ML23089A175

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Tn Americas LLC Application for Amendment 4 to NUHOMS Eos Certificate of Compliance No. 1042, Revision 1 - Response to Request for Supplemental Information
ML23089A175
Person / Time
Site: 07201042
Issue date: 03/30/2023
From: Narayanan P
TN Americas LLC
To:
Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML23089A174 List:
References
CAC 001028, EPID L-2022-LLA-0017, CoC No. 1042, Rev 1, E-61991
Download: ML23089A175 (1)


Text

March 30, 2023 E-61991 U. S. Nuclear Regulatory Commission Columbia Office 7160 Riverwood Drive Attn: Document Control Desk Columbia, MD 21046 Tel: (410) 910-6900 One White Flint North

@Orano_USA 11555 Rockville Pike Rockville, MD 20852

Subject:

Application for Amendment 4 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 1 (Docket 72-1042, CAC No.

001028, EPID: L-2022-LLA-0017) - Response to Request for Supplemental Information

References:

[1] Letter from Christian Jacobs to Prakash Narayanan, Acceptance Review of TN Americas LLC Application for Certificate of Compliance No. 1042, Amendment No. 4, to NUHOMS EOS System (Docket No. 72-1042, CAC No. 001028, EPID: L-2022-LLA-0017) - Request for Supplemental Information, dated January 30, 2023

[2] Letter E-59796, dated September 29, 2022, from Prakash Narayanan, Application for Amendment 4 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 0 (Docket 72-1042)

This submittal provides responses to the Request for Supplemental Information (RSI) forwarded by Reference [1] above. Enclosure 2 herein provides a proprietary version of the response to the RSI and Observation (OBS) items. Enclosure 3 provides a public version of these responses. Each RSI and OBS response has a section stating the impact of the response on the application, both Technical Specifications (TS) and updated final safety analysis report (UFSAR), indicating which sections, tables, etc., have been changed.

Enclosure 4 provides a listing of the CoC 1042 Amendment 4, Revision 1 TS changes, along with a justification, resulting from these RSI and OBS responses.

Enclosure 5 provides a list of changed TS and UFSAR pages. Enclosure 6 provides a complete update to the TS, denoted as Revision 1 to Amendment 4 Proposed Technical Specifications.

Enclosure 7 provides the UFSAR changed pages associated with this Revision 1 to the application for Amendment 4. Enclosure 8 provides the public version of the Enclosure 7 UFSAR changed pages.

For the UFSAR, replacement and new Amendment 4, Revision 1 pages are provided. The pages include a footer on each replacement or new page annotated as 72-1042 Amendment 4, Revision 1, March 2023 with changes indicated by italicized text and revision bars. The new changes associated with each RSI or OBS Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

Document Control Desk E-61991 Page 2 of 2 response is further annotated with gray shading and an indication of which RSI or OBS is associated with the changes.

For the TS, Amendment 4 changes on Revision 1 pages are indicated by italicized text, revision bars, and gray shading and an indication of which RSI or OBS response is associated with the changes to distinguish them from the changes proposed in Revision 0 of the Amendment 4 application. provides a description of Amendment 4 changes not related to the RSI responses.

Change number 1 in this enclosure is considered Amendment 4 scope change 7. Change number 6 in this enclosure is considered Amendment 4 scope change 8. Change number 8 in this enclosure is considered Amendment 4 scope change 9. Enclosure 10 provides the reference called out in the response to RSI 3-8 and is considered proprietary. Since Enclosure 10 contains entirely proprietary information, no public version is provided.

Certain portions of this submittal include proprietary information, which may not be used for any purpose other than to support the NRC staffs review of the application. In accordance with 10 CFR 2.390, TN Americas LLC is providing an affidavit (Enclosure 1), specifically requesting that this proprietary information be withheld from public disclosure. The submittal also includes security-related information.

TN Americas LLC looks forward to working with the NRC staff on this amendment application.

We are prepared to meet with the staff to resolve any questions the staff might have. Should the NRC staff require additional information to support review of this application, please do not hesitate to contact Mr. Glenn Mathues at 410-910-6538, or by email at Glenn.Mathues@orano.group.

Sincerely, Prakash Narayanan Chief Technical Officer cc: Chris Jacobs (NRC), Senior Project Manager, Storage and Transportation Licensing Branch, Division of Fuel Management

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390
2. RSIs and Responses (Proprietary)
3. RSIs and Responses (Public)
4. List of New CoC 1042 Amendment 4, Revision 1 Technical Specification Changes and Justifications
5. List of Changed TS and UFSAR Pages Involved in CoC 1042 Amendment 4, Revision 1
6. Proposed Technical Specifications, CoC 1042 Amendment 4, Revision 1
7. CoC 1042 Amendment 4, Revision 1 UFSAR Changed Pages (Proprietary)
8. CoC 1042 Amendment 4, Revision 1 UFSAR Changed Pages (Public)
9. Description of Amendment 4 Changes Not Related to the RSI Responses
10. RSI 3-8 Reference - C-2.45, Tornado Missile Impact (Proprietary)

Enclosure 1 to E-61991 AFFIDAVIT PURSUANT TO 10 CFR 2.390 TN Americas LLC )

State of Maryland ) ss.

County of Howard )

I, Prakash Narayanan, depose and say that I am Chief Technical Officer of TN Americas LLC, duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought is contained in the following enclosures, as listed below:

  • Enclosure 2 - RSis and Responses
  • Enclosure 10 - RSI 3-8 Reference - C-2.45, Tornado Missile Impact These documents have been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by TN Americas LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

1) The information sought to be withheld from public disclosure involves portions of certain RSI responses, pottions of the UFSAR, and a reference for RSI 3-8, all related to the design of the NUHOMSEOS System, which are owned and have been held in confidence by TN Americas LLC, or were provided in confidence to TN Americas LLC and have been held in confidence.
2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.
3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC, because the information consists of descriptions of the design and analysis of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their product' s position or impair the position of TN Americas LLC ' s product, and avoid developing similar data and analyses in supp011 of their processes, methods, or apparatus .

Further the deponent sayeth not. J O I

~'(~~

Prakash Narayanan Chief Technical Officer, TN Americas LLC

-~ day of March 2023 .

Notary Public My Commission Expires O"'b / Q\rl /LlJG r Page 1 of I

Enclosure 2 to E-61991 RSIs and Responses Withheld Pursuant to 10 CFR 2.390

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on Pages 1 through 3 Withheld Pursuant to 10 CFR 2.390 Page 1 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-2:

Provide descriptions of the basic installed configurations of an EOS-HSM-SC, e.g., single, one-row array, or two-row array that are documented in the SAR. Indicate in the SAR section 3.9.8 which HSM-SC configuration is being evaluated for each structural compliance check, noting whether that configuration bounds all possible configurations and a rationale behind these statements.

SAR and technical specification (TS) sections provide seemingly conflicting information regarding the expected installation configuration. This conflict creates doubt as to whether the most conservative configuration has been evaluated. A list of noted general conflicts follows: 1)

TS sections 4.5.1 and 5.1.2.b only mention rear shield wall, 2) SAR section 1.1 mentions rear and end shear walls, but also states that empty interior modules can be employed in lieu of shield walls, 3) SAR section 1.2.1.3 mentions rear and end walls, but also states that end walls will be employed between modules, 4) SAR section 3.9.8.1 mentions rear and end walls.

Furthermore, the stability analyses, (e.g., SAR sections 2.3.4, 3.6.2 and 3.9.7), seem to consider several different variations: a) one end wall is present, b) one end wall is present and reevaluation is performed omitting it, and c) end and rear walls are present.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-2:

The HSM-SC, as with the HSM-RC, can be arranged either in a single-row array, or in back-to-back double row arrays. In either configuration, end shield walls are installed at each end of a module array to provide the required missile and shielding protection. During installation, however, two or more empty modules can be substituted for the end walls until the array is fully built. Because of this allowance, end shield walls are omitted from TS Section 4.5.1. The thick concrete side walls between EOS-HSMs described in UFSAR Section 1.2.1.3 refer to the wall of the HSM base itself, not end (side) shield walls. Independent side shield walls are generally not installed between modules within a given array. However, in certain instances, where the complete array is not built in one phase, the general licensees may prefer to install an end (side) wall in lieu of empty HSMs and complete the array later by adding HSMs at a later date. Only in single-row arrays are rear shield walls installed along the back of each module. There are no rear shield walls installed between modules of a back-to-back double row array.

All the structural analyses in UFSAR Section 3.9.8 consider an individual module as a conservative estimate of the response of the EOS-HSM-SC structural elements under the postulated static and dynamic loads for any EOS-HSM-SC array configuration. As with the HSM-RC structural analyses, the only checks that consider the shield walls are the tornado missile evaluation (end and rear shield walls), and stability checks (end shield wall only). It is clear that either end or rear shield walls may be subject to impacts from tornado missiles and, therefore, must be evaluated. Following the previously approved method of evaluation for the HSM-RC, all the stability evaluations in UFSAR Section 3.9.8.11 conservatively consider a single module with one end shield wall and ignore the rear shield wall and corner block because there never exists a freestanding, loaded HSM with nothing on either side.

UFSAR Section 2.3.4 has been revised to remove mention of stability evaluations with no shield wall, and instead state that the seismic stability response of a single, freestanding HSM with an end shield wall is considered.

Page 4 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Impact:

UFSAR Section 2.3.4 has been revised as described in the response.

Page 5 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-3:

Provide complete and accurate design bases and design criteria for the HSM-SC. Specifically identify which portions of Regulatory Guide 1.243, Rev. 0 (RG) were considered in the design of the HSM-SC and update the SAR for these citations. The design criteria in SAR section 3.9.8.3 states that the guidelines of RG 1.243 were considered, but the RG is not cited in any other portion of the SAR. It is not clear whether the conditions applied by the staff in section C of the RG are observed.

SAR section 2.1.2 indicates that the HSM-SC is designed to ANSI/AISC N690-18 Code, and section 2.4.2.2 indicates that any exceptions taken to the Code are indicated in TS section 4.4.4. However, SAR section 2.4.2.2 states that load combinations in ANS 57.9-84 are employed for design, as shown in table 2-7, which is a Code exception to ANSI/AISC N690-18 design requirements and is not cited in TS section 4.4.4. NUREG-2215 Section 4.5.4 provides guidance that the analysis load combinations should be consistent with the design code requirements.

The load combinations presented in ANS 57.9-84 are in alignment with the American Concrete Institute codes for reinforced concrete (i.e., 318 and 349), whereas the load combinations prescribed in ANSI/AISC N690-18 are intended specifically for steel-plate composite (SC) design, as modified by RG 1.243, Rev. 0.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-3:

The HSM-SC is designed, detailed, and analyzed per AISC N690-18 using the load combinations specified in Section 6.17.3.1 of ANSI 57.9-1984 and considering the applicable sections of RG 1.243. RG 1.243 endorses the use of AISC N690-18, and the load combinations contained in RG 1.243 are based on those in AISC N690-18, with some modifications. The RG 1.243/AISC N690-18 load combinations are intended to cover a wide range of structural applications, similar to those in ACI-349, where additional load combinations are used to account for various uncertainties. For the design of dry-storage structures, ANSI 57.9 contains the most applicable load combinations in accordance with NUREG 1536, R1 (and the more current NUREG 2215). This approach is consistent with the Certificate of Compliance (CoC)

No.1042 licensing basis, and is also consistent with the approach used for the reinforced concrete HSM designs, where the ANSI 57.9 load combinations are used in lieu of those contained in ACI-349. The use of ANSI 57.9 load combinations has been added as a code alternative to Technical Specifications (TS) Section 4.4.4.

Page 6 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Additionally, the maximum ductility ratio of all components complies with the limit of 1.0 for shear-controlled SC components with shear reinforcement spaced more than half the section thickness per Section 11.1.7 of RG 1.243. UFSAR Section 3.9.8.10.6.2 has been updated to reflect compliance with RG 1.243. Per Section 11.1.8.1 of RG 1.243, criteria for perforation are used for local loads due to tornado missiles, which are impactive loads. All shear strength calculations are in accordance with Section N9.3 of AISC N690-18 and consider the appropriate dynamic increase factors per Section 11.1.8.2 of RG 1.243. Missile interface forcing functions are derived by the impulse-momentum theorem in accordance with Section N9.1.6c(b) of AISC N690-18. All SC components satisfy the criteria for both local effects and overall structural response. All SC component concrete thicknesses are sufficient to prevent perforation ignoring the contribution of the faceplate. This meets the recommendations of Section 11.1.9 of RG 1.243. As recommended by Section 11.2 of RG 1.243, the required strength for the entire region is determined by averaging the demand over panel sections, where the panel section dimensions are limited to the wall thickness, in accordance with, or more conservatively than is required by, Section N9.2.5 of AISC N690-18.

Finally, Section 11.3 of RG 1.234 recommends the use of equation A-N9-16 from AISC N690-18 for calculating the compressive strength of SC walls be limited to surface temperatures up to 300 °F in accordance with Section N9.3.2 of the AISC N690-18 code commentary. The maximum accident-thermal temperature of the HSM-SC is 458 °F as shown in UFSAR Figure 3.9.8-4. However, per Figure C-A-N9.3.1 of AISC N690-18, the overestimate of compressive strength at 482 °F is up to approximately 10%. The maximum HSM-SC compression demand-to-capacity (D/C) ratio for the accident-thermal load combination is 0.57 at the upper side wall as shown in UFSAR Table 3.9.8-3. Therefore, there is significant margin available, and the compression D/C ratios are acceptable despite possible 10% overestimation of capacity.

Impact:

UFSAR Sections 3.9.8.10.6.2 and TS Section 4.4.4 have been revised as described in the response.

Page 7 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 Page 8 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-5:

Identify the basis for the live load of 200 psf applied to the HSM-SC roof, as cited in SAR section 3.9.8.7 (refers to section 3.9.4.7 and table 3.9.4-4) and advise whether it is used in the live load case employed in all load combinations for structural analysis and stability evaluations.

Update the SAR as necessary to document what magnitude of live load is employed for the various structural and stability evaluations.

SAR table 3.9.4-4 indicates the 200 psf load includes 110 psf snow and ice load, as cited in SAR section 2.3.5 and TS section 4.5.3. This 110 psf snow load is identified as the 100-year roof snow load, specified for most areas of the continental United States for an unheated structure. It is unclear to staff how the magnitude of the remaining 90 psf roof live load was determined. Although the guidance in table 4-2 of NUREG-2215 indicates that snow be included in the live load case, the ANSI/AISC N690 section NB2.5 load definitions and combinations differ: snow and roof live load are not only mutually exclusive when included in load combinations, but also have a lower load factor applied than live load effects defined in code section NB2.1. Additionally, the staff is concerned that this amplified gravitational live load in all load combinations may unconservatively counteract uplift, overturning, or sliding evaluations that are presented throughout the SAR. NUREG-2215 Section 4.5.4 provides guidance that the analysis load combinations be consistent with the design code requirements. This additional information is required to proceed with the review of the structural adequacy and stability evaluation results.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-5:

A live load of 200 psf applied to the HSM-SC roof is a generic conservative value used in the HSM-SC analyses to envelope all postulated live loadings, including snow and ice plus any miscellaneous conduits, ladders, lights, etc. which may be added to the roof. This value is consistent with the roof pressure live load used in previous horizontal storage module (HSM) license applications. Sections 3.2.4 of the CoC 1004 UFSAR [2] and 3.1.2.2.2.1 of the CoC 1029 UFSAR [1] identify the same 200 psf roof live load.

While ANSI/AISC N690 considers snow and roof live loads as mutually exclusive in its defined load combinations, this is not the basis for design load combinations for the HSM-SC. As stated in UFSAR Section 2.4.2.2, ANSI 57.9-84 load combinations are employed for design. As such, snow and ice are considered as part of the roof live load.

As shown in UFSAR Table 3.9.4-5, the roof live load, which is part of the load case LL listed in UFSAR Table 3.9.4-4, is considered in load combinations C1, C2, and C3 only. The roof live load is not considered in stability analysis cases where its inclusion would produce non-conservative uplift, overturning, and/or sliding.

References:

1. Updated Final Safety Analysis Report for the Standardized Advanced NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Docket Number 72-1029, Revision 11.
2. Updated Final Safety Analysis Report for the Standardized Advanced NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Docket Number 72-1004, Revision 20.

Page 9 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Impact:

No change as a result of this RSI.

Page 10 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-6:

Provide stability analysis information for the NUHOMS EOS HSM-SC and document in the SAR.

SAR section 3.9.8.11 addresses the stability analyses for tornado wind and missile impact, flood, seismic, and interaction with adjacent horizontal storage modules. The description of the stability analyses in this section references a corresponding analysis described in SAR section 3.9.7 for the NUHOMS EOS HSM-RC, often simply stating a resulting factor of safety for each analysis or that the HMS-RC results are bounding. Referencing the previous analysis may be sufficient to describe certain aspects of the analysis, such as the methodology, if they are identical to those used to analyze the HSM-SC. However, this approach does not highlight how aspects of the analysis that are unique to the HSM-SC (e.g., horizontal storage module (HSM) configuration and self-weight) are considered. It also does not document the numerical analysis results that form the basis of the reported factor of safety for each loading condition.

The staff notes that the design basis tornado wind and missile evaluation results presented in SAR section 3.9.8.11.2 show sliding occurring for a single HSM-SC. SAR section 3.9.8.11.5 states that the results are conservative when the interaction of adjacent modules is considered.

Provide justification for not meeting the guidance provided in table 4-3 of NUREG-2215, which requires a safety factor of 1.1, and how this safety factor is met with a multi-module configuration.

SAR sections 2.3.4 and 3.9.8.9 reference CoC No. 1029 (for the Advanced NUHOMS Horizontal Modular Storage System) as the basis for the stability evaluation methodology employed for the HSM-SC dynamic analyses. The methodology is not easily identifiable by external reference and its content should appear in this SAR for configuration control purposes.

The information in SAR section 3.9.8.11 is insufficient for the staff to begin its review of the stability of the HSM-SC. The staff notes that section 4.5.4.1 of NUREG-2215 discusses the information necessary for the review of hand calculations like those typically used for stability analyses.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-6:

The stability analyses performed for the HSM-SC are identical methodologically to those performed for the HSM-RC and detailed in UFSAR Section 3.9.7. There are no aspects of the stability analysis that are unique to the HSM-SC. The assumptions, load combinations, and configurations considered are the same except as noted in UFSAR Section 3.9.8.11.1. The only distinctions are numerical (weight, for example), but the same formulae presented in UFSAR Section 3.9.7.1.8 are applied to produce the factors of safety presented for the HSM-SC.

The cases that simply state that the HSM-RC analysis is bounding were not explicitly recalculated. Both the dynamic and time-dependent overturning analysis of tornado wind concurrent with massive missile impact loading performed for the HSM-RC resulted in a large safety factor (over 20 for the dynamic analysis, and over 6 for the time-dependent analysis). The interior and exterior dimensions of the HSM-SC compared to the HSM-RC are negligibly different, and the minimum HSM-SC weight accounting for the minimum concrete weight density is heavier compared to the HSM-RC. Similarly, the end shield wall used for the HSM-SC is considered similar in dimensions and weight to the end shield walls used for the HSM-RC.

Finally, the maximum weight of the DSC for the HSM-SC is the same as used for the HSM-RC.

The increased weight of the HSM-SC increases the stabilizing moment. The change in CG height of the HSM-SC compared to the HSM-RC is considered negligible. Due to the large Page 11 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 safety factors calculated for these cases in the HSM-RC with the same methodology, it was concluded that the HSM-SC has similar safety factors and is therefore acceptable.

The value of 1.09 inches of sliding presented in UFSAR Section 3.9.8.11.2 represents a conservative theoretical maximum sliding case including a safety factor of 1.1 for a single HSM-SC module with one shield wall. In actual scenarios, this sliding distance could not be achieved because of energy absorption due to contact with the adjacent module as described in UFSAR Section 3.9.7.1.8.4 for the HSM-RC. Thus, the maximum displacement described in UFSAR Section 3.9.8.11.2 is conservative and bounding.

The statements in UFSAR Sections 2.3.4 and 3.9.8.9 that reference the CoC 1029 [1] dynamic analysis methodology concern the use of LS-DYNA for non-linear, dynamic seismic stability analyses of the HSM as described in Section 11.2.1.2.1 and Appendix B.11.2.1.2.1 of the CoC 1029 UFSAR. As discussed in response to RAI 3-1 for Amendment 0 to CoC 1042 [2], this is similar to the approach presented in Sections 2.3.4 and 3.9.4.9.2 of the UFSAR and Item 5 of Section 4.5.3 of Technical Specification for the HSM-RC wherein a provision for dynamic analyses has been provided if necessary. It is only the case that should such analyses be required to meet site specific requirements, and/or at sites where the response spectra at the base of the HSM are larger than analyzed herein, they must be performed in accordance with the previously accepted methodology documented in the CoC 1029 UFSAR utilizing the provisions of 10 CFR 72.48. As such, there is little reason to explicitly detail the methodology for analyses whose results are not presented in this UFSAR.

Reference:

1. Updated Final Safety Analysis Report for the Standardized Advanced NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Docket Number 72-1029, Revision 11.
2. Revision 4 to Application for Approval of the Spent Fuel Cask Design for the NUHOMS EOS System, Response to Request for Additional Information (Docket No. 72-1042, TAC No. L25028) (ADAMS ML15364A505).

Impact:

No change as a result of this RSI.

Page 12 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on Pages 13 through 15 Withheld Pursuant to 10 CFR 2.390 Page 13 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-8:

Provide information to support the HSM-SC global structural response to missile effects in SAR section 3.9.8.10.6.2, as follows:

a) Provide additional structural component input information, i.e., thickness and length.

b) Provide the rationale behind modifying the idealization of the HSM-SC end walls from a simply-supported plate model in SAR section 3.9.4.10.6.2 to a simply-supported beam in section 3.9.8.10.6.2.

c) Provide a summary of resulting ductility ratios for each component evaluated.

d) Clearly document in the appropriate sections of the SAR whether credit is taken for the presence of shield walls acting as missile barriers when evaluating the contiguous HSM-SC overpack structure for compliance with codes and regulations for missile loading effects.

e) Provide SAR Reference 3.9.8-12: Bechtel Corporation Design Guide Number C-2.45 for Design of Structures for Tornado Missile Impact, revision 0, April 1982.

The global structural analysis for tornado missile effects in SAR section 3.9.8.10.6.2 relies on single degree-of-freedom response charts and methodology from the cited reference to determine ductility ratios for various structural components of the HSM-SC. The SAR description in this section points to section 3.9.4.10.6.2 for a description of the methodology, which does not identify the input parameters such as thicknesses or lengths of the structural components being considered in the evaluation. Thus, it is unclear whether the HSM-SC evaluation is based on the end and rear shield walls, or those of the contiguous HSM-SC overpack. Section 2.4.2.1 of Ingecid Calculation 00624IT004, Rev. 0, (included in application 2) states that all HSM-SC walls except the front wall are considered as interior (as defined by the Code) due to the presence of shield walls. This statement implies that the majority of the contiguous HSM-SC walls are not affected by missile impacts, an assumption that was not found to be clearly stated in the body of the SAR. In either case, no rationale is provided for the difference in the end wall support conditions between the HSM-RC and HSM-SC sections, or why the magnitude of the tabulated results is so disparate. The resulting ductility ratios for each HSM-SC component evaluated are not presented in SAR section 3.9.8.10.6.2, thus it is not possible to verify that they are within acceptable Code-prescribed limits. The staff notes that section 4.5.4.1 of NUREG-2215 discusses the information necessary for the review of hand calculations like those employed to determine component ductility ratios. This additional information, as well as a copy of the cited reference, are required to proceed with the review of the HSM-SC global structural response from missile effects.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-8:

Item a:

As noted in UFSAR Section 3.9.8.1, the configuration of the HSM-SC, in terms of component dimensions and thicknesses, is essentially the same as that of the HSMS-FPS-RC, and component overall dimensions are identified on UFSAR Drawing EOS01-3300-SAR. The following thicknesses are applicable for the HSM-SC:

  • 44-inch thick roof Page 16 of 43

RSIs and Responses - Public Enclosure 3 to E-61991

  • 42-inch thick front wall
  • 36-inch thick end shield wall
  • 36-inch thick rear shield wall
  • 31.5-inch thick shielding door Item b:

The HSM-SC end shield wall was evaluated considering both the simply supported plate, and simply supported beam idealization models. Modeling the shield wall as a beam produced more conservative results, so the more conservative idealization is reported in UFSAR Section 3.9.8.10.6.2.

Item c:

Item d:

The structural response of each of the five components listed above is evaluated individually and independently of other components. These are the only components that may interface with missile loading. The side and back walls of the contiguous HSM-SC are not evaluated for missile loading since they are always blocked by either another module or a shield wall.

Similarly, no credit is taken for the contiguous HSM-SC walls behind the shield walls in the evaluations of the rear and end shield walls other than as simple supports.

Item e:

Reference 1 is attached to this RSI response as Enclosure 10.

Reference:

1. Bechtel Corporation, Design Guide Number C-2.45 for Design of Structures for Tornado Missile Impact, Revision 0, April 1982.

Impact:

No change as a result of this RSI.

Page 17 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on Pages 18 and 19 Withheld Pursuant to 10 CFR 2.390 Page 18 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 References

1. Ingecid Calculation 00624IT004 Revision 0, Optimized Design of the EOS-HSM Steel Plate Composite Structure.
2. Ingecid Calculation 00624IT003 Revision 0, Effect of the Partial Composite Action on the Flexure Stiffness of the SC Sections.
3. Ingecid Calculation 00624IT005 Revision 0, Structural Assessment of the Laboratory Testing results.

Impact:

UFSAR Sections 3.9.8.6.1 and 3.9.8.10.1 have been revised as described in the response.

UFSAR Table 3.9.8-3 has been revised as described in the response.

Table RSI 3-9-1 Dimensions and Parameters of EOS-HSM-SC Structure Components Page 20 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on Pages 21 through 25 Withheld Pursuant to 10 CFR 2.390 Page 21 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-10:

Provide information for the determination of structural acceptability of the ITS connecting items of the HSM-SC, including vertical rods, roof connection angle and bolts, and connections bolts for door, shield walls, and OVC, as follows:

a) Identify materials, design codes, and design load combinations for each item.

b) Provide bounding structural design load demands resulting from design load combinations for each component being evaluated.

c) Provide the structural capacities per the applicable design code.

d) Provide demand-to-capacity ratios for all connection components.

The staff notes that the materials specifications of some of the listed items are included in SAR table 8-2. It is also noted that demand-to-capacity ratios for the heat shield connectors are reported in SAR section 3.9.8.10.4, however, no indication of the design code, material strength or load combinations considered is provided. The information in SAR section 3.9.8 is insufficient for the staff to begin its review of the HSM-SC.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-10:

All HSM-SC connections and embedments and the methodology employed for their design are identical to those for the HSM-RC design as described below. Note that the roof connection angles, bolts, and embedments are not-important-to-safety, as noted in response to RSI 3-4, and, therefore, are omitted from this response. [

]

The material for the vertical threaded rods connecting the upper and lower segments of the HSM-SC is ASTM A722 Gr 150. The material for all other fasteners and embedments, including the door, shield wall, outlet vent cover, and heat shield threaded rods is ASTM A193 Gr B7.

The embedments are designed to the requirements of Appendix D of ACI 349-06, as referenced in Section N9.4.3 of AISC N690-18. The bolts and external threaded rod connections are designed in accordance with the AISC Manual of Steel Construction. The load combinations considered are the same as for the HSM-RC design as shown in UFSAR Table 3.9.4-5.

UFSAR Section 3.9.8.10.7 and Tables 3.9.8-5 and 3.9.8-6 have been added to include the requested bounding demands, capacities, and demand-to-capacity ratios for the HSM-SC connection components. UFSAR Section 3.9.8.12 has been updated to add ACI 349-06, Appendix D as Reference 3.9.8-13.

Impact:

UFSAR Sections 3.9.8.10.7 and 3.9.8.12, and Tables 3.9.8-5 and 3.9.8-6 have been added as described in the response.

Page 26 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-11:

Provide information in the SAR for the HSM-SC heat shield structural adequacy check, including determination of associated in-structure response spectra (ISRS).

