 ISFSI HSM AMPs and TLAAs, respectively.

9.8.5.3 Results of AMR - TC The TMI-2 UFSAR describes the use of a TC to move DSCs into and out of the HSMs. Thus, the TC is required to retrieve a DSC and is in-scope for aging management under the renewed TMI-2 ISFSI license. DOE-ID does not possess a TC (either an MP187 or OS197 as authorized by the design basis) associated with the TMI-2 ISFSI license at the INL Site. Because use of an MP187 TC aged over 20 years is prohibited by a TMI-2 ISFSI license TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-10

condition, no AMR was performed for the MP187 TC design. The AMR for the OS197 TC design is incorporated by reference (IBR) from the renewal application for Standardized NUHOMS 10 CFR 72 Certificate of Compliance (CoC) 1004 [0]. Specifically, the following portions of the document Renewal Application for the Standardized NUHOMS System, Certificate of Compliance No. 1004, Revision 3, dated September 29, 2016, are IBR into the TMI-2 ISFSI licensing basis:

  • Sections 1.2.2.3, 3.3.3, 3.4, 3.4.1, 3.4.2, 3.4.3, 3.7 and Appendices 1A-1K, 2C (pertaining to the OS197 TC); Appendix 2E (Table 2E-3 only);

Appendix 3B (pertaining to the OS197 TC); and Appendix 6A (Section 6A.7 only).

DOE-ID will acquire access to an OS197 TC when one is needed at the TMI-2 ISFSI via an important-to-safety purchase order. A determination will be made at that time as to the method of obtaining access, but in all cases, it will be developed under a procurement process using a DOE-ID Quality Assurance program. Suitable procurement documents will specify the design, operating, and maintenance requirements for the TC for use in retrieving the TMI-2 DSCs from the HSM, consistent with applicable license requirements and commitments. Furthermore, if use of the TC used to retrieve the DSC requires the use of TC spacers, the spacers shall have been fabricated less than 20 years prior to their use at the TMI-2 ISFSI. DOE-ID will ensure compliance with these procurement requirements under the DOE-ID Quality Assurance program.

9.8.5.4 Results of AMR - Basemat and Approach Slab The one aging effect evaluated for the ISFSI basemat and approach slab is differential settlement. Differential settlement can be because of subgrade consolidation or movement of soils upon which the structures are founded.

The results of the AMR revealed that the potential aging mechanism that could cause differential settlement is not credible at the TMI-2 ISFSI for the duration of the PEO. Therefore, no TLAA or AMP is required.

9.8.5.5 Results of AMR - TMI-2 Canister The aging effects and related aging mechanisms that were evaluated during the AMR for the in-scope TMI-2 Canister subcomponent SSCs are:

a) Aging Effect: Loss of material Associated Aging Mechanisms:

  • General corrosion
  • Crevice corrosion
  • Pitting corrosion
  • Galvanic corrosion
  • Microbiologically induced corrosion
  • Wear TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-11

b) Aging Effect: Cracking Associated Aging Mechanisms:

  • Thermal fatigue c) Aging Effect: Change in Material Properties Associated Aging Mechanisms:
  • Intergranular corrosion
  • Creep
  • Thermal aging
  • Irradiation embrittlement Each of the above combinations of aging effect and aging mechanism was evaluated to determine the appropriate AMA for each TMI-2 Canister subcomponent SSC. The results of the AMR revealed that there are no credible aging effects requiring management for the TMI-2 Canisters at the TMI-2 ISFSI for the duration of the PEO. Therefore, no TLAAs or AMPs are required.

9.8.6 Aging Management Programs The AMRs for the DSC and HSM resulted in the need to develop AMPs to manage the aging effects and mechanisms for the subcomponents comprising these major components. No other AMRs of in-scope components resulted in the need for AMPs. The AMPs summarized in the following subsections address the scope of the AMPs, the parameters monitored or inspected, the detection of aging effects, and the acceptance criteria (AC). DOE-ID will develop, implement, and maintain AMP implementing procedures for the duration of the PEO.

9.8.6.1 DSC Aging Management Program DOE-ID will develop and maintain procedures to implement the DSC subcomponent AMPs shown in Table 9.8-7.

Procedures to implement the DSC AMP will include remote inspections performed in the sheltered environment. These procedures will include insertion of a remote borescope camera into the HSM through the rear drain hole. Additionally, procedures will be developed for temporary removal of the front HSM shield door to allow for insertion of a borescope camera in the gap between the DSC and the HSM opening. A temporary inspection cover will be installed on the front of the HSM to allow the inspection probe to be inserted at designated intervals around the DSC.

9.8.6.2 HSM Aging Management Program DOE-ID will develop and maintain procedures to implement the HSM subcomponent AMPs shown in Table 9.8-8.

Similar to procedures for the DSC AMP, DOE-ID will develop procedures TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-12

to implement the HSM AMP which will include remote inspections performed in the sheltered environment. These procedures will include insertion of a remote borescope camera into the HSM through the rear drain hole. Additionally, procedures will be developed for temporary removal of the front HSM shield door to allow for insertion of a borescope camera in the gap between the DSC and the HSM opening. A temporary inspection cover will be installed on the front of the HSM to allow the inspection probe to be inserted at designated intervals around the DSC to obtain a view of the HSM interior.

9.8.6.3 OS197 Transfer Cask Aging Management Program The OS197 TC AMP was approved as part of the renewal of the Standardized NUHOMS 10 CFR 72 and is IBR into this FSAR. Table 12.3-5 of Revision 17 to the Standardized NUHOMS UFSAR [9.5] is repeated as Table 9.8-9. This AMP is supported by additional information also IBR into the TMI-2 ISFSI licensing basis found in Section 6A.7 of Appendix 6 to Revision 3 of the CoC 1004 renewal application [9.4].

A future OS197 TC supplier may choose to provide a new OS197 TC or an OS197 TC aged less than the 20-year TMI-2 ISFSI initial licensing period.

Thus, the selected OS197 TC SSCs may, or may not require implementation of the AMP described in Table 9.8-9. Because it is unknown until the time of procurement whether the OS197 TC provided under that procurement will require any aging management activities, if any are required, they will be coordinated with the OS197 TC supplier. As discussed in Section 9.8.5.3, requirements for the supplier to perform all required maintenance, tests, and inspection activities (including AMPs) of the OS197 TC prior to use at the TMI-2 ISFSI will be included in the procurement documents. Further, procedures for operation of the OS197 TC will be developed or revised as appropriate, prior to use by the entity performing DSC transfer operations.

Such procedures will comply with all applicable requirements in the TMI-2 ISFSI renewed license, technical specifications, and UFSAR.

9.8.7 Time-Limited Aging Analyses 9.8.7.1 DSC TLAA A TLAA as documented in Section 8.3.2 evaluates the effects of cyclic thermal loading (fatigue) on the mechanical properties of DSC materials of the TMI-2 ISFSI and remains applicable during the PEO.

9.8.7.2 HSM TLAA A TLAA as documented in Section 8.1.1.5.D evaluates the effects of irradiation on the mechanical properties of HSM concrete materials of the TMI-2 ISFSI and remains applicable during the PEO.

9.8.7.3 OS197 TC TLAA The OS197 TC TLAAs approved as part of the renewal of the Standardized NUHOMS 10 CFR 72 CoC are IBR into this FSAR. These TLAAs are summarized in Appendix 3B to Revision 3 to the Standardized NUHOMS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-13

CoC 1004 renewal application [9.4].

9.8.8 Tollgate Assessments Industry guidance on the preparation of ISFSI LRAs is contained in NEI 14-03

[9.2]. NEI 14-03 introduces the concept of tollgates and tollgate assessments, and provides specific guidance in Section 3.6.5 and Appendix A of the document.

DOE-ID performs tollgate assessments during the PEO of the TMI-2 ISFSI, spanning the period from March 19, 2019 through March 19, 2039, or the date the last licensed material is removed from the ISFSI, whichever occurs sooner.

DOE-ID may choose to integrate the tollgate assessment into existing ISFSI assessment programs, while continuing to meet the underlying intent of the tollgate concept. Tollgate assessments for the TMI-2 ISFSI will be performed as shown in Table 9.8-6.

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Table 9.8-1 Results of Component-Level and Contents Scoping Evaluation TMI-2 ISFSI SSC/Contents Criterion 1 Criterion 2 Criterion 3 In-Scope Dry Shielded Canister(1) Yes N/A N/A Yes Horizontal Storage Module (except Yes N/A N/A Yes HSM-15)(2)

Overpack HSM (HSM-15)(3) No No N/A No Transfer Cask Yes N/A N/A Yes Dry Film Lubricant No No N/A No Handling and Transfer Equipment(4) No No N/A No ISFSI Basemat and Approach Slab No Yes N/A Yes Other Transfer Equipment(5) No No N/A No Auxiliary Equipment(6) No No N/A No Miscellaneous Equipment(7) No No N/A No TMI-2 Core Debris N/A N/A No No TMI-2 Canisters(8) N/A N/A Yes Yes Notes:

(1) DSC includes (but is not limited to) the DSC shell, top/bottom cover plates, purge and vent block, grapple ring and HEPA filters.

(See Section 2.3.2.1 of [9.3])

(2) HSM includes HSM-1 through HSM-30, excluding HSM-15. Subcomponents include (but are not limited to) the HSM reinforced concrete walls, roof, and end shield walls; DSC steel structure support assembly; HSM accessories (DSC seismic retainer, shielded door assemblies and door supports); and associated attachment/installation hardware (tie rods, bolts, nuts, washers, embedment assemblies, mechanical splices) (See Section 2.3.2.2 of [9.3]).

(3) Overpack HSM includes all of HSM-15 and its internal DSC overpack liner (See Section 2.3.3.1 of [9.3]).

(4) Handling and Transfer equipment includes (but is not limited to) cask rigging, cask bottom/top spacers, and TC lifting yoke (See Section 2.3.3.2 of [9.3]).

(5) Other Transfer Equipment includes (but is not limited to) a hydraulic ram system (HRS), a Transfer Trailer, a prime mover for Transfer Trailer towing, cask support skid, auxiliary equipment mounted on the skid and skid positioning system (SPS) (See Section 2.3.3.3 of [9.3]).

(6) Auxiliary Equipment includes, but is not limited to, a vacuum drying system (VDS) and an automated welding system (AWS)

(See Section 2.3.3.4 of [9.3]).

(7) Miscellaneous Equipment includes (but is not limited to) ISFSI security fence and gate(s), lighting, lightning protection, communications, monitoring, and alarm systems (See Section 2.3.3.5 of [9.3]).

(8) The three TMI-2 Canister types include the TMI-2 Fuel Canister, TMI-2 Filter Canister, and TMI-2 Knockout Canister (See Section 2.3.2.3 of [9.3]).

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-14

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity DRY-SHIELDED CANISTER (DSC) 219-02-1000 1 DSC BASKET ASSEMBLY 1 SPACER DISC, 1 1/4 PLATE 2 NO YES NO NO NO NO 219-02-1000 1 DSC BASKET ASSEMBLY 2 TOP SPACER DISC, 1 1/4 PLATE 2 NO YES NO NO NO NO 219-02-1000 1 DSC BASKET ASSEMBLY 3 SUPPORT ROD, Ø 1-1/2 ROD 2 NO YES NO NO NO NO PIPE SLEEVE - LONG, 2.00 NPS 2 YES 219-02-1000 1 DSC BASKET ASSEMBLY 4 NO NO NO NO NO SCHEDULE 80 PIPE SLEEVE - SHORT, 2.00 NPS 2 YES 219-02-1000 1 DSC BASKET ASSEMBLY 5 NO NO NO NO NO SCHEDULE 80 219-02-1000 1 DSC BASKET ASSEMBLY 6 END SLEEVE 2 NO YES NO NO NO NO 219-02-1001 1 DSC SHELL ASSEMBLY 1 CYLINDRICAL SHELL, 5/8" PLATE 1 YES YES NO YES YES YES 219-02-1001 1 DSC SHELL ASSEMBLY 2 OUTER BOTTOM COVER 1 NO YES NO NO YES YES 219-02-1001 1 DSC SHELL ASSEMBLY 3 BOTTOM SHIELD PLUG 1 NO YES NO NO NO NO 219-02-1001 1 DSC SHELL ASSEMBLY 4 GRAPPLE RING, 1" PLATE 1 NO NO NO NO NO YES 219-02-1001 1 DSC SHELL ASSEMBLY 5 GRAPPLE RING SUPPORT, 3/4" PLATE 1 NO NO NO NO NO YES 219-02-1001 1 DSC SHELL ASSEMBLY 6 INNER BOTTOM COVER 3/4" PLATE 1 YES YES NO NO YES NO 219-02-1002 1 DSC BASKET-SHELL ASSEMBLY 5 SUPPORT RING 3/4" PLATE 1 YES NO NO NO NO NO VENT PORT SHIELD BLOCK, 1-3/4 219-02-1002 1 DSC BASKET-SHELL ASSEMBLY 6 1 NO YES NO NO NO NO PLATE TOP SHIELD PLUG, PLATE 3 219-02-1003 1 DSC MAIN ASSEMBLY 2 1 YES YES NO NO YES NO 1-1/4" THICK PLATE 219-02-1003 1 DSC MAIN ASSEMBLY 3 TOP COVER PLATE 1 YES YES NO NO YES NO 219-02-1003 1 DSC MAIN ASSEMBLY 4 PURGE PORT BLOCK 2 NO YES NO NO NO NO 219-02-1003 1 DSC MAIN ASSEMBLY 9 TOP SHIELD PLUG PLATE 1 & 2 1 NO YES NO NO NO NO DSC PURGE PORT FILTER 219-02-1010 2 1 FILTER HOUSING 1 YES YES NO NO NO NO ASSEMBLY DSC PURGE PORT FILTER 219-02-1010 2 5 HEPA TYPE FILTER W/GASKET 1 YES NO NO NO NO NO ASSEMBLY DSC PURGE PORT FILTER DUAL C-SEALS, EG & G PRESSURE 219-02-1010 2 10 1 YES NO NO NO NO NO ASSEMBLY SCIENCE (FILTER HOUSING)

DSC PURGE PORT FILTER SCREW, CAP SOCKET HD, 219-02-1010 2 14 1 YES NO NO NO NO NO ASSEMBLY 1/2 - 13 UNC - 2A X 0.75" LONG DSC PURGE PORT FILTER SCREW, CAP SOCKET HD, 219-02-1010 2 16 1 YES NO NO NO NO NO ASSEMBLY 1 - 8 UNC - 2A X 3.00" LONG DSC PURGE PORT FILTER DUAL C-SEALS, EG&G PRESSURE 219-02-1010 2 20 1 YES NO NO NO NO NO ASSEMBLY SCIENCE DSC PURGE PORT FILTER 219-02-1010 2 22 LOCK WASHER 1 YES NO NO NO NO NO ASSEMBLY 219-02-1011 2 DSC VENT PORT FILTER ASSEMBLY 1 FILTER HOUSING 1 YES YES NO NO NO NO 219-02-1011 2 DSC VENT PORT FILTER ASSEMBLY 5 HEPA TYPE FILTER W/GASKET 1 YES NO NO NO NO NO DUAL C-SEALS, EG & G PRESSURE 219-02-1011 2 10 1 YES NO NO NO NO NO DSC VENT PORT FILTER ASSEMBLY SCIENCE (FILTER HOUSING)

SCREW, CAP SOCKET HD, 219-02-1011 2 DSC VENT PORT FILTER ASSEMBLY 14 1 YES NO NO NO NO NO 1/2 - 13 UNC - 2A X 0.75" LONG TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-15

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity SCREW, CAP SOCKET HD, 219-02-1011 2 DSC VENT PORT FILTER ASSEMBLY 16 1 YES NO NO NO NO NO 1 - 8 UNC - 2A X 3.00" LONG DUAL C-SEALS, EG&G PRESSURE 219-02-1011 2 20 1 YES NO NO NO NO NO DSC VENT PORT FILTER ASSEMBLY SCIENCE 219-02-1011 2 DSC VENT PORT FILTER ASSEMBLY 22 LOCK WASHER 1 YES NO NO NO NO NO Fabrication Specification 1 DSC ASSEMBLY N/A WELD FILLER METAL 1 YES NO NO NO YES YES 219-02-107 Fabrication Specification 1 DSC ASSEMBLY N/A INORGANIC ZINC-RICH COATING 2 NO NO NO NO YES NO 219-02-107 HORIZONTAL STORAGE MODULE (HSM)

HSM ISFSI GENERAL 219-02-5100 1 5100-203 BOLT, 3/4-10 UNC-2A X 2" LONG 1 NO NO NO NO YES NO ARRANGEMENT HSM ISFSI GENERAL 219-02-5100 1 5100-301 NUT, 1 1/8-7 UNC-2B 1 NO NO NO NO YES NO ARRANGEMENT HSM ISFSI GENERAL 219-02-5100 1 5100-305 NUT, 1 1/2-6 UNC-2B 1 NO NO NO NO YES NO ARRANGEMENT HSM ISFSI GENERAL 219-02-5100 1 NOTE 10 GROUT - SHIELD WALL PANELS 1 NO YES NO NO NO NO ARRANGEMENT 219-02-5100/

HSM ISFSI GENERAL WORK ORDER 1 NOTE 8 LIFTING STRAND LOOP POCKET FILL 2 NO NO NO NO YES NO ARRANGEMENT (WO) 642973 STANDARD MODULE MAIN 219-02-5101 1 5101-204 BOLT, 3/4 - 10 UNC - 2A X 2-3/4 LONG 1 NO NO NO NO YES YES ASSEMBLY STANDARD MODULE MAIN 219-02-5101 1 5101-206 BOLT, 3/4 - 10 UNC - 2A X 3-1/4 LONG 1 NO NO NO NO YES YES ASSEMBLY STANDARD MODULE MAIN 219-02-5101 1 5101-208 BOLT, 1 1/4 - 7 UNC - 2A X 3-1/2 LONG 1 NO NO NO NO YES NO ASSEMBLY STANDARD MODULE MAIN 219-02-5101 1 5101-210 BOLT, 1-1/4 - 7 UNC - 2A X 4-1/4 LONG 1 NO NO NO NO YES NO ASSEMBLY STANDARD MODULE MAIN 219-02-5101 1 5101-307 NUT, 1-5/8 -5 1/2 UNC-2B 2 NO NO NO NO YES NO ASSEMBLY STANDARD MODULE MAIN 219-02-5101 1 5101-311 NUT, 1-1/4 -7 UNC - 2B 1 NO NO NO NO YES NO ASSEMBLY STANDARD MODULE MAIN GROUT - LIFTING STRAND LOOP 219-02-5101 1 NOTE 16 2 NO NO NO NO YES NO ASSEMBLY POCKET FILL STANDARD MODULE MAIN WELD FILLER MATERIAL 219-02-5101 1 NOTE 2B 1 NO NO NO NO YES YES ASSEMBLY (CATEGORY B COMPONENTS)

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-16

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity Field Design Changes:

219-02-5101/ STANDARD MODULE MAIN TMI-2 ISFSI HSM ROOF BOLT 1 FDC 2 NO NO NO NO YES NO WO 635917 ASSEMBLY PROTECTIVE COVER 7682, FDC 7715 HSM STANDARD MODULE BASE REINFORCEMENT BARS, 219-02-5103 1 NOTE 5 1 NO NO NO NO YES NO UNIT OTHER THAN #4 HSM STANDARD MODULE BASE NOTES 219-02-5103 1 CONCRETE 1 NO YES NO YES YES NO UNIT 1&14 HSM STANDARD MODULE BASE NOTES GROUT - MOUNTING HOLES &

219-02-5103 1 2 NO NO NO NO YES NO UNIT 8&18 EMBEDMENT VOIDS SLOW-RISE POLYURETHANE FOAM 219-02-5104 2 HSM ROOF SLAB NOTE 15 2 NO NO NO NO YES NO FORMULA SPRAY FOAM NOTE 15 WATER RESISTANT POLYURETHANE 219-02-5104 2 HSM ROOF SLAB / FDC FOAM MATERIAL, 6-1/2" X 6-1/2" X 1/8" 2 NO NO NO NO YES NO 7715 THICK (NOT ADHESIVE)

REINFORCEMENT BARS, 219-02-5104 2 HSM ROOF SLAB NOTE 5 1 NO NO NO NO YES NO OTHER THAN #4 NOTES 219-02-5104 2 HSM ROOF SLAB CONCRETE 1 NO YES NO YES YES NO 1&11 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-101 FRONT MOUNTING PLATE, 1" THICK 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-102 REAR MOUNTING PLATE, 1" THICK 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-103 STIFFENER PLATE, 1/2" THICK 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-104 STIFFENER PLATE, 1/2" THICK 1 NO NO NO NO YES YES SUPPORT PLATE, 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-105 1 NO NO NO NO YES YES 1-1/2" THICK X 7" LONG 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-106 CANISTER STOP PLATE, 1-1/8" THICK 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-107 SUPPORT RAIL, W12 X 96 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-109 STIFFENER PLATE, 1/2" THICK 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-110 RAIL EXTENSION PLATE, 3/4" THICK 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE 5105-111 CROSS BEAM, W6 X 25 1 NO NO NO NO YES YES 219-02-5105 1 HSM DSC SUPPORT STRUCTURE NOTE 2 WELD FILLER MATERIAL 1 NO NO NO NO YES YES 219-02-5105/