SAR section 3.9.8.10.4 addresses the heat shield design for the HSM-SC, referring to HSM-RC section 3.9.4.10.4, stating that the design is identical. However, SAR section 3.9.8.9 explains that a modal time history analysis of the HSM-SC is performed to obtain ISRS for the heat shield support points. This statement implies that different ISRS than those for the heat shields of the HSM-RC, as presented in figures 3.9.4-16 to -21, are employed to determine the response of the heat shield plates and support bolts. Based on the resulting heat shield plate and bolt results presented in SAR section 3.9.8.10.4, it appears that the resulting load demands are in fact different than those for the HSM-RC. Additionally, the design code, materials and load combinations employed for the structural adequacy check of the plates and bolts are not identified in the SAR. The information in SAR section 3.9.8.10.4 is insufficient for the staff to begin its review of the HSM-SC heat shields.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-11:

The heat shields and support bolts for the HSM-SC are identical in terms of dimensions, materials, quantity, design code, and applicable load combinations to those used in the HSM-FPS-RC, as described in UFSAR Section 3.9.8.10.4. As such, the modal frequencies and mass participation factors are also identical to those presented in SAR Table 3.9.4-24 and Table 3.9.4-25a. However, the HSM-SC module itself is certain to produce slightly different spectral accelerations at the heat shield mounting points than the HSM-RC. Therefore, in order to validate the adequacy of the existing heat shield design for implementation in the HSM-SC, the same method of evaluation used for the HSM-RC and detailed in UFSAR Section 3.9.4.9.2, is repeated to determine the ISRS of the HSM-SC at the heat shield support locations and resulting equivalent static loads. This difference in equivalent static load, which is a result of different responses within the HSM module rather than differences in the heat shields or supports themselves, explains the discrepancy in load demands between the HSM-SC and HSM-RC.

UFSAR Figures 3.9.8-5 through 3.9.8-10 have been added to present the ISRS at the side and roof heat shield support points for the HSM-SC. UFSAR Section 3.9.8.9 has been revised to reference these figures and provide clarity that heat shield design is unchanged between the HSM-SC and HSM-FPS-RC, but the design loads differ due to HSM response.

Impact:

UFSAR Figure 3.9.8-5 through Figure 3.9.8-10 have been added as described in the response.

UFSAR Section 3.9.8.9 has been revised as described in the response.

Page 27 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 3-12:

Provide information in the SAR for the HSM-SC DSC support structure analysis and axial restraint results.

SAR sections 3.9.8.10.2 and 3.9.8.10.5 address the DSC support structure and axial restraint, respectively. SAR section 3.9.8.10.2 states that the HSM-SC DSC structure is identical to that of the HSM-FPS-RC presented in SAR section 3.9.4.10.2, also referring to the applicable results tables employed in that evaluation. Cite which length of the HSM-FPS-RC in table 3.9.4-17a corresponds to the HSM-SC. Upon review of SAR section 3.9.4.10.2, the applicable design code is stated, however the load cases, load combinations and materials are not. A demand-to-capacity (D/C) ratio for the HSM-SC stop plate is said to be different than the values presented for the HSM-FPS-RC, per load combination C4, but this load combination is not identified, and it is not explicitly explained why the D/C ratio is different. Similarly, SAR section 3.9.8.10.5 states that the HSM-SC DSC axial restraint is identical to that of the HSM-RC presented in SAR section 3.9.4.10.5. No design code, material properties, or load combinations, or analysis results are cited in either SAR section as the basis for the applied loads or load capacity. The information in SAR sections 3.9.8.10.2 and 3.9.8.10.5 are insufficient for the staff to begin its review of the HSM-SC DSC support structure and axial restraint.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to RSI 3-12:

The flat plate support (FPS) dry shielded canister (DSC) support structure configuration is only available for the medium length HSMs and, as noted in UFSAR Section 3.9.8.1, only the medium length option is evaluated for HSM-SC. UFSAR Table 3.9.4-17a does not present different lengths of the HSM-FPS-RC, but different span lengths of the FPS rail between supports. All the results in Table 3.9.4-17a pertain only to the medium length HSM and are applicable to HSM-SC. Applicable load cases and load combinations for the FPS DSC support structure are described in UFSAR Sections 3.9.4.4 and 3.9.4.5, respectively, and defined in Tables 3.9.4-15 and 3.9.4-16. The FPS DSC support structure is constructed of primarily ASTM A572 steel with a Nitronic 60 stainless steel sliding rail as detailed in UFSAR Table 8-2.

Load combination C4 is defined in UFSAR Table 3.9.4-5 for concrete components and is the accident-earthquake load combination. The accident-earthquake load combination for the DSC support structure is defined in UFSAR Table 3.9.4-16. The load on the stop plate and its weld is governed by the acceleration of the DSC into the stop plate during a seismic event. In turn, DSC seismic acceleration varies between the different HSM configurations due to the overall system response. Other components of the support structure are not governed by the earthquake load case, and so behave the same regardless of the HSM configuration in which they are installed.

The design criteria, including design code and codes for loads and load combinations, for steel components including the DSC axial restraint are defined in UFSAR Section 3.9.4.3. Similar to the stop plate, the accident-earthquake load combination is governing as the axial restraint is loaded when resisting seismic acceleration of the DSC towards the HSM door. Materials for the axial restraint are identified in UFSAR Table 8-2.

Impact:

UFSAR Section 3.9.8.10.2 has been revised as described in the response.

Page 28 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on Pages 29 and 30 Withheld Pursuant to 10 CFR 2.390 Page 29 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Observation 3-3:

Justify why the thermal expansion evaluation for the HSM-RC heat shields are applicable to those for the HSM-SC, as stated in SAR section SAR 3.9.8.10.4.

The HSM-RC SAR section 3.9.4.10.4 states that no thermal stress will be induced in the heat shield panels as the presence of slotted holes allow free thermal growth. However, no slotted holes in the HSM-SC heat shields are shown on Sheet 5 of 17 of Dwg. EOS01-3300-SAR.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to Observation 3-3:

The heat shields for the HSM-SC remain unchanged from the design of the heat shields of the HSM-FPS-RC. This is shown on Detail 1, Sheet 5 of EOS01-3300-SAR which notes that for both the roof and side heat shields to refer to drawing EOS01-3000-SAR. [

]

Therefore, the information presented in UFSAR Section 3.9.4.10.4 regarding the thermal stresses in the heat shields remains valid for the HSM-SC.

Impact:

No change as a result of this Observation.

Page 31 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Observation 3-4:

Justify how radial thermal growth of the HSM door is not constrained as described in SAR section SAR 3.9.8.10.3, as well as why the door support bolt evaluation presented in HSM-RC SAR section 3.9.4.10.3 and based on the ACI 349 Code, is applicable.

Although not specifically identified on the Dwg. EOS01-3300-SAR, it is assumed that for the HMS-SC the four door attachment bolts interface with the front wall via an embedded coupling device, similar to those shown in sections A, B and C of Dwg. Sht. 3. The attachment bolt embedment detail for the SC door differs from that shown in the EOS01-3000-SAR, Rev. 4 drawing set. Provide evidence that the structural bolt embedment capacities stated in SAR section 3.9.4.10.3 are still applicable or provide the Code basis for any new capacities.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to Observation 3-4:

The circular inner portion of the HSM-SC door, which is closest to the dry shielded canister (DSC) and, therefore, most likely to expand due to increased temperature, has a [ ]

diameter. All portions of the HSM-SC door opening are large enough to accommodate insertion and extraction of the EOS 37PTH and 89BTH DSCs whose outer diameter is [ ]

This gap is sufficiently large to accommodate any radial thermal expansion of the door. A similar gap exists between the middle circular portion of the door and the recessed area of the door opening where it fits.

AISC N690-18 does not provide much explicit guidance for the design of embedded connections in steel-plate composite (SC) structures, like those used for the HSM-SC door supports. Instead, Section N9.4.3(e) requires the available strength of embedded shear lugs and shapes be determined in accordance with ACI 349, Appendix D. This is the same design code used for the embedded connections in the HSM-RC. UFSAR Section 3.9.8.10.3 only states that the governing load described in UFSAR Section 3.9.4.10.3 is applicable, not the entire door bolt evaluation. [

] See the response to RSI 3-10 for further information.

Impact:

No change as a result of this Observation.

Page 32 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Proprietary Information on Pages 33 through 37 Withheld Pursuant to 10 CFR 2.390 Page 33 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Observation 3-7:

Provide further technical justification in TS section 4.4.4 for the use of faceplate material for the exterior door and outlet vent cover (OVC) that has a yield strength of less than the minimum of 50 ksi required by code section N9.1.1(d).

The ANSI/AISC N690-18 code commentary section N9.1.1(d) provides the explanation that the minimum yield strength of 50 ksi is specified to avoid premature yielding from concrete casting and thermally-induced stresses.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to Observation 3-7:

As discussed in UFSAR Section 3.9.8.10.3 the HSM-SC door is free to grow radially when subjected to thermal loads. This is similarly true of the OVC, which rests on the HSM-SC roof and is free to expand in any direction due to thermal growth. Therefore, stresses due to thermal growth are not a concern for these components.

Additionally, since both the HSM-SC door and OVC are not truly walls and are significantly smaller components than, for example, the HSM-SC base, residual stresses from concrete casting are expected to be very low. The height of the overall volume of concrete required to fill these components, which is directly proportional to the hydrostatic pressure during casting, is much less than what is needed for a large wall. Also, both the HSM-SC door and OVC may have the concrete cast in a horizontal orientation, which reduces the total height of concrete even further. Therefore, residual stresses from concrete casting will not contribute to premature yielding of the faceplates of the HSM-SC door or OVC.

TS Section 4.4.4 has been updated to more directly address the intent of N690-18 Section N9.1.1(d) as presented in the code commentary.

Impact:

TS Section 4.4.4 has been revised as described in the response.

Page 38 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Observation 3-8:

Justify the applicability of appendix N9 of the ANSI/AISC N690-18 code for the design of the roof and OVC, as they are not being employed as walls for the HSM-SC.

From an initial review of the code by staff it does not appear that the cited code appendix, titled Steel-Plate Composite (SC) Walls, extends to the design of horizontally-oriented structural elements.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to Observation 3-8:

It is not a requirement of ANSI/AISC N690-18 Appendix N9 for SC components to be oriented vertically, and thus considered as walls, in order for the Appendix to be applicable. As discussed in the Code commentary for Appendix N9 of ANSI/AISC N690-18, the general requirements of Section N9.1.1 must be met for code applicability. The general requirements of Section N9.1.1 do not prescribe any specific orientation for SC components, and the HSM-SC roof and OVC meet all of the requirements of Section N9.1.1 except as noted in TS Section 4.4.4. Moreover, "SC slab" is mentioned in the preamble of the Code commentary for Appendix N9 as well as in the Code commentary for Appendix N9.4.1, which indicates applicability of the Code for SC components oriented horizontally. Therefore, the horizontal orientation of the HSM-SC roof and OVC does not preclude them from being designed in accordance with Appendix N9 of ANSI/AISC N690.

Impact:

No change as a result of this Observation.

Page 39 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Observation 3-9:

Justify the applicability of appendix N9 of the ANSI/AISC N690-18 code for the design of the walls of the HSM-SC, as they are not positively anchored at their base to the supporting basemat, in the middle where they are split for modularity purposes, nor at their top to the roof.

From an initial review of the code by staff, it does not appear that the code appendix addresses these non-continuous support conditions.

This information is necessary to demonstrate compliance with 10 CFR 72.236(b), (d) and (l).

Response to Observation 3-9:

It is not a requirement of ANSI/AISC N690-18 Appendix N9 for SC components to be positively anchored to either each other, or to a concrete basemat. Section N9.4 provides guidance for such connections or anchorages but does not require their presence for code applicability. As discussed in the Code commentary for Appendix N9 of ANSI/AISC N690-18, Appendix N9 is limited to steel-plate composite (SC) walls satisfying the general requirements of Section N9.1.1. This includes both faceplates of a given SC wall being connected to each other, not adjacent walls, using ties and being anchored to the concrete infill, not the ground. These requirements are met by the shear studs and tie bars specified on Drawing EOS01-3300-SAR.

Non-continuous support conditions are also found in precast concrete construction of the HSM-RC. As with the HSM-SC components, the HSM-RC base is not tied to the basemat, split in the middle in the case of the segmented design, and connected to the roof only through NITS angles and bolts.

Impact:

No change as a result of this Observation.

Page 40 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Materials RSIs and Observation:

RSI 8-1:

Provide material properties for ASTM A572 Gr. 65 cited as an optional material for the EOS-DSC support structure.

The applicant is adding an option of using ASTM A572 Gr. 65 for the flat plate support for EOS-DSC support structure. The staff was not able to locate the material properties for ASTM A572 Gr. 65 in the application.

This information is needed to satisfy the requirements of 10 CFR 72.236(b).

Response to RSI 8-1:

The material properties for ASTM A572 Gr. 65 are presented in UFSAR Table 8-14a. This material properties table for ASTM A572 Gr. 65 was introduced as part of Revision 1 of the UFSAR for the CoC 1042 (ADAMS ML18075A058).

Impact:

No change as a result of this RSI.

Page 41 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 RSI 8-2:

Provide the applicable standard(s) that will be used for the anodized aluminum for the 4H and 4HA basket types.

The applicant provided a minimum emissivity value for anodized aluminum to promote heat transfer. The staff notes that aluminum can be anodized using various standards and the resultant emissivity values for anodized aluminum is typically dependent on the thickness of the anodized layer. The application does not indicate which standard or standards will be used to consistently obtain emissivity values that meet or exceed the required minimum value.

This information is needed to satisfy the requirements of 10 CFR 72.236(b) and (f).

Response to RSI 8-2:

If a basket is designated as Type 4HA (either A4HA or B4HA), all aluminum basket plates in that basket shall be anodized to achieve a minimum specified emissivity of 0.70, as shown in Note 6 of the Drawing EOS01-1010-SAR Revision 5A. To verify that this emissivity value is met, the plates are tested in accordance with ASTM E408-13 to determine the acceptability of the anodized aluminum plates.

Impact:

No change as a result of this RSI.

Page 42 of 43

RSIs and Responses - Public Enclosure 3 to E-61991 Observation 8-1:

Clarify whether an anodized coating on aluminum is required for the 4H and 4HA basket types.

The staff notes that page 1-10, Rev 4, 06/22, states that the aluminum basket plates may be anodized to allow for storage of fuels with decay heats greater than the specific kilowatt (kW) value. However, on page 1-4 and 1-35, a Note on the drawing states anodizing is required for aluminum plates for basket types that hold fuels with decay heats greater than the specified kW value.

This information is needed to satisfy the requirements of 10 CFR 72.236(b) and (f).

Response to Observation 8-1:

As noted on Note 6 of the Drawing EOS01-1010-SAR, if a basket is designated as Type 4HA (A4HA/B4HA), all aluminum basket plates in that basket shall be anodized to achieve the minimum specified emissivity. The second statement in Note 6, provides the background for requiring anodizing of basket plates. As an example, if a heat load zoning configuration (HLZC) for Type 4H basket is developed with decay heats greater than the 3.5 kW/fuel assembly, that basket will be re-designated as Type 4HA and all aluminum basket plates shall be anodized.

Impact:

No change as a result of this Observation.

Page 43 of 43

Enclosure 4 to E-61991 List of New CoC 1042 Amendment 4, Revision 1 Technical Specifications Changes and Justifications Changed Technical Specifications (TS) Area and Justification Page Number Table of Contents, List of Updated Tables, and List of Figures As described in Enclosure 9, Change Number 8, in the sixth paragraph of the THERMAL PARAMETERS section, the Section 2.1, Page 2-2 phrase to accommodate site-specific conditions has been added.

As described in the response to OBS 3-7, within the N9.1.1(d) row, several sentences have been added to the JUSTIFICATION AND COMPENSATORY MEASURES Section 4.4.4, Page 4-13 section to more directly address the intent of ANSI/AISC N690-18 Section N9.1.19(d) as presented in the code commentary.

As described in the response to RSI 3-3, the use of ANSI 57.9 Section 4.4.4, Page 4-13 load combinations has been added as a code alternative to TS Section 4.4.4.

As described in Enclosure 9, Change Number 5, the value Figure F-12, Page F-31 (87.4kW total) has been delete and note 3 has been edited for clarification.

Page 1 of 1

Enclosure 5 to E-61991 List of TS and UFSAR Pages Involved in CoC 1042 Amendment 4, Revision 1 Technical Specifications Pages 2-2 4-13 F-31 UFSAR Pages and Drawing Sheets 1-4 1-12 1-13 Drawing EOS01-3300-SAR 1-33 (17 Sheets) 2-10 2-17 2-64 3-35 3.9.8-4 3.9.8-6 3.9.8-7 3.9.8-10 3.9.8-11 3.9.8-12 3.9.8-14 3.9.8-17 3.9.8-18 3.9.8-20 3.9.8-21 3.9.8-26 3.9.8-27 3.9.8-28 3.9.8-29 3.9.8-30 3.9.8-31 8-5 8-25 A.8-3 A.8-12 A.8-13 B.9-12 B.9-13 B.9-14 B.9-15 B.9-16 B.9-17 B.9-18 B.12-6 B.12-11 Page 1 of 1

Enclosure 6 to E-61991 Proposed Technical Specifications, CoC 1042 Amendment 4, Revision 1

Revision 1 to Amendment 4 Proposed Technical Specifications CoC 1042 APPENDIX A NUHOMS EOS SYSTEM GENERIC TECHNICAL SPECIFICATIONS Amendment 4

TABLE OF CONTENTS (continued) PAGE Use and Application ................................................................................................. 1-1 Definitions .....................................................................................................1-1 Logical Connectors .......................................................................................1-5 Completion Times .........................................................................................1-7 Frequency...................................................................................................1-10 Functional and Operating Limits............................................................................... 2-1 Fuel to be Stored in the EOS-37PTH DSC ...................................................2-1 Fuel to be Stored in the EOS-89BTH DSC ...................................................2-5 Fuel to be stored in the 61BTH Type 2 DSC ................................................2-8 Functional and Operating Limits Violations ................................................2-11 Limiting Condition for Operation (LCO) and Surveillance Requirement (SR)

Applicability .............................................................................................................. 3-1 DSC Fuel Integrity ........................................................................................3-3 Fuel Integrity during Drying ............................................................. 3-3 DSC Helium Backfill Pressure ......................................................... 3-5 Time Limit for Completion of DSC Transfer .................................... 3-7 Cask Criticality Control ...............................................................................3-10 Soluble Boron Concentration ........................................................ 3-10 Radiation Protection ...................................................................................3-12 DSC and TRANSFER CASK (TC) Surface Contamination ........... 3-12 Design Features ....................................................................................................... 4-1 Site ...............................................................................................................4-1 4.1.1 Site Location.................................................................................... 4-1 Storage System Features .............................................................................4-1 4.2.1 Storage Capacity ............................................................................. 4-1 4.2.2 Storage Pad .................................................................................... 4-1 Canister Criticality Control ............................................................................4-1 4.3.1 Neutron Absorber Tests .................................................................. 4-2 4.3.2 High Strength Low Alloy Steel for Basket Structure for EOS-37PTH and EOS-89BTH DSCs. ...................................................... 4-2 Codes and Standards ...................................................................................4-3 4.4.1 HORIZONTAL STORAGE MODULE (HSM) ................................... 4-3 4.4.2 DRY SHIELDED CANISTER (DSC) (EOS-37PTH, EOS-89BTH, and 61BTH Type 2) ............................................................ 4-4 4.4.3 TRANSFER CASK .......................................................................... 4-4 4.4.4 Alternatives to Codes and Standards .............................................. 4-4 Storage Location Design Features .............................................................4-15 4.5.1 Storage Configuration ................................................................... 4-15 4.5.2 Concrete Storage Pad Properties to Limit DSC Gravitational Loadings Due to Postulated Drops................................................ 4-15 4.5.3 Site Specific Parameters and Analyses ........................................ 4-15 Administrative Controls ............................................................................................ 5-1 Programs ......................................................................................................5-1 5.1.1 Radiological Environmental Monitoring Program ............................ 5-1 5.1.2 Radiation Protection Program ......................................................... 5-1 5.1.3 HSM Thermal Monitoring Program.................................................. 5-3 Lifting Controls..............................................................................................5-7 5.2.1 TC/DSC Lifting Height and Temperature Limits .............................. 5-7 5.2.2 Cask Drop ....................................................................................... 5-7 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 ii

TABLE OF CONTENTS (continued) PAGE Concrete Testing ..........................................................................................5-8 Hydrogen Gas Monitoring .............................................................................5-9 EOS-HSM Wind Deflectors ..........................................................................5-9 List of Tables Table 1 Fuel Assembly Design Characteristics for the EOS-37PTH DSC ........................... T-1 Table 2 Maximum Uranium Loading per FFC for Failed PWR Fuel ..................................... T-1 Table 3 Co-60 Equivalent Activity for CCs Stored in the EOS-37PTH DSC ........................ T-1 Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH ................................ T-2 Table 5 Minimum B-10 Content in the Neutron Poison Plates of the EOS-37PTH DSC ..... T-4 Table 6 Fuel Assembly Design Characteristics for the EOS-89BTH DSC ........................... T-5 Table 7A PWR Minimum Enrichments as a Function of Burnup ............................................ T-6 Table 7B EOS-37PTH DSC Fuel Qualification Table for Storage in the HSM-MX, All Fuel ......................................................................................................................... T-7 Table 7C EOS-37PTH DSC Fuel Qualification Table for Storage in the EOS-HSM, All Fuel .................................................................................................................... T-8 Table 8 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the EOS-89BTH DSC............................................................................ T-9 Table 9 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Intact Fuel) .................................................. T-10 Table 10 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Damaged Fuel) ........................................... T-11 Table 11 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Failed and Damaged Fuel) .......................... T-12 Table 12 Maximum Lattice Average Initial Enrichments and Minimum B-10 Areal Density for the 61BTH Type 2 DSC for > 16 Damaged Fuel Assemblies ............. T-13 Table 13 BWR Fuel Assembly Design Characteristics for the 61BTH Type 2 DSC ............ T-14 Table 14 Maximum Uranium Loading per FFC for Failed 61BTH Type 2 Fuel .................... T-15 Table 15 Deleted .................................................................................................................. T-16 Table 16 Deleted .................................................................................................................. T-17 Table 17 System Configurations for 61BTH Type 2 HLZCs ................................................. T-18 Table 18 BWR Minimum Enrichments as a Function of Burnup (EOS-89BTH DSC and 61BTH Type 2 DSC) ............................................................................................. T-19 Table 19 61BTH Type 2 DSC Fuel Qualification Table, All Fuel .......................................... T-20 Table 20 61BTH Type 2 DSC Fuel Qualification Table, HLZC 2, 4, 5, 6, 7, and 8, Peripheral Locations.............................................................................................. T-21 Table 21 EOS-89BTH DSC Fuel Qualification Table, All Fuel ............................................. T-22 Table 22 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125 ...... T-23 Table 23 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108 ...... T-24 Table 24 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125/135 AND Storage in the EOS-HSM .................................................. T-25 Table 25 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108 ...... T-26 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 iii

TABLE OF CONTENTS (continued) PAGE List of Figures Figure 1A Deleted .................................................................................................................... F-1 Figure 1B Heat Load Zone Configuration 2 for the EOS-37PTH DSC .................................... F-2 Figure 1C Heat Load Zone Configuration 3 for the EOS-37PTH DSC .................................... F-3 Figure 1D Heat Load Zone Configuration 4 for the EOS-37PTH DSC .................................... F-4 Figure 1E Heat Load Zone Configuration 5 for the EOS-37PTH DSC .................................... F-5 Figure 1F Heat Load Zone Configuration 6 for the EOS-37PTH DSC .................................... F-6 Figure 1G Heat Load Zone Configuration 7 for the EOS-37PTH DSC .................................... F-7 Figure 1H Heat Load Zone Configuration 8 for the EOS-37PTH DSC .................................... F-8 Figure 1I Heat Load Zone Configuration 9 for the EOS-37PTH DSC .................................... F-9 Figure 1J Deleted .................................................................................................................. F-10 Figure 1K Heat Load Zone Configuration 11 for the EOS-37PTH DSC ................................ F-11 Figure 2 EOS-89BTH DSC Heat Load Zone Configurations for transfer in the EOS-TC108.................................................................................................................... F-12 Figure 3 Peripheral (P) and Inner (I) Fuel Locations for the EOS-37PTH DSC .................. F-13 Figure 4A Heat Load Zone Configuration 1 for the 61BTH Type 2 DSC ............................... F-14 Figure 4B Heat Load Zone Configuration 2 for the 61BTH Type 2 DSC ............................... F-15 Figure 4C Heat Load Zone Configuration 3 for the 61BTH Type 2 DSC ............................... F-16 Figure 4D Heat Load Zone Configuration 4 for the 61BTH Type 2 DSC ............................... F-17 Figure 4E Heat Load Zone Configuration 5 for the 61BTH Type 2 DSC ............................... F-18 Figure 4F Heat Load Zone Configuration 6 for the 61BTH Type 2 DSC ............................... F-19 Figure 4G Heat Load Zone Configuration 7 for the 61BTH Type 2 DSC ............................... F-20 Figure 4H Heat Load Zone Configuration 8 for the 61BTH Type 2 DSC ............................... F-21 Figure 4I Heat Load Zone Configuration 9 for the 61BTH Type 2 DSC ............................... F-22 Figure 4J Heat Load Zone Configuration 10 for the 61BTH Type 2 DSC ............................. F-23 Figure 5 Location of Damaged and Failed Fuel Assemblies inside the 61BTH Type 2 DSC ....................................................................................................................... F-24 Figure 6 Peripheral (P) and Inner (I) Fuel Locations for the 61BTH Type 2 DSC ............... F-25 Figure 7 Peripheral Location Restrictions for Reconstituted Fuel with Irradiated Stainless Steel Rods for the 61BTH Type 2 DSC ................................................. F-26 Figure 8 Peripheral (P) and Inner (I) Fuel Locations for the EOS-89BTH DSC .................. F-27 Figure 9 EOS-89BTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108 ........................................................................................................... F-28 Figure 10 Empty Locations in Short-Loading Configurations for the EOS-89BTH DSC ....... F-29 Figure 11 Maximum Heat Load Configuration 1 for EOS-89BTH DSC (MHLC-89-1)

Transferred in the EOS-TC125 ............................................................................. F-30 Figure 12 Maximum Heat Load Configuration 1 for EOS-37PTH DSC (MHLC-37-1)

Transferred in the EOS-TC125/135 AND Stored in the EOS-HSM ....................... F-31 Figure 13 Damaged and Failed Fuel Configurations for the EOS-37PTH DSC .................... F-32 Figure 14 EOS-37PTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108 ........................................................................................................... F-33 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 iv

Definitions 1.1 USE AND APPLICATION Definitions


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

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

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

BLEU FUEL Blended Low Enriched Uranium (BLEU) FUEL material is generated by down-blending high enriched uranium (HEU). Because the feedstock contains both unirradiated and irradiated HEU, fresh BLEU fuel has elevated concentrations of U-232, U-234, and U-236.

CONTROL COMPONENTS (CCs) Authorized CCs include Burnable Poison Rod Assemblies (BPRAs), Thimble Plug Assemblies (TPAs), Control Rod Assemblies (CRAs), Control Element Assemblies (CEAs), Control Spiders, Rod Cluster Control Assemblies (RCCAs), Axial Power Shaping Rod Assemblies (APSRAs), Orifice Rod Assemblies (ORAs), Peripheral Power Suppression Assemblies (PPSAs), Vibration Suppression Inserts (VSIs), Flux Suppression Inserts (FSIs), Burnable Absorber Assemblies (BAAs), Neutron Source Assemblies (NSAs) and Neutron Sources. CCs not explicitly listed are also authorized as long as external materials are limited to zirconium alloys, nickel alloys, and stainless steels. Non-fuel hardware that are positioned within the fuel assembly after the fuel assembly is discharged from the core such as Guide Tubes or Instrument Tube Tie Rods or Anchors, Guide Tube Inserts, BPRA Spacer Plates or devices that are positioned and operated within the fuel assembly during reactor operation such as those listed above are also considered to be authorized CCs.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-1

Definitions 1.1 1.1 Definitions (continued)

DAMAGED FUEL DAMAGED FUEL assemblies are fuel assemblies containing fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks. The extent of damage in the fuel assembly, including non-cladding damage, is to be limited so that a fuel assembly maintains its configuration for normal and off-normal conditions.

The extent of cladding damage is also limited so that no release of pellet material is observed during inspection and handling operations in the pool prior to loading operations. DAMAGED FUEL assemblies shall also contain top and bottom end fittings. DAMAGED FUEL assemblies may also contain missing or partial fuel rods.

DRY SHIELDED An EOS-37PTH DSC, EOS-89BTH DSC, and CANISTER (DSC) 61BTH Type 2 DSC are sealed containers that provide confinement of fuel in an inert atmosphere.

FAILED FUEL FAILED FUEL is defined as ruptured fuel rods, severed fuel rods, loose fuel pellets, fuel fragments, or fuel assemblies that may not maintain configuration for normal or off-normal conditions.

FAILED FUEL may contain breached rods, grossly breached rods, or other defects such as missing or partial rods, missing grid spacers, or damaged spacers to the extent that the assembly may not maintain configuration for normal or off-normal conditions. FAILED FUEL shall be stored in a failed fuel canister (FFC).

FUEL BUILDING The FUEL BUILDING is the site-specific area or facility where the LOADING OPERATIONS take place.

FUEL CLASS A FUEL CLASS includes fuel assemblies of the same array size for a particular type of fuel design.

For example, WEV 17x17, WEO 17x17, and ANP Advanced MK BW 17x17 fuel assemblies are part of a WE 17x17 FUEL CLASS.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-2

Definitions 1.1 1.1 Definitions (continued)

HORIZONTAL An HSM is a reinforced concrete structure for STORAGE MODULE (HSM) storage of a loaded DSC at a spent fuel storage installation. Where the term HSM is used without distinction, this term shall apply to both the EOS-HSM and HSM-MX.

The term EOS-HSM refers to the base unit for storage of a single DSC as a single piece (EOS-HSM) or as a split base (EOS-HSMS).

The term MATRIX (HSM-MX) refers to the two-tiered staggered structure for storage of the DSCs.

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

(ISFSI)

INTACT FUEL Fuel assembly with no known or suspected cladding defects in excess of pinhole leaks or hairline cracks, and with no missing rods.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on a DSC in a TC while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the DSC and end when the TC is ready for TRANSFER OPERATIONS (i.e., when the cask is in a horizontal position on the transfer trailer.) LOADING OPERATIONS do not include DSC transfer between the TC and the HSM.

LOW-ENRICHED OUTLIER FUEL LOW-ENRICHED OUTLIER FUEL is PWR and (LEOF) BWR fuel with enrichments below the minimum enrichment specified in Table 7A and Table 18, respectively.

RECONSTITUTED FUEL ASSEMBLY A RECONSTITUTED FUEL ASSEMBLY is a fuel assembly where one or more fuel rods are replaced by low enriched uranium or natural uranium fuel rods or non-fuel rods.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-3

Definitions 1.1 1.1 Definitions (continued)

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI, while a DSC containing fuel assemblies is located in an HSM on the storage pad within the ISFSI perimeter.

STORAGE OPERATIONS do not include DSC transfer between the TC and the HSM.

TRANSFER CASK (TC) A TRANSFER CASK (TC) (EOS-TC108, EOS-TC125, EOS-TC135, and OS197/OS197H/OS197FC-B/OS197HFC-B) consists of a licensed NUHOMS System TC.

When used without distinction, the term EOS-TC includes the EOS-TC108, EOS-TC125, and EOS-TC135. The term OS197 includes the OS197/OS197H/OS197FC-B/OS197HFC-B. The TC is placed on a transfer trailer for movement of a DSC to the HSM.

TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities involving the movement of a TC loaded with a DSC containing fuel assemblies.

TRANSFER OPERATIONS begin after the TC has been placed horizontal on the transfer trailer ready for TRANSFER OPERATIONS and end when the DSC is at its destination and/or no longer horizontal on the transfer trailer. TRANSFER OPERATIONS include DSC transfer between the TC and the HSM.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on a DSC to unload fuel assemblies.

UNLOADING OPERATIONS begin when the DSC is no longer horizontal on the transfer trailer and end when the last fuel assembly has been removed from the DSC. UNLOADING OPERATIONS do not include DSC transfer between the HSM and the TC.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-4

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

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

BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action).

The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors.

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

EXAMPLES The following examples illustrate the use of logical connectors:

EXAMPLE 1.2-1 ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO (Limiting A.1 Verify Condition for AND Operation) not met.

A.2 Restore In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-5

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO not met. A.1 Stop OR A.2 A.2.1 Verify AND A.2.2 A.2.2.1 Reduce OR A.2.2.2 Perform OR A.3 Remove This example represents a more complicated use of logical connectors.

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

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-6

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

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO are not met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the facility is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the facility is not within the LCO Applicability.

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

EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and Changing Conditions.

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action B.1 Perform Action 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and associated B.1 Completion AND Time not met.

B.2 Perform Action 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B.2 (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-7

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES Condition B has two Required Actions. Each Required Action has its own (continued) separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

EXAMPLES EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not A.1 Restore system 7 days within limit. to within limit.

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

Completion Time AND not met.

B.2 Perform Action 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> B.2.

When a system is determined to not meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Condition A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-8

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS


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

Separate Condition entry is allowed for each component.

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

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

Completion Time AND not met.

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

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

The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis.

When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component.

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

TIME EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-9

Frequency 1.4 1.0 USE AND APPLICATION Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.

Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With a SR satisfied, SR 3.0.4 imposes no restriction.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-10

Frequency 1.4 1.4 Frequency (continued)

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

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

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

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-11

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES EXAMPLE 1.4-2 (continued)

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

The use of once indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by AND).

This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

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

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-12

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES EXAMPLE 1.4-3 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY


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

Not required to be met until 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after verifying the helium leak rate is within limit.

Verify EOS DSC vacuum drying Once after verifying the helium pressure is within limit. leak rate is within limit.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the specified Frequency. Should the vacuum drying pressure not be met immediately following verification of the helium leak rate while in LOADING OPERATIONS, this Note allows 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> to perform the Surveillance. The Surveillance is still considered to be performed within the specified Frequency.

Once the helium leak rate has been verified to be acceptable, 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, plus the extension allowed by SR 3.0.2, would be allowed for completing the Surveillance for the vacuum drying pressure. If the Surveillance was not performed within this 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> interval, there would then be a failure to perform the Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 1-13

Fuel to be Stored in the EOS-37PTH DSC 2.1 FUNCTIONAL AND OPERATING LIMITS Fuel to be Stored in the EOS-37PTH DSC PHYSICAL PARAMETERS:

FUEL CLASS Unconsolidated B&W 15x15, WE 14x14, WE 15x15, WE 17x17, CE 14x14, CE 15x15 and CE 16x16 FUEL CLASS PWR fuel assemblies (with or without CCs) that are enveloped by the fuel assembly design characteristics listed in Table 1.

Number of FUEL ASSEMBLIES with CCs 37 Maximum Fuel Assembly plus CC Weight 1900 lbs DAMAGED FUEL ASSEMBLIES:

Number and Location of DAMAGED Maximum of 8 DAMAGED FUEL Assemblies.

FUEL Assemblies Balance may be INTACT FUEL, empty cells, or dummy assemblies. Number and Location of DAMAGED FUEL assemblies are shown in Figures 1F, 1H, and 1K, and 13. The DSC basket cells which store DAMAGED FUEL assemblies are provided with top and bottom end caps.

FAILED FUEL:

Number and Location of FAILED FUEL Maximum of 4 FAILED FUEL locations. Balance may be INTACT FUEL assemblies, empty cells, or dummy assemblies. Number and Location of FAILED FUEL assemblies are shown in Figures 1F, 1H, and 1K, and 13. FAILED FUEL shall be stored in a failed fuel canister (FFC).

Maximum Uranium Loadings per FFC for Per Table 2 FAILED FUEL RECONSTITUTED FUEL ASSEMBLIES:

  • Limits for transfer in the EOS- Per Table 24 TC125/135 AND storage in the EOS-HSM
  • Limits for transfer in the EOS- 37 RECONSTITUTED FUEL ASSEMBLIES per TC125/135 AND storage in the HSM- DSC with a minimum cooling time of 2 years MX
  • Limits for transfer in the EOS-TC108 Per Table 25 (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-1

Fuel to be Stored in the EOS-37PTH DSC 2.1 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

BLENDED LOW ENRICHED URANIUM (BLEU) FUEL Assemblies:

  • Number of BLEU FUEL Assemblies 37 per DSC THERMAL PARAMETERS:

Maximum Heat Load Configuration Per Figures 1B, 1C, 1D, 1E AND 1F for transfer in the (MHLC) and Decay Heat Calculations EOS-TC108 and storage in EOS-HSM.

Per Figures 1G, 1H AND 1I for transfer in the EOS-TC108 /TC125/TC135 and storage in HSM-MX.

Per Figure 1K for transfer in the EOS-TC108 and storage in HSM-MX.

Per Figure 12, which specifies maximum allowable heat loads in a six-zone configuration, for transfer in the EOS-TC125/TC135 and storage in the EOS-HSM.

Heat load zoning configurations (HLZCs) enveloped by the MHLC in Figure 12 are allowed for transfer in the EOS-TC125/TC135 and storage in the EOS-HSM. Chapter 2, Section 2.4.3.2 of the UFSAR provides the specific HLZCs.

The maximum allowable heat loads may be reduced based on the thermal analysis methodology in the UFSAR to accommodate site-specific conditions. However, the maximum decay heat for each FA shall not exceed the values specified in the aforementioned figures.

The licensee is responsible for ensuring that uncertainties in fuel enrichment and burnup are correctly accounted for in the decay heat calculations.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-2 All Indicated Changes are Enclosure 9, Item 8

Fuel to be Stored in the EOS-37PTH DSC 2.1 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

THERMAL PARAMETERS (continued) For FAs with active fuel length shorter than 144 inches, reduce the maximum heat load per FA in each loading zone of the HLZCs using a scaling factor (SF) as shown below.

qShort FA = q Bounding FA SF ,

La ,Short FA k eff ,Short FA SF = .

La ,Bounding FA k eff ,Bounding FA Where, keff= Effective conductivity for FA, q = Decay heat load per assembly defined for each loading zone, La= Active fuel length, SF= Scaling factor (SF) for short FAs.

The effective conductivity for the shorter FA should be determined using the same methodology documented in the UFSAR.

For FAs with active fuel length greater than 144 inches, no scaling is required and the maximum heat loads listed for each HLZC are applicable.

Decay Heat per DSC 50.0 kW and as specified for the applicable heat load zone configuration (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-3

Fuel to be Stored in the EOS-37PTH DSC 2.1 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

RADIOLOGICAL PARAMETERS:

Maximum Assembly Average Burnup 62 GWd/MTU Minimum Cooling Time For all fuel to be stored in the HSM-MX, minimum cooling time as a function of burnup and enrichment per Table 7B.

For all fuel to be stored in the EOS-HSM, minimum cooling time as a function of burnup and enrichment per Table 7C.

1 year for the EOS-TC125/135 2 years for the EOS-TC108 Minimum Assembly Average Initial Fuel As specified in Table 7A as a function of assembly Enrichment average burnup.

Maximum Planar Average Initial Fuel As specified in Table 4 as a function of minimum Enrichment soluble boron concentration Minimum B-10 Concentration in Poison As specified in Table 5 Plates Number and location of LOW-ENRICHED 4 LEOF in the peripheral locations. A minimum OUTLIER FUEL (LEOF) of three non-LEOFs shall circumferentially separate LEOFs within the peripheral locations.

No limitation for LEOF in the inner locations. The peripheral and inner locations are defined in Figure 3.

CONTROL COMPONENTS (CCs)

Maximum Co-60 equivalent activity for the As specified in Table 3 CCs.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-4

Fuel to be Stored in the EOS-89BTH DSC 2.2 2.0 FUNCTIONAL AND OPERATING LIMITS Fuel to be Stored in the EOS-89BTH DSC PHYSICAL PARAMETERS:

INTACT unconsolidated 7x7, 8x8, 9x9, 10x10, FUEL CLASS and 11x11 FUEL CLASS BWR assemblies (with or without channels) that are enveloped by the fuel assembly design characteristics listed in Table 6.

NUMBER OF INTACT FUEL 89 ASSEMBLIES Channel Hardware Channeled fuel may be stored with or without associated channel hardware.

Maximum Uranium Loading 198 kg/assembly Maximum Fuel Assembly Weight with a 705 lb Channel RECONSTITUTED FUEL ASSEMBLIES:

  • Limits for transfer in the EOS-TC125 Per Table 22
  • Limits for transfer in the EOS-TC108 Per Table 23 BLENDED LOW ENRICHED URANIUM (BLEU) FUEL ASSEMBLIES:
  • Number of BLEU FUEL Assemblies 89 per DSC (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-5

Fuel to be Stored in the EOS-89BTH DSC 2.2 2.2 Fuel to be Stored in the EOS-89BTH DSC (continued)

THERMAL PARAMETERS:

Maximum Heat Load Configuration Per Figure 2 for transfer in the EOS-TC108.

(MHLC) and Decay Heat Calculations Per Figure 11, which specifies maximum allowable heat loads in a six-zone configuration, for transfer in the EOS-TC125.

Heat load zoning configurations (HLZCs) enveloped by the MHLC in Figure 11 are allowed for transfer in the EOS-TC125 and storage in the EOS-HSM or HSM-MX. Chapter 2, Section 2.4.3.2 of the UFSAR provides the specific HLZCs.

The maximum allowable heat loads may be reduced based on the thermal analysis methodology in the UFSAR. However, the maximum decay heat for each FA shall not exceed the values specified in Figure 11.

The licensee is responsible for ensuring that uncertainties in fuel enrichment and burnup are correctly accounted for in the decay heat calculations.

For FAs with active fuel length shorter than 144 inches, reduce the maximum decay heat for each FA in each loading zone of the HLZCs using a scaling factor (SF) as shown below.

qShort FA = q Bounding FA SF ,

La ,Short FA k eff ,Short FA SF = .

La ,Bounding FA k eff ,Bounding FA Where, keff = Effective conductivity for FA, q = Decay heat load per assembly defined for each loading zone, La = Active fuel length, SF = Scaling factor for short FAs.

The effective conductivity for the shorter FA should be determined using the same methodology documented in the UFSAR.

For FAs with active fuel length greater than 144 inches, no scaling is required and the maximum heat loads listed for each HLZC are applicable.

Decay Heat per DSC 48.2 kW for EOS-TC125 41.6 kW for EOS-TC108 (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-6

Fuel to be Stored in the EOS-89BTH DSC 2.2 2.2 Fuel to be Stored in the EOS-89BTH DSC continued)

RADIOLOGICAL PARAMETERS:

Maximum Assembly Average Burnup 62 GWd/MTU Minimum Cooling Time As specified as a function of burnup and enrichment per Table 21.

1.0 year for EOS-TC125 3.0 years for EOS-TC108; See Figure 2 for additional cooling times for HLZC 2 and 3 transferred in the EOS-TC108.

Maximum Lattice Average Initial Fuel Per Table 8 Enrichment Minimum B-10 Concentration in Poison Per Table 8 Plates Minimum Assembly Average Initial As specified in Table 18 as a function of assembly Fuel Enrichment average burnup.

Number and location of LOW- 4 LEOF in the peripheral locations. A minimum ENRICHED OUTLIER FUEL (LEOF) of six non-LEOFs shall circumferentially separate LEOFs within the peripheral locations. No limitation for LEOF in the inner locations. The peripheral and inner locations are defined in Figure 8.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-7

Fuel to be stored in the 61BTH Type 2 DSC 2.3 2.0 FUNCTIONAL AND OPERATING LIMITS Fuel to be stored in the 61BTH Type 2 DSC PHYSICAL PARAMETERS:

FUEL CLASS INTACT or DAMAGED or FAILED 7x7, 8x8, 9x9, 10x10 or 11x11 BWR assemblies (with or without channels) that are enveloped by the fuel assembly design characteristics listed in Table 13 Number of INTACT FUEL ASSEMBLIES 61 Channel Hardware Chaneled fuel may be stored with or without associated channel hardware.

Maximum Uranium Loading 198 kg/ assembly Maximum Fuel Assembly Weight with a 705 lbs Channel DAMAGED FUEL ASSEMBLIES:

Number and Location of DAMAGED Maximum of 61 DAMAGED FUEL assemblies as FUEL Assemblies shown in Figure 5. Balance may be INTACT FUEL, empty cells, or dummy assemblies. The DSC basket cells which store DAMAGED FUEL assemblies are provided with top and bottom end caps.

FAILED FUEL:

Number and Location of FAILED FUEL Maximum of 4 FAILED FUEL locations as shown in Figure 5 Balance may be INTACT FUEL assemblies, empty cells, or dummy assemblies. FAILED FUEL shall be stored in a failed fuel canister (FFC)

Maximum Uranium Loadings per FFC for Table 14 FAILED FUEL RECONSTITUTED FUEL ASSEMBLIES:

  • Number of RECONSTITUTED FUEL 61 ASSEMBLIES per DSC
  • Maximum number of irradiated 120 stainless steel rods per DSC (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-8

Fuel to be stored in the 61BTH Type 2 DSC 2.3

  • Maximum number of irradiated 10 stainless steel rods per RECONSTITUTED FUEL ASSEMBLY
  • Loading restrictions for locations Inner and peripheral loading locations are defined within the basket in Figure 6.

Inner Loading Locations:

  • RECONSTITUTED FUEL ASSEMBLIES may be loaded in any compartment within the inner locations.

Peripheral Loading Locations:

  • RECONSTITUTED FUEL ASSEMBLIES with 5 irradiated stainless steel rods per fuel assembly may be loaded into all peripheral locations (i.e., not restricted).
  • RECONSTITUTED FUEL ASSEMBLIES with

> 5 and 10 irradiated stainless steel rods per fuel assembly shall have at least one fuel assembly that does not contain irradiated stainless steel rods on each peripherally adjacent location (see Figure 7).

BLENDED LOW ENRICHED URANIUM (BLEU) FUEL Assemblies:

  • Number of BLEU FUEL Assemblies 61 per DSC THERMAL/RADIOLOGICAL PARAMETERS:

Heat Load Zone Configuration and Fuel Limitations on decay heats are presented in the Qualification respective HLZC tables in Figures 4A through 4J.

Maximum Assembly Average Burnup 62 GWd/MTU Minimum Cooling Time For all fuel, minimum cooling time as a function of burnup and enrichment per Table 19.

For the peripheral fuel of HLZC 2, 4, 5, 6, 7, and 8 only, minimum cooling time as a function of burnup and enrichment per Table 20. The peripheral and inner locations are defined in Figure 6.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-9

Fuel to be stored in the 61BTH Type 2 DSC 2.3 Minimum Assembly Average Initial Fuel As specified in Table 18 as a function of assembly Enrichment average burnup.

Decay Heat per DSC 31.2 kW Maximum Lattice Average Initial Per Table 9, Table 10, Table 11 or Table 12 Enrichment Minimum B-10 Concentration in Poison Per Table 9, Table 10, Table 11 or Table 12 Plates Number and location of LOW-ENRICHED 4 LEOF in the peripheral locations. A minimum OUTLIER FUEL (LEOF) of five non-LEOFs shall circumferentially separate LEOFs within the peripheral locations. No limitation for LEOF in the inner locations. The peripheral and inner locations are defined in Figure 6.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-10

Functional and Operating Limits Violations 2.4 2.0 FUNCTIONAL OPERATING LIMITS Functional and Operating Limits Violations If any Functional and Operating Limit of 2.1 or 2.2 or 2.3 is violated, the following ACTIONS shall be completed:

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

2.4.2 Within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, notify the NRC Operations Center.

2.4.3 Within 60 days, submit a special report which describes the cause of the violation and the ACTIONS taken to restore compliance and prevent recurrence.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 2-11

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

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

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

LCO 3.0.3 Not applicable to a spent fuel storage cask.

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

Exceptions to this Specification are stated in the individual Specifications.

These exceptions allow entry into specified conditions in the Applicability when the associated ACTIONS to be entered allow operation in the specified condition in the Applicability only for a limited period of time.

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

LCO 3.0.6 Not applicable to a spent fuel storage cask.

LCO 3.0.7 Not applicable to a spent fuel storage cask.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-1

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

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

For Frequencies specified as once, the above interval extension does not apply. If a Completion Time requires periodic performance on a once per . . . basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance.

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

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

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

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-2

DSC Fuel Integrity 3.1 DSC Fuel Integrity Fuel Integrity during Drying LCO 3.1.1 Medium:

Helium shall be used for cover gas during drainage of bulk water (blowdown or draindown) from the DSC.

Pressure:

The DSC vacuum drying pressure shall be sustained at or below 3 Torr (3 mm Hg) absolute for a period of at least 30 minutes following evacuation.

APPLICABILITY: During LOADING OPERATIONS but before TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A. If the required vacuum A.1 30 days drying pressure cannot be obtained.

A.1.1 Confirm that the vacuum drying system is properly installed. Check and repair the vacuum drying system as necessary.

OR A.1.2 Establish helium pressure of at least 0.5 atm and no greater than 15 psig in the DSC.

OR A.2 Flood the DSC with 30 days spent fuel pool water or water meeting the requirements of LCO 3.2.1, if applicable, submerging all fuel assemblies.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-3

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1 Verify that the DSC vacuum drying Once per DSC, after an acceptable pressure is less than or equal to 3 Torr NDE of the inner top cover plate to (3 mm Hg) absolute for at least 30 DSC shell weld.

minutes following evacuation.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-4

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

DSC Helium Backfill Pressure LCO 3.1.2 DSC helium backfill pressure shall be 2.5 +/- 1 psig (stable for 30 minutes after filling) after completion of vacuum drying.

APPLICABILITY: During LOADING OPERATIONS but before TRANSFER OPERATIONS.

ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME


NOTE ----------------- A.1 30 days Not applicable until SR 3.1.2 is performed.

A.1.1 Maintain helium atmosphere


in the DSC cavity.

A. The required backfill AND pressure cannot be A.1.2 Confirm, check and repair obtained or stabilized.

or replace as necessary the vacuum drying system, helium source and pressure gauge.

AND A.1.3 Check and repair, as necessary, the seal weld between the inner top cover plate and the DSC shell.

OR A.2 Establish the DSC helium 30 days backfill pressure to within the limit. If pressure exceeds the criterion, release a sufficient quantity of helium to lower the DSC cavity pressure within the limit.

OR (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-5

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

COMPLETION CONDITION REQUIRED ACTION TIME A.3 Flood the DSC with spent 30 days fuel pool water or water meeting the requirements of LCO 3.2.1, if applicable, submerging all fuel assemblies.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify that the DSC helium backfill pressure is Once per DSC, after the 2.5 +/- 1 psig stable for 30 minutes after filling. completion of SR 3.1.1 requirement.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-6

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

Time Limit for Completion of DSC Transfer LCO 3.1.3 The time to transfer the DSC to the HSM shall be within the limits.

Additionally, if the DSC and HLZC combination result in a time limit for completion of transfer from the table below, the air circulation system shall be assembled and be verified to be operable within 7 days before commencing the TRANSFER OPERATIONS of the loaded DSC.

TIME LIMITS DSC MODEL APPLICABLE HLZC (HOURS)

EOS-37PTH HLZCs qualified per Figure 12 8(1)

EOS-37PTH HLZC 3 No Limit EOS-37PTH HLZC 1, 2, or 4-11 8(1) (2)

EOS-89BTH HLZCs qualified per Figure 11 8(1)

EOS-89BTH HLZC 2 10(1)(3)

EOS-89BTH HLZC 3 No Limit(3) 61BTH Type 2 HLZC 1, 2, 3, 4, or 9 No limit 61BTH Type 2 5, 6, or 8 23 61BTH Type 2 7 or 10 10


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

1. The time limit for completion of a DSC transfer is defined as the time elapsed in hours after the initiation of draining of TC/DSC annulus water until the completion of insertion of the DSC into the HSM. For transfer of an EOS-DSC, the time limit for transfer operations is determined based on the EOS-37PTH DSC in EOS-TC125 with the maximum allowable heat load of 50 kW or EOS-89BTH DSC in EOS-TC125 with the maximum allowable heat load of 48.2 kW. If the maximum heat load of a DSC is less than 50 kW for EOS-37PTH DSC or 48.2 kW for the EOS-89BTH DSC, a new time limit can be determined to provide additional time for transfer operations. The calculated time limit shall not be less than the time limit specified in LCO 3.1.3. The calculation should be performed using the same methodology documented in the UFSAR.
2. HLZC 2, 4-6 (shown in Figures 1B, 1D-1F) time limits apply for the EOS-37PTH DSC transferred in the EOS-TC108 only. HLZC 7-9 time limits apply for storage in the HSM-MX. If transferring the EOS-37PTH with HLZC 2, 4-6, or 11 in the EOS-TC125 and storing in the EOS-HSM, the limits for Figure 12 apply. Time limits also apply for HLZC 1, 2, and 4-11 when storing WE 14 x 14.
3. HLZC 2 and 3 (shown in Figure 2) time limits apply for the EOS-89BTH transferred in the EOS-TC108 only. If transferring the EOS-89BTH with HLZC 2 or 3 in the EOS-TC125, the limits for Figure 11 apply.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-7

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

APPLICABILITY: During LOADING OPERATIONS AND TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME


NOTE ------------------- A.1 If the TC is in the cask 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> handling area in a Not applicable until SR 3.1.3 is vertical orientation, performed.

remove the TC top


cover plate and fill the A. The required time limit for TC/DSC annulus with completion of a DSC transfer clean water.

not met. OR A.2 If the TC is in a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (1) (2) horizontal orientation on the transfer skid, initiate air circulation in the TC/DSC annulus by starting one of the redundant blowers.

OR A.3 Return the TC to the 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> (1) (2) cask handling area and follow required action A.1 above.

1. For EOS-37PTH and EOS-89BTH DSCs: If Required Action A.2 is initiated, run the blower for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. After the blower is turned off, the time limit for completion of DSC transfer is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If Required Action A.2 fails to complete within one hour, follow Required Action A.3 for the time remaining in the original Required Action A.3 completion time of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The minimum duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to run the blower and the time limit of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the blower is turned off for completion of the transfer operations are determined based on the EOS-37PTH DSC in EOS-TC125 with the maximum allowable heat load of 50 kW or EOS-89BTH DSC in EOS-TC125 with the maximum allowable heat load of 48.2 kW. If the maximum heat load of a DSC is less than 50 kW for EOS-37PTH DSC or 48.2 kW for the EOS-89BTH DSC, new time limits can be determined to provide additional time for these transfer operations. The calculated time limits shall not be less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for completion of transfer operation after the blower is turned off. The calculation should be performed using the same methodology documented in the UFSAR.
2. For 61BTH Type 2 DSC: If Required Action A.2 is initiated, run the blower for a minimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. After the blower is turned off, the time limit for completion of DSC transfer is 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. If Required Action A.2 fails to complete within one hour, follow Required Action A.3 for the time remaining in the original Required Action A.3 completion time of 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The minimum duration of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to run the blower and the time limit of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> after the blower is turned off for completion of the transfer operations are determined based on the 61BTH Type 2 DSC in OS197FC-B TC with the maximum allowable heat load of 31.2 kW. If the maximum heat load of a DSC is less than 31.2 kW, new time limits can be determined to provide additional time for these transfer operations. The calculated time limits shall not be less than 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for completion of transfer operation after the blower is turned off. The calculation should be performed using the same methodology documented in the UFSAR.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-8

DSC Fuel Integrity 3.1 3.1 DSC Fuel Integrity (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3 Verify that the time limit for completion of Once per DSC, after the initiation of DSC transfer is met. draining of TC/DSC annulus water.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-9

Cask Criticality Control 3.2 Cask Criticality Control Soluble Boron Concentration LCO 3.2.1 The boron concentration of the spent fuel pool water and the water added to the cavity of a loaded EOS-37PTH DSC shall be at least the boron concentration shown in Table 4 for the basket type and fuel enrichment selected.

APPLICABILITY: During LOADING and UNLOADING OPERATIONS with fuel and liquid water in the EOS-37PTH DSC cavity.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A. Soluble boron concentration A.1 Suspend loading of fuel Immediately limit not met. assemblies into DSC.

AND A.2 A.2.1 Add boron and re- Immediately sample, and test the concentration until the boron concentration is shown to be at least that required.

OR A.2.2 Remove all fuel Immediately assemblies from DSC.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-10

Cask Criticality Control 3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify soluble boron concentration limit Within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> before insertion of the in spent fuel pool water and water to be first fuel assembly into the DSC.

added to the DSC cavity is met using AND two independent measurements (two samples analyzed by different Every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter while the individuals) for LOADING DSC is in the spent fuel pool or until OPERATIONS. the fuel has been removed from the DSC.

SR 3.2.1.2 Verify soluble boron concentration limit Once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> prior to flooding in spent fuel pool water and water to be DSC during UNLOADING added to the DSC cavity is met using OPERATIONS.

two independent measurements (two AND samples analyzed by different individuals) for UNLOADING Every 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter while the OPERATIONS. DSC is in the spent fuel pool or until the fuel has been removed from the DSC.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-11

Radiation Protection 3.3 Radiation Protection DSC and TRANSFER CASK (TC) Surface Contamination LCO 3.3.1 Removable surface contamination on the outer top 1 foot surface of the DSC AND the exterior surfaces of the TC shall not exceed:

a. 2,200 dpm/100 cm2 from beta and gamma sources; and
b. 220 dpm/100 cm2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS ACTIONS:


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

Separate condition entry is allowed for each DSC and TC.