Fabrication 1 HSM DSC SUPPORT STRUCTURE NOTE 5 COATING 2 NO NO NO NO YES NO Specification 219-02-115 HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-101 PLATE 1/2 THICK 1 NO YES NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-102 ROLLED PLATE 3/8 THICK 1 NO YES NO NO YES YES FABRICATED FASTENERS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-17

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-103 PLATE 1-1/2 THICK 1 NO YES NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-105 MOUNTING PLATE 1 THICK 1 NO YES NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-118 PLATE 3/4 THICK 1 NO NO NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-120 PLATE 1/2 THICK 2 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-121 PLATE 1/2 THICK 2 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-125 DOOR, PLATE 1-1/2 THICK 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-126 SPACER, PLATE 1-1/2 THICK 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND HEAVY DUTY HINGE (REAR ACCESS 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-127 1 NO NO NO NO YES NO DOOR)

FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-130 ANGLE, L8 X 8 X 1 THICK 1 NO NO NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-131 STIFFENER PLATE, 1/2 THICK 1 NO NO NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-135 PLATE, 3/4 THICK 2 NO NO NO NO NO YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-137 PLATE, 3/4 THICK 1 NO NO NO NO YES YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-139 TUBE STEEL, 5 X 5 X 3/8" THICK 2 NO NO NO NO NO YES FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-140 PLATE, 4-1/2 SQUARE X 1/4 THICK 2 NO NO NO NO NO YES FABRICATED FASTENERS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-18

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity HSM ERECTION HARDWARE AND SEISMIC RETAINER, TUBE STEEL, 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-141 1 NO NO NO NO YES NO 4 X 4 X 1/2 THICK X 1-0 LONG FABRICATED FASTENERS HSM ERECTION HARDWARE AND REAR DSC SUPPORT STRUCTURE LUG 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-148 1 NO NO NO NO YES NO PLATE, 2 X 4 X 1 THICK FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-149 SHIELD WALL TIE PLATE, 3/4 THICK 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND RICHMOND DOWEL BAR SPLICER 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-154 (DB-SAE) WITH 1-9/16-8 UN THREAD 2 NO NO NO NO YES NO FABRICATED FASTENERS AND #11 BAR HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-155 WASHER PLATE, 1/2 THICK 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-157 WASHER PLATE, 1/2 THICK 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND RICHMOND DOWEL BAR SPLICER 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-158 (DB-SAE) WITH 1-9/16-8 UN THREAD 2 NO NO NO NO YES NO FABRICATED FASTENERS AND # 11 BAR HSM ERECTION HARDWARE AND SHIELD WALL CAST-IN-PLACE BOLT, 1 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-251 1 NO NO NO NO YES NO 1/8-7UNC - 2A X 1 - 0 LONG FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-307 NUT, 1 1/2 - 6 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-308 COUPLING NUT, 1 1/2 - 6 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-310 NUT, 1 1/4 - 7 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-311 COUPLING NUT, 1 1/4 - 7 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-313 NUT, 2 - 4 1/2 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-314 COUPLING NUT, 2 - 4 1/2 - 7 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-19

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-316 NUT, 3/4 - 10 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-317 COUPLING NUT, 3/4 - 10 UNC - 2B 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-452 WASHER PLATE 6 SQ X 1 THICK 2 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-506 STUD, 1 1/2 - 6 UNC - 2A 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-509 STUD, 1 1/4 - 7 UNC - 2A 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-512 STUD, 2 - 4 1/2 UNC - 2A 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-515 STUD, 3/4 - 10 UNC - 2A 1 NO NO NO NO YES NO FABRICATED FASTENERS HSM ERECTION HARDWARE AND SHIELD WALL SUPPORT STUD, 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-544 1 NO NO NO NO YES NO 1 1/2-6UNC-2A FABRICATED FASTENERS HSM ERECTION HARDWARE AND ROOF ATTACHMENT BOLT, 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-553 2 NO NO NO NO YES NO ROD Ø 1-5/8 FABRICATED FASTENERS HSM ERECTION HARDWARE AND NELSON STUD, TYPE S3L, 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-619 1 NO NO NO NO YES YES

Ø 3/4 X 3-3/16 LONG FABRICATED FASTENERS HSM ERECTION HARDWARE AND NELSON STUD, TYPE H4L Ø 1/2 X 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 5107-643 2 NO NO NO NO NO YES 4-1/8 LONG FABRICATED FASTENERS HSM ERECTION HARDWARE AND NOTE 1/ WELD FILLER MATERIAL (ATTACHES 219-02-5107 1 MISCELLANEOUS STEEL DOORS & 1 NO NO NO NO YES YES NOTE 18 DSC SUPPORT STRUCTURE)

FABRICATED FASTENERS HSM ERECTION HARDWARE AND 219-02-5107 1 MISCELLANEOUS STEEL DOORS & NOTE 11 CONCRETE FILL 1 NO YES NO NO NO NO FABRICATED FASTENERS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-20

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity 219-02-5107/

HSM ERECTION HARDWARE AND NOTES Fabrication 1 MISCELLANEOUS STEEL DOORS & 2-3, 9-10, COATING 2 NO NO NO NO YES NO Specification FABRICATED FASTENERS 13 219-02-115 NOTE 1/

219-02-5108 0 HSM END MODULE SHIELD WALL REINFORCEMENT BARS 1 NO NO NO NO YES NO NOTE 9 NOTE 1/

219-02-5108 0 HSM END MODULE SHIELD WALL CONCRETE 1 NO YES NO NO YES NO NOTE 9 TMI-2 KNOCKOUT CANISTER KNOCKOUT CANISTER UPPER 02-1150946-C 3 1 1150946C POISON TUBE ASSEMBLY 3 NO NO YES NO YES NO HEAD WELDMENT KNOCKOUT CANISTER UPPER 02-1150946-C 3 2 1150946C TOP END CAP 3 NO NO YES NO YES NO HEAD WELDMENT KNOCKOUT CANISTER UPPER 02-1150946-C 3 3 1150946C BOTTOM END CAP 3 NO NO YES NO YES NO HEAD WELDMENT KNOCKOUT CANISTER UPPER 02-1150946-C 3 4 1150946C PIPE 1" SCHEDULE 160 3 NO NO YES NO YES NO HEAD WELDMENT KNOCKOUT CANISTER UPPER 02-1150946-C 3 5 1150946C B4C PELLET 3 NO NO YES NO NO NO HEAD WELDMENT KNOCKOUT CANISTER BOTTOM 1150968D BOTTOM SUPPORT PLATE 02-1150968-D 2 1 3 NO YES YES YES YES NO SUPPORT PLATE ASSEMBLY ASSEMBLY KNOCKOUT CANISTER BOTTOM 02-1150968-D 2 2 1150950E BOTTOM SUPPORT PLATE 3 NO YES YES YES YES NO SUPPORT PLATE ASSEMBLY KNOCKOUT CANISTER INTERNALS 1154027F KNOCKOUT CANISTER 02-1154027-F 4 1 3 NO YES YES YES YES NO ASSEMBLY INTERNALS ASSEMBLY KNOCKOUT CANISTER INTERNALS 02-1154027-F 4 2 1155233D POISON TUBE A 3 NO NO YES NO YES NO ASSEMBLY KNOCKOUT CANISTER INTERNALS 02-1154027-F 4 3 1150946C POISON TUBE B 3 NO NO YES NO YES NO ASSEMBLY KNOCKOUT CANISTER INTERNALS 1150968D BOTTOM SUPPORT PLATE 02-1154027-F 4 4 3 NO YES YES YES YES NO ASSEMBLY ASSEMBLY KNOCKOUT CANISTER INTERNALS 1150939D INTERMEDIATE SUPPORT 02-1154027-F 4 5 3 NO NO YES NO YES NO ASSEMBLY PLATE A KNOCKOUT CANISTER INTERNALS 02-1154027-F 4 7 1150937D SUPPORT RING 3 NO NO YES NO YES NO ASSEMBLY KNOCKOUT CANISTER INTERNALS 02-1154027-F 4 9 1150954D SEAL PLATE 3 NO NO YES NO YES NO ASSEMBLY KNOCKOUT CANISTER INTERNALS 02-1154027-F 4 14 1154090C CENTER TUBE 3 NO NO YES NO YES NO ASSEMBLY TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-21

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity KNOCKOUT CANISTER INTERNALS 1154034F INTERNALS & SHELL 02-1154034-F 3 1 3 NO YES YES NO YES NO

& SHELL ASSEMBLY ASSEMBLY KNOCKOUT CANISTER INTERNALS 1150945C SHELL (KNOCKOUT &

02-1154034-F 3 2 3 NO YES YES NO YES NO

& SHELL ASSEMBLY FILTER CANISTER)

KNOCKOUT CANISTER INTERNALS 1154027F KNOCKOUT CANISTER 02-1154034-F 3 3 3 NO YES YES YES YES NO

& SHELL ASSEMBLY INTERNALS ASSEMBLY 1154041F KNOCKOUT CANISTER 02-1154041-F 3 KNOCKOUT CANISTER ASSEMBLY 1 3 NO YES YES YES YES NO ASSEMBLY 02-1154041-F 3 KNOCKOUT CANISTER ASSEMBLY 2 1154045D BOTTOM HEAD ASSEMBLY 3 NO YES YES YES YES NO 1154046F KNOCKOUT CANISTER 02-1154041-F 3 KNOCKOUT CANISTER ASSEMBLY 3 3 NO YES YES YES YES NO UPPER HEAD WELDMENT KNOCKOUT & FILTER CANISTER 1154045D CANISTER LOWER HEAD 02-1154045-D 5 1 3 NO YES YES YES YES NO LOWER HEAD ASSEMBLY ASSEMBLY KNOCKOUT & FILTER CANISTER 1150917D CANISTER LOWER HEAD 02-1154045-D 5 2 3 NO YES YES YES YES NO LOWER HEAD ASSEMBLY (KNOCKOUT & FILTER CANISTER)