CONDITION REQUIRED ACTION COMPLETION TIME A. Top 1 foot exterior surface of A.1 Decontaminate the DSC Prior to TRANSFER the DSC removable surface to bring the removable OPERATIONS contamination limits not met. contamination to within limits.

B. TC removable surface B.1 Decontaminate the TC Prior to TRANSFER contamination limits not met. to bring the removable OPERATIONS contamination to within limits EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-12

Radiation Protection 3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify that the removable contamination Once, prior to TRANSFER on the top 1 foot exterior surface of the OPERATIONS.

DSC is within limits.

SR 3.3.1.2 Verify by either direct or indirect methods Once, prior to TRANSFER that the removable contamination on the OPERATIONS.

exterior surfaces of the TC is within limits.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 3-13

Design Features 4.0 DESIGN FEATURES The specifications in this section include the design characteristics of special importance to each of the physical barriers and to the maintenance of safety margins in the NUHOMS EOS System design.

Site 4.1.1 Site Location Because this UFSAR is prepared for a general license, a discussion of a site-specific ISFSI location is not applicable.

Storage System Features 4.2.1 Storage Capacity The total storage capacity of the ISFSI is governed by the plant-specific license conditions.

4.2.2 Storage Pad For sites for which soil-structure interaction is considered important, the licensee is to perform site-specific analysis considering the effects of soil-structure interaction.

Amplified seismic spectra at the location of the HSM center of gravity (CG) is to be developed based on the soil-structure interaction (SSI) responses. EOS-HSM seismic analysis for the reinforced concrete EOS-HSM (EOS-HSM-RC) information is provided in UFSAR Appendix 3.9.4, Section 3.9.4.9.2. The steel-plate composite EOS-HSM (EOS-HSM-SC) seismic analysis information is provided in UFSAR Appendix 3.9.8, Section 3.9.8.9. HSM-MX seismic analysis information is provided in UFSAR Appendix A.3.9.4, Section A.3.9.4.9.2.

The storage pad location shall have no potential for liquefaction at the site-specific safe shutdown earthquake (SSE) level.

Additional requirements for the pad configuration are provided in Technical Specification 4.5.2.

Canister Criticality Control The NUHOMS EOS-37PTH DSC is designed for the storage of PWR fuel assemblies with a maximum planar average initial enrichment of less than or equal to 5.0 wt. %

U-235 taking credit for soluble boron during LOADING OPERATIONS and the boron content in the poison plates of the DSC basket. The EOS-37PTH DSC uses a boron carbide/aluminum metal matrix composite (MMC) poison plate material. The EOS-37PTH DSC has two different neutron poison loading options, A and B, based on the boron content in the poison plates as listed in Table 5. Table 4 also defines the requirements for boron concentration in the DSC cavity water as a function of the DSC basket type for the various FUEL CLASSES authorized for storage in the EOS-37PTH DSC.

The NUHOMS EOS-89BTH DSC is designed for the storage of BWR fuel assemblies with a maximum lattice average initial enrichment of less than or equal to 5.00 wt. %

U-235 taking credit for the boron content in the poison plates of the DSC basket. There are three neutron poison loading options specified for the EOS-89BTH DSC depending on the type of poison material and the B-10 areal density in the plates, as specified in Table 8.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-1

Design Features 4.0 4.0 Design Features (continued)

The 61BTH Type 2 DSC is designed for the storage of BWR fuel assemblies with a maximum lattice average initial enrichment of less than or equal to 5.0 wt. % U-235 taking credit for the boron content in the poison plates of the DSC basket. The 61BTH Type 2 DSC has multiple basket configurations based on the absorber material type (borated aluminum alloy, metal matrix composite (MMC), or Boral) and boron content in the absorber plates as listed in Table 9 through Table 12.

4.3.1 Neutron Absorber Tests The neutron absorber used for criticality control in the DSC baskets may be one of the following materials:

Boron carbide/MMC BORAL (EOS-89BTH or 61BTH Type 2 DSCs only)

Borated aluminum (61BTH Type 2 DSC only)

Acceptance Testing (MMC, BORAL, and borated aluminum)

B-10 areal density is verified by neutron attenuation testing or by chemical analysis of coupons taken adjacent to finished panels, and isotopic analysis of the boron carbide powder. The minimum B-10 areal density requirements are specified in Table 5 for EOS-37PTH, Table 8 for EOS-89BTH, and Table 9 through Table 12 for 61BTH Type 2 DSCs.

Finished panels are subject to visual and dimensional inspection.

Qualification Testing (MMC only)

MMCs are qualified for use in the NUHOMS EOS System by verification of the following characteristics.

The chemical composition is boron carbide particles in an aluminum alloy matrix.

The form is with or without an aluminum skin.

The median boron carbide particle size by volume is 80 microns with no more than 10% over 100 microns.

The boron carbide content is 50% by volume.

The porosity is 3%.

4.3.2 High Strength Low Alloy Steel for Basket Structure for EOS-37PTH and EOS-89BTH DSCs.

The basket structural material shall be a high strength low alloy (HSLA) steel meeting one of the following requirements A, B, or C:

A. ASTM A829 Gr 4130 or AMS 6345 SAE 4130, quenched and tempered at not less than 1050°F, 103.6 ksi minimum yield strength and 123.1 ksi minimum ultimate strength at room temperature.

B. ASME SA-517 Gr A, B, E, F, or P.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-2

Design Features 4.0 4.0 Design Features (continued)

C. Other HSLA steel, with the specified heat treatment, meeting these qualification and acceptance criteria:

i. If quenched and tempered, the tempering temperature shall be at no less than 1000 °F, ii. Qualified prior to first use by testing at least two lots and demonstrating that the fracture toughness value KJIc 150 ksi in at -40 °F with 95%

confidence.

iii. Qualified prior to first use by testing at least two lots and demonstrating that the 95% lower tolerance limit of yield strength and ultimate strength the values in UFSAR Table 8-10.

iv. Meet production acceptance criteria based on the 95% lower tolerance limit of yield strength and ultimate strength at room temperature as determined by qualification testing described in Section 4.3.2.C.iii.

The basket structural material shall also meet one of the following production acceptance criteria for impact testing at -40 °F:

a. Charpy testing per ASTM A370, minimum absorbed energy 25 ft-lb average, 20 ft-lb lowest of three (for sub-size specimens, reduce these criteria per ASTM A370-17 Table 9), or
b. Dynamic tear testing per ASTM E604 with acceptance criterion minimum 80%

shear fracture appearance.

Codes and Standards 4.4.1 HORIZONTAL STORAGE MODULE (HSM)

The reinforced concrete HSM is designed in accordance with the provisions of ACI 349-

06. The steel-plate composite HSM steel is designed in accordance with the provisions of ANSI/AISC N690-18. The steel-plate composite HSM concrete is designed and constructed in accordance with ACI 318-08. Code alternatives are discussed in Technical Specification 4.4.4. Load combinations specified in ANSI 57.9-1984, Section 6.17.3.1 are used for combining normal operating, off-normal, and accident loads for the HSM.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-3

Design Features 4.0 4.0 Design Features (continued) 4.4.2 DRY SHIELDED CANISTER (DSC) (EOS-37PTH, EOS-89BTH, and 61BTH Type 2)

The DSC confinement boundary is designed, fabricated and inspected to the maximum practical extent in accordance with ASME Boiler and Pressure Vessel Code Section III, Division 1, Subsection NB, NF, and NG, for Class 1 components. The ASME code edition years and any addenda for the various DSC types and relevant subsections are provided in the table below. Code alternatives are discussed in Technical Specification 4.4.4.

DSC Type Applicable Code Edition/Year EOS-37PTH, ASME B&PV Code,Section III, Division 1, 2010 Edition with EOS-89BTH Subsection NB Addenda through 2011 61BTH Type 2 ASME B&PV Code,Section III, Division 1, 1998 Edition with Subsections NB, NG and NF Addenda through 2000 4.4.3 TRANSFER CASK The EOS-TC design stress analysis and OS197 design stress analysis and fabrication, exclusive of the trunnions and the neutron shield enclosures, is performed in accordance with applicable codes as provided in the table below. The stress allowables for the upper trunnions for the EOS-TCs and the upper and lower trunnions for the OS197 conform to ANSI N14.6-1993 for single-failure-proof lifting.

TC Applicable Code Edition/Year EOS-TC ASME B&PV Code, 2010 Edition with Section III, Division 1, Addenda through 2011 Subsection NF for Class 1 supports OS197 ASME B&PV Code, 1983 Edition with Winter Section III, Division 1, 1985 Addenda Subsection NC for Class 2 vessels 4.4.4 Alternatives to Codes and Standards ASME Code alternatives for the EOS-37PTH, EOS-89BTH DSC, and 61BTH Type 2 DSC are listed below:

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-4

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB REFERENCE ASME CODE JUSTIFICATION AND COMPENSATORY CODE REQUIREMENT MEASURES SECTION/ARTICLE NCA All Not compliant with NCA NB-1100 Requirements for The canister shell, the inner top cover, the inner bottom Code Stamping of cover or bottom forging assembly, the outer top cover, Components and the drain port cover and vent port plug are designed and fabricated in accordance with the ASME Code,Section III, Subsection NB to the maximum extent practical. However, Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp, or to be ASME Certified.

NB-2121 Permitted Material Type 2205 and UNS S31803 are duplex stainless Specifications steels that provide enhance resistance to chloride-induced stress corrosion cracking. They are not included in Section II, Part D, Subpart 1, Tables 2A and 2B. UNS S31803 has been accepted for Class 1 components by ASME Code Case N-635-1, endorsed by NRC Regulatory Guide 1.84. Type 2205 falls within the chemical and mechanical requirements of UNS S31803. Normal and off-normal temperatures remain below the 600 °F operating limit. Accident conditions may exceed this limit, but only for durations too short to cause embrittlement.

NB-2130 Material must be Material is certified to meet all ASME Code criteria but supplied by ASME is not eligible for certification or Code Stamping if a approved material non-ASME fabricator is used. As the fabricator is not suppliers required to be ASME certified, material certification to NB-2130 is not possible. Material traceability and NB-4121 Material Certification certification are maintained in accordance with the by Certificate Holder NRC approved QA program associated with CoC 1042.

NB-2300 Fracture toughness Type 2205 and UNS S31803 duplex stainless steels requirements for are tested by Charpy V-notch only per NB-2300. Drop material weight tests are not required. Impact testing is not required for the vent port plug.

NB-2531 Drain port cover; SA-578 applies to 3/8" and thicker plate only; allow straight beam alternate UT techniques to achieve meaningful UT ultrasonic testing results.

(UT) per SA-578 for all plates for vessel NB- 2531 and NB-2541 Vent port plug UT This plug may be made from plate or bar. Due to its and liquid penetrant small area, it has no structural function. It is leak testing (PT) tested along with the inner top cover plate after welding. Therefore, neither UT nor PT are required.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-5

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB (continued)

REFERENCE CODE JUSTIFICATION AND COMPENSATORY ASME CODE REQUIREMENT MEASURES SECTION/ARTICLE NB-4243 and NB-5230 Category C weld The shell to the outer top cover plate (OTCP) weld, the joints in vessels and shell to the inner top cover weld, and the drain port similar weld joints in cover and vent port plug welds are all partial other components penetration welds. The cover-to-shell welds are shall be full designed to meet the guidance provided in NUREG-penetration joints. 1536, Revision 1 for the stress reduction factor.

These welds shall be Nondestructive examination (NDE) is done by qualified examined by UT or personnel, in accordance with Section V and the radiographic testing acceptance standards of Section III, Subsection NB-(RT) and either PT or 5000, except as noted for OTCP weld option 2 magnetic particle ultrasonic examination.

testing (MT). As an alternative to the NDE requirements of NB-5230 for Category C welds, all of these closure welds will be multi-layer welds and receive a root and final PT examination, except for the shell to the OTCP weld.

OTCP weld option 1 The shell to OTCP weld will be a multi-layer weld and receive multi-level PT examination in accordance with the guidance provided in NUREG 1536 Revision 1 for NDE. The multi-level PT examination provides reasonable assurance that flaws of interest will be identified.

OTCP weld option 2 The shell to the outer top cover plate weld will be examined by UT.

NB-5330 Ultrasonic The UT acceptance criteria for OTCP weld option 2 Acceptance are:

Standards 1. Rounded flaws are evaluated by the acceptance criteria of NB-5331(a).

2. Planar flaws are allowable up to the limit (W - hi)

D at any location, where hi is the sum of the depth of aligned planar defects, W is the measured weld thickness, and D is the minimum weld depth required by NB-3000.

3. Planar flaws that penetrate the surface of the weld are not allowable.

NB-5520 NDE Personnel must Permit use of the Recommended Practice SNT-TC-1A be qualified to the up to the edition as cited in Table NCA-7000-1 of the 2006 edition of SNT- latest ASME Code edition listed in 10 CFR 50.55a at TC-1A the time of construction.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-6

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB (continued)

REFERENCE CODE JUSTIFICATION AND COMPENSATORY ASME CODE REQUIREMENT MEASURES SECTION/ARTICLE NB-6000 All completed The DSC is not a complete or installed pressure pressure retaining vessel until the top closure is welded following systems shall be placement of fuel assemblies within the DSC. Due to pressure tested the inaccessibility of the shell and lower end closure welds following fuel loading and top closure welding, as an alternative, the pressure testing of the DSC is performed in two parts. The DSC shell, shell bottom, including all longitudinal and circumferential welds, is pneumatically tested and examined at the fabrication facility when using the three plate bottom assembly.

If using a single piece bottom forging, the fabrication pressure test may be waived although the helium leak test requirement remains in place. The low test pressure test does not stress a single piece bottom and bottom-to-shell weld sufficiently to cause pre-existing defects to propagate into leaks. For the purpose of finding leaks, the helium leak test is far more sensitive than the pressure test.

The shell to the inner top cover closure weld is pressure tested and examined for leakage in accordance with NB-6300 in the field.

The drain port cover and vent port plug welds will not be pressure tested; these welds and the shell to the inner top cover closure weld are helium leak tested after the pressure test.

Per NB-6324 the examination for leakage shall be done at a pressure equal to the greater of the design pressure or three-fourths of the test pressure. As an alternative, if the examination for leakage of these field welds, following the pressure test, is performed using helium leak detection techniques, the examination pressure may be reduced to 1.5 psig.

This is acceptable given the significantly greater sensitivity of the helium leak detection method.

NB-7000 Overpressure No overpressure protection is provided for the Protection EOS-37PTH or EOS-89BTH DSC. The function of the DSC is to contain radioactive materials under normal, off-normal, and hypothetical accident conditions postulated to occur during transportation.

The DSC is designed to withstand the maximum internal pressure considering 100% fuel rod failure at maximum accident temperature.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-7

Design Features 4.0 4.0 Design Features (continued)

EOS-37PTH and EOS-89BTH DSC ASME Code Alternatives, Subsection NB (continued)

NB-8000 Requirements for The EOS-37PTH and EOS-89BTH DSC are stamped nameplates, or engraved with the information required by 10 CFR stamping and reports Part 72. Code stamping is not required for these per NCA-8000 DSCs. QA Data packages are prepared in accordance with requirements of the NRC approved QA program associated with CoC 1042.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-8

Design Features 4.0 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Confinement Boundary REFERENCE ASME ALTERNATIVES, JUSTIFICATION & COMPENSATORY CODE SECTION/ CODE REQUIREMENT MEASURES ARTICLE NCA All Not compliant with NCA. Quality Assurance is provided according to 10 CFR Part 72 Subpart G in lieu of NCA-4000.

NCA-1140 Use of Code editions and Code edition and addenda other than those specified in Section addenda 4.4.2 may be used for construction, but in no case earlier than 3 years before that specified in the Section 4.4.2 table.

Materials produced and certified in accordance with ASME Section II material specification from Code Editions and Addenda other than those specified in Section 4.4.2 may be used, so long as the materials meet all the requirements of Article 2000 of the applicable Subsection of the Section III Edition and Addenda used for construction.

NB-1100 Requirements for Code Code Stamping is not required. As Code Stamping is not required, Stamping of Components, the fabricator is not required to hold an ASME N or NPT stamp, Code reports and or to be ASME Certified.

certificates, etc.

NB-1132 Attachments with a pressure Bottom shield plug and outer bottom cover plate are outside code retaining function, including jurisdiction; these components together are much larger than stiffeners, shall be required to provide stiffening for the inner bottom cover plate; the considered part of the weld that retains the outer bottom cover plate and with it the bottom component. shield plug is subject to root and final PT examination.

NB-2130 Material must be supplied Material is certified to meet all ASME Code criteria but is not eligible by ASME approved material for certification or Code Stamping if a non-ASME fabricator is used.

suppliers. As the fabricator is not required to be ASME certified, material certification to NB-2130 is not possible. Material traceability and NB-4121 Material Certification by certification are maintained in accordance with TNs NRC approved Certificate Holder QA program.

NB-4243 and NB-5230 Category C weld joints in The shell to the outer top cover weld, the shell to the inner top cover vessels and similar weld weld, the siphon and vent cover plate welds, and the vent and joints in other components siphon block welds to the shell are all partial penetration welds.

shall be full penetration As an alternative to the NDE requirements of NB-5230 for Category joints. These welds shall be C welds, all of these closure welds will be multi-layer welds and examined by UT or RT and receive a root and final PT examination, except for the shell to the either PT or MT. outer top cover weld. The shell to the outer top cover weld will be a multi-layer weld and receive multi-level PT examination in accordance with the guidance provided in NUREG-1536 Revision 1 for NDE. The multi-level PT Examination provides reasonable assurance that flaws of interest will be identified. The PT examination is done by qualified personnel, in accordance with Section V and the acceptance standards of Section III, Subsection NB-5000. All of these welds will be designed to meet the guidance provided in NUREG-1536 Revision 1 for stress reduction factor.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-9

Design Features 4.0 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Confinement Boundary REFERENCE ASME ALTERNATIVES, JUSTIFICATION & COMPENSATORY CODE SECTION/ CODE REQUIREMENT MEASURES ARTICLE NB-6100 and 6200 All completed pressure The 61BTH Type 2 DSC is not a complete or installed pressure retaining systems shall be vessel until the top closure is welded following placement of Fuel pressure tested. Assemblies with the DSC. Due to the inaccessibility of the shell and lower end closure welds following fuel loading and top closure welding, as an alternative, the pressure testing of the DSC is performed in two parts. The DSC shell and shell bottom (including all longitudinal and circumferential welds) is pressure tested and examined at the fabrication facility.

The shell to the inner top cover closure weld are pressure tested and examined for leakage in accordance with NB-6300 in the field.

The siphon/vent cover welds are not pressure tested; these welds and the shell to the inner top cover closure weld are helium leak tested after the pressure test.

Per NB-6324, the examination for leakage shall be done at a pressure equal to the greater of the design pressure or three-fourths of the test pressure. As an alternative, if the examination for leakage of these field welds, following the pressure test, is performed using helium leak detection techniques, the examination pressure may be reduced to 1.5 psig. This is acceptable given the significantly greater sensitivity of the helium leak detection method.

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

The function of the DSC is to contain radioactive materials under normal, off-normal and hypothetical accident conditions postulated to occur during transportation and storage. The DSC is designed to withstand the maximum possible internal pressure considering 100% fuel rod failure at maximum accident temperature.

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

NB-5520 NDE personnel must be Permit use of the Recommended Practice SNT-TC-1A to include up qualified to a specific to the most recent 2011 edition.

edition of SNT-TC-1A.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-10

Design Features 4.0 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Basket REFERENCE ASME ALTERNATIVES, JUSTIFICATION & COMPENSATORY CODE SECTION/ CODE REQUIREMENT MEASURES ARTICLE NCA All Not compliant with NCA. Quality Assurance is provided according to 10 CFR Part 72 Subpart G in lieu of NCA-4000.

NCA-1140 Use of Code editions and Code edition and addenda other than those specified in Section addenda 4.4.2 may be used for construction, but in no case earlier than 3 years before that specified in the Section 4.4.2 table.

Materials produced and certified in accordance with ASME Section II material specification from Code Editions and Addenda other than those specified in Section 4.4.2 may be used, so long as the materials meet all the requirements of Article 2000 of the applicable Subsection of the Section III Edition and Addenda used for construction.

NG/NF-1100 Requirements for Code Code Stamping is not required. As Code Stamping is not required, Stamping of Components, the fabricator is not required to hold an ASME N or NPT stamp, Code reports and or to be ASME Certified.

certificates, etc.

NG/NF-2000 Use of ASME Material Some baskets include neutron absorber and aluminum plates that are not ASME Code Class 1 material. They are used for criticality safety and heat transfer, and are only credited in the structural analysis with supporting their own weight and transmitting bearing loads through their thickness. Material properties in the ASME Code for Type 6061 aluminum are limited to 400 °F to preclude the potential for annealing out the hardening properties. Annealed properties (as published by the Aluminum Association and the American Society of Metals) are conservatively assumed for the aluminum transition rails for use above the Code temperature limits.

NG/NF-2130 Material must be supplied Material is certified to meet all ASME Code criteria but is not eligible by ASME approved for certification or Code Stamping if a non-ASME fabricator is used.

material suppliers. As the fabricator is not required to be ASME certified, material certification to NG/NF-2130 is not possible. Material traceability and NG/NF-4121 Material Certification by certification are maintained in accordance with TNs NRC approved Certificate Holder QA program.

NG-3352 Table NG-3352-1 lists the The fuel compartment tubes may be fabricated from sheet with full permissible welded joints penetration seam weldments. Per Table NG-3352-1, a joint and quality factors. efficiency (quality) factor of 0.5 is to be used for full penetration weldments examined in accordance with ASME Section V visual examination (VT). A joint efficiency (quality) factor of 1.0 is utilized for the fuel compartment longitudinal seam welds (if present) with VT examination. This is justified because the compartment seam weld is thin and the weldment is made in one pass; and both surfaces of the weldment (inside and outside) receive 100% VT examination. The 0.5 quality factor, applicable to each surface of the weldment, results is a quality factor of 1.0 since both surfaces are 100% examined. In addition, the fuel compartments have no pressure retaining function and the stainless steel material that comprises the fuel compartment tubes is very ductile.

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

NG/NF-5520 NDE personnel must be Permit use of the Recommended Practice SNT-TC-1A to include up qualified to a specific to the most recent 2011 edition.

edition of SNT-TC-1A.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-11

Design Features 4.0 4.0 Design Features (continued)

Code alternatives for the HSM concrete specifications are listed below:

REFERENCE ALTERNATIVES, JUSTIFICATION ACI349-06 CODE REQUIREMENT AND COMPENSATORY SECTION/ARTICLE MEASURES Appendix E, Section Paragraph E.4.3 requires testing of The concrete temperature limit criteria E.4-Concrete concrete for temperatures higher than in NUREG-1536, Section 8.4.14.2 is Temperatures, those given in Paragraph E.4.1. used for normal and off-normal Paragraph E.4.3 conditions.

Alternatively, per ACI 349-13, Code Requirements for Nuclear Safety-Related Concrete Structures and Commentary, Section RE.4, the specified compressive strength, which may be tested up to 56 days, is increased to 7,000 psi for HSM fabrication so that any losses in properties (e.g., compressive strength) resulting from long-term thermal exposure will not affect the safety margins based on the specified 5,000 psi compressive strength used in the design calculations. Additionally, also as indicated in Section RE.4, short, randomly oriented steel fibers may be used to provide increased ductility, dynamic strength, toughness, tensile strength, and improved resistance to spalling.

The safety margin on compressive strength is 40% for a concrete temperature limit of 300 °F normal and off-normal conditions.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-12

Design Features 4.0 4.0 Design Features (continued)

Code alternatives for the steel-plate composite HSM specifications are listed below:

REFERENCE JUSTIFICATION AND CODE REQUIREMENT ANSI/AISC N690 COMPENSATORY MEASURES N9.1.1.(a) For exterior SC walls, the minimum value of As presented in Commentary for Section the section thickness, tsc, shall be 18 inches N9.1.1(a) of N690, the minimum section (450 mm). For interior SC walls, the minimum thickness for exterior SC walls is based on Table tsc shall be 12 inches (300 mm). 1 of NUREG-0800, Revision 3, Section 3.5.3, Revision 3. It requires minimum 16.9-inch thick (430mm) 4-ksi (28 MPa) reinforced concrete (RC) walls to resist a tornado missile.

Conservatively, the SC wall is treated as a RC wall for missile loading. The 10.25 inch and 14.5 inch sections of the door are supported by the front wall of the EOS-HSM-SC during missile impact. Therefore, the door meets the specified minimum thickness value of 18 inches for exterior walls. The minimum thickness for interior walls is based on the maximum reinforcement ratio and minimum faceplate thickness. The specified minimum thickness value of 12 inches is conservatively rounded up from the actual minimum of 10 inches as presented in Commentary for Section N9.1.1(a) of N690.

Therefore, the 10.25-inch thick section of the door and 11.38-inch section of the OVC does meet the minimum thickness requirement.

N9.1.1.(d) The specified minimum yield stress of The door and OVC steel plates are constructed faceplates, Fy, shall not be less than 50 ksi from ASTM A36. As presented in the (350 MPa) nor more than 65 ksi (450 MPa). Commentary for Section N9.1.1(d) of N690, the minimum yield strength of faceplates is intended to prevent premature yielding due to residual stresses from concrete casting and thermally induced stresses. The door and OVC are free to OBS 3-7 grow when subjected to thermal loads and require a concrete volume of relatively low height resulting in insignificant pressure on the faceplates during casting as compared to a large EOS-HSM-SC wall. Therefore, stresses due to thermal growth and residual stress from concrete casting will not contribute to premature yielding of the faceplates in these components.

Additionally, the margins for the door thickness RSI 3-3 to withstand local damage due to missile attack, ductile capacity for missile impact, and structural adequacy for punching shear are sufficiently large. The margins for the OVC are sufficiently large as well. Therefore, a material meeting the properties of ASTM A36 will have sufficient strength for this application.

NB2 Required load combinations for normal, severe The load combinations contained in AISC N690-environmental, and extreme environmental and 18 are intended to cover a wide range of abnormal conditions. structural applications where additional load combinations are used to cover various uncertainties. For the design of dry-storage structures, NUREG 1536, R1 (and the more current NUREG 2215) endorse the load combinations specified in Section 6.17.3.1 of ANSI 57.9-1984 as the most applicable load combinations. Therefore, the use of ANSI 57.9-1984 load combinations in lieu of those specified in AISC-N690-18 is acceptable for this application.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-13

Design Features 4.0 Proposed alternatives to the above-specified ASME and ACI codes, other than the aforementioned alternatives, may be used when authorized by the Director of the Office of Nuclear Material Safety and Safeguards, or designee. The applicant should demonstrate that:

1. The proposed alternatives would provide an acceptable level of quality and safety, or
2. Compliance with the specified requirements of above-specified ASME and ACI codes would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

The applicant should also submit information regarding the environmental impact of such a request to support the NRCs NEPA regulations in 10 CFR Part 51. Any proposed alternatives must be submitted and approved prior to implementation.

Requests for exceptions in accordance with this section should be submitted in accordance with 10 CFR 72.4.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-14

Design Features 4.0 4.0 Design Features (continued)

Storage Location Design Features The following storage location design features and parameters shall be verified by the system user to assure technical agreement with the UFSAR.

4.5.1 Storage Configuration EOS-HSMs and HSM-MXs are placed together in single rows or back to back arrays. A rear shield wall is placed on the rear of any single row loaded EOS-HSM.

4.5.2 Concrete Storage Pad Properties to Limit DSC Gravitational Loadings Due to Postulated Drops The EOS-37PTH DSC and EOS-89BTH DSC have been evaluated for drops of up to 65 inches onto a reinforced concrete storage pad. The 61BTH Type 2 DSC has been evaluated for drops of up to 80 inches onto a reinforced concrete storage pad.

4.5.3 Site Specific Parameters and Analyses The following parameters and analyses are applicable to all HSMs unless specifically noted and shall be verified by the system user for applicability at their specific site. Other natural phenomena events, such as lightning, tsunamis, hurricanes, and seiches, are site specific and their effects are generally bounded by other events, but they should be evaluated by the user.

1. Flood levels up to 50 ft and water velocity of 15 fps.
2. One-hundred year roof snow load of 110 psf.
3. Normal ambient temperature is based on the heat load of the DSC as follows:

For the EOS-HSM:

a. For the EOS-37PTH DSCs with a heat load less than or equal to 41.8 kW or for the EOS-89BTH DSCs with a heat load less than or equal to 41.6 kW, the minimum temperature is -20 °F. The maximum calculated normal average ambient temperature corresponding to a 24-hour period is 90 °F.
b. For the EOS-37PTH DSCs with a heat load greater than 41.8 kW or for the EOS-89BTH DSCs with a heat load greater than 41.6 kW, the minimum temperature is -20 °F. The maximum calculated average yearly temperature is 70 °F.

For the HSM-MX:

c. The minimum temperature is -20 °F. The maximum calculated normal average ambient temperature corresponding to a 24-hour period is 90 °F.
4. Off-normal ambient temperature range of -40 °F without solar insolation to 117 °F with full solar insolation. The 117 °F off-normal ambient temperature corresponds to a 24-hour calculated average temperature of 103 °F.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-15

Design Features 4.0 4.0 Design Features (continued)

5. The response spectra at the base of the HSMs shall be compared against the response spectra defined in UFSAR Section 2.3.4 for the EOS-HSM, and Section A.2.3.4 for the HSM-MX and shown to be enveloped by the UFSAR response spectra. If it is not enveloped, stability can be demonstrated by either static or dynamic analysis.
6. The potential for fires and explosions shall be addressed, based on site-specific considerations.
7. Supplemental Shielding: In cases where engineered features (i.e., berms, shield walls) are used to ensure that the requirements of 10 CFR 72.104(a) are met, such features are to be considered important to safety and must be evaluated to determine the applicable Quality Assurance Category.
8. If an INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) site is located in a coastal salt water marine atmosphere, then any load-bearing carbon steel DSC support structure rail components for the EOS-HSM, or front and rear DSC supports for the HSM-MX shall be procured with a minimum 0.20% copper content or stainless steel shall be used for corrosion resistance. For weld filler material used with carbon steel, 1% or more nickel bearing weld material would also be acceptable in lieu of 0.20% copper content.
9. If an ISFSI site is required to evaluate blockage of air vents for durations longer than evaluated in the UFSAR, a new duration can be determined based on site-specific parameters. The evaluation should be performed using the same methodology documented in the UFSAR.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 4-16

Administrative Controls 5.0 ADMINISTRATIVE CONTROLS Programs Each user of the NUHOMS EOS System will implement the following programs to ensure the safe operation and maintenance of the ISFSI:

  • Radiological Environmental Monitoring Program (see 5.1.1 below)
  • Radiation Protection Program (see 5.1.2 below)
  • HSM Thermal Monitoring Program (see 5.1.3 below) 5.1.1 Radiological Environmental Monitoring Program
a. A radiological environmental monitoring program will be implemented to ensure that the annual dose equivalent to an individual located outside the ISFSI controlled area does not exceed the annual dose limits specified in 10 CFR 72.104(a).
b. Operation of the ISFSI will not create any radioactive materials or result in any credible liquid or gaseous effluent release.

5.1.2 Radiation Protection Program The Radiation Protection Program will establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR Part 20 and Part 72.

a. As part of its evaluation pursuant to 10 CFR 72.212, the licensee shall perform an analysis to confirm that the limits of 10 CFR Part 20 and 10 CFR 72.104 will be satisfied under the actual site conditions and configurations considering the planned number of DSCs to be used and the planned fuel loading conditions. This analysis is also used to qualify fuel considered for loading, as outlined below:
1. For the DSCs considered for loading, select HLZC(s) appropriate to store the spent fuel.
2. Compute the decay heat of the fuel assemblies considered for loading.

Methods include, but are not limited to, NRC Regulatory Guide 3.54, or the methodology described in the UFSAR (i.e., ORIGEN-ARP).

3. Compute the source term for the fuel assemblies considered for loading. The design basis source terms provided in the UFSAR may be used for site-specific shielding analysis if they are shown to bound the site-specific source terms.
4. Demonstrate computationally that the EOS-HSM or HSM-MX to be loaded meets the dose rate requirements of TS 5.1.2(c). This evaluation may be used as the basis for the dose rate limits established in TS 5.1.2(b).
5. Demonstrate computationally that direct radiation from the ISFSI meets the requirements of 72.104.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-1

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

b. On the basis of the analysis in TS 5.1.2(a), the licensee shall establish a set of HSM dose rate limits which are to be applied to DSCs used at the site. Limits shall establish dose rates for:
i. HSM front face, ii. HSM door centerline, and iii. End shield wall exterior for the EOS-HSM or exterior side wall of the HSM-MX monolith.
c. Notwithstanding the limits established in TS 5.1.2(b), the dose rate limits may not exceed the following values as calculated for a content of design basis fuel as follows:

For EOS-HSM:

i. 65 mrem/hr average over the front face, ii. 15 mrem/hr at the door centerline, and iii. 5 mrem/hr average at the end shield wall exterior.

For HSM-MX:

i. 165 mrem/hr average over the front face, ii. 15 mrem/hr at the door centerline, and iii. 5 mrem/hr average at the exterior side wall of the HSM-MX monolith.

If the measured dose rates do not meet the limits of TS 5.1.2(b) or TS 5.1.2(c),

whichever are lower, the licensee shall take the following actions:

  • Notify the U.S. Nuclear Regulatory Commission (Director of the Office of Nuclear Material Safety and Safeguards) within 30 days,
  • Administratively verify that the correct fuel was loaded,
  • Ensure proper installation of the HSM door,
  • Ensure that the DSC is properly positioned on the DSC supports, and
  • Perform an analysis to determine that placement of the as-loaded DSC at the ISFSI will not cause the ISFSI to exceed the radiation exposure limits of 10 CFR Part 20 and 10 CFR Part 72 and/or provide additional shielding to assure exposure limits are not exceeded.
d. A monitoring program to ensure the annual dose equivalent to any real individual located outside the ISFSI controlled area does not exceed regulatory limits is incorporated as part of the environmental monitoring program in the Radiological Environmental Monitoring Program of TS 5.1.1.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-2

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

e. When using the EOS-TC108 with a liquid neutron shield (NS), the NS shall be verified to be filled when DSC cavity draining or TC/DSC annulus draining operations are initiated and continually monitored during the first five minutes of the draining evolution to ensure the NS remains filled. The NS shall also be verified to be filled prior to the movement of the loaded TC from the decontamination area.

Observation of water level in the expansion tank or some other means can be used to verify compliance with this requirement.

f. Following completion of the DSC shell assembly at the fabricator facility, the inner bottom cover plate, canister shell and all associated welds are leak-tested to demonstrate that these welds and components meet the leak-tight criterion ( 1.0 x 10-7 reference cm3/sec) as defined in American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment, ANSI N14.5-1997. If the leakage rate exceeds 1.0 x 10-7 reference cm3/sec, check and repair these welds or components.

Following completion of the welding of the DSC shell to the inner top cover and drain port cover and vent plug after fuel loading, these welds and components are leak-tested to demonstrate that they meet the leak-tight criterion ( 1.0 x 10-7 reference cm3/sec) as defined in American National Standard for Radioactive Materials - Leakage Tests on Packages for Shipment, ANSI N14.5-1997. If the leakage rate exceeds 1.0 x 10-7 reference cm3/sec, check and repair these welds or components.

5.1.3 HSM Thermal Monitoring Program Two separate programs for the EOS-HSM and MATRIX HSM are described in Technical Specifications 5.1.3.1 and 5.1.3.2, respectively.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-3

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) 5.1.3.1 EOS-HSM Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each EOS-HSM. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria.

Each user must implement either TS 5.1.3.1(a) OR 5.1.3.1(b).

a. Daily Visual Inspection of EOS-HSM Inlets and Outlets (Front Wall and Roof Birdscreens) and Wind Deflectors
i. The user shall develop and implement procedures to perform visual inspection of EOS-HSM inlets and outlets on a daily basis.

Perform a daily visual inspection of the air vents to ensure that EOS-HSM air vents are not blocked for more than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. If visual inspection indicates blockage, clear air vents and replace or repair birdscreens if damaged. If the air vents are blocked or could have been blocked for more than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

ii. Daily Visual Inspection of Wind Deflectors If wind deflectors are required per TS 5.5, the user shall develop and implement procedures to perform visual inspection of the wind deflectors on a daily basis.

There is a possibility that the wind deflectors could become damaged or lost by extreme winds, tornados, or other accidents. The condition caused by a damaged or lost wind deflector is bounded by the air vent blockage postulated and analyzed in the UFSAR accident analyses. The procedures shall ensure that the duration of a damaged or lost wind deflector will not exceed periods longer than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> as assumed in the UFSAR analyses for vent blockage. If visual inspection indicates a damaged or lost wind deflector, replace or repair the wind deflector. If the wind deflectors are damaged or could have been damaged for more than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

b. Daily EOS-HSM Temperature Measurement Program
i. The user shall develop a daily temperature measurement program to verify the thermal performance of each NUHOMS EOS System. The user shall establish administrative temperature limits to (1) detect off-normal and accident blockage conditions before the EOS- HSM components and fuel cladding temperatures would exceed temperature design limits and (2) ensure the EOS-HSM air vents are not blocked for more than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. The daily temperature measurements shall include one of the following options:
1. direct measurement of the EOS-HSM concrete temperature
2. direct measurement of inlet and outlet air temperatures (continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-4

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

If the direct measurement of the inlet and outlet air temperatures (option 2) is performed, the measured temperature differences of the inlet and outlet vents of each individual EOS-HSM must be compared to the predicted temperature differences for each individual EOS-HSM during normal operations. The measured temperature difference between the inlet and outlet vents shall not exceed 138 °F.

ii. The user shall establish in the program, measurement locations in the EOS-HSM that are representative of the EOS-HSM thermal performance and directly correlated to the predicted fuel cladding temperatures, air mass flow rates, and NUHOMS EOS System temperature distributions that would occur with the off-normal and accident blockage conditions, as analyzed in the UFSAR. The administrative temperature limits shall employ appropriate safety margins that ensure temperatures would not exceed design basis temperature limits in the UFSAR, and be based on the UFSAR methodologies used to predict thermal performance of the NUHOMS EOS System. If the direct measurement of the inlet and outlet air temperatures (option 2) is performed, the user must develop procedures to measure air temperatures that are representative of inlet and outlet air temperatures, as analyzed in the UFSAR. The user must also consider site-specific environmental conditions, loaded decay heat patterns, and the proximity of adjacent EOS-HSM modules in the daily air temperature measurement program. The user must ensure that measured air temperatures reflect only the thermal performance of each individual module, and not the combined performance of adjacent modules.

iii. The user shall establish in the program the appropriate actions to be taken if administrative temperature criteria are exceeded. If an administrative temperature limit is exceeded during a daily measurement, the user shall inspect the vents, wind deflectors if installed, and implement TS 5.1.3.1(a) for the affected system, until the cause of the excursion is determined and necessary corrective actions are completed under the site corrective action program.

iv. If measurements or other evidence indicate that the EOS-HSM concrete temperatures have exceeded the concrete accident temperature limit of 500

°F for more than 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, the user shall perform an analysis and/or tests of the concrete in accordance with TS 5.3. The user shall demonstrate that the structural strength of the EOS-HSM has an adequate margin of safety and take appropriate actions to return the EOS-HSM to normal operating conditions.

v. If measurements or other evidence indicate that off-normal or accident temperature limits for fuel cladding have been exceeded, verify that canister confinement is maintained and assess analytically the condition of the fuel.

Additionally, within 30 days, take appropriate actions to restore the spent fuel to a safe configuration.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-5

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) 5.1.3.2 HSM-MX Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each HSM-MX. There are no credible scenarios that could block both the inlet and outlet vents. Therefore, only blockage of inlet vent is considered in the UFSAR. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria. Each user must implement either TS 5.1.3.2(a) OR 5.1.3.2(b).

a. Daily Visual Inspection of HSM-MX Inlets and Outlets (Front Wall and Roof Birdscreens)

The user shall develop and implement procedures to perform visual inspection of HSM-MX inlets and outlets on a daily basis.

Perform a daily visual inspection of the air vents to ensure that HSM-MX air vents are not blocked for more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />. If visual inspection indicates blockage, clear air vents and replace or repair birdscreens if damaged. If the air vents are blocked or could have been blocked for more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

b. Daily HSM-MX Temperature Measurement Program
i. The user shall develop a daily temperature measurement program to verify the thermal performance of each HSM-MX System through direct measure of the HSM-MX concrete temperature. The user shall establish administrative temperature limits to (1) detect off-normal and accident blockage conditions before the HSM-MX components and fuel cladding temperatures would exceed temperature design limits and (2) ensure the HSM-MX air vents are not blocked for more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />.

ii. The user shall establish in the program measurement locations in the HSM-MX that are representative of the HSM-MX thermal performance and directly correlated to the predicted fuel cladding temperatures, air mass flow rates, and NUHOMS MATRIX System temperature distributions that would occur with the off-normal and accident blockage conditions, as analyzed in the UFSAR. The administrative temperature limits shall employ appropriate safety margins that ensure temperatures would not exceed design basis temperature limits in the UFSAR, and be based on the UFSAR methodologies used to predict thermal performance of the NUHOMS MATRIX System.

iii. The user shall establish in the program the appropriate actions to be taken if administrative temperature criteria are exceeded. If an administrative temperature limit is exceeded during a daily measurement, the user shall inspect the vents and implement TS 5.1.3.2(a) for the affected system, until the cause of the excursion is determined and necessary corrective actions are completed under the site corrective action program.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-6

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued) iv. If measurements or other evidence indicate that the HSM-MX concrete temperatures have exceeded the concrete accident temperature limit of 500

°F for more than 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, the user shall perform an analysis and/or tests of the concrete in accordance with TS 5.3. The user shall demonstrate that the structural strength of the HSM-MX has an adequate margin of safety and take appropriate actions to return the HSM-MX to normal operating conditions.

v. If measurements or other evidence indicate that off-normal or accident temperature limits for fuel cladding have been exceeded, verify that canister confinement is maintained and assess analytically the condition of the fuel.

Additionally, within 30 days, take appropriate actions to restore the spent fuel to a safe configuration.

Lifting Controls 5.2.1 TC/DSC Lifting Height and Temperature Limits The requirements of 10 CFR 72 apply to TC/DSC lifting/handling height limits outside the FUEL BUILDING. The requirements of 10 CFR Part 50 apply to TC/DSC lifting/handling height limits inside the FUEL BUILDING. Confirm the surface temperature of the TC before TRANSFER OPERATIONS of the loaded TC/DSC.

The lifting height of a loaded TC/ DSC is limited as a function of low temperature and the type of lifting/handling device, as follows:

No lifts or handling of the TC/DSC at any height are permissible at TC surface temperatures below 0 °F The maximum lift height of the TC/DSC shall be 65 inches for the EOS-DSCs or 80 inches for the 61BTH Type 2 DSC if the surface temperature of the TC is above 0 °F and a non-single-failure-proof lifting/handling device is used.

No lift height restriction is imposed on the TC/DSC if the TC surface temperature is higher than 0 °F, and a single-failure-proof lifting/handling system is used.

The requirements of 10 CFR Part 72 apply when the TC/DSC is in a horizontal orientation on the transfer trailer. The requirements of 10 CFR Part 50 apply when the TC/DSC is being lifted/handled using the cask handling crane/hoist. (This distinction is valid only with respect to lifting/handling height limits.)

5.2.2 Cask Drop Inspection Requirement The TC will be inspected for damage and the DSC will be evaluated after any TC with a loaded DSC side drop of 15 inches or greater.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-7

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

Background

TC/DSC handling and loading activities are controlled under the 10 CFR Part 50 license until a loaded TC/DSC is placed on the transporter, at which time fuel handling activities are controlled under the 10 CFR Part 72 license.

Safety Analysis The analysis of bounding drop scenarios shows that the TC will maintain the structural integrity of the DSC confinement boundary from an analyzed side drop height of 65 inches for the EOS-DSCs and 80 inches for the 61BTH Type 2 DSC. This 65-inch/80-inch drop height envelopes the maximum height from the bottom of the TC when secured to the transfer trailer while en route to the ISFSI.

Although analyses performed for cask drop accidents at various orientations indicate much greater resistance to damage, requiring the inspection of the DSC after a side drop of 15 inches or greater ensures that:

1. The DSC will continue to provide confinement.
2. The TC can continue to perform its design function regarding DSC transfer and shielding.

Concrete Testing HSM concrete shall be tested during the fabrication process for elevated temperatures to verify that there are no significant signs of spalling or cracking and that the concrete compressive strength is greater than that assumed in the structural analysis. Tests shall be performed at or above the calculated peak accident temperature and for a period no less than the permissible duration as specified in Technical Specification 5.1.3.

HSM concrete temperature testing shall be performed whenever:

  • There is a change in the supplier of the cement, or
  • There is a change in the source of the aggregate, or
  • The water-cement ratio changes by more than 0.04.

(continued)

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-8

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS (continued)

Hydrogen Gas Monitoring For DSCs, while welding the inner top cover during LOADING OPERATIONS, and while cutting the inner top cover to DSC shell weld when the DSC cavity is wet during UNLOADING OPERATIONS, hydrogen monitoring of the space under the top shield plug in the DSC cavity is required, to ensure that the combustible mixture concentration remains below the flammability limit of 4%. If this limit is exceeded, all welding operations shall be stopped and the DSC cavity purged with helium to reduce hydrogen concentration safely below the limit before welding or cutting operations can be resumed.

EOS-HSM Wind Deflectors If the heat load of an EOS-37PTH DSC during STORAGE OPERATIONS is greater than 41.8 kW, wind deflectors shall be installed on the EOS-HSM.

If the heat load of a fuel assembly loaded per HLZC 5 in the EOS-37PTH DSC during STORAGE OPERATIONS is greater than 1.625 kW, wind deflectors shall be installed on the EOS-HSM.

If the heat load of an EOS-89BTH DSC during STORAGE OPERATIONS is greater than 41.6 kW, wind deflectors shall be installed on the EOS-HSM.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 5-9

Tables Table 1 Fuel Assembly Design Characteristics for the EOS-37PTH DSC B&W WE CE WE CE WE CE PWR FUEL CLASS 15X15 17X17 15X15 15X15 14X14 14X14 16X16 Fissile Material UO2 UO2 UO2 UO2 UO2 UO2 UO2 Maximum Number of Fuel 208 264 216 204 176 179 236 Rods Maximum Number of 17 25 9 21 5 17 5 Guide/ Instrument Tubes Table 2 Maximum Uranium Loading per FFC for Failed PWR Fuel Maximum Uranium Fuel Assembly Class Loading (MTU)

WE 17x17 0.550 CE 16x16 0.456 BW 15x15 0.492 WE 15x15 0.480 CE 15x15 0.450 CE 14x14 0.400 WE 14x14 0.410 Table 3 Co-60 Equivalent Activity for CCs Stored in the EOS-37PTH DSC Maximum Co-60 Equivalent Activity per DSC (Curies/DSC)(2)

Transfer in the EOS- Transfer in the Transfer in the EOS-TC108 AND (storage EOS-TC125/135 TC125/135 AND in the EOS-HSM OR AND storage in the storage in the EOS-Fuel Region HSM-MX) HSM-MX HSM Active Fuel 32,656 37,259 Plenum/Top Region 6,671 7,607 Notes:

1. Not Used.
2. NSAs and Neutron Sources shall only be stored in the inner zone of the basket. Figure 3 defines the compartments categorized as the Inner and Peripheral Zones.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-1

Tables Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH (2 Pages)

Maximum Planar Average Initial Enrichment (wt. % U-235) as a Function of Soluble Boron Concentration and Basket Type (Fixed Poison Loading) With and Without CCs Basket Type PWR Fuel Class Minimum A1/A2/A3/A4H/A4L/A5 B1/B2/B3/B4H/B4L/B5 Soluble w/o CCs w/ CCs w/o CCs w/ CCs Boron (ppm) DAMAGED/ DAMAGED/ DAMAGED/ DAMAGED/

INTACT INTACT INTACT INTACT FAILED FAILED FAILED FAILED FUEL FUEL FUEL FUEL FUEL(2) FUEL(2) FUEL(3) FUEL(3) 2000 4.35 4.20 4.35 4.15 4.50 4.15 4.45 4.25 2100 4.50 4.20 4.45 4.20 4.65 4.25 4.60 4.40 WE 17x17 2200 4.60 4.40 4.55 4.35 4.75 4.45 4.70 4.55 Class 2300 4.70 4.45 4.65 4.50 4.85 4.65 4.85 4.60 2400 4.85 4.45 4.80 4.60 5.00 4.65 4.95 4.75 2500 4.95 4.65 4.90 4.70 5.00 5.00 5.00 4.95 2000 5.00 4.75 5.00 4.70 5.00 5.00 5.00 5.00 2100 5.00 5.00 5.00 5.00 - - - -

CE 16x16 2200 - - - - - - - -

Class 2300 - - - - - - - -

2400 - - - - - - - -

2500 - - - - - - - -

2000 4.25 4.05 4.20 4.00 4.40 4.10 4.35 4.15 2100 4.40 4.10 4.30 4.15 4.55 4.20 4.45 4.25 2200 4.50 4.25 4.45 4.15 4.65 4.35 4.60 4.30 BW 15x15 2300 4.60 4.35 4.55 4.30 4.80 4.40 4.70 4.50 Class 2400 4.75 4.40 4.65 4.45 4.90 4.55 4.85 4.50 2500 4.85 4.55 4.75 4.65 5.00 4.75 4.90 4.75 2600 (1) (1) (1) (1) 5.00 5.00 (1) (1) 2000 4.45 4.10 4.40 4.10 4.55 4.30 4.55 4.25 2100 4.60 4.15 4.55 4.15 4.65 4.50 4.65 4.35 2200 4.70 4.25 4.65 4.35 4.80 4.55 4.80 4.45 WE 15x15 2300 4.85 4.35 4.75 4.45 5.00 4.50 4.95 4.50 2400 4.95 4.50 4.90 4.50 5.00 4.90 5.00 4.80 2500 5.00 4.75 5.00 4.65 5.00 5.00 5.00 5.00 2000 4.60 4.25 4.55 4.20 4.75 4.35 4.70 4.30 2100 4.70 4.45 4.65 4.40 4.85 4.50 4.85 4.35 CE 15x15 2200 4.85 4.50 4.80 4.45 5.00 4.60 4.95 4.60 Assembly 2300 5.00 4.55 4.90 4.65 5.00 5.00 5.00 4.80 Class 2400 5.00 5.00 5.00 4.85 5.00 5.00 5.00 5.00 2500 - - 5.00 5.00 - - - -

2000 5.00 5.00 5.00 4.50 5.00 5.00 5.00 4.95 2100 - - 5.00 4.95 - - 5.00 5.00 CE 14x14 2200 - - 5.00 5.00 - - - -

Assembly 2300 - - - - - - - -

Class 2400 - - - - - - - -

2500 - - - - - - - -

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-2

Tables Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH (2 Pages)

Maximum Planar Average Initial Enrichment (wt. % U-235) as a Function of Soluble Boron Concentration and Basket Type (Fixed Poison Loading) With and Without CCs Basket Type PWR Fuel Class Minimum A1/A2/A3/A4H/A4L/A5 B1/B2/B3/B4H/B4L/B5 Soluble w/o CCs w/ CCs w/o CCs w/ CCs Boron (ppm) DAMAGED/ DAMAGED/ DAMAGED/ DAMAGED/

INTACT INTACT INTACT INTACT FAILED FAILED FAILED FAILED FUEL FUEL FUEL FUEL FUEL(2) FUEL(2) FUEL(3) FUEL(3) 2000 5.00 5.00 5.00 5.00 5.00 5.00 5.00 5.00 2100 - - - - - - - -

WE 14x14 2200 - - - - - - - -

Class 2300 - - - - - - - -

2400 - - - - - - - -

2500 - - - - - - - -

Notes:

1. Not analyzed.
2. May only be stored in basket types A4H and A4L
3. May only be stored in basket types B4H and B4L EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-3

Tables Table 5 Minimum B-10 Content in the Neutron Poison Plates of the EOS-37PTH DSC Minimum B-10 Content Basket Type (areal density) for MMC (mg/cm2)

A1/A2/A3/A4H/A4L/A5 28.0 B1/B2/B3/B4H/B4L/B5 35.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-4

Tables Table 6 Fuel Assembly Design Characteristics for the EOS-89BTH DSC BWR FUEL BWR Fuel CLASS ID Example Fuel Designs (1)(2) 7x7 ENC-7-A ENC-IIIA 7x7 ENC-7-B ENC-III ENC-IIIE ENC-IIIF 7x7 GE-7-A GE-1, GE-2, GE-3 8x8 ENC-8-A ENC Va and Vb 8x8 ABB-8-A SVEA-64 8x8 ABB-8-B SVEA-64 8x8 FANP-8-A FANP 8x8-2 8x8 GE-8-A GE-4, XXX-RCN 8x8 GE-8-B GE-5, GE-Pres GE-Barrier GE-8 Type 1 8x8 GE-8-C GE-8 Type II 8x8 GE-8-D GE-9, GE-10 9x9 FANP-9-A FANP-9x9-79/2 FANP-9x9-72 FANP-9x9-80 FANP-9x9-81 9x9 FANP-9-B Siemens QFA ATRIUM 9 9x9 GE-9-A GE-11, GE-13 10 x 10 ABB-10-A SVEA-92 SVEA-96Opt SVEA-100 10 x 10 ABB-10-B SVEA-92 SVEA-96 SVEA-100 10 x 10 ABB-10-C SVEA-96Opt2 10 x 10 FANP-10-A ATRIUM 10 ATRIUM 10XM 10 x 10 GE-10-A GE-12, GE-14 10 x 10 GE-10-B GNF2 11 x 11 FANP-11-A ATRIUM 11 Notes:

1. Any fuel channel average thickness up to 0.120 inch is acceptable on any of the fuel designs.
2. Example BWR fuel designs are listed herein and are not all-inclusive.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-5

Tables Table 7A PWR Minimum Enrichments as a Function of Burnup Burnup Range Minimum Enrichment (GWd/MTU) (wt. % U-235) 1-6 0.7 7-16 1.3 17-30 1.8 31-62 Burnup/16(1)

Notes:

(1) Round enrichment down to the nearest 0.1%. Example: for 62 GWd/MTU, 62/16 = 3.875%,

round down to 3.8%.

(2) Fuel below the minimum enrichment defined in this table is classified as LOW-ENRICHED OUTLIER FUEL. Number and location are specified in Section 2.1.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-6

Tables Table 7B EOS-37PTH DSC Fuel Qualification Table for Storage in the HSM-MX, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 1.3 1.8 2.0 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 2.95 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 4.92 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 9.84 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 14.76 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 19.68 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 22.14 2.16 2.12 2.09 2.05 2.04 2.02 2.00 2.00 24.60 2.35 2.31 2.28 2.26 2.24 2.18 2.14 27.06 2.55 2.51 2.49 2.47 2.41 2.35 29.52 2.76 2.75 2.71 2.64 2.58 30.50 2.85 2.82 2.74 2.67 34.10 3.22 3.20 3.11 3.03 Notes:

(1) The minimum cooling time is 2.0 years.

(2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.

(3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.

(4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-7

Tables Table 7C EOS-37PTH DSC Fuel Qualification Table for Storage in the EOS-HSM, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 1.3 1.8 2.0 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 2.95 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 3.44 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 7.87 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 8.36 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 9.84 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 14.76 1.08 1.07 1.03 1.01 1.00 1.00 1.00 1.00 1.00 1.00 1.00 19.68 1.35 1.32 1.30 1.27 1.25 1.24 1.23 1.20 1.17 22.14 1.48 1.46 1.43 1.40 1.39 1.38 1.34 1.31 24.60 1.62 1.59 1.56 1.55 1.53 1.49 1.45 27.06 1.75 1.72 1.71 1.69 1.65 1.60 29.52 1.89 1.88 1.85 1.80 1.76 30.50 1.94 1.92 1.87 1.82 34.10 2.19 2.17 2.11 2.06 Notes:

(1) The minimum cooling time is 1 year. For fuel transferred in the EOS-TC108, the minimum cooling time is 2.0 years.

(2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.

(3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.