FILTER & KNOCKOUT CANISTER 1154046F KNOCKOUT CANISTER HEAD 02-1154046-F 6 1 3 NO YES YES YES YES NO SKIRT WELDMENT FILTER & KNOCKOUT CANISTER 1150943E KNOCKOUT CANISTER 02-1154046-F 6 3 3 NO YES YES YES YES NO SKIRT UPPER HEAD KNOCKOUT CANISTER POISON 1155233D KNOCKOUT CANISTER 02-1155233-D 2 1 3 NO NO YES NO YES NO TUBE ASSEMBLY POISON TUBE ASSEMBLY KNOCKOUT CANISTER POISON 1155233D TUBE 2-1/8 OD X 0.065 02-1155233-D 2 2 3 NO NO YES NO YES NO TUBE ASSEMBLY THICK WALL KNOCKOUT CANISTER POISON 02-1155233-D 2 3 1155233D BOTTOM END PLUG 3 NO NO YES NO YES NO TUBE ASSEMBLY KNOCKOUT CANISTER POISON 02-1155233-D 2 4 1155233D TOP END PLUG 3 NO NO YES NO YES NO TUBE ASSEMBLY KNOCKOUT CANISTER POISON 02-1155233-D 2 5 1155233D B4C PELLET 3 NO NO YES NO NO NO TUBE ASSEMBLY KNOCKOUT CANISTER ASSEMBLY 02-1161301-D 1 UFSAR NOTE 3: WELD FILLER METAL 3 NO NO NO NO YES NO SAR TMI-2 FILTER CANISTER FILTER CANISTER POISON TUBE 02-1150949-D 5 1 1150949D POISON TUBE ASSEMBLY 3 NO NO YES NO YES NO ASSEMBLY FILTER CANISTER POISON TUBE 1150949D; TUBE 2-1/8 OD X 0.065 02-1150949-D 5 2 3 NO NO YES NO YES NO ASSEMBLY THICK WALL FILTER CANISTER POISON TUBE 02-1150949-D 5 3 1150949D; BOTTOM END PLUG 3 NO NO YES NO YES NO ASSEMBLY FILTER CANISTER POISON TUBE 02-1150949-D 5 4 1150949D; TOP END PLUG 3 NO NO YES NO YES NO ASSEMBLY FILTER CANISTER POISON TUBE 02-1150949-D 5 5 1150949D; B4C PELLET 3 NO NO YES NO NO NO ASSEMBLY TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-22

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity FILTER CANISTER UPPER HEAD 02-1150959-D 4 1 1150959D UPPER HEAD WELDMENT 3 NO YES YES YES YES NO WELDMENT FILTER CANISTER UPPER HEAD 1150958D FILTER CANISTER UPPER 02-1150959-D 4 5 3 NO YES YES YES YES NO WELDMENT HEAD 1154018F FILTER CANISTER 02-1154018-F 5 FILTER CANISTER ASSEMBLY 1 3 NO YES YES YES YES NO ASSEMBLY 02-1154018-F 5 FILTER CANISTER ASSEMBLY 2 1150959D UPPER HEAD WELDMENT 3 NO YES YES YES YES NO 02-1154018-F 5 FILTER CANISTER ASSEMBLY 3 1154045D BOTTOM HEAD ASSEMBLY 3 NO YES YES YES YES NO 1154020E FILTER CANISTER SUB-02-1154020-E 3 FILTER CANISTER SUB-ASSEMBLY 1 3 NO YES YES NO YES NO ASSEMBLY 02-1154020-E 3 FILTER CANISTER SUB-ASSEMBLY 3 1150945C SHELL 3 NO YES YES NO YES NO 02-1154020-E 3 FILTER CANISTER SUB-ASSEMBLY 6 1150949D POISON TUBE ASSEMBLY 3 NO NO YES NO YES NO 02-1161299-D 1 FILTER CANISTER ASSEMBLY SAR UFSAR NOTE 3: WELD FILLER METAL 3 NO NO NO NO YES NO TMI-2 FUEL CANISTER FUEL CANISTER NEUTRON POISON 02-1095753-E 2 1 18163E100 TUBE ASSEMBLY 3 NO YES YES YES YES NO SHROUD FUEL CANISTER NEUTRON POISON 02-1095753-E 2 2 18163E100-1 OUTER SKIN 3 NO YES YES YES YES NO SHROUD FUEL CANISTER NEUTRON POISON 02-1095753-E 2 3 18163E100-2 INNER SKIN 3 NO YES YES YES YES NO SHROUD FUEL CANISTER NEUTRON POISON 02-1095753-E 2 4 18163E100-3 BORAL 3 NO YES YES YES YES NO SHROUD FUEL CANISTER BOTTOM PLATE 1150998E FUEL CANISTER BOTTOM 02-1150998-E 2 1 3 NO YES YES YES YES NO ASSEMBLY PLATE ASSEMBLY FUEL CANISTER BOTTOM PLATE 02-1150998-E 2 2 1150992E BOTTOM PLATE 3 NO YES YES YES YES NO ASSEMBLY 1150999F FUEL CANISTER LOWER 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 1 3 NO YES YES YES YES NO ASSEMBLY 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 2 1095753E BORAL SHROUD 3 NO YES YES YES YES NO ASSEMBLY 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 3 1154014F FUEL CANISTER BULKHEAD 3 NO YES YES YES YES NO 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 5 1150983C FUEL CANISTER SHELL 3 NO YES YES YES YES NO 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 6 1154045D LOWER HEAD ASSEMBLY 3 NO YES YES YES YES NO 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 7 1150998E BOTTOM PLATE ASSEMBLY 3 NO YES YES YES YES NO 02-1150999-F 4 FUEL CANISTER LOWER ASSEMBLY 9 1150999F CONCRETE MIX 3 NO YES YES YES YES NO 1154026F FUEL CANISTER HEAD 02-1154026-F 6 FUEL CANISTER HEAD WELDMENT 1 3 NO YES YES YES YES NO WELDMENT 02-1154026-F 6 FUEL CANISTER HEAD WELDMENT 2 1150989F FUEL CANISTER UPPER HEAD 3 NO YES YES YES YES NO 02-1154026-F 6 FUEL CANISTER HEAD WELDMENT 4 1150993C SHOCK ABSORBER SUPPORT 3 NO NO NO NO YES NO 02-1154026-F 6 FUEL CANISTER HEAD WELDMENT 5 1150995C IMPACT PLATE "D" 3 NO NO NO NO YES NO 02-1154026-F 6 FUEL CANISTER HEAD WELDMENT 7 1150994C IMPACT PLATE "C" 3 NO NO NO NO YES NO 02-1154026-F 6 FUEL CANISTER HEAD WELDMENT 12 1154021C FUEL CANISTER BOLT 3 NO NO NO NO YES NO TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-23

Table 9.8-2 In-Scope Subcomponents for Aging Management IN-SCOPE SUBCOMPONENT IDENTIFICATION INTENDED FUNCTION Heat-Drawing Item Scoping Radiation Sub- Structural Drawing Number Component Item Description Confinement Removal Retrievability Revision Num. Criterion Shielding Criticality Capability Integrity 02-1154070-F 3 FUEL CANISTER ASSEMBLY 1 1154070F FUEL CANISTER ASSEMBLY 3 NO YES YES YES YES NO 1150999E FUEL CANISTER LOWER 02-1154070-F 3 FUEL CANISTER ASSEMBLY 2 3 NO YES YES YES YES NO ASSEMBLY 1154026F FUEL CANISTER UPPER HEAD 02-1154070-F 3 FUEL CANISTER ASSEMBLY 3 3 NO YES YES YES YES NO WELDMENT 02-1161300-D B1 FUEL CANISTER ASSEMBLY SAR UFSAR NOTE 3: WELD FILLER METAL 3 NO NO NO NO YES NO TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-24

Table 9.8-3 Materials and Environments for DSC AMRs Service Component Item Description Materials Environments DSC BASKET ASSEMBLY SPACER DISC, 1 1/4 PLATE CARBON STEEL INTERNAL DSC DSC BASKET ASSEMBLY TOP SPACER DISC, 1 1/4 PLATE CARBON STEEL INTERNAL DSC INTERNAL DSC BASKET ASSEMBLY SUPPORT ROD, Ø 1-1/2 ROD CARBON STEEL DSC/ENCASED PIPE SLEEVE - LONG, 2.00 NPS DSC BASKET ASSEMBLY SCHEDULE 80 CARBON STEEL INTERNAL DSC PIPE SLEEVE - SHORT, 2.00 NPS DSC BASKET ASSEMBLY SCHEDULE 80 CARBON STEEL INTERNAL DSC DSC BASKET ASSEMBLY END SLEEVE CARBON STEEL INTERNAL DSC SHELTERED/

DSC SHELL ASSEMBLY CYLINDRICAL SHELL, 5/8" PLATE CARBON STEEL INTERNAL DSC SHELTERED/

DSC SHELL ASSEMBLY OUTER BOTTOM COVER CARBON STEEL ENCASED DSC SHELL ASSEMBLY BOTTOM SHIELD PLUG CARBON STEEL ENCASED DSC SHELL ASSEMBLY GRAPPLE RING, 1" PLATE CARBON STEEL SHELTERED GRAPPLE RING SUPPORT, 3/4" DSC SHELL ASSEMBLY CARBON STEEL SHELTERED PLATE INNER BOTTOM COVER 3/4" INTERNAL DSC/

DSC SHELL ASSEMBLY CARBON STEEL PLATE ENCASED DSC BASKET-SHELL SUPPORT RING 3/4" PLATE CARBON STEEL INTERNAL DSC ASSEMBLY DSC BASKET-SHELL VENT PORT SHIELD BLOCK, 1-3/4 CARBON STEEL INTERNAL DSC ASSEMBLY PLATE TOP SHIELD PLUG, PLATE 3 INTERNAL DSC/

DSC MAIN ASSEMBLY CARBON STEEL 1-1/4" THICK PLATE ENCASED SHELTERED/

DSC MAIN ASSEMBLY TOP COVER PLATE CARBON STEEL ENCASED DSC MAIN ASSEMBLY PURGE PORT BLOCK CARBON STEEL INTERNAL DSC DSC MAIN ASSEMBLY TOP SHIELD PLUG PLATE 1 & 2 CARBON STEEL INTERNAL DSC DSC PURGE PORT FILTER SHELTERED/

FILTER HOUSING CARBON STEEL ASSEMBLY INTERNAL DSC DSC PURGE PORT FILTER STAINLESS STEEL WITH ELASTOMERIC SHELTERED/

HEPA TYPE FILTER W/GASKET ASSEMBLY (NEOPRENE) SEAL INTERNAL DSC DSC PURGE PORT FILTER DUAL C-SEALS, EG & G PRESSURE INCONEL X-750 OR EPDM ELASTOMER INTERNAL DSC ASSEMBLY SCIENCE (FILTER HOUSING)

DSC PURGE PORT FILTER SCREW, CAP SOCKET HD, ENCASED/

STAINLESS STEEL ASSEMBLY 1/2 - 13 UNC - 2A X 0.75" LONG INTERNAL DSC DSC PURGE PORT FILTER SCREW, CAP SOCKET HD, STAINLESS STEEL SHELTERED ASSEMBLY 1 - 8 UNC - 2A X 3.00" LONG DSC PURGE PORT FILTER DUAL C-SEALS, EG&G PRESSURE INCONEL X-750 INTERNAL DSC ASSEMBLY SCIENCE DSC PURGE PORT FILTER SHELTERED/

LOCK WASHER CARBON STEEL OR STAINLESS STEEL ASSEMBLY INTERNAL DSC DSC VENT PORT FILTER SHELTERED/

FILTER HOUSING CARBON STEEL ASSEMBLY INTERNAL DSC DSC VENT PORT FILTER STAINLESS STEEL WITH ELASTOMERIC SHELTERED/

HEPA TYPE FILTER W/GASKET ASSEMBLY (NEOPRENE) SEAL INTERNAL DSC DSC VENT PORT FILTER DUAL C-SEALS, EG & G PRESSURE INCONEL X-750 OR EPDM ELASTOMER INTERNAL DSC ASSEMBLY SCIENCE (FILTER HOUSING)

DSC VENT PORT FILTER SCREW, CAP SOCKET HD, ENCASED/

STAINLESS STEEL ASSEMBLY 1/2 - 13 UNC - 2A X 0.75" LONG INTERNAL DSC DSC VENT PORT FILTER SCREW, CAP SOCKET HD, STAINLESS STEEL SHELTERED ASSEMBLY 1 - 8 UNC - 2A X 3.00" LONG DSC VENT PORT FILTER DUAL C-SEALS, EG&G PRESSURE INCONEL X-750 INTERNAL DSC ASSEMBLY SCIENCE DSC VENT PORT FILTER SHELTERED/

LOCK WASHER CARBON STEEL OR STAINLESS STEEL ASSEMBLY INTERNAL DSC SHELTERED/

DSC ASSEMBLY WELD FILLER METAL CARBON STEEL INTERNAL DSC SHELTERED/

DSC ASSEMBLY INORGANIC ZINC-RICH COATING ZINC-RICH INORGANIC COATING INTERNAL DSC TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-25

Table 9.8-4 Materials and Environments for HSM AMRs Service Component Item Description Materials Environments CARBON, HSM ISFSI GENERAL ARRANGEMENT BOLT, 3/4-10 UNC-2A X 2" LONG CARBON/BORON, OR OUTDOOR ALLOY STEEL HSM ISFSI GENERAL ARRANGEMENT NUT, 1 1/8-7 UNC-2B CARBON STEEL OUTDOOR HSM ISFSI GENERAL ARRANGEMENT NUT, 1 1/2-6 UNC-2B CARBON STEEL OUTDOOR HSM ISFSI GENERAL ARRANGEMENT GROUT - SHIELD WALL PANELS CEMENTITIOUS GROUT OUTDOOR SILICONE SEALANT HSM ISFSI GENERAL ARRANGEMENT LIFTING STRAND LOOP POCKET FILL OUTDOOR (CHEMICAL GROUT)

CARBON, STANDARD MODULE MAIN ASSEMBLY BOLT, 3/4 - 10 UNC - 2A X 2-3/4 LONG CARBON/BORON, OR OUTDOOR ALLOY STEEL CARBON, STANDARD MODULE MAIN ASSEMBLY BOLT, 3/4 - 10 UNC - 2A X 3-1/4 LONG CARBON/BORON, OR OUTDOOR ALLOY STEEL CARBON, STANDARD MODULE MAIN ASSEMBLY BOLT, 1 1/4 - 7 UNC - 2A X 3-1/2 LONG CARBON/BORON, OR SHELTERED ALLOY STEEL CARBON, STANDARD MODULE MAIN ASSEMBLY BOLT, 1-1/4 - 7 UNC - 2A X 4-1/4 LONG CARBON/BORON, OR SHELTERED ALLOY STEEL STANDARD MODULE MAIN ASSEMBLY NUT, 1-5/8 -5 1/2 UNC-2B CARBON STEEL SHELTERED STANDARD MODULE MAIN ASSEMBLY NUT, 1-1/4 -7 UNC - 2B CARBON STEEL SHELTERED GROUT - LIFTING STRAND LOOP STANDARD MODULE MAIN ASSEMBLY CEMENTITIOUS GROUT OUTDOOR POCKET FILL E70XX ELECTRODE WELD FILLER MATERIAL (WELD FILLER STANDARD MODULE MAIN ASSEMBLY SHELTERED (CATEGORY B COMPONENTS) COMPATIBLE WITH CARBON STEEL)

TMI-2 ISFSI HSM ROOF BOLT STANDARD MODULE MAIN ASSEMBLY STAINLESS STEEL OUTDOOR PROTECTIVE COVER REINFORCEMENT BARS, HSM STANDARD MODULE BASE UNIT CARBON STEEL EMBEDDED OTHER THAN #4 HSM STANDARD MODULE BASE UNIT CONCRETE CONCRETE OUTDOOR GROUT - MOUNTING HOLES &

HSM STANDARD MODULE BASE UNIT CEMENTITIOUS GROUT OUTDOOR EMBEDMENT VOIDS SLOW-RISE POLYURETHANE FOAM POLYURETHANE HSM ROOF SLAB EMBEDDED FORMULA SPRAY FOAM (PLASTIC)

WATER RESISTANT POLYURETHANE POLYURETHANE HSM ROOF SLAB FOAM MATERIAL, 6-1/2" X 6-1/2" X 1/8" EMBEDDED (PLASTIC)

THICK (NOT ADHESIVE)

REINFORCEMENT BARS, HSM ROOF SLAB CARBON STEEL EMBEDDED OTHER THAN #4 HSM ROOF SLAB CONCRETE CONCRETE OUTDOOR HSM DSC SUPPORT STRUCTURE FRONT MOUNTING PLATE, 1" THICK CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE REAR MOUNTING PLATE, 1" THICK CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE STIFFENER PLATE, 1/2" THICK CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE STIFFENER PLATE, 1/2" THICK CARBON STEEL SHELTERED SUPPORT PLATE, HSM DSC SUPPORT STRUCTURE CARBON STEEL SHELTERED 1-1/2" THICK X 7" LONG HSM DSC SUPPORT STRUCTURE CANISTER STOP PLATE, 1-1/8" THICK CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE SUPPORT RAIL, W12 X 96 CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE STIFFENER PLATE, 1/2" THICK CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE RAIL EXTENSION PLATE, 3/4" THICK CARBON STEEL SHELTERED HSM DSC SUPPORT STRUCTURE CROSS BEAM, W6 X 25 CARBON STEEL SHELTERED E70XX ELECTRODE (WELD FILLER HSM DSC SUPPORT STRUCTURE WELD FILLER MATERIAL SHELTERED COMPATIBLE WITH CARBON STEEL)

INORGANIC ZINC HSM DSC SUPPORT STRUCTURE COATING PRIMER WITH EPOXY SHELTERED ENAMEL TOP COAT TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-26

Table 9.8-4 Materials and Environments for HSM AMRs Service Component Item Description Materials Environments HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & PLATE 1/2 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & ROLLED PLATE 3/8 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & PLATE 1-1/2 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & MOUNTING PLATE 1 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & PLATE 3/4 THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND SHELTERED/

MISCELLANEOUS STEEL DOORS & PLATE 1/2 THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND SHELTERED/

MISCELLANEOUS STEEL DOORS & PLATE 1/2 THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & DOOR, PLATE 1-1/2" THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & SPACER, PLATE 1-1/2" THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND HEAVY DUTY HINGE (REAR ACCESS MISCELLANEOUS STEEL DOORS & CARBON STEEL OUTDOOR DOOR)

FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & ANGLE, L8 X 8 X 1 THICK CARBON STEEL SHELTERED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & STIFFENER PLATE, 1/2 THICK CARBON STEEL SHELTERED FABRICATED FASTENERS HSM ERECTION HARDWARE AND OUTDOOR/

MISCELLANEOUS STEEL DOORS & PLATE, 3/4 THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND SHELTERED/

MISCELLANEOUS STEEL DOORS & PLATE, 3/4 THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & TUBE STEEL, 5 X 5 X 3/8" THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & PLATE, 4-1/2 SQUARE X 1/4 THICK CARBON STEEL EMBEDDED FABRICATED FASTENERS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-27

Table 9.8-4 Materials and Environments for HSM AMRs Service Component Item Description Materials Environments HSM ERECTION HARDWARE AND SEISMIC RETAINER, TUBE STEEL, MISCELLANEOUS STEEL DOORS & CARBON STEEL SHELTERED 4 X 4 X 1/2 THICK X 1-0 LONG FABRICATED FASTENERS HSM ERECTION HARDWARE AND REAR DSC SUPPORT STRUCTURE LUG MISCELLANEOUS STEEL DOORS & CARBON STEEL SHELTERED PLATE, 2 X 4 X 1 THICK FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & SHIELD WALL TIE PLATE, 3/4 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND RICHMOND DOWEL BAR SPLICER MISCELLANEOUS STEEL DOORS & (DB-SAE) WITH 1-9/16-8 UN THREAD CARBON STEEL EMBEDDED FABRICATED FASTENERS AND #11 BAR HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & WASHER PLATE, 1/2 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & WASHER PLATE, 1/2 THICK CARBON STEEL OUTDOOR FABRICATED FASTENERS HSM ERECTION HARDWARE AND RICHMOND DOWEL BAR SPLICER MISCELLANEOUS STEEL DOORS & (DB-SAE) WITH 1-9/16-8 UN THREAD CARBON STEEL EMBEDDED FABRICATED FASTENERS AND # 11 BAR HSM ERECTION HARDWARE AND CARBON, SHIELD WALL CAST-IN-PLACE BOLT, 1 OUTDOOR/

MISCELLANEOUS STEEL DOORS & CARBON/BORON, OR 1/8-7UNC - 2A X 1 - 0 LONG EMBEDDED FABRICATED FASTENERS ALLOY STEEL HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & NUT, 1 1/2 - 6 UNC - 2B CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND QUENCHED CARBON MISCELLANEOUS STEEL DOORS & COUPLING NUT, 1 1/2 - 6 UNC - 2B EMBEDDED STEEL FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & NUT, 1 1/4 - 7 UNC - 2B CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND QUENCHED CARBON MISCELLANEOUS STEEL DOORS & COUPLING NUT, 1 1/4 - 7 UNC - 2B EMBEDDED STEEL FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & NUT, 2 - 4 1/2 UNC - 2B CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND QUENCHED CARBON MISCELLANEOUS STEEL DOORS & COUPLING NUT, 2 - 4 1/2 - 7 UNC - 2B EMBEDDED STEEL FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & NUT, 3/4 - 10 UNC - 2B CARBON STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND QUENCHED CARBON MISCELLANEOUS STEEL DOORS & COUPLING NUT, 3/4 - 10 UNC - 2B EMBEDDED STEEL FABRICATED FASTENERS TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-28

Table 9.8-4 Materials and Environments for HSM AMRs Service Component Item Description Materials Environments HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & WASHER PLATE 6 SQ X 1 THICK CARBON STEEL SHELTERED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & STUD, 1 1/2 - 6 UNC - 2A FERRITIC STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & STUD, 1 1/4 - 7 UNC - 2A FERRITIC STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & STUD, 2 - 4 1/2 UNC - 2A FERRITIC STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & STUD, 3/4 - 10 UNC - 2A FERRITIC STEEL EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND SHIELD WALL SUPPORT STUD, MISCELLANEOUS STEEL DOORS & FERRITIC STEEL EMBEDDED 1 1/2-6UNC-2A FABRICATED FASTENERS HSM ERECTION HARDWARE AND CARBON, ROOF ATTACHMENT BOLT, SHELTERED/