(4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-8

Tables Table 8 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the EOS-89BTH DSC Maximum Lattice Average Initial Minimum B-10 Enrichment Areal Density Loading (wt. % U-235) (mg/cm2)

Configuration Basket Type - Number of All fuel Fuel Except ABB-10-C ATRIUM 11 Assemblies (1) ABB-10-C MMC BORAL Fuel Fuel and ATRIUM 11 89 4.20 4.05 4.05 88 4.45 4.25 4.25 A1/A2/A3 (2) 32.7 39.2 87 4.60 4.40 4.35 84 5.00 4.90 4.80 89 4.55 4.35 4.30 88 4.80 4.60 4.50 B1/B2/B3 (2) 41.3 49.6 87 4.95 4.70 4.65 84 5.00 5.00 5.00 89 (3) Not 60.0 C1/C2/C3 (2) 4.85 4.60 Allowed Note:

1. See Figure 10 for 88-FA, 87-FA and 84-FA loading configurations.
2. Mixing fuel types in the same DSC is permissible based on the calculated enrichments for each fuel type for a given basket type and loading configuration. For example, when mixing GNF2 and ATRIUM 11 fuels in basket type A1/A2/A3 and 88-fuel-assembly loading configuration, the maximum enrichment for GNF2 fuels is 4.45wt% and the maximum enrichment for ATRIUM 11 fuels is 4.25wt%.
3. ATRIUM 11 fuel is not an allowed content for basket type C1/C2/C3.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-9

Tables Table 9 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Intact Fuel)

Maximum Lattice Minimum B-10 Areal Density, Average Initial (mg/cm2)

Basket Type Enrichment Borated (wt. % U-235)(1) Boral Aluminum/MMC A 3.7 22 27 B 4.1 32 38 C 4.4 42 50 D 4.6 48 58 E 4.8 55 66 F 5.0(1) 62 75 Note:

1) For ATRIUM 11 fuel assemblies, the U-235 wt. % enrichment is reduced by 0.55%. The ATRIUM 11 fuel assemblies are authorized for storage in the Type F basket only.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-10

Tables Table 10 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Damaged Fuel)

Maximum Lattice Average Initial Minimum B-10 Areal Density, Enrichment (wt. % U-235) (mg/cm2)

Basket Up to 4 Five or More Type Damaged Damaged Borated Boral Assemblies(1) Assemblies(1) Aluminum/MMC (16 Maximum)

A 3.7 2.80 22 27 B 4.1 3.10 32 38 C 4.4 3.20 42 50 D 4.6 3.40 48 58 E 4.8 3.50 55 66 F 5.0(2, 3) 3.60 62 75 Notes:

1) See Figure 5 for the location of damaged fuel assemblies within the 61BTH Type 2 DSC.
2) ATRIUM 11 fuel assemblies are authorized for storage only in the Type F basket only with a maximum of 4 damaged fuel assemblies.
3) For ATRIUM 11 fuel assemblies, the U-235 wt. % enrichment is reduced by 0.55%.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-11

Tables Table 11 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Failed and Damaged Fuel)

Maximum Lattice Average Initial Minimum B-10 Areal Enrichment (wt. % U-235) Density (mg/cm2)

Up to 4 Failed Up to 4 Failed Assemblies (Corner Assemblies Locations) and up to 12 Basket (Corner Damaged Assemblies Borated Type Locations)(1, 2) (Interior Locations)(1, 2) Aluminum/MMC Boral A 3.7 2.8 22 27 B 4.0 3.1 32 38 C 4.4 3.2 42 50 D 4.6 3.4 48 58 E 4.8 3.4 55 66 F 5.0 3.5 62 75 Notes:

1) See Figure 5 for the locations of the failed and damaged assemblies within the 61BTH Type 2 DSC.
2) Failed ATRIUM 11 fuel assemblies are not authorized for storage in the 61BTH Type 2 DSC.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-12

Tables Table 12 Maximum Lattice Average Initial Enrichments and Minimum B-10 Areal Density for the 61BTH Type 2 DSC for > 16 Damaged Fuel Assemblies Up to 57 Damaged Fuel at 3.30 Minimum B-10 Areal Density wt. % U-235 (mg/cm2)

Remaining Remaining Four Basket Four Intact Damaged Borated Type Assemblies (1) Assemblies (1) Aluminum/MMC Boral A - - - -

B - - - -

C - - - -

D 5.00 4.20 48 58 E 5.00 4.20 55 66 F 5.00 4.20 62 75 Note:

1) See Figure 5 for the locations of the damaged assemblies within the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-13

Tables Table 13 BWR Fuel Assembly Design Characteristics for the 61BTH Type 2 DSC Initial Design or BWR FUEL Reload Fuel CLASS Designation(1) (3)

GE1 7x7-GE2 49/0 GE3 8x8-GE4 63/1 GE-5 8x8- GE-Pres 62/2 GE-Barrier GE8 Type I 8x8- GE8 60/4 Type II 8x8- GE9 60/1 GE10 9x9- GE11 74/2 GE13 GE12 10x10-GE14 92/2 GNF2 7x7-ENC-IIIA 49/0 7x7-ENC-III(2) 48/1Z 8x8- ENC Va 60/4Z ENC Vb 8x8- FANP 62/2 8x8-2 9x9- FANP9 79/2 9x9-2 Siemens 9x9 QFA 10x10- ATRIUM-10 91/1 ATRIUM-10XM 11x11 ATRIUM-11 Notes:

(1) Any fuel channel average thickness up to 0.120 inch is acceptable on any of the fuel designs.

(2) Includes ENC-IIIE and ENC-IIIF.

(3) Initial designs or reload fuel designations belonging to a listed fuel class, but not listed herein may be qualified for storage using the same methodology as documented in the UFSAR.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-14

Tables Table 14 Maximum Uranium Loading per FFC for Failed 61BTH Type 2 Fuel Fuel Maximum Assembly MTU/Assembly Class 7x7 0.198 8x8 0.188 9x9 0.180 10x10 0.187 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-15

Tables Table 15 Deleted EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-16

Tables Table 16 Deleted EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-17

Tables Table 17 System Configurations for 61BTH Type 2 HLZCs HLZC Storage Module Transfer Cask OS197/OS197H/

1 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

2 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

3 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

4 HSM-MX OS197FC-B/OS197HFC-B 5 HSM-MX OS197FC-B/OS197HFC-B 6 HSM-MX OS197FC-B/OS197HFC-B 7 HSM-MX OS197FC-B/OS197HFC-B 8 HSM-MX OS197FC-B/OS197HFC-B OS197/OS197H/

9 HSM-MX OS197FC-B/OS197HFC-B 10 HSM-MX OS197FC-B/OS197HFC-B EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-18

Tables Table 18 BWR Minimum Enrichments as a Function of Burnup (EOS-89BTH DSC and 61BTH Type 2 DSC)

Burnup Range Minimum Enrichment (GWd/MTU) (wt. %)

1-6 0.7 7-19 0.9 20-35 Burnup/20(1) 36-62 Burnup/16(1)

Notes:

1) Round down to the nearest 0.1%. Example: for 62 GWd/MTU, 62/16 = 3.875%, round down to 3.8%.
2) Fuel below the minimum enrichment defined in this table is classified as LOW-ENRICHED OUTLIER FUEL. Number and location are specified in Section 2.2 for the EOS-89BTH DSC and in Section 2.3 for the 61BTH Type 2 DSC.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-19

Tables Table 19 61BTH Type 2 DSC Fuel Qualification Table, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 0.9 1.0 1.5 1.7 2.2 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 1.19 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 1.39 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.97 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 3.76 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 3.96 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 5.94 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 6.93 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 7.13 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 7.92 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 8.91 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 9.90 2.11 2.06 2.01 2.00 2.00 2.00 2.00 10.89 2.29 2.24 2.22 2.19 2.11 2.05 11.88 2.48 2.46 2.43 2.34 2.27 12.28 2.57 2.53 2.44 2.36 Notes:

1) The minimum cooling time is 2.0 years.
2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.
3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.
4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-20

Tables Table 20 61BTH Type 2 DSC Fuel Qualification Table, HLZC 2, 4, 5, 6, 7, and 8, Peripheral Locations (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 0.9 1.0 1.5 1.7 2.2 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 1.19 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 1.39 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.97 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 2.00 3.76 2.35 2.33 2.23 2.20 2.12 2.09 2.06 2.03 2.01 2.00 2.00 2.00 2.00 2.00 3.96 2.41 2.31 2.28 2.20 2.16 2.13 2.10 2.08 2.06 2.05 2.04 2.02 2.00 5.94 3.13 3.09 2.98 2.93 2.88 2.83 2.79 2.75 2.74 2.72 2.67 2.63 6.93 3.55 3.43 3.36 3.29 3.24 3.18 3.14 3.12 3.10 3.03 2.98 7.13 3.52 3.45 3.39 3.33 3.27 3.22 3.21 3.18 3.11 3.06 7.92 3.87 3.79 3.71 3.64 3.58 3.57 3.53 3.45 3.38 8.91 4.39 4.29 4.20 4.12 4.10 4.05 3.94 3.85 9.90 5.03 4.91 4.80 4.77 4.70 4.56 4.43 10.89 5.86 5.70 5.65 5.56 5.35 5.18 11.88 6.97 6.89 6.75 6.45 6.19 12.28 7.53 7.36 7.00 6.70 Notes:

1) The minimum cooling time is 2.0 years.
2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.
3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.
4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.
5) The peripheral locations are defined in Figure 6.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-21

Tables Table 21 EOS-89BTH DSC Fuel Qualification Table, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup Fuel Assembly Average Initial U-235 Enrichment (wt.%)

(GWd/FA) 0.7 0.9 1.0 1.5 1.7 2.2 2.5 2.8 3.1 3.4 3.7 3.8 4.0 4.5 5.0 1.19 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.39 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 2.97 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 3.76 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 3.96 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 5.94 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 6.93 1.11 1.06 1.03 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 7.13 1.09 1.06 1.03 1.00 1.00 1.00 1.00 1.00 1.00 1.00 7.92 1.17 1.14 1.11 1.08 1.06 1.05 1.04 1.00 1.00 8.91 1.28 1.25 1.22 1.19 1.18 1.16 1.12 1.09 9.90 1.40 1.36 1.33 1.32 1.30 1.25 1.21 10.89 1.51 1.48 1.46 1.44 1.39 1.34 11.88 1.63 1.62 1.59 1.53 1.48 12.28 1.68 1.66 1.60 1.54 Notes:

1) The minimum cooling time is 1.0 year.
2) The burnup in GWd/FA is the assembly average burnup in GWd/MTU multiplied by the MTU of the fuel assembly.
3) Linear interpolation is allowed to obtain a cooling time within the specified range of burnup and enrichment values.
4) Extrapolation is allowed to obtain a cooling time in the gray-shaded region.
5) For fuel transferred in the EOS-TC108, additional cooling time restrictions are specified in Figure 2.

EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-22

Tables Table 22 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125 Parameter Limit Number of RECONSTITUTED FUEL 89 ASSEMBLIES per DSC Maximum number of irradiated stainless Per table below steel rods per RECONSTITUTED FUEL ASSEMBLY Minimum cooling time Per table below Number of Irradiated Stainless Steel Rods per Fuel Assembly Minimum 7x7 Class 8x8 Class 9x9 Class 10x10 Class 11x11 Class Cooling Time (years)

Min. Max. Min. Max. Min. Max. Min. Max. Min. Max.

0 5 0 6 0 7 0 9 0 11 Per Table 21 6 15 7 18 8 22 10 26 12 34 2.00 16 20 19 24 23 29 27 34 35 46 2.25 21 25 25 30 30 37 35 43 47 57 2.50 26 30 31 36 38 44 44 51 58 69 2.75 31 35 37 42 45 51 52 60 70 80 3.00 36 49 43 64 52 81 61 100 81 112 3.25 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-23

Tables Table 23 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108 Parameter Limit Number of RECONSTITUTED FUEL

  • 89 (all types)

ASSEMBLIES per DSC

  • 49 containing irradiated stainless steel rods Maximum number of irradiated stainless steel
  • 100 for 7x7 Class rods per DSC
  • 120 for 8x8 Class
  • 140 for 9x9 Class
  • 180 for 10x10 Class
  • 220 for 11x11 Class Maximum number of irradiated stainless steel
  • 5 for 7x7 Class rods per RECONSTITUTED FUEL ASSEMBLY
  • 6 for 8x8 Class
  • 7 for 9x9 Class
  • 9 for 10x10 Class
  • 11 for 11x11 Class Loading restrictions for locations within the Per Figure 9 basket Minimum cooling time Per Table 21 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-24

Tables Table 24 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125/135 AND Storage in the EOS-HSM Parameter Limit Number of RECONSTITUTED FUEL 37 ASSEMBLIES per DSC Maximum number of irradiated stainless steel Per table below rods per RECONSTITUTED FUEL ASSEMBLY Minimum cooling time Per table below Number of Irradiated Stainless Steel Rods per Fuel Assembly Minimum Cooling 14x14 Class 15x15 Class 16x16 Class 17x17 Class Time (years)

Min. Max. Min. Max. Min. Max. Min. Max.

0 8 0 10 0 11 0 13 Per Table 7C 9 17 11 20 12 23 14 25 3.00 18 34 21 40 24 45 26 51 4.00 35 51 41 60 46 68 52 76 4.50 52 68 61 80 69 91 77 102 5.00 69 85 81 100 92 113 103 127 5.25 86 102 101 120 114 136 128 152 5.50 103 118 121 140 137 159 153 178 5.75 119 135 141 160 160 182 179 203 6.00 136 179 161 216 183 236 204 264 6.25 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-25

Tables Table 25 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108 Number of RECONSTITUTED FUEL

  • 37 (all types)

ASSEMBLIES per DSC

  • 21 containing irradiated stainless steel rods Maximum number of irradiated stainless steel
  • 32 for 14x14 Class rods per DSC
  • 40 for 15x15 Class
  • 48 for 16x16 and 17x17 Classes Maximum number of irradiated stainless steel
  • 4 for 14x14 Class rods per RECONSTITUTED FUEL
  • 5 for 15x15 Class ASSEMBLY
  • 6 for 16x16 and 17x17 Classes Loading restrictions for locations within the Per Figure 14 basket Minimum cooling time 2 years EOS System Amendment 4 Proposed Technical Specifications - Revision 1 T-26

Figures Figure 1A Deleted EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-1

Figures Zone Number 1 2 3 Maximum Decay Heat, (H), (kW/FA plus CCs, if included) 1.0 1.5 1.05 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 41.8 Figure 1B Heat Load Zone Configuration 2 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-2

Figures Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus CCs, if included) 0.95 1.0 1.0 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 36.35 Figure 1C Heat Load Zone Configuration 3 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-3

Figures Zone Number 1 2 3 Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.625 1.6 Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 50.0(1)

Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1D Heat Load Zone Configuration 4 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-4

Figures Zone Number 1 2 3 4 Maximum Decay Heat (kW/FA plus CCs, if included) 0.7 0.5 2.4 0.85 Maximum Number of Fuel Assemblies 5 6 8 18 Maximum Decay Heat per DSC (kW) 41.0 Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1E Heat Load Zone Configuration 5 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-5

Figures Z3 Z3** Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3** Z1 Z1 Z1 Z1 Z1 Z3**

Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z3** Z3

(*) denotes location where INTACT or DAMAGED FUEL can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

Zone Number 1 2(1) 3(1)

Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.5 1.3125(2)

Maximum Number of Fuel Assemblies 13 8 16 Maximum Decay Heat per DSC (kW) 46.00

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.
2. The maximum allowable heat load per FAILED FUEL compartment is 0.8 kW.

Figure 1F Heat Load Zone Configuration 6 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-6

Figures Zone Number 1 2 3 Maximum Number of Fuel Assemblies 13 8 16 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.60 1.3125 Maximum Decay Heat per DSC (kW) 41.8(1)

Lower Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.9 1.60 1.60 Maximum Decay Heat per DSC (kW) 50.0(1)

Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1G Heat Load Zone Configuration 7 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-7

Figures Z3 Z3** Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3** Z1 Z1 Z1 Z1 Z1 Z3**

Z3 Z2* Z1 Z1 Z1 Z2* Z3 Z3 Z2* Z1 Z2* Z3 Z3 Z3** Z3

(*) denotes location where INTACT or DAMAGED FUEL can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

Zone Number 1 2(2) 3(2)(3)

Maximum Number of Fuel Assemblies 13 8 16 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.8 1.50 1.50 Maximum Decay Heat per DSC (kW) 41.8(1)(4)

Lower Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.8 1.50 1.50 Maximum Decay Heat per DSC (kW) 46.4(1)

Notes:

1. The maximum decay heat per DSC is limited to 41.8 kW when DAMAGED or FAILED FUEL is loaded.
2. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.
3. The maximum allowable heat load per FAILED FUEL is 0.8 kW.
4. Adjust payload to maintain total canister heat load within the specified limit.

Figure 1H Heat Load Zone Configuration 8 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-8

Figures Z5 Z4 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z3 Z2 Z1 Z2 Z3 Z4 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z4 Z3 Z2 Z1 Z2 Z3 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z4 Z5 Zone Number 1 2 3 4 5 Maximum Decay Heat (kW/FA plus CCs, if 0.50 0.70 2.0 0.75 2.4 included)

Maximum Number of Fuel Assemblies 5 6 4 18 4 Maximum Decay Heat per DSC (kW) 37.80 Figure 1I Heat Load Zone Configuration 9 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-9

Figures Figure 1J Deleted EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-10

Figures Z4* Z1 Z4*

Z3 Z3 Z3 Z3 Z3 Z4*/** Z3 Z1 Z1 Z1 Z3 Z4*/**

Z1 Z3 Z1 Z1 Z1 Z3 Z1 Z2* Z3 Z1 Z1 Z1 Z3 Z2*

Z3 Z3 Z3 Z3 Z3 Z2 Z1 Z2

(*) denotes location where INTACT or DAMAGED FUEL ASSEMBLY can be stored.

(**) denotes location where INTACT or FAILED FUEL can be stored.

Zone Number 1 2(1) 3 4(1)

Maximum Number of Fuel Assemblies 13 4 16 4 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.5 3.0 0.7 3.0(2)

Maximum Decay Heat per DSC (kW) 41.8 Lower Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.5 3.5 0.7 3.2(2)

Maximum Decay Heat per DSC (kW) 44.5 Notes:

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.
2. The maximum allowable heat load per FAILED FUEL is 0.8 kW.

Figure 1K Heat Load Zone Configuration 11 for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-11

Figures Heat Load Zone Configuration 2 Zone Number 1 2 3(1)

Maximum Decay Heat (kW/FA plus channel, if included) 0.4 0.5 0.5 Maximum Number of Fuel Assemblies 29 20 40 Maximum Decay Heat per DSC (kW) 41.6 Heat Load Zone Configuration 3 Zone Number 1 2 3(2)

Maximum Decay Heat (kW/FA plus channel, if included) 0.36 0.4 0.4 Maximum Number of Fuel Assemblies 29 20 40 Maximum Decay Heat per DSC (kW) 34.44 Notes:

1. The minimum cooling time for HLZC 2 Zone 3 in the EOS-TC108 is 9.7 years.
2. The minimum cooling time for HLZC 3 Zone 3 in the EOS-TC108 is 9.0 years.

Figure 2 EOS-89BTH DSC Heat Load Zone Configurations for transfer in the EOS-TC108 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-12

Figures P P P P I I I P P I I I I I P P I I I I I P P I I I I I P P I I I P P P P Figure 3 Peripheral (P) and Inner (I) Fuel Locations for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-13

Figures Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA NA 0.393 NA NA NA Maximum Decay Heat per Zone (kW) NA NA 22.0 NA NA NA Maximum Decay Heat per DSC (kW) 22.0 Figure 4A Heat Load Zone Configuration 1 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-14

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) NA 8.75 NA 11.52 6.48 NA Maximum Decay Heat per DSC (kW) 22.0(1)

(1) Adjust payload to maintain total DSC heat load within the specified limit Figure 4B Heat Load Zone Configuration 2 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-15

Figures Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 NA NA NA NA Maximum Decay Heat per Zone (kW) NA 19.4 NA NA NA NA Maximum Decay Heat per DSC (kW) 19.4 Figure 4C Heat Load Zone Configuration 3 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-16

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) 0.22 0.35 NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) 1.98 5.60 NA 11.52 6.48 NA Maximum Decay Heat per DSC (kW) 19.4(1)

(1) Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4D Heat Load Zone Configuration 4 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-17

Figures Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 NA NA 0.54 NA Maximum Decay Heat per Zone (kW) NA 3.15 NA NA 28.08 NA Maximum Decay Heat per DSC (kW) 31.2(1)

(1) Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4E Heat Load Zone Configuration 5 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-18

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z6 Z6 Z6 Z6 Z6 Z4 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z4 Z6 Z6 Z6 Z6 Z6 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) 0.22 NA NA 0.48 0.54 0.70 Maximum Decay Heat per Zone (kW) 1.98 NA NA 11.52 6.48 11.20 Maximum Decay Heat per DSC (kW) 31.2 Figure 4F Heat Load Zone Configuration 6 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-19

Figures Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA NA NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) NA NA NA 12.00 19.44 NA Maximum Decay Heat per DSC (kW) 31.2(1)

(1) Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4G Heat Load Zone Configuration 7 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-20

Figures Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) NA 0.35 0.393 0.48 0.54 NA Maximum Decay Heat per Zone (kW) NA 3.15 6.288 11.52 6.48 NA Maximum Decay Heat per DSC (kW) 27.4(1)

(1) Adjust payload to maintain total DSC heat load within the specified limit.

Figure 4H Heat Load Zone Configuration 8 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-21

Figures Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Zone 1 Zone 2 Zone 3 Zone 4 Maximum Decay Heat 0.393 0.48 0.35 0.35 (kW/FA)

Maximum Decay Heat per 3.54 7.68 4.2 8.4 Zone (kW)

Maximum Decay Heat per 22.0(1)

DSC (kW)

Note 1: Adjust payload to maintain total canister heat load within the specified limit.

Figure 4I Heat Load Zone Configuration 9 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-22

Figures Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Zone 1 Zone 2 Zone 3 Zone 4 Maximum Decay Heat 0.393 0.48(2) 1.20(2) 0.48(2)

(kW/FA)

Maximum Decay Heat per 3.54 7.68 14.4 11.52 Zone (kW)

Maximum Decay Heat per 31.2(1)

DSC (kW)

Note 1: Adjust payload to maintain total canister heat load within the specified limit.

Note 2: If the maximum decay heat per FA in Zone 3 is greater than 0.9 kW, the maximum decay heat per FA in Zone 2 and Zone 4 shall be less than or equal to 0.393 kW.

Figure 4J Heat Load Zone Configuration 10 for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-23

Figures C C C A B C C C B A B B C C C B B C C C C C C C C C C C C C C C C C C C C C C C C C C C B B C C C B B A B C C C B A C C C Corner Locations Interior Locations A B See Note 1 See Note 2 Interior/Edge Locations C

See Note 3 Note 1: When loading up to 4 damaged or 4 failed assemblies, these must be placed in corner A locations, and the remaining locations B and C shall be loaded with intact fuel. If fewer than 4 damaged or 4 failed assemblies are to be stored, the remaining A locations may be loaded with intact fuel provided they meet the respective damaged or failed enrichment limits of Table 10 or Table 11. Damaged and failed fuel shall not be mixed, i.e., up to four damaged assemblies may be stored, or up to four failed assemblies may be stored in A locations.

Note 2: If loading more than four damaged assemblies, place first four damaged assemblies in the corner A locations per Note 1, and up to 12 additional damaged assemblies in these interior B locations, with the remaining intact in a 61BTH Type 2 Basket. The maximum lattice average initial enrichment of assemblies (damaged or intact stored in the 2x2 cells) is limited to the Five or More Damaged Assemblies column of Table 10. For the 61BTH Type 2 DSC containing both damaged and failed fuel assemblies, this enrichment is limited to the and up to 12 Damaged Assemblies column of Table 11.

Note 3: If loading more than 16 damaged assemblies, place the first 57 damaged assemblies in the interior/edge "C" and the interior B locations. Place the remaining four intact or damaged assemblies in the corner "A" locations. The maximum lattice average initial enrichments of assemblies is limited to the Remaining Four Intact Assemblies or Remaining Four Damaged Assemblies column of Table 12.

Figure 5 Location of Damaged and Failed Fuel Assemblies inside the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-24

Figures P P P P P I I I P P P I I I I I P P I I I I I I I P P I I I I I I I P P I I I I I I I P P I I I I I P P P I I I P P P P P Figure 6 Peripheral (P) and Inner (I) Fuel Locations for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-25

Figures RECONSTITUTED FUEL ASSEMBLIES with 5 irradiated stainless steel rods may be loaded into all peripheral locations (i.e., not restricted). See Figure 6 for peripheral locations.

A RECONSTITUTED FUEL ASSEMBLY with > 5 and 10 irradiated stainless steel rods may be loaded in any peripheral location, with additional restrictions in accordance with Section 2.3. Examples:

If Location B contains a RECONSTITUTED FUEL ASSEMBLY with > 5 irradiated stainless steel rods, peripherally adjacent Locations A and C shall contain fuel assemblies that do not contain irradiated stainless steel rods.

If Locations E and G contain RECONSTITUTED FUEL ASSEMBLIES with > 5 irradiated stainless steel rods, peripherally adjacent Locations D, F, and H shall contain fuel assemblies that do not contain irradiated stainless steel rods.

Figure 7 Peripheral Location Restrictions for Reconstituted Fuel with Irradiated Stainless Steel Rods for the 61BTH Type 2 DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-26

Figures P P P P P I I I P P P I I I I I I I P P I I I I I I I P P I I I I I I I I I P P I I I I I I I I I P P I I I I I I I I I P P I I I I I I I P P I I I I I I I P P P I I I P P P P P Figure 8 Peripheral (P) and Inner (I) Fuel Locations for the EOS-89BTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-27

Figures X X X X X X R X X X X X R R R R R X X X R R R R R R R X X X R R R R R R R X X X R R R R R R R R R X X X R R R R R R R X X X R R R R R R R X X X R R R R R X X X X X R X X X X X X R = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods allowed at these locations.

X = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods not allowed at these locations.

Note: No restrictions on location for RECONSTITUTED FUEL ASSEMBLIES that do not contain irradiated stainless steel rods.

Figure 9 EOS-89BTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-28

Figures C

C B A/C B C C

Note:

1. Location identified as A is for empty placement in 88-FA Loading
2. Locations identified as B are for empty placements in 87-FA Loading
3. Locations identified as C are for empty placements in 84-FA Loading Figure 10 Empty Locations in Short-Loading Configurations for the EOS-89BTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-29

Figures Z6 Z5 Z6 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z4 Z2 Z2 Z2 Z1 Z2 Z2 Z2 Z4 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z6 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z6 Z5 Z3 Z1 Z1 Z1 Z1 Z1 Z1 Z1 Z3 Z5 Z6 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z6 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z4 Z2 Z2 Z2 Z1 Z2 Z2 Z2 Z4 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z6 Z5 Z6 Zone No. Z1 Z2 Z3 Z4 Z5 Z6 Max. Decay Heat per SFA (kW) 0.40 0.60 1.30 1.70 1.30 1.70 No. of Fuel Assemblies 29 20 20 8 4 8 Heat Load Per Zone 11.6 12.0 26.0 13.6 5.2 13.6 Max. Decay Heat per DSC (kW) See Note 1 for EOS-HSM and Note 2 for HSM-MX Notes:

1. Maximum heat load for EOS-89BTH DSC during Storage is 48.2 kW in EOS-HSM.
2. Maximum heat load for EOS-89BTH DSC during Storage is 48.2 kW in lower compartment of HSM-MX and 41.8 kW in upper compartment of HSM-MX.

Figure 11 Maximum Heat Load Configuration 1 for EOS-89BTH DSC (MHLC-89-1) Transferred in the EOS-TC125 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-30

Figures Z4 Z3 Z4 Z4 Z3 Z2 Z3 Z4 Z5 Z3 Z2 Z1 Z2 Z3 Z5 Z6 Z2 Z1 Z2 Z1 Z2 Z6 Z5 Z3 Z2 Z1 Z2 Z3 Z5 Z4 Z3 Z2 Z3 Z4 Z4 Z3 Z4 Zone No. Z1 Z2 Z3 Z4 Z5 Z6 Max. Decay Heat per SFA (kW) 1.5 1.0 2.4 3.5 4.3 1.6 No. of Fuel Assemblies 4 9 10 8 4 2 Heat Load Per Zone 6.0 9.0 24.0 28.0 17.2 3.2 Max. Decay Heat per DSC (kW) See Note 1 Notes:

1. Maximum heat load for EOS-37PTH DSC during Storage is 50.0 kW in the EOS-HSM.
2. See Figure 13 for Damaged/failed fuel locations.
3. MHLC-37-1 is only applicable for transfer operations in an EOS-TC125 or EOS-TC135 transfer cask and storage in an EOS-HSM storage module. It is not applicable to the following configurations:

A. transfer in an EOS-TC108 transfer cask and storage in either an EOS-HSM or HSM-MX storage module or B. transfer in an EOS-TC125 or EOS-TC135 transfer cask and storage in an HSM-MX storage module.