MISCELLANEOUS STEEL DOORS & CARBON/BORON, OR ROD Ø 1-5/8 EMBEDDED FABRICATED FASTENERS ALLOY STEEL HSM ERECTION HARDWARE AND NELSON STUD, TYPE S3L, MISCELLANEOUS STEEL DOORS & CARBON STEEL EMBEDDED

Ø 3/4 X 3-3/16 LONG FABRICATED FASTENERS HSM ERECTION HARDWARE AND NELSON STUD, TYPE H4L Ø 1/2 X MISCELLANEOUS STEEL DOORS & CARBON STEEL EMBEDDED 4-1/8 LONG FABRICATED FASTENERS E70XX ELECTRODE HSM ERECTION HARDWARE AND WELD FILLER MATERIAL (ATTACHES (WELD FILLER MISCELLANEOUS STEEL DOORS & SHELTERED DSC SUPPORT STRUCTURE) COMPATIBLE WITH FABRICATED FASTENERS CARBON STEEL)

HSM ERECTION HARDWARE AND MISCELLANEOUS STEEL DOORS & CONCRETE FILL CONCRETE EMBEDDED FABRICATED FASTENERS HSM ERECTION HARDWARE AND INORGANIC ZINC MISCELLANEOUS STEEL DOORS & COATING PRIMER WITH EPOXY SHELTERED FABRICATED FASTENERS ENAMEL TOP COAT HSM END MODULE SHIELD WALL REINFORCEMENT BARS CARBON STEEL EMBEDDED HSM END MODULE SHIELD WALL CONCRETE CONCRETE OUTDOOR TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-29

Table 9.8-5 Materials and Environments for TMI-2 Canister AMRs Component Item Description Materials Service Environments TMI-2 KNOCKOUT CANISTER KNOCKOUT CANISTER UPPER HEAD INTERNAL TMI-2 1150946C POISON TUBE ASSEMBLY STAINLESS STEEL WELDMENT CANISTER/ ENCASED KNOCKOUT CANISTER UPPER HEAD INTERNAL TMI-2 1150946C TOP END CAP STAINLESS STEEL WELDMENT CANISTER/ ENCASED KNOCKOUT CANISTER UPPER HEAD INTERNAL TMI-2 1150946C BOTTOM END CAP STAINLESS STEEL WELDMENT CANISTER/ ENCASED KNOCKOUT CANISTER UPPER HEAD INTERNAL TMI-2 1150946C PIPE 1" SCHEDULE 160 STAINLESS STEEL WELDMENT CANISTER/ ENCASED KNOCKOUT CANISTER UPPER HEAD 1150946C B4C PELLET BORON CARBIDE ENCASED WELDMENT KNOCKOUT CANISTER BOTTOM SUPPORT 1150968D BOTTOM SUPPORT PLATE INTERNAL TMI-2 STAINLESS STEEL PLATE ASSEMBLY ASSEMBLY CANISTER KNOCKOUT CANISTER BOTTOM SUPPORT INTERNAL TMI-2 1150950E BOTTOM SUPPORT PLATE STAINLESS STEEL PLATE ASSEMBLY CANISTER KNOCKOUT CANISTER INTERNALS 1154027F KNOCKOUT CANISTER INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY INTERNALS ASSEMBLY CANISTER KNOCKOUT CANISTER INTERNALS 1155233D POISON TUBE A STAINLESS STEEL ENCASED ASSEMBLY KNOCKOUT CANISTER INTERNALS INTERNAL TMI-2 1150946C POISON TUBE B STAINLESS STEEL ASSEMBLY CANISTER KNOCKOUT CANISTER INTERNALS 1150968D BOTTOM SUPPORT PLATE INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY ASSEMBLY CANISTER KNOCKOUT CANISTER INTERNALS 1150939D INTERMEDIATE SUPPORT INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY PLATE A CANISTER KNOCKOUT CANISTER INTERNALS INTERNAL TMI-2 1150937D SUPPORT RING STAINLESS STEEL ASSEMBLY CANISTER INTERNAL TMI-2 KNOCKOUT CANISTER INTERNALS 1150954D SEAL PLATE STAINLESS STEEL CANISTER/

ASSEMBLY ENCASED KNOCKOUT CANISTER INTERNALS INTERNAL TMI-2 1154090C CENTER TUBE STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED INTERNAL DSC/

KNOCKOUT CANISTER INTERNALS & 1154034F INTERNALS & SHELL STAINLESS STEEL INTERNAL TMI-2 SHELL ASSEMBLY ASSEMBLY CANISTER INTERNAL DSC/

KNOCKOUT CANISTER INTERNALS & 1150945C SHELL (KNOCKOUT &

STAINLESS STEEL INTERNAL TMI-2 SHELL ASSEMBLY FILTER CANISTER)

CANISTER KNOCKOUT CANISTER INTERNALS & 1154027F KNOCKOUT CANISTER INTERNAL TMI-2 STAINLESS STEEL SHELL ASSEMBLY INTERNALS ASSEMBLY CANISTER INTERNAL DSC/

1154041F KNOCKOUT CANISTER KNOCKOUT CANISTER ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 ASSEMBLY CANISTER INTERNAL DSC/

KNOCKOUT CANISTER ASSEMBLY 1154045D BOTTOM HEAD ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 CANISTER INTERNAL DSC/

1154046F KNOCKOUT CANISTER KNOCKOUT CANISTER ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 UPPER HEAD WELDMENT CANISTER INTERNAL DSC/

KNOCKOUT & FILTER CANISTER LOWER 1154045D CANISTER LOWER HEAD STAINLESS STEEL INTERNAL TMI-2 HEAD ASSEMBLY ASSEMBLY CANISTER INTERNAL DSC/

KNOCKOUT & FILTER CANISTER LOWER 1150917D CANISTER LOWER HEAD STAINLESS STEEL INTERNAL TMI-2 HEAD ASSEMBLY (KNOCKOUT & FILTER CANISTER)

CANISTER INTERNAL DSC/

1154046F KNOCKOUT CANISTER FILTER & KNOCKOUT CANISTER SKIRT STAINLESS STEEL INTERNAL TMI-2 HEAD WELDMENT CANISTER INTERNAL DSC/

1150943E KNOCKOUT CANISTER FILTER & KNOCKOUT CANISTER SKIRT STAINLESS STEEL INTERNAL TMI-2 UPPER HEAD CANISTER KNOCKOUT CANISTER POISON TUBE 1155233D KNOCKOUT CANISTER INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY POISON TUBE ASSEMBLY CANISTER/ ENCASED TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-30

Table 9.8-5 Materials and Environments for TMI-2 Canister AMRs Component Item Description Materials Service Environments KNOCKOUT CANISTER POISON TUBE 1155233D TUBE 2-1/8 OD X 0.065 INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY THICK WALL CANISTER/ ENCASED KNOCKOUT CANISTER POISON TUBE INTERNAL TMI-2 1155233D BOTTOM END PLUG STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED KNOCKOUT CANISTER POISON TUBE INTERNAL TMI-2 1155233D TOP END PLUG STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED KNOCKOUT CANISTER POISON TUBE 1155233D B4C PELLET BORON CARBIDE ENCASED ASSEMBLY INTERNAL DSC/

KNOCKOUT CANISTER ASSEMBLY SAR NOTE 3: WELD FILLER METAL STAINLESS STEEL INTERNAL TMI-2 CANISTER TMI-2 FILTER CANISTER FILTER CANISTER POISON TUBE INTERNAL TMI-2 1150949D POISON TUBE ASSEMBLY STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED FILTER CANISTER POISON TUBE 1150949D; TUBE 2-1/8 OD X 0.065 INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY THICK WALL CANISTER/ ENCASED FILTER CANISTER POISON TUBE INTERNAL TMI-2 1150949D; BOTTOM END PLUG STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED FILTER CANISTER POISON TUBE INTERNAL TMI-2 1150949D; TOP END PLUG STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED FILTER CANISTER POISON TUBE 1150949D; B4C PELLET BORON CARBIDE ENCASED ASSEMBLY INTERNAL DSC/

FILTER CANISTER UPPER HEAD 1150959D UPPER HEAD WELDMENT STAINLESS STEEL INTERNAL TMI-2 WELDMENT CANISTER INTERNAL DSC/

FILTER CANISTER UPPER HEAD 1150958D FILTER CANISTER UPPER STAINLESS STEEL INTERNAL TMI-2 WELDMENT HEAD CANISTER INTERNAL DSC/

1154018F FILTER CANISTER FILTER CANISTER ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 ASSEMBLY CANISTER INTERNAL DSC/

FILTER CANISTER ASSEMBLY 1150959D UPPER HEAD WELDMENT STAINLESS STEEL INTERNAL TMI-2 CANISTER INTERNAL DSC/

FILTER CANISTER ASSEMBLY 1154045D BOTTOM HEAD ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 CANISTER INTERNAL DSC/

1154020E FILTER CANISTER SUB-FILTER CANISTER SUB-ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 ASSEMBLY CANISTER INTERNAL DSC/

FILTER CANISTER SUB-ASSEMBLY 1150945C SHELL STAINLESS STEEL INTERNAL TMI-2 CANISTER INTERNAL TMI-2 FILTER CANISTER SUB-ASSEMBLY 1150949D POISON TUBE ASSEMBLY STAINLESS STEEL CANISTER INTERNAL DSC/

FILTER CANISTER ASSEMBLY SAR NOTE 3: WELD FILLER METAL STAINLESS STEEL INTERNAL TMI-2 CANISTER TMI-2 FUEL CANISTER FUEL CANISTER NEUTRON POISON INTERNAL TMI-2 18163E100 TUBE ASSEMBLY STAINLESS STEEL SHROUD CANISTER/ ENCASED FUEL CANISTER NEUTRON POISON INTERNAL TMI-2 18163E100-1 OUTER SKIN STAINLESS STEEL SHROUD CANISTER/ ENCASED FUEL CANISTER NEUTRON POISON INTERNAL TMI-2 18163E100-2 INNER SKIN STAINLESS STEEL SHROUD CANISTER/ ENCASED FUEL CANISTER NEUTRON POISON 18163E100-3 BORAL BORAL ENCASED SHROUD FUEL CANISTER BOTTOM PLATE 1150998E FUEL CANISTER BOTTOM INTERNAL TMI-2 STAINLESS STEEL ASSEMBLY PLATE ASSEMBLY CANISTER FUEL CANISTER BOTTOM PLATE INTERNAL TMI-2 1150992E BOTTOM PLATE STAINLESS STEEL ASSEMBLY CANISTER 1150999F FUEL CANISTER LOWER INTERNAL TMI-2 FUEL CANISTER LOWER ASSEMBLY STAINLESS STEEL ASSEMBLY CANISTER TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-31

Table 9.8-5 Materials and Environments for TMI-2 Canister AMRs Component Item Description Materials Service Environments 1095753E BORAL SHROUD INTERNAL TMI-2 FUEL CANISTER LOWER ASSEMBLY STAINLESS STEEL ASSEMBLY CANISTER/ ENCASED INTERNAL DSC/

1154014F FUEL CANISTER FUEL CANISTER LOWER ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 BULKHEAD CANISTER INTERNAL DSC/

FUEL CANISTER LOWER ASSEMBLY 1150983C FUEL CANISTER SHELL STAINLESS STEEL INTERNAL TMI-2 CANISTER/ ENCASED INTERNAL DSC/

FUEL CANISTER LOWER ASSEMBLY 1154045D LOWER HEAD ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 CANISTER 1150998E BOTTOM PLATE INTERNAL TMI-2 FUEL CANISTER LOWER ASSEMBLY STAINLESS STEEL ASSEMBLY CANISTER INTERNAL TMI-2 FUEL CANISTER LOWER ASSEMBLY 1150999F CONCRETE MIX LICON CANISTER/ ENCASED INTERNAL DSC/

1154026F FUEL CANISTER HEAD FUEL CANISTER HEAD WELDMENT STAINLESS STEEL INTERNAL TMI-2 WELDMENT CANISTER INTERNAL DSC/

1150989F FUEL CANISTER UPPER FUEL CANISTER HEAD WELDMENT STAINLESS STEEL INTERNAL TMI-2 HEAD CANISTER 1150993C SHOCK ABSORBER INTERNAL TMI-2 FUEL CANISTER HEAD WELDMENT STAINLESS STEEL SUPPORT CANISTER INTERNAL TMI-2 FUEL CANISTER HEAD WELDMENT 1150995C IMPACT PLATE "D" STAINLESS STEEL CANISTER INTERNAL TMI-2 FUEL CANISTER HEAD WELDMENT STAINLESS STEEL 1150994C IMPACT PLATE "C" CANISTER INTERNAL DSC/

FUEL CANISTER HEAD WELDMENT 1154021C FUEL CANISTER BOLT INCONEL 625 INTERNAL TMI-2 CANISTER INTERNAL DSC/

1154070F FUEL CANISTER FUEL CANISTER ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 ASSEMBLY CANISTER INTERNAL DSC/

1150999E FUEL CANISTER LOWER FUEL CANISTER ASSEMBLY STAINLESS STEEL INTERNAL TMI-2 ASSEMBLY CANISTER INTERNAL DSC 1154026F FUEL CANISTER UPPER FUEL CANISTER ASSEMBLY STAINLESS STEEL /INTERNAL TMI-2 HEAD WELDMENT CANISTER INTERNAL DSC/

FUEL CANISTER ASSEMBLY SAR NOTE 3: WELD FILLER METAL STAINLESS STEEL INTERNAL TMI-2 CANISTER TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-32

Table 9.8-6 TMI-2 ISFSI Tollgates DUE TOLLGATE ASSESSMENT DATE Evaluate information from the following sources and perform a written assessment of the aggregate impact of the information, including but not limited to applicable and relevant trends, corrective actions required, and the effectiveness of the AMPs with which they are associated:

  • Results, if any, of research and development programs focused specifically on aging-related degradation mechanisms identified as potentially affecting DSS ISFSIs
  • Relevant domestic and international OE including research results on aging effects/mechanisms (including non-nuclear on an opportunistic basis) 1 3/19/2024
  • Relevant results of domestic and international ISFSI and DSS performance monitoring
  • Relevant results of domestic and international ISFSI and DSS inspections Topics of particular interest for the TMI-2 ISFSI tollgate assessment should include, the following:
  • Reinforced concrete degradation in general, and degradation of NUHOMS HSMs in particular
  • Deterioration of carbon steel and coatings Evaluate additional information gained from the sources listed in Tollgate 1 along with any new relevant sources and perform a written assessment of the aggregate impact of 2 3/19/2029 the information. This evaluation should be informed by the results of Tollgate 1. The aging effects and mechanisms evaluated at this Tollgate, and the time at which it is conducted, may be adjusted based on the results of the Tollgate 1 assessment.

3 3/19/2034 Same as Tollgate 1, as informed by the results of Tollgates 1 and 2 4 3/19/2039 Same as Tollgate 1, as informed by the results of Tollgates 1, 2, and 3 TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-33

Table 9.8-7 DSC Aging Management Program Number of SSCs Environment Frequency Inspection Type Trending Acceptance Criteria (AC) Corrective Actions SSCs The DSC shell, and in Sheltered 2 DSCs Baseline AMP Remote Visual Same DSCs, VT-3: ASME Section XI, Subarticle IWB- Step 1: Perform VT-1 inspection on flaw particular: crevice locations (DOE12T- inspection to be (IWA-2210, VT-3 Frequency 3514.1 and Section 10.2 of ASTM D7167 indications if the VT-3 AC is exceeded or (i.e., where the shell sits on the 002 and performed no later Inspection) decreased to 5 for coatings with limits on blistering, if it is required based on prior inspection support rail); fabrication welds DOE12T- than two years +/- 1 year if cracking, flaking, rusting and physical results and resulting corrective actions of the confinement boundary 004) after the effective exceed AC or damage. dispositioned per deficiency tracking and the associated heat affected date of the evidence of VT-1 (as required): ASME Section XI, system in STI-NLF-QA-016 (See [9.3]

zone (HAZ) renewed license, adverse steel Subarticle IWB-3514.1 and Section A1.7).

(i.e., longitudinal and then at 10-year degradation -No indications of pitting or crevice Step 2A: If the VT-1 examination reveals circumferential welds on the intervals (with a corrosion (localized corrosion); a localized corrosion flaw exceeds the cylindrical shell including 2-year grace -No indications of galvanic corrosion as allowable flaw size in the IWB-3514.1 coatings) period)* evidenced by red-orange corrosion acceptance standards, then procedures in

- Normally Non-Accessible products emanating from crevice locations [9.3] Section A1.7.1 are followed.

Areas (e.g., support rail plate-to-DSC shell Step 2B: If the VT-1 examination reveals interface); coating degradation does not meet AC or

-No indications of corrosion products near VT-1 AC are exceeded (i.e., other VT-1 crevices; AC limits indicated), then procedures in

-No indications of corrosion products on or [9.3] Section A1.7 are followed. If aging adjacent to confinement boundary welds; effects are confirmed, this may include

-Section 10.2 of ASTM D7167 for more frequent inspections and performing coatings with limits on blistering, cracking, inspections in inaccessible locations.

flaking, rusting, and physical damage TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-34

Table 9.8-7 DSC Aging Management Program Number of SSCs Environment Frequency Inspection Type Trending Acceptance Criteria (AC) Corrective Actions SSCs DSC SSCs (Steel including Sheltered 2 DSCs Baseline AMP Direct Visual Same surfaces VT-3: ASME Section XI, Subarticle IWB- Step 1: Perform VT-1 inspection on flaw Coatings) in rear of HSM (DOE12T- inspection to be (IWA-2210, VT-3 every five 3514.1 and Section 10.2 of ASTM D7167 indications if the VT-3 AC is exceeded or including the Vent and Purge 002 and performed no later Inspection) years for coatings with limits on blistering, if it is required based on prior inspection Port HEPA Filters and DOE12T- than 1 year after cracking, flaking, rusting and physical results and resulting corrective actions Housings, and Vent and Purge 004) the effective date damage. dispositioned per deficiency tracking Port Filter Housing attachment of the renewed VT-1 (as required): ASME Section XI, system in STI-NLF-QA-016 (See [9.3]

fasteners and portions of Outer license and at 5- Subarticle IWB-3514.1 and Section A1.7).

Top Cover plate, closure weld year intervals -No indications of pitting or crevice Step 2A: If the VT-1 examination reveals and HAZ thereafter (with a corrosion (localized corrosion); a localized corrosion flaw exceeds the

- Accessible Areas 1-year grace -No indications of galvanic corrosion as allowable flaw size in the IWB-3514.1 period).* evidenced by red-orange corrosion acceptance standards, then procedures in Normally products emanating from crevice locations [9.3] Section A1.7.1 are followed.

synchronized with (e.g., support rail plate-to-DSC shell Step 2B: If the VT-1 examination reveals SR 3.1.1.1. interface); coating degradation does not meet AC or

-No indications of corrosion products near VT-1 AC are exceeded (i.e., other VT-1 crevices; AC limits indicated), then procedures in

-No indications of corrosion products on or [9.3] Section A1.7 are followed. If aging adjacent to confinement boundary welds; effects are confirmed, this may include

-Section 10.2 of ASTM D7167 for more frequent inspections and performing coatings with limits on blistering, cracking, inspections in inaccessible locations.

flaking, rusting, and physical damage DSC SSCs (Steel including Sheltered As required In accordance Direct or Remote In accordance Via the TMI-2 ISFSI corrective action Further evaluation and disposition per Coatings) including on upper per with Corrective Visual or both with program deficiency tracking provided by STI-NLF-surface of the DSC shell (i.e., scheduled Actions, [9.3] Corrective STI-NLF-QA-016, to ensure the aging QA-016, including more frequent where atmospheric particulates inspection Section A1.7 Actions, [9.3] effect is adequately managed and that the inspections and if detection of evidence of would settle); Outer Bottom findings Section A1.7 SSCs intended function is maintained loss of material from localized corrosion Cover plate, Grapple Ring and STI- during the PEO (pitting or crevice corrosion), the Assembly plates, their welds NLF-QA- expanded corrective action standard and HAZs; Portions of the 016 outlined in [9.3] Section A1.7.1.

Outer Top Cover plate, HAZ corrective and associated closure weld actions

- Inaccessible Areas

  • The interval clock starts as of the due date of the prior inspection. For example, if the ten-year inspection is due on 01/01/2025 and performed on 05/30/2026 (within the two-year grace period), the next inspection is still due on 01/01/2035 and must be performed no later than 01/01/2037.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-35

Table 9.8-8 HSM Aging Management Program SSCs Environment Number of SSCs Frequency Inspection Type Trending Acceptance Criteria (AC) Corrective Actions HSM SSCs Outdoor All 29 HSMs Baseline AMP inspection to be Direct Visual All HSMs ACI 349.3R - Second Tier (including Disposition per deficiency (Concrete performed no later than two (ACI 349.3R, Section 5.2.4 for Sealants, Chemical tracking system in STI-NLF-QA-including years after the license renewal Section 3.5.1) Grouts) 016 (See [9.3] Section A2.7). For Fillers/Sealants) - effective date, and at 5-year any concrete conditions Normally intervals thereafter (with a 1- exceeding 2nd tier criteria, a accessible areas year grace period)* technical evaluation of degradation assessing whether ASR is an apparent or root cause.