Figure 12 Maximum Heat Load Configuration 1 for EOS-37PTH DSC (MHLC-37-1) Transferred in the EOS-TC125/135 AND Stored in the EOS-HSM EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-31 All Indicated Changes are Enclosure 9, Item 5

Figures D2 F1 D2 D1 D1 D2/F2 D1 D1 D2/F2 F1 F1 D2 D1 D1 D2 D1 D1 F1 Notes:

1. The damaged fuel locations are marked with a D1 for configuration 1, and D2 for configuration 2. Only one configuration may be loaded in each DSC.
2. The Failed fuel locations are marked with an F1 for configuration 1, and F2 for configuration 2. Only one configuration may be loaded in each DSC. Failed fuel in all configurations is limited to 0.8 kW.
3. Damaged and failed fuel shall not be loaded in the same DSC.

Figure 13 Damaged and Failed Fuel Configurations for the EOS-37PTH DSC EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-32

Figures X X X X R R R X X R R R R R X X R R R R R X X R R R R R X X R R R X X X X R = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods allowed at these locations.

X = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods not allowed at these locations.

Note: No restrictions on location for RECONSTITUTED FUEL ASSEMBLIES that do not contain irradiated stainless steel rods.

Figure 14 EOS-37PTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108 EOS System Amendment 4 Proposed Technical Specifications - Revision 1 F-33

Enclosure 7 to E-61991 CoC 1042 Amendment 4, Revision 1 UFSAR Changed Pages Withheld Pursuant to 10 CFR 2.390

Enclosure 8 to E-61991 CoC 1042 Amendment 4, Revision 1 UFSAR Changed Pages (Public)

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Introduction The type of fuel to be stored in the NUHOMS EOS System is light water reactor (LWR) fuel of the PWR and BWR type. The EOS-37PTH DSC is designed to accommodate up to 37 intact PWR FAs with uranium dioxide (UO2) fuel, zirconium alloy cladding, and with or without control components (CCs). The EOS-37PTH DSC is also designed to accommodate up to eight damaged FAs or up to four failed fuel canisters (FFCs) with the balance intact FAs. The EOS-89BTH DSC is designed to accommodate up to 89 intact BWR FAs with uranium dioxide (UO2) fuel, zirconium alloy cladding, and with or without fuel channels. The physical and radiological characteristics of these payloads are provided in Chapter 2.

The NUHOMS EOS System consists of the following components as shown in Figure 1-1 through Figure 1-7:

  • Two dual-purpose (storage and transportation) DSCs that provide confinement in an inert environment, structural support and criticality control for the FAs; the EOS-37PTH DSC and the EOS-89BTH DSC. The DSC shells are welded stainless or duplex steel pressure vessels that includes thick shield plugs at either end to maintain occupational exposures as low as reasonably achievable (ALARA).
  • Three EOS-37PTH DSC basket designs, see the table below. Basket Type 1 has non-staggered basket plates as shown in EOS01-1010-SAR for storage of intact fuel only. Basket Type 4 incorporates a plate configuration that offsets the aluminum plates to allow for damaged/failed fuel storage in the EOS-37PTH DSC. The Type 4 basket has two options. The Type 4H basket is fabricated from a coated steel plate for higher emissivity and higher conductivity poison plate, while the Type 4L basket has a low emissivity coated steel plate and a low conductivity poison plate. These requirements are further detailed in the material and design limits discussed in Section 4.2 and Section 10.1. The 4HA basket type is a subset of the 4H basket where the aluminum basket plates are anodized. This anodizing is required when HLZCs with decay heats greater than 3.5 kW are stored in the basket. When used without distinction, 4H includes both basket types 4H and 4HA. The Type 5 basket is similar to the Type 1 basket in configuration, but also incorporates the low emissivity coated steel plates and low conductivity poison plate. The maximum heat loads and the allowable HLZCs for Basket Types 1, 4 and 5 are listed in Table 1-2. Each of these basket types also allows for two levels of boron loading in the poison plates (A and B). Each basket type is designated as follows:

EOS-37PTH Basket Types Neutron Poison TYPE 1 (Non- TYPE 4 TYPE 5 Loading staggered basket (Damaged/Failed (Non-staggered, Option high K, high ) Fuel) Low K, Low )

A (Low B-10) A1 A4H/A4HA/A4L A5 B (High B-10) B1 B4H/B4HA/B4L B5 March 2023 Revision 1 72-1042 Amendment 4 Page 1-4 All Indicated Changes are Enclosure 9, Item 2

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Basket transition rails provide the transition between the rectangular basket structure and the cylindrical DSC shell. The transition rails are made of extruded aluminum open or solid sections, which are reinforced with internal steel as necessary. These transition rails provide the transition to a cylindrical exterior surface to match the inside surface of the DSC shell. The transition rails support the fuel basket egg-crate structure and transfer mechanical loads to the DSC shell. They also provide the thermal conduction path from the basket assembly to the DSC shell wall, making the basket assembly efficient in rejecting heat from its payload. The nominal dimension of each fuel compartment opening is sized to accommodate the limiting assembly with sufficient clearance around the FA.

The EOS-89BTH DSC is designed for a maximum heat load of 48.2 kW. The internal basket assembly contains a storage position for each FA. The criticality analysis credits the fixed borated neutron absorbing material placed between the FAs.

Sub-criticality during wet loading/unloading, drying, sealing, transfer, and storage operations is maintained through the geometric separation of the FAs by the basket assembly, and the neutron absorbing capability of the EOS-89BTH DSC materials, as applicable. Based on poison material and boron loading, and the HLZC, nine basket types are provided, as shown on drawing EOS01-1020-SAR. Poison material and boron loading requirements are discussed in Chapter 10.

In general, the dimensions of the EOS-89BTH DSC components described in the text and provided in figures and tables of this UFSAR are nominal dimensions for general system description purposes. Actual design dimensions are contained in the drawings in Section 1.3.2 of this UFSAR. See Sections 1.4.2 and 2.2.2 for a discussion of the contents authorized to be stored in this DSC.

Horizontal Storage Module Each EOS-HSM or EOS-HSMS provides a self-contained modular structure for storage of spent fuel canisterized in an EOS-37PTH or EOS-89BTH DSC. The EOS-HSMS is essentially identical to the EOS-HSM except that the base is split into two sections (upper and lower), which are tied together via shear keys and six grouted tie rods. Henceforth in this UFSAR, EOS-HSM is used interchangeably for both the EOS-HSM and EOS-HSMS. The EOS-HSM is constructed from reinforced concrete and structural steel.

The EOS-HSM may be constructed from reinforced concrete and steel, termed EOS-HSM-RC, or alternatively, the components may be constructed from a steel-plate composite. The steel-plate composite EOS-HSM is termed the EOS-HSM-SC, and is included when generically referring to the EOS-HSM. Only the split base, FPS configuration (EOS-HSMS-FPS-SC) is available for the steel-plate composite EOS-HSM. As such, any generic reference to a steel-plate composite HSM in this UFSAR refers to this configuration. See clarification table below.

March 2023 Revision 1 72-1042 Amendment 4 Page 1-12 All Indicated Changes are in response to RSI 3-1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 EOS-HSM EOS-HSM-RC EOS-HSM-SC EOS-HSM-RC EOS-HSMS-RC - -

EOS-HSM-FPS-RC EOS-HSMS-FPS-RC - EOS-HSMS-FPS-SC The thick roof and walls of the EOS-HSM provide substantial neutron and gamma shielding. Contact doses for the EOS-HSM are designed to be ALARA. The key design parameters of the EOS-HSM are listed in Table 1-1.

The nominal thickness of the EOS-HSM roof is 44 inches for biological shielding.

Separate shield walls at the end of a module row in conjunction with the module base wall, provide a minimum total thickness of four feet for shielding. Similarly, an additional shield wall is used at the rear of the module if the ISFSI is configured as single module arrays to provide a minimum total thickness of four feet of shielding with the module base rear wall. Sufficient shielding is provided by thick concrete side walls between EOS-HSMs in an array to minimize doses in adjacent EOS-HSMs during loading and retrieval operations.

72.48 72.48 72.48 March 2023 Revision 1 72-1042 Amendment 4 Page 1-13 All Indicated Changes are in response to RSI 3-1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Table 1-1 Key Design Parameters of the NUHOMS EOS System Components (2 Pages) 311,000 EOS-Short EOS-HSM-RC 334,000 EOS-Medium(1)

Total Weight not including DSC (lbs.)

351,000 EOS-Long EOS-HSM-SC Total Weight not including 361,000 DSC (lbs.)

Materials of Construction (EOS-HSM-RC) Reinforced concrete and structural steel Materials of Construction (EOS-HSM-SC) Concrete, structural steel for faceplates, and carbon/alloy/bolt steels for studs and tie bars Heat Removal Conduction, convection, and radiation OnSite Transfer Cask (EOS-TC) 206.76 EOS-TC108 Overall Length (in) 208.21 EOS-TC125 228.71 EOS-TC135 90.61 EOS-TC108 w/ NS tank 88.50 EOS-TC108 w/o NS tank Outside Diameter (in) 95.38 maximum EOS-TC125 95.38 EOS-TC135 199.17 EOS-TC108 Cavity Length (in) 199.25 EOS-TC125 219.75 EOS-TC135 2.50 EOS-TC108 Lead Thickness (in) 3.12-3.56 EOS-TC125 3.56 EOS-TC135 46.5 EOS-TC108 Gross Weight (with neutron shield and steel 62.1 maximum EOS-TC125 lid and no payload) (tons) 67.9 EOS-TC135 Carbon steel shell assemblies and closures with lead shielding, aluminum and carbon steel Materials of Construction lids and aluminum neutron shield tank for the TC108 Internal Atmosphere Air Note 1: Without the optional outlet vent dose reduction hardware presented in Item 2, Section 1.2.1.3.

March 2023 Revision 1 72-1042 Amendment 4 Page 1-33 All Indicated Changes are in response to RSI 3-1

Proprietary and Security Related Information for Drawing EOS01-3300-SAR, Rev. 0B Withheld Pursuant to 10 CFR 2.390

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 In addition, LCO 3.1.3 of the TS [2-18] notes that a minimum duration of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> shall be allowed for transfer operations (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> for the transfer and 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for recovery as allowed by the action statements). Table 2-10 presents the minimum transfer time limits for the various HLZCs. It should be noted that these time limits are the minimum required time limits for transfer operations based on the maximum allowable heat loads for each HLZC and a new time limit may be determined to allow for longer time limits if the DSC is loaded to less than the maximum allowable limit.

The evaluations presented for storage in EOS-HSM and EOS-TC125/135 in Chapter 4 present the methodology to evaluate and pre-qualify additional HLZCs. , Item 4 Section 2.4.3.1 presents the detailed methodology to evaluate and pre-qualify additional HLZCs based on these evaluations.

For EOS-37PTH DSCs transferred in the EOS-TC108 and stored in EOS-HSM or HSM-MX and for those transferred in EOS-TC125/TC135 and stored in the HSM-MX, Figures 1B through 1I and Figure 1K of the Technical Specifications [2-18] apply.

These figures define the maximum decay heat, failed/damaged fuel locations, and other parameters for PWR fuel assemblies, with or without CCs, authorized for storage. These tables are used to ensure that the decay heat load of the FA to be stored is less than that as specified in each table, and that the corresponding radiation source term is consistent with the shielding analysis presented in Chapter 6. The parameters of Section 2.1 of the TS [2-18] apply. Enclosure 9, Item 7 The heat loads listed in Figure 2-3a through Figure 2-3m and Figures 1B through 1I, and Figure 1K of the TS [2-18] are the maximum allowable heat loads for each FA and the maximum allowable heat load per DSC. These heat loads can be reduced to ensure adequate heat removal capability is maintained to accommodate site-specific conditions. Some examples of the site-specific conditions are a higher ambient temperature, different blocked vent duration, a requirement to use a different neutron absorber plate or a requirement for a specific coating on the basket steel plates or to accommodate longer DSC lengths than those specified in Section 1.1 for the EOS-Short HSM, based on ISFSI layout considerations. Each of these changes could result in a change to the inputs of the thermal evaluation utilized in the UFSAR. To ensure that adequate heat removal is maintained with these modified inputs, the bounding evaluations for storage and transfer operations should be re-evaluated. The maximum fuel cladding temperature based on the modified inputs shall be lower than the maximum fuel cladding temperatures listed in the Chapter 4 and Chapter A.4 for the same bounding evaluations. In addition, new HLZCs may also be developed based on site-specific conditions using the approach presented in Section 2.4.3.1. Any design changes considered to accommodate the site specific conditions shall be evaluated as noted in Section 2.4.3.1. These site-specific configurations shall be listed in Table 1-2 along with a description of the limitations with regards to the heat loads or the new HLZC applicable to these configurations.

Enclosure 9, Item 8 March 2023 Revision 1 72-1042 Amendment 4 Page 2-10

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 2.3.3 Water Level (Flood) Design EOS-HSM inlet vents are blocked when the depth of flooding is greater than 0.76 m (2 ft-6 in.) above the level of the ISFSI basemat. The DSC is wetted when flooding exceeds a depth of 1.7 m (5 ft-8 in.) above ISFSI basemat. Greater flood heights result in submersion of the DSC and blockage of the EOS-HSM outlet vents.

The DSC and EOS-HSM are conservatively designed for an enveloping design basis flood. The flood is postulated to result from natural phenomena such as tsunamis and seiches as specified by 10 CFR 72.122(b) [2-6]. A bounding assumption of a 15-meter (50-foot) flood height and water velocity of 4.6 m/sec (15 fps) is used for the flood evaluation. The EOS-HSM is evaluated for the effects of the 4.6 m/sec (15 fps) water current impinging upon the side of the submerged EOS-HSM. The DSC is subjected to an external pressure equivalent to a 15-meter (50-foot) head of water.

These evaluations are presented in Chapter 3 and Section 12.3.5. The effects of water reflection on DSC criticality safety are addressed in Chapter 7. Due to its short term infrequent use, the onsite EOS-TC is not explicitly evaluated for flood effects. ISFSI procedures should ensure that the EOS-TC is not used for DSC transfer during flood conditions.

The plant-specific design basis flood (if the possibility for flooding exists at a particular ISFSI site) should be evaluated by the licensee and shown to be enveloped by the flooding conditions used for this generic evaluation of the NUHOMS EOS System.

2.3.4 Seismic Design The seismic design criteria for the EOS-HSM are based on the NRC Regulatory Guide 1.60 [2-13] response spectra anchored at a zero period acceleration (ZPA) of 0.45g in the horizontal direction and 0.30g in the vertical direction and enhanced frequency content above 9 Hz. The horizontal and vertical components of the design response spectra correspond to a maximum horizontal ground acceleration of 1.0g are shown in Figure 2-1. The seismic structural evaluations consider both stability evaluation and stress qualification of the EOS-HSM. The structural stress qualifications of the HSM concrete, steel, and SC components are conservatively based on the spectra shown in Figure 2-1 anchored at 0.50g in the horizontal direction and 0.33g in the vertical direction. The stability criteria for seismic loading are based on the stability response of a single, freestanding EOS-HSM with an end shield wall.

The EOS-HSMs in the array have no anchorage to the concrete basemat and there are no positive structural connections between EOS-HSMs. The stability analyses consider the effects of sliding and rocking motions, and determine the maximum possible sliding of a single module with and without an end shield wall. The EOS-HSM will neither slide nor overturn at design ZPA of 0.45g in the horizontal direction and 0.30g in the vertical direction.

March 2023 Revision 1 72-1042 Amendment 4 Page 2-17 All Indicated Changes are in response to RSI 3-2

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Zone Number 1 2 3 4 Maximum Decay Heat (kW/FA plus CCs, if included) 0.7 0.5 2.4 0.85 Maximum Number of Fuel Assemblies 5 6 8 18 Maximum Decay Heat per DSC (kW) 41.0 Notes:

1. Adjust payload to maintain total canister heat load within the specified limit.
2. See UFSAR Table 1-2 or TS Section 2.1 for applicable system configurations.

Figure 2-3e Heat Load Zone Configuration 5 for the EOS-37PTH DSC March 2023 Revision 1 72-1042 Amendment 4 Page 2-64 All Indicated Changes are Enclosure 9, Item 4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Table 3-7 Summary of EOS-89BTH DSC Component Weights Component Description Weight (lb)

DSC Shell 17,000 Basket Assembly 27,400 Dry/Unloaded/Open DSC 44,400 89 Fuel Assemblies 62,800 DSC Top Shield Plug 7,340 Flooding Water in Loaded DSC 15,900 Flooded/Loaded Open DSC 131,000 DSC Top Cover Plates 5060 Sealed/Loaded DSC Weight 120,000 Table 3-8 Summary of EOS-HSM Weight and Center of Gravity Component Description Value Total Weight (lb) 350,000 Empty EOS-HSM-RC Long Center of Gravity from Bottom in Vertical Direction 126.5 inches EOS-HSM-RC Long Loaded Maximum Weight (lb) 484,000 with EOS-37PTH DSC Center of Gravity from Bottom in Vertical Direction 120.8 inches Total Weight (lb) 362,000 Empty EOS-HSM-SC Center of Gravity from Bottom in Vertical Direction 125.6 inches EOS-HSM-SC Loaded with Maximum Weight (lb) 481,000 EOS-37PTH DSC Center of Gravity from Bottom in Vertical Direction 120.7 inches Notes:

1. The weight and center of gravity values listed in the table are corresponding to the maximum concrete density of 160 pcf.

March 2023 Revision 1 72-1042 Amendment 4 Page 3-35 All Indicated Changes are in response to RSI 3-1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-4 Appendix 3.9.8 is newly added in Amendment 4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD The design basis seismic load used for analysis of the EOS-HSM-SC components is as discussed in Section 2.3.4. Based on N690-18 [3.9.8-3], a damping value of five percent is used for seismic analysis of SC components of the EOS-HSM-SC. An evaluation of the frequency content of the loaded EOS-HSM-SC is performed to determine the amplified accelerations associated with the design basis seismic response spectra for the EOS-HSM-SC. Modal frequencies and mass participation factors of the EOS-HSM-SC are shown in Table 3.9.8-1. The results of the frequency analysis yield a lowest frequency of 18.29 Hz in the transverse direction and 30.12 Hz in the longitudinal direction.

Because the lowest vertical frequency exceeds 45 Hz, the spectral acceleration is not amplified in the vertical direction. Therefore, based on the Regulatory Guide 1.60 response spectra amplifications, and conservatively using zero period acceleration (ZPA) accelerations of 0.50g and 0.33g in the horizontal and vertical directions, respectively, the corresponding seismic accelerations used for the design of the EOS-HSM-SC are 1.073g and 0.703g in the transverse and RSI 3-7 longitudinal directions, respectively, and 0.333g in the vertical direction. The resulting amplified accelerations are given in Table 3.9.8-2. An equivalent static analysis of the EOS-HSM-SC is performed by applying the amplified seismic acceleration loads as described in Section 3.9.4.9.2 for the EOS-HSM-RC.

Like the EOS-HSM-RC, for sites where the response spectra at the base of the HSM are larger than analyzed, more than one module may need to tie together to prevent significant sliding or to prevent the modules from banging into each other causing unacceptable damage. The requirements on the faceplate, stud, and tie may also need to be reviewed, and the faceplate thickness and tie size may be increased for such sites. The tie and stud spacing may be adjusted as well.

The stability evaluation of the EOS-HSM-SC due to a 0.45g Horizontal/0.30g Vertical seismic load is discussed in Section 3.9.8.11. The stability evaluation by dynamic analysis shall be performed using the analysis methodology RSI 3-11 described in CoC 1029 [3.9.8-10].

Seismic analysis of the EOS-HSM-SC heat shields consists of a modal time-history analysis of the EOS-HSM-SC for obtaining four percent damped in-structure response spectra (ISRS) at heat shields support locations as shown in Figure 3.9.8-5 through Figure 3.9.8-10. The earthquake time histories compatible with the RG 1.60 spectra, described in Section 3.9.4.9.2 for the EOS-HSM-RC, are used as seismic input motion. The ISRS for the heat shields is conservatively determined using ground motion based on the RG 1.60 spectra anchored at 0.50g and 0.33g in the horizontal and vertical directions, respectively. The modal frequencies and mass participation factors of the heat shields, described in Section 3.9.4.9.2 for the EOS-HSM-FPS-RC, are applicable to the EOS-HSM-SC. The results of an equivalent static analysis of the EOS-HSM-SC heat shields using the seismic acceleration load corresponding to the previously obtained ISRS are discussed in Section 3.9.8.10.4.

March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-6 Appendix 3.9.8 is newly added in Amendment 4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Structural Evaluation The load combination results of the EOS-HSM-SC components are presented in this section.

3.9.8.10.1 EOS-HSM-SC SC Components The governing load demands and capacities, and corresponding load combinations for each of the SC components of the EOS-HSM-SC are presented in Table 3.9.8-3. The demand-to-capacity ratios for all component categories are less than one for all strength categories.

3.9.8.10.2 FPS DSC Support Structure The FPS DSC support structure of the EOS-HSM-SC is identical with the support structure for the EOS-HSM-FPS-RC, and the load combination results for the FPS DSC support structure provided in Table 3.9.4-17a, Table 3.9.4-21a, RSI 3-12 and Table 3.9.4-22a are applicable to the FPS DSC support structure of the EOS-HSM-SC except for the results for the stop plate, which are affected by the accident earthquake load combination. The demand-to-capacity ratio for the stop plate of the EOS-HSM-SC is 0.98. Therefore, the DSC support structure is adequate to resist the foreseeable loads applied to it.

March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-7 Appendix 3.9.8 is newly added in Amendment 4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Component Ry (kip) Tn (sec)

End Wall 1624 0.0300 Rear Wall 4680 0.00626 Base Front Wall 3174 0.00471 Roof 1648 0.0264 RSI 3-3 Door 1257 0.00168 The maximum value of ductility ratio of all five components is found to be less than 1.0, which meets the allowable ductility ratio of 1.0 for shear-controlled SC components with shear reinforcement spaced more than half the section thickness as per RG 1.243 [3.9.8-4]. Therefore, the global response of the EOS-HSM-SC is within the deformation limit meeting the ductility requirement. Per

[3.9.8-11], punching shear as a failure mode is inherently prevented by an SC wall designed to resist local failure. Therefore, no additional evaluation of the EOS-HSM-SC is required for punching shear.

3.9.8.10.7 Connections and Embedments The structural fasteners, connections, and concrete embedments used in the EOS-HSM-SC are in general identical to those for the EOS-HSM-RC. [

RSI 3-10

] The demands, capacities, and demand-to-capacity ratios of the connections and embedments are presented in Table 3.9.8-5 and Table 3.9.8-6.

Stability Evaluation The sliding and overturning stability analyses of the EOS-HSM-SC due to design basis wind, flood, seismic, and massive missile impact loads are performed using hand calculations.

March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-10 Appendix 3.9.8 is newly added in Amendment 4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD 3.9.8.11.1 General Description The stability of the EOS-HSM-SC unit is evaluated for the same four load cases that are considered for the EOS-HSM-RC in Appendix 3.9.7, namely, tornado-generated wind loads, massive missile impact loads, flood loads, and seismic loads. The weight of an empty EOS-HSM-SC is between 306.8 kips minimum and 360.8 kips maximum. As in the stability evaluation of the EOS-HSM-RC, bounding upper and lower values of concrete density are considered; a concrete-to-concrete friction coefficient of 0.6 is used; the stability analysis considers rigid body motions; and the differential pressure load caused by the tornado pressure drop is ignored. Consideration is also given to partial steel-to-concrete friction at the base of the HSM resulting in an effective friction coefficient of 0.576. The stability is evaluated using the same methodologies described in Appendix 3.9.7.

3.9.8.11.2 Design Basis Tornado (Wind and Missile)

The tornado wind speed and resulting wind pressures on the module considered in the stability analysis are described in Section 3.9.7.1.8.1. Conservatively, a single loaded module (including door, roof, and OVC) with one end shield wall is considered. The HSM is taken at the bounding minimum weight of 306.8 kips to minimize resistances to sliding and overturning. Results of stability evaluations for the design basis tornado are summarized below.

  • Static Overturning Analysis due to Tornado Wind: The safety factor against overturning computed for the EOS-HSM-SC due to tornado wind is 1.61.
  • Dynamic Overturning Analysis of Tornado Wind Concurrent with Massive Missile Impact Loading: The evaluation for the EOS-HSM-RC presented in Section 3.9.7.1.8.1.2 is bounding for the EOS-HSM-SC.
  • Time-Dependent Overturning Analysis of Tornado Wind Concurrent with Massive Missile Impact Loading: The evaluation for the EOS-HSM-RC presented in Section 3.9.7.1.8.1.3 is bounding for the EOS-HSM-SC.
  • Sliding Analysis for Tornado Wind Concurrent with Massive Missile Impact loading: The sliding distance of the EOS-HSM-SC is calculated to be 1.09 inches.
  • Time-Dependent Sliding Analysis for Tornado Wind Concurrent with Massive Impact Loading: The governing sliding displacement is 1.10 inch.

3.9.8.11.3 Flood Loads The flood load on the module considered in the stability analysis is described in Section 3.9.7.1.8.2. Conservatively, a single loaded module (including door, roof, and OVC) with one end shield wall is considered. The HSM is taken at the bounding minimum weight of 306.8 kips to minimize resistances to sliding and overturning. Results of stability evaluations for the flood loads are summarized below.

March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-11 Appendix 3.9.8 is newly added in Amendment 4 All Indicated Changes are in response to RSI 3-1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD

  • Overturning Analysis: The factor of safety against overturning for a single, freestanding EOS-HSM-SC due to the postulated design basis flood water velocity is 1.15.
  • Sliding Analysis: The factor of safety against sliding for a single, freestanding EOS-HSM-SC due to the postulated design basis flood water velocity is 1.37.

3.9.8.11.4 Seismic Load The seismic load on the module considered in the stability analysis is described in Section 3.9.7.1.8.3. Conservatively, a single loaded module (including door, roof, and OVC) with one end shield wall is considered. Both the bounding upper and lower weights of the module are considered. Results of stability evaluations for the seismic load are summarized below.

  • Static Overturning Analysis of the EOS-HSM-SC due to Seismic Load: The safety factor against overturning is 1.02 and is greater than 1. The difference in safety factors between the maximum and minimum concrete density cases is negligibly small. The maximum acceptable acceleration values before tipping occurs are 0.45g horizontal and 0.30g vertical.
  • Static Sliding Analysis of the EOS-HSM-SC due to Seismic Load: The safety factor against sliding is 1.02 and is greater than 1. The difference in safety factors between the maximum and minimum concrete density cases is negligibly small. The maximum acceptable acceleration values before sliding occurs are 0.45g horizontal and 0.30g vertical.
  • Seismic Stability of the DSC on DSC Support Structure inside the EOS-HSM-SC: The safety factor against DSC lift off from the DSC support is 1.01. The maximum acceptable acceleration values before any uplift occurs are 0.455g horizontal and 0.303g vertical.

3.9.8.11.5 Interaction of EOS-HSM-SC with Adjacent Modules When interaction of the EOS-HSM-SC with adjacent modulus is considered, the maximum displacement obtained in this section is conservative and bounding and this conservatism also applies to overturning, as described in Section 3.9.7.1.8.4 for the EOS-HSM-RC.

3.9.8.11.6 Results For the maximum seismic acceleration of 0.45g horizontal and 0.30g vertical, no sliding will occur. Also, there will be no overturning at this set of seismic accelerations.

For flood, wind, and missile impact, it is also determined that the uplift values are small and so the DSC remains stable on the support rails. For seismic loading, it is also determined that there is no uplift of the DSC.

March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-12 Appendix 3.9.8 is newly added in Amendment 4 All Indicated Changes are in response to RSI 3-1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD References Code of Federal Regulation Title 10, Part 72 (10CFR Part 72), Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.

ANSI/ANS 57.9-1984, Design Criteria for an Independent Spent Fuel Storage Installation (Dry Storage Type), American National Standards Institute, American Nuclear Society.

AISC (2018), Specification for Safety-Related Steel Structures for Nuclear Facilities, ANSI/AISC N690-18, American Institute of Steel Construction.

U.S. Nuclear Regulatory Commission, Regulatory Guide 1.243, Safety-Related Steel Structures and Steel-plate Composite Walls for other than Reactor Vessels and Containments, Rev. 0, August 2021.

American Institute of Steel Construction, AISC Manual of Steel Construction, 13th Edition or Later.

AISC (2016), Specification for Structural Steel Buildings, ANSI/AISC 360-16, American Institute of Steel Construction.

Not used.

Not used.

ANSYS Computer Code and Users Manual, Release 17.1.

AREVA Inc., Updated Final Safety Analysis Report for The Standardized Advanced NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 11, US NRC Docket Number 72-1029, November 2021.

J. M. Kim, J. Bruhl, and A. Varma, Design of SC Walls Subjected to Impactive Loading for Local and Global Demands, 23rd Conference on Structural Mechanics in Reactor Technology, 2015.

Bechtel Corporation, Design Guide Number C-2.45 for Design of Structures for Tornado Missile Impact, Revision 0, April 1982.