HSM SSCs (Steel Outdoor All 29 HSMs Baseline AMP inspection to be Direct Visual All HSMs VT-3: ASME Section XI, Subarticle Disposition per deficiency including performed no later than two (IWA-2210, VT- IWF-3400 and Section 10.2 of ASTM tracking system in STI-NLF-QA-Coatings) - years after the license renewal 3 Inspection on D7167 for coatings with limits on 016 (See [9.3] Section A2.7),

Normally effective date, and at 5-year Steel Hardware) blistering, cracking, flaking, rusting including a more detailed VT-1 accessible areas intervals thereafter (with a 1- and physical damage and with flaws visual examination of flaws year grace period)* defined by any of the following: identified

-Corrosion and material wastage (loss of material)

-Crevice and pitting corrosion (loss of material)

-Worn, flaking, or oxide-coated surfaces (loss of material)

-Corrosion stains on adjacent components and structures (loss of material)

-Stains caused by leaking rainwater HSM SSCs Outdoor Two Areas on two Baseline AMP inspection to be RILEM Tube Same surfaces ACI 349.3R - Second Tier ( 80% Reapply water repellent coating (Silane Coating) HSMs (1 Vertical performed no later than 1 year Test (Test each year water repellency) and re-test water repellency using and 1 Horizontal after the license renewal Method II.4) RILEM Tube Test (Test Method Surface) and 1 effective date, and at 1-year II.4) vertical surface on intervals thereafter (with a 3-HSM End Shield month grace period)*

Wall TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-36

Table 9.8-8 HSM Aging Management Program SSCs Environment Number of SSCs Frequency Inspection Type Trending Acceptance Criteria (AC) Corrective Actions HSM SSCs - Sheltered Two Bolt Cover Baseline AMP inspection on Direct Visual New set of Two ACI 349.3R - Second Tier (including Disposition per deficiency Normally non- Assemblies - If no the first set of Roof Protective (IWA-2210, VT- Each Year on Section 5.2.4 for Polyurethane tracking system in STI-NLF-QA-accessible evidence of adverse Bolt Cover assemblies are to be 3 Inspection on Rolling Five components) 016 (See [9.3] Section A2.7),

(Protective Bolt concrete degradation performed within the first year Steel Hardware) Year Basis (i.e., For steel components, VT-3: ASME including for steel components a Covers and after the license renewal with Direct Repeat Set One Section XI, Subarticle IWF-3400 and more detailed VT-1 visual Polyurethane effective date. The 2nd, 3rd, 4th, Visual on on Year 6, Set as applicable Section 10.2 of ASTM examination of flaws identified.

Gasket and Filler and 5th sets of baseline remaining SSCs Two on Year 7, D7167 for coatings with limits on For any concrete conditions and surrounding inspections are due in the (ACI 349.3R, etc.) blistering, cracking, flaking, rusting exceeding 2nd tier criteria, a concrete, subsequent 1-year intervals. A Section 3.5.1) and physical damage and with flaws technical evaluation of Attachment Bolt, grace period of 3 months may defined by any of the following: degradation assessing whether Nut and Washer be applied for the due date of -Corrosion and material wastage (loss ASR is an apparent or root cause.

Plate) each baseline and AMP of material) inspection* -Crevice and pitting corrosion (loss of material)

-Worn, flaking, or oxide-coated surfaces (loss of material)

-Corrosion stains on adjacent components and structures (loss of material)

-Stains caused by leaking rainwater HSM SSCs Sheltered 2 HSMs (HSM-16 Baseline AMP inspection to be Remote Visual Same HSMs, ACI 349.3R - Second Tier Disposition per deficiency (Concrete) - and HSM-5) performed no later than two (ACI 349.3R, decreased to 5 +/- tracking system in STI-NLF-QA-Normally non- years after the license renewal Section 3.5.1) 1 year if exceed 016 (See [9.3] Section A2.7),

accessible areas effective date, then at 10-year AC or evidence including if aging effects are intervals thereafter, with a 2- of adverse confirmed, it may warrant more year grace period* concrete frequent inspections or degradation performing inspections in inaccessible locations. For any concrete conditions exceeding 2nd tier criteria, a technical evaluation of degradation assessing whether ASR is an apparent or root cause.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-37

Table 9.8-8 HSM Aging Management Program SSCs Environment Number of SSCs Frequency Inspection Type Trending Acceptance Criteria (AC) Corrective Actions HSM SSCs (Steel Sheltered 2 HSMs (HSM-16 Baseline AMP inspection to be Remote Visual Same HSMs, Article IWF-3000 and Subarticle Disposition per deficiency including and HSM-5) performed no later than two (IWA-2210, VT- decreased to 5 +/- IWA-3100 (Section 10.2 of ASTM tracking provided by STI-NLF-Coatings) - years after the license renewal 3 Inspection on 1 year if exceed D7167 for coatings with limits on QA-016 (See [9.3] Section A2.7),

Normally non- effective date, then at 10-year Steel Hardware) AC or evidence blistering, cracking, flaking, rusting including if aging effects are accessible areas intervals thereafter, with a 2- of adverse steel and physical damage) confirmed, it may warrant more year grace period* degradation frequent inspections or performing inspections in inaccessible locations.

HSM SSCs - Sheltered As required per In accordance with Corrective Direct or Remote In accordance Via the TMI-2 ISFSI corrective action Further evaluation and Inaccessible Areas scheduled inspection Actions, [9.3] Section A2.7 Visual or both with Corrective program STI-NLF-QA-016 to ensure disposition per deficiency including the findings and Actions, [9.3] the aging effect is adequately tracking provided by Seismic Retainer, STI-NLF-QA-016 Section A2.7 managed and that the SSCs intended STI-NLF-QA-016 (See [9.3]

backside of HSM corrective actions function is maintained during the Section A2.7), including more Shield Door and PEO frequent inspections.

HSM Shield Door opening

  • The interval clock starts as of the prior inspection due date. For example, if a 5-year inspection is due on 01/01/2025 and performed on 05/30/2025 (within the 1-year grace period), the next inspection is still due on 01/01/2030 and must be performed no later than 01/01/2031.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-38

Table 9.8-9 OS197 Transfer Cask Aging Management Program AMP Element AMP Activity Scope of Program This program visually inspects and monitors the accessible TC subcomponent surfaces, including cask cavity surfaces (e.g., inner liner), and the OS197L supplemental shielding subcomponents, to ensure they are intact and free from loss of material due to general, crevice or pitting corrosion and loss of material due to wear.

Preventative The program is a condition-monitoring program. Demineralized water shall be used to fill the neutron Actions shield, rather than municipal water. The neutron shield shall be drained before storage to prevent damage due to freezing and mitigate corrosion. When not in use the TC should be stored in a building or container that prevents direct exposure to precipitation. Tarpaulins, if used, should not be in contact with the TC surface to prevent accumulation of condensation. After fuel is loaded in the DSC and the cask is raised above the pool water surface, the cask is rinsed off with demineralized water.

Parameters Surface condition: wear, corrosion, and coating.

Monitored or Signs of leakage for the liquid neutron shield.

Inspected Detection of Aging Effects Method or Visual inspection per VT-3. Any area of the TC exhibiting evidence of possible crevices, pits, water stains Technique: or discoloration during the VT-3 examinations is subjected to a VT-1 examination per IWA-2211. Fasteners are inspected for threaded parts condition, corrosion, and signs of wear or other degradation. PT Exams of the upper and lower trunnion bearing surface and the accessible upper and lower trunnion welds. VT-3 exam is also performed to detect any signs of neutron shield leakage (TC with liquid neutron shield only) with VT-1 employed if there are any signs of corrosion.

Frequency: VT-3: once per five years VT-1 if indications of possible deterioration during VT-3 inspection PT: once per five years Liquid neutron shield: once per five years Sample Size: Each TC.

Data Collection: Records of inspection. Photos or videos. Records of any required corrective actions.

Timing of At frequency defined above. If the TC has not been used for more than 5 years, TC aging management is Inspections: not required, but the inspection must be performed prior to next use of the TC.

Monitoring and A baseline inspection is performed as part of the monitoring and trending activities so that the inspection Trending results can be used for subsequent trending.

Acceptance

  • VT-3 and VT-1 examinations in accordance with Section XI IWA-2213 and IWA-2211, respectively. If Criteria corrosion on any of the transfer cask subcomponents or wear of the inner liner thickness are detected, the finding is entered into the licensees corrective action program to determine, based on engineering evaluation, the extent and impact of the corrosion on the ability of the TC to perform its intended function.
  • PT exam acceptance of the trunnion bearing surfaces and accessible welds per ASME Section III, NC-5350.
  • Acceptable coatings are free of peeling or delamination. Blistering, cracking, flaking, rusting, and physical damage will be evaluated to determine acceptability.

Corrective Unsatisfactory degradation is entered in a corrective action program for resolution. Deficiencies are either Actions corrected or are evaluated to be acceptable for continued service through engineering analysis. Extent of condition investigation per the licensees corrective action program may trigger additional inspections via a different method, increased inspection frequency and/or expanded inspection sample size.

Confirmation Confirmatory actions, as needed, are implemented as part of the CoC holder or licensees corrective action Process program, as applicable.

Administrative Administrative controls under the CoC holder or licensees QA procedures and corrective action program Controls provide a formal review and approval process. Licensee individual events and conditions not rising to the level of NRC reportability based on the criteria in 10 CFR 72 are communicated to the CoC holder.

Operating The overall effectiveness of these inspections/activities in maintaining the condition and functionality of the Experience casks is supported by the continued use of the transfer casks and their continued compliance with the certificate of compliance.

TMI-2 SAR-II-8.4 3/31/21 Chapter 9 Rev. 13 Page 9.8-39

9.9 References 9.1 U.S. Nuclear Regulatory Commission, NUREG-1927, Revision 1, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel, June 2016, NRC Accession Number ML16179A148.

9.2 Nuclear Energy Institute, NEI 14-03, Revision 2, Format, Content and Implementation Guidance for Dry Cask Storage Operations-Based Aging Management, December 2016, Washington D.C.

9.3 U.S. Department of Energy-Idaho Office, TMI-2 Independent Spent Fuel Storage Installation Application for 10 CFR 72 Specific License Renewal, Special Nuclear Materials License Number SNM-2508 (Docket No. 72-20), Revision 3, May 2019, NRC Accession Number ML19150A336.

9.4 AREVA TN Americas, Renewal Application for the Standardized NUHOMS System, Certificate of Compliance No. 1004, Revision 3, September 29, 2016, NRC Accession Number 16279A371 (Submittal Enclosure 3, Proprietary Version) and ML16279A372 (Submittal Enclosure 4, Public Version).

9.5 TN Americas LLC, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 17, March 2018, Docket No. 72-1004, NRC Accession Number 18079A008 (Proprietary Version) and ML18079A007 (Public Version).

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