ACI 349-06, Code Requirements for Nuclear Safety Related Concrete Structures, American Concrete Institute.

March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-14 Appendix 3.9.8 is newly added in Amendment 4 All Indicated Changes are in response to RSI 3-10

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Proprietary Information on Pages 3.9.8-17 and 3.9.8-18 Withheld Pursuant to 10 CFR 2.390 March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-17 Appendix 3.9.8 is newly added in Amendment 4 All Indicated Changes are in response to RSI 3-9

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Proprietary Information on Pages 3.9.8-20 and 3.9.8-21 Withheld Pursuant to 10 CFR 2.390 March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-20 Appendix 3.9.8 is newly added in Amendment 4 All Indicated Changes are in response to RSI 3-10

NUHOMS EOS System Updated Final Safety Analysis Report Rev. TBD, TBD Proprietary Information on Pages 3.9.8-26 through 3.9.8-31 Withheld Pursuant to 10 CFR 2.390 March 2023 Revision 1 72-1042 Amendment 4 Page 3.9.8-26 Appendix 3.9.8 is newly added in Amendment 4 All Indicated Changes are in response to RSI 3-11

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 EOS-HSM Horizontal Storage Module The applicable codes for EOS-HSM-RC are:

  • DSC support structure design per AISC Manual of Steel Construction [8-11].

The applicable codes for EOS-HSM-SC are:

  • Steel-plate composite design and construction per ANSI/AISC-N690-18 [8-53].
  • DSC support structure design per AISC Manual of Steel Construction [8-11].

Cement, aggregate, reinforcing steel, faceplate, studs, tie bars, and DSC support structure steel conform to ASTM specifications.

The EOS-HSM concrete is designed and constructed using a specified compressive strength of 5,000 psi, normal weight concrete. The specified compressive strength may be determined at 28 days or at test age designated for determination of f'c. The cement is Type II or Type III Portland cement meeting the requirements of ASTM C150 [8-54] or blended Portland cement meeting the requirements of ASTM C595 [8-55]. The concrete aggregate meets the specifications of ASTM C33. The reinforcing steel is ASTM A615 or A706 Gr 60 deformed bars placed vertically and horizontally at each face of the walls and roof.

For EOS-HSM-RC, the concrete surface temperature limits criteria are based on the provisions in Section 3.5.1.2 of NUREG-1536, as follows:

  • If concrete temperatures in general or local areas are at or below 200 °F for normal/off-normal conditions/occurrences, no tests to prove capability at elevated temperatures or reduction of concrete strength are required.
  • If concrete temperatures in general or local areas exceed 200 °F but do not exceed 300 °F, no tests to prove capability at elevated temperatures or reduction of concrete strength are required if the aggregates have a coefficient of thermal expansion (CTE) no greater than 6x10-6 in/in/°F, or are one of the following materials: limestone, dolomite, marble, basalt, granite, gabbro, or rhyolite.

March 2023 Revision 1 72-1042 Amendment 4 Page 8-5 All Indicated Changes are Enclosure 9, Item 1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Outokumpu, Data Sheet Duplex Stainless Steel.

Euronorm EN485-2, Aluminium and aluminium alloys - Sheet, strip and plate - Part 2: Mechanical properties.

Euronorm EN573-3, Aluminium and aluminium alloys - Chemical composition and form of wrought products - Part 3: Chemical composition and form of products.

Ryerson Plastics, Edition 26.

The Steel Construction Institute, Design Manual for Structural Stainless Steel, 4th Edition, 2017.

American National Standard, Specification for Safety-Related Steel Structures for Nuclear Facilities, ANSI/AISC-N690-18, June 28, 2018.

ASTM International, C150/C150M, Standard Specification for Portland Cement.

ASTM International, C595/C595M, Standard Specification for Blended Hydraulic Cements.

March 2023 Revision 1 72-1042 Amendment 4 Page 8-25 All Indicated Changes are Enclosure 9, Item 1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 A.8.2 Materials Selection This section discusses the materials used in the HSM-MX components. Table A.8-1 summarizes the materials selected for HSM-MX. Materials utilized in the HSM-MX are largely the same as those used in the EOS-HSM, and the materials for the EOS-DSCs and EOS-TCs have not changed. Therefore, the tables described in Section 8.2 also applicable to HSM-MX. Temperature-dependent mechanical and thermal properties for the materials listed in Table A.8-1 are presented in Table A.8-2 through Table A.8-4.

A.8.2.1 Applicable Codes and Standards and Alternatives A.8.2.1.1 EOS-37PTH and EOS-89BTH DSC No change from Section 8.2.1.1.

A.8.2.1.2 EOS-TC Transfer Cask No change from Section 8.2.1.2.

A.8.2.1.3 HSM-MX Horizontal Storage Module The applicable codes for the HSM-MX are:

  • DSC Support design per AISC Manual of Steel Construction [A.8-7].

Cement, aggregate, reinforcing steel, and steel structures conform to ASTM specifications.

The HSM-MX concrete subcomponents are designed and constructed using a specified 28-day compressive strength of 5,000 psi, normal weight concrete. The cement is Type II or Type III Portland cement meeting the requirements of ASTM C150 [A.8-19] or blended Portland cement meeting the requirements of ASTM C595

[A.8-20]. The concrete aggregate meets the specifications of ASTM C33. The reinforcing steel is ASTM A615 or A706 Gr. 60 deformed bars placed vertically and horizontally at each face of the walls, roof and slabs.

The concrete surface temperature limits criteria are based on the provisions in Section 3.5.1.2 of NUREG-1536, as follows:

  • If concrete temperatures in general or local areas are at or below 200 °F for normal/off-normal conditions/occurrences, no tests to prove capability at elevated temperatures or reduction of concrete strength are required.
  • If concrete temperatures, in general, or local areas exceed 200 °F, but do not exceed 300 °F, no tests to prove capability at elevated temperatures or reduction of concrete strength are required if the aggregates have a coefficient of thermal March 2023 Revision 1 72-1042 Amendment 4 Page A.8-3 All Indicated Changes are Enclosure 9, Item 1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 A.8.7 References A.8-1 NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General license Facility, Revision 1, U.S. Nuclear Regulatory Commission, July 2010.

A.8-2 American Society of Mechanical Engineers, ASME Boiler and Pressure Vessel Code, 2010 Edition with 2011 Addenda.

A.8-3 Mark Fintel, Handbook of Concrete Engineering, September 1974.

A.8-4 ACI-318-08, Building Code Requirement for Structural Concrete and Commentary, American Concrete Institute.

A.8-5 American Concrete Institute, Code Requirements for Nuclear Safety Related Concrete Structures, ACI-349-06.

A.8-6 PNNL-15870, Re. 1, Compendium of Material Composition Data for Radiation Transport Modeling, Pacific Northwest National Laboratory, March 2011.

A.8-7 American Institute of Steel Construction, Manual of Steel Construction, 13th Edition or 14th Edition.

A.8-8 Mark Fintel, Handbook of Concrete Engineering, Second Edition, September 1985.

A.8-9 ASTM A572/A572M, Standard Specification for High-Strength Low-Alloy Columbium-Vanadium Structural Steel, Latest Edition.

A.8-10 ACI-349-13, Code Requirements for Nuclear Safety Related Concrete Structures and Commentary, American Concrete Institute.

A.8-11 American Welding Society, AWS D1.1, March 2010, Structural Welding Code-Steel.

A.8-12 [

. ]

A.8-13 C. P. Larrabee, S. K. Coburn, The Atmospheric Corrosion of Steels as Influenced by Changes in Chemical Composition, First International Congress on Metallic Corrosion, 1962 A.8-14 ASTM A992, Standard Specification for Structural Steel Shapes.

A.8-15 Duke Energy Carolinas, LLC, Oconee Nuclear Station, Docket No. 72-4, License No.

SNM-2503, License Renewal Application for the Site-Specific Independent Spent Fuel Storage Installation (ISFSI) - Response to Requests for Additional Information, License Amendment Request No. 2007-06, ADAMS ML090370066, January 30, 2009 (Response to Question A-4).

A.8-16 Calvert Cliffs Nuclear Power Plant, Independent Spent Fuel Storage Installation, Material License No. SNM-2505, Docket No. 72-8, Response to Request for Supplemental Information, RE: Calvert Cliffs Independent Spent Fuel Storage Installation License Renewal Application (TAC No. L24475), ADAMS ML12212A216, July 27, 2012.

A.8-17 CoC 1042 Appendix A, NUHOMS EOS System Generic Technical Specifications, Amendment 4.

March 2023 Revision 1 72-1042 Amendment 4 Page A.8-12 All Indicated Changes are Enclosure 9, Item 1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 A.8-18 ASTM A588/A588M, "Standard Specification for High-Strength Low-Alloy Structural Steel, up to 50 ksi [345 MPa] Minimum Yield Point, with Atmospheric Corrosion Resistance."

A.8-19 ASTM International, C150/C150M Standard Specification for Portland Cement.

A.8-20 ASTM International, C595/C595M, Standard Specification for Blended Hydraulic Cements.

March 2023 Revision 1 72-1042 Amendment 4 Page A.8-13 All Indicated Changes are Enclosure 9, Item 1

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 B.9.1.6 DSC Transfer to the HSM-MX CAUTION: The insides of empty compartments have the potential for high dose rates due to adjacent loaded compartments. Proper as low as reasonably achievable (ALARA) practices should be followed for operations inside these compartments and in the areas outside these compartments whenever the door from the empty compartment has been removed.

1. MX-LC Rails are installed, aligned, and verified on the pad for the loading campaign. Alignment is verified to the specifically designated features on the face of HSM-MX.

CAUTION: Prior to using the MX-LC to lift the loaded TC above the applicable lift height restriction of Technical Specification (TS) 5.2.1 [B.9-2], verify that the requirements of a safe condition and forecast, as defined in Section A.2.4.2.4, are satisfied regarding local weather. If, during operations with the MX-LC, the weather deteriorates from a safe condition and forecast, place the MX-LC in a secured position with the loaded TC at a height not to exceed the applicable lift height restriction of TS 5.2.1 [B.9-2].

2. Prior to transferring the TC to the ISFSI, remove the HSM-MX door, inspect the compartment of the HSM-MX, remove any debris, and ready the HSM-MX to receive a DSC. The doors on adjacent compartments should remain in place.
3. Inspect the DSC and MX-RRT support pads, and add spacer blocks at the front and rear DSC supports inside HSM-MX compartment.
4. For ALARA purposes, reinstall the HSM-MX door.
5. Inspect the HSM-MX air inlet and outlets to ensure that they are clear of debris.

Inspect the screens on the air inlet and outlets for damage.

CAUTION: The insides of empty compartments have the potential for high dose rates due to adjacent loaded compartments. Proper ALARA practices should be followed for operations inside these compartments and in the areas outside these compartments whenever the MX-RRT operations are being performed.

6. Remove the MX-RRT cover plates and shield plugs.
7. Insert and install MX-RRT into HSM-MX. Extend the MX-RRT rollers, secure and verify that the rollers are extended.
8. Transfer the TC from the plants fuel/reactor building to the ISFSI along the designated transfer route.

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NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22

9. Once at the ISFSI, move the transfer trailer inside the MX-LC at home position between the skid and the MX-LC grappling mechanism.
10. Use the MX-LC grappling mechanism to capture the skid along with TC, disengage the skid positioning system, move the skid up in the vertical direction to clear it from the transfer trailer, and then the transfer trailer is moved from MX-LC.
11. Remove the FC system and install the ram cylinder assembly.

11.a If the HSM-MX upper compartment is to be loaded, install the MX-LC brackets to the embedments on each adjacent HSM-MX module.

12. Remove the HSM-MX door and, if applicable, install the HSM-MX TC adapter.
13. Unbolt and remove the TC top cover plate.
14. Move the MX-LC along the rail in front of the HSM-MX until the TC is laterally aligned with the targeted compartment.

14a. Prior to lifting the TC above the applicable lift height restriction of TS 5.2.1 [B.9-2],

install the MX-LC wheel chocks on the MX-LC gantry boxes with a gap of no greater than 1/4 inch.

15. The skid is moved until the target compartment is reached. If necessary, adjust the MX-LC position until the MX-LC is properly aligned with the targeted compartment. For alignment with the HSM-MX upper modules, the MX-LC wheel chocks may be temporarily adjusted by no greater than 1/4 inch while performing lateral alignment of the TC.
16. Secure the MX-LC/skid/cask to the front wall embedments of the HSM-MX using the restraints.

16a. Install the MX-LC wheel chocks on the MX-LC gantry boxes, if not previously installed.

17. The hydraulic power unit is connected to the ram cylinder. The grapple is moved until it engages with the grapple ring of the canister. Using the ram cylinder, fully insert the DSC into the HSM-MX compartment.
18. Disengage the ram grapple mechanism so that the grapple is retracted away from the DSC grapple ring.
19. Retract the MX-RRT rollers; the DSC is lowered onto the HSM-MX front and rear DSC supports.

March 2023 Revision 1 72-1042 Amendment 4 Page B.9-13 All Indicated Changes are Enclosure 9, Item 6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 Note: The time limit for transfer operations, if any, starts with the initiation of the TC/DSC annulus water draining described in Step 9 of Section 9.1.4 and ends when the DSC is fully seated onto the front and rear DSC supports.

CAUTION: Verify that the applicable time limits for transfer operations of Section 3.1.3 of the Technical Specifications [B.9-2] are met.

20. Remove the wall embedments from the HSM-MX.

20a. Remove the MX-LC wheel chocks on the MX-LC gantry boxes.

21. Retract the skid with TC from docking position and lower it.
22. If applicable, remove the HSM-MX TC adapter. Place the HSM-MX door.

Verify that the HSM dose rates are compliant with the limits specified in Section 5.1.2 of the Technical Specifications [B.9-2].

23. Move MX-LC to its home position, and the transfer trailer is moved into accepting position.
24. Lower the skid along with TC onto the transfer trailer. Reconnect the skid positioning system. Remove the ram cylinder assembly.
25. Bolt the TC cover plate into place, tightening the bolts to the required torque in a star pattern.

CAUTION: The insides of empty compartments have the potential for high dose rates due to adjacent loaded compartments. Proper ALARA practices should be followed for operations inside these compartments and in the areas outside these compartments whenever the MX-RRT operations are being performed.

26. Remove the MX-RRT from the HSM-MX.
27. Place MX-RRT shield plugs and cover plates for the MX-RRT accesses.
28. Move the transfer trailer from MX-LC to the designated equipment storage area.

Return the remaining transfer equipment to the storage area.

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

B.9.1.7 Monitoring Operations Refer to Section A.9.1.7.

March 2023 Revision 1 72-1042 Amendment 4 Page B.9-14 All Indicated Changes are Enclosure 9, Item 6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 B.9.2 Procedures for Unloading the DSC The following section outlines the procedures for retrieving the DSC from the HSM-MX. The procedures for removing the FAs from the DSC are the same as described in Section T.8.2.2 of reference [B.9-3].

B.9.2.1 DSC Retrieval from the HSM-MX

1. Ready the TC, transfer trailer, loading crane, and skid for service. Fill the TC liquid neutron shield and remove the top cover plate from the TC. Transfer the trailer into the ISFSI.

Note: Verify that a TC spacer of appropriate height is placed inside the TC to provide the correct airflow and interface at the top of the TC during cutting and unloading operations for DSCs that are shorter than the TC cavity length.

2. MATRIX MX-LC rails are installed, aligned, and verified on the pad for the unloading campaign. Alignment is verified to the specifically designated features on the face of HSM-MX.

CAUTION: Prior to using the MX-LC to lift the loaded TC above the applicable lift height restriction of Technical Specification (TS) 5.2.1 [B.9-2], verify that the requirements of a safe condition and forecast, as defined in Section A.2.4.2.4, are satisfied regarding local weather. If, during operations with the MX-LC, the weather deteriorates from a safe condition and forecast, place the MX-LC in a secured position with the loaded TC at a height not to exceed the applicable lift height restriction of TS 5.2.1 [B.9-2].

3. Move the transfer trailer inside the MX-LC home position between the skid and the MX-LC grappling mechanism.
4. Use the MX-LC grappling mechanism to capture the skid along with TC, disengage the skid positioning system, move the skid up vertically to clear it from the transfer trailer, and then move the transfer trailer from the MX-LC.
5. Install the ram cylinder assembly.

CAUTION: The insides of empty compartments have the potential for high dose rates due to adjacent loaded compartments. Proper ALARA practices should be followed for operations inside these compartments and in the areas outside these compartments whenever the MX-RRT operations are being performed.

6. Remove the MX-RRT shield blocks plugs and cover plates.

March 2023 Revision 1 72-1042 Amendment 4 Page B.9-15 All Indicated Changes are Enclosure 9, Item 6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22

7. Insert and install MX-RRT into HSM-MX. Extend the MX-RRT rollers, secure and verify that the rollers are extended.

7a. If the HSM-MX upper compartment is to be unloaded, install the MX-LC brackets to the embedments on each adjacent HSM-MX module.

CAUTION: The insides of empty compartments have the potential for high dose rates due to adjacent loaded compartments. Proper ALARA practices should be followed for operations inside these compartments and in the areas outside these compartments whenever the door from the empty compartment has been removed.

8. Remove the HSM-MX door and, if applicable, install the HSM-MX TC adapter.
9. Unbolt and remove the TC top cover plate.
10. Move the MX-LC along the rail in front of the HSM-MX until the TC is laterally aligned with the targeted compartment.
11. Not used.
12. The skid is moved until the target compartment is reached. If necessary, adjust the MX-LC position until the MX-LC is properly aligned with the targeted compartment.
13. Secure the MX-LC/skid/cask to the front wall embedments of the HSM-MX using the restraints.

13a. Install the MX-LC wheel chocks on the MX-LC gantry boxes with a gap of no greater than 1/4 inch.

14. The hydraulic power unit is connected to the ram cylinder. The grapple is moved until it engages with the grapple ring of the canister. Using ram cylinder, fully insert the ram into HSM-MX compartment.
15. Operate the ram grapple and engage the grapple arms with the DSC grapple ring.
16. Recheck all alignment marks and ready all systems for DSC transfer.

CAUTION: The time limits for the unloading of the DSC should be determined using the heat loads at the time of the unloading operation and the methodology presented in Sections 4.5 and 4.6 before pulling the DSC out of the HSM-MX.

17. Activate the ram to pull the DSC into the TC.
18. Disengage the ram grapple mechanism so that the grapple is retracted away from the DSC grapple ring.

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NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22

19. Retract and disengage the ram system from the TC and move it clear of the TC.

Remove the TC embedments from the HSM-MX.

20. Retract the skid with TC from docking position and lower it.

20a. Remove the MX-LC wheel chocks on the MX-LC gantry boxes.

21. Move MX-LC to its home position and move the transfer trailer to accepting position.
22. Lower the skid along with TC onto the transfer trailer. Reconnect the skid positioning system, remove the ram cylinder assembly, and reinstall the FC system.
23. Bolt the TC cover plate into place, tightening the bolts to the required torque in a star pattern.

CAUTION: The insides of empty compartments have the potential for high dose rates due to adjacent loaded compartments. Proper ALARA practices should be followed for operations inside these compartments and in the areas outside these compartments whenever the MX-RRT operations are being performed.

24. Disconnect MX-RRT operating mechanism and retract MX-RRT to MX-RRT handling device.
25. Place MX-RRT shield plugs and cover plates for the MX-RRT accesses.
26. Move the transfer trailer from MX-LC and ready the trailer for transfer.
27. If applicable, remove the HSM-MX TC adapter. Replace the HSM-MX door.

B.9.2.2 Removal of Fuel from the DSC Refer to Section T.8.2.2 of reference [B.9-3].

March 2023 Revision 1 72-1042 Amendment 4 Page B.9-17 All Indicated Changes are Enclosure 9, Item 6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 B.9.3 References B.9-1 U.S. Nuclear Regulatory Commission, Regulatory Guide 3.61 Standard Format and Content for a Topical Safety Analysis Report for a Spent Fuel Dry Storage Container, February 1989.

B.9-2 CoC 1042 Appendix A, NUHOMS EOS System Generic Technical Specifications, Amendment 4.

B.9-3 TN Americas LLC, Updated Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 18, USNRC Docket Number 72-1004, January 2019.

B.9-4 SNT-TC-1A, American Society for Nondestructive Testing, Personnel Qualification and Certification in Nondestructive Testing, 1992.

B.9-5 U.S. Nuclear Regulatory Commission, Interim Staff Guidance (ISG)-22, Potential Rod Splitting Due to Exposures to an Oxidizing Atmosphere during Short-term Cask Loading Operations in LWR or Other Uranium Oxide Based Fuel.

B.9-6 U.S. Nuclear Regulatory Commission, Office of the Nuclear Material Safety and Safeguards, Safety Evaluation of VECTRA Technologies Response to Nuclear Regulatory Commission Bulletin 96-04 for the NUHOMS-24P and NUHOMS-7P.

B.9-7 U.S. Nuclear Regulatory Commission Bulletin 96-04, Chemical, Galvanic or Other Reactions in Spent Fuel Storage and Transportation Casks, July 5, 1996.

March 2023 Revision 1 72-1042 Amendment 4 Page B.9-18 All Indicated Changes are Enclosure 9, Item 6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 At the ISFSI site, the transfer skid/trailer is used in conjunction with the MATRIX loading crane (MX-LC). The MX-LC is used to assist in loading the DSC into the HSM. The MX-LC is designed, fabricated, installed, tested, inspected, and qualified in accordance with the applicable portions of ASME NOG-1 [B.12-7], as a Type I gantry type of crane, per the guidance provided in NUREG-0612 [B.12-5]. The transfer skid/trailer is backed up to, and aligned with, the HSM-MX using transfer equipment. The OS197-TC/MX-LC is docked with, and secured to, the HSM-MX access opening. The MX-RRT rollers are extended into HSM-MX through front wall slots for the MX-RRT and secured. The loaded DSC is transferred to or from the HSM-MX using transfer equipment. The MX-RRT is then lowered to place the DSC on the front and rear DSC supports in the HSM-MX. As a result, for a loaded OS197-TC drop accident to occur during these operations is considered non credible.

ASME NOG-1 [B.12-7] prohibits the use of a Type I gantry crane under extreme weather conditions (i.e., tornado wind and missile conditions, and high winds), and imposes administrative controls to place the crane in a secured position in advance of impending extreme weather conditions involving wind gusts that are expected to exceed the operating wind limit of the ISFSI equipment. This is consistent with the definition of a safe condition and forecast, defined in Section A.2.4.2.4, which requires that a safe condition and forecast be verified for the lift height restrictions of a loaded TC/DSC.

Lifts of the OS197-TC loaded with the dry storage canister are made within the existing heavy load requirements and procedures of the licensed nuclear power plant.

The OS197-TC design meets requirements of NUREG-0612 [B.12-5] and American National Standards Institute (ANSI) N14.6 [B.12-6].

The OS197-TC is transferred to the ISFSI in a horizontal configuration. Therefore, the only drop accident evaluated during storage or transfer operations is a side drop or a corner drop.

The OS197-TC and DSC are evaluated for postulated side and corner drops to demonstrate structural integrity during transfer and plant handling.

Accident Analysis No change to accident analysis as described in Sections T.11.2.5.2 of [B.12-3].

Accident Dose Calculation The accident dose of 46 mrem at 100 m from the EOS-TC documented in Section 12.3.1 of the EOS UFSAR Revision TBD bounds the accident dose for the 61BTH DSC within the OS197-TC. This dose is significantly below the 10 CFR 72.106 limit of 5 rem. Accident dose rates for the OS197-TC are provided in Section B.6.4.3.

Corrective Actions No change to corrective actions as described in Sections T.11.2.5.4 of [B.12-3].

March 2023 Revision 1 72-1042 Amendment 4 Page B.12-6 All Indicated Changes are Enclosure 9, Item 6

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 4, 06/22 B.12.4 References B.12-1 Title 10, Code of Federal Regulations, Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.

B.12-2 ANSI/ANS-57.9-1984, Design Criteria for an Independent Spent Fuel Storage Installation (Dry Storage Type), American National Standards Institute, American Nuclear Society.

B.12-3 TN Americas LLC, Updated Final Safety Analysis Report for the Standardized NUHOMS Horizontal Modular Storage System for Irradiated Nuclear Fuel, Revision 18, USNRC Docket Number 72-1004, January 2019.

B.12-4 Title 10, Code of Federal Regulations, Part 50, Domestic Licensing of Production and Utilization Facilities.

B.12-5 NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, U.S. Nuclear Regulatory Commission, July 1980.

B.12-6 ANSI N14.6-1993, American National Standards for Special Lifting Device for Shipping Containers Weighing 10,000 lbs. or More for Nuclear Materials, American National Standards Institute.

B.12-7 ASME NOG-1-2015, Rules for Construction of Overhead and Gantry Cranes (Top Running Bridge, Multiple Girder), The American Society of Mechanical Engineers, New York, New York, 2015.

March 2023 Revision 1 72-1042 Amendment 4 Page B.12-11 All Indicated Changes are Enclosure 9, Item 6

Enclosure 9 to E-61991 The scope of Amendment 4 to the NUHOMS EOS Certificate of Compliance (CoC) No. 1042 has been modified as described below.

Change No. 1:

An additional scope item has been added to allow use of a blended Portland cement that would be certified to the requirements of ASTM C595. The reason for this change is that the cement supplier will no longer provide cement in accordance with ASTM C150 since the supplier is transitioning to a cement with a smaller carbon footprint that includes 10% limestone. This change supports continued EOS HSM and EOS HSM-MX fabrication activities.

In support of this additional scope, changes have been made to UFSAR Sections 8.2.1.3, EOS HSM Horizontal Storage Module; 8.7, References; A.8.2.1.3, HSM-MX Horizontal Storage Module; and A.8.7, References.

Change No. 2:

An editorial correction has been made to UFSAR page 1-4 where, in the fourth paragraph, the number 1 has been added before 4, and 5 are listed in Table 1-2. The number 1, which refers to Basket Type 1 was inadvertently omitted under Revision 0 of the Amendment 4 application.

Change No. 3:

An editorial correction has been made to UFSAR page 2-10 where, in the third paragraph, a space is added between the word Section and 2.4.3.1.

Change No. 4 An editorial correction has been made to UFSAR page 2-64 where, for this specific figure and table, incorrect information is presented. The correct information is in Technical Specifications (TS) page F-5 and the figure and table on UFSAR page 2-64 have been corrected to match the figure and table on TS page F-5.

Change No. 5 An editorial correction has been made on TS page F-31 where (87.4kW total) has been deleted. This entry should have been omitted under Revision 0 of the Amendment 4 application.

Additionally, Note 3 to this figure has been edited for clarification.

Change 6 An additional scope item has been added with respect to the use of the MX-LC for the 61BTH Type 2 dry shielded canisters (DSCs). The reason for this change is that, under Amendment 3, TN addressed detail to demonstrate the single failure proof capability of the Matrix Loading Crane (MX-LC). That information was provided to demonstrate compliance with CoC 1042 Amendment 3 Condition 5 for lifts of the dry shielded canister (DSC) and transfer cask (TC) above heights not analyzed for an accidental drop, and to comply with CoC 1042 Amendment 3 Page 1 of 2

Enclosure 9 to E-61991 TS 5.2.1 for TC/DSC lifting height limits. However, TN omitted addressing use of the MX-LC for the 61BTH DSCs. This change supports the continued use of the HSM-MX Horizontal Storage Module in conjunction with the MX-LC for 61BTH DSCs.

In support of this additional scope, changes have been made to UFSAR Sections B.9.1.6, DSC Transfer to the HSM-MX; B.9.2.1, DSC Retrieval from the HSM-MX; B.9.3, References; B.12.3.1, OS197 Transfer Cask (TC) Drop; and B.12.4, References.

Change 7 An editorial correction has been made to UFSAR page 2-10, where in the fourth paragraph reference to the heat load zoning configurations from the TS, specifically Figures 1B through 1I and Figure 1K, were omitted in error under Revision 0 of the Amendment 4 application. The phrase 'and Figures 1B through 1I, and Figure 1K of the TS' has been added.

Change 8 An additional scope item has been added to clarify the scenarios under which the maximum heat loads can be reduced for EOS-37PTH. The reason for this change is to clarify the different site-specific conditions that could result in a reduction in the maximum heat load for existing heat load zoning configurations (HLZCs) and to also note that new HLZCs could be developed based on the maximum heat load zoning configuration (MHLC) methodology described in Section 2.4.3.1. This clarifying language has been added to the fourth paragraph on UFSAR page 2-10 and to page 2-2 of the TS.

Page 2 of 2

Enclosure 10 to E-61991 RSI 3-8 Reference - C-2.45, Tornado Missile Impact Withheld Pursuant to 10 CFR 2.390