Text

Attachment 2 - Copy of NRC Certificate of Compliance for Spent Fuel Storage Casks
	ML23146A141
Person / Time
Site:	Holtec
Issue date:	05/26/2023
From:	; Holtec
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML23146A138	List: ML23146A139; ML23146A140; ML23146A141; ML23146A142;
References
	5014962
	Download: ML23146A141 (1)
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Attachment 2 to Holtec Letter 5014962 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (10-2004) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Page 1 of 5 The U.S. Nuclear Regulatory Commission is issuing this Certificate of Compliance pursuant to Title 10 of the Code of Federal Regulations, Part 72, "Licensing Requirements for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste" (10 CFR Part 72). This certificate is issued in accordance with 10 CFR 72.238, certifying that the storage design and contents described below meet the applicable safety standards set forth in 10 CFR Part 72, Subpart L, and on the basis of the Final Safety Analysis Report (FSAR) of the cask design. This certificate is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, and the conditions specified below.

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

Date Date 1014 05/31/00 05/31/20 72-1014 178 TBD USA/72-1014 Issued To: (Name/Address)

Holtec International Holtec Technology Campus One Holtec Blvd.

Camden, NJ 08104 Safety Analysis Report Title Holtec International Inc.,

Final Safety Analysis Report for the HI-STORM 100 Cask System CONDITIONS This certificate is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Technical Specifications) and Appendix B (Approved Contents and Design Features) for aboveground systems except Version E, HI-TRAC MS, MPC-32M, and Version 1 of MPC-32 and MPC-68; the attached Appendix C (Technical Specifications) and Appendix D (Approved Contents and Design Features) for the HI-STORM 100S Version E, HI-TRAC MS, MPC-32M, and Version 1 of MPC-32 and MPC-68M; or the attached Appendix A-100U (Technical Specifications) and Appendix B-100U (Approved Contents and Design Features) for underground systems, and the conditions specified below:

1. CASK

a. Model No.: HI-STORM 100 Cask System The HI-STORM 100 Cask System (the cask) consists of the following components: (1) interchangeable multi-purpose canisters (MPCs), which contain the fuel; (2) a storage overpack (HI-STORM), which contains the MPC during storage; and (3) a transfer cask (HI-TRAC), which contains the MPC during loading, unloading and transfer operations. The cask stores up to 32 pressurized water reactor fuel assemblies or 68 boiling water reactor fuel assemblies.

b. Description The HI-STORM 100 Cask System is certified as described in the Final Safety Analysis Report (FSAR) and in the U.S. Nuclear Regulatory Commissions (NRC) Safety Evaluation Report (SER) accompanying the Certificate of Compliance (CoC). The cask comprises three discrete components: the MPC, the HI-TRAC transfer cask, and the HI-STORM storage overpack.

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

Page 1 of 155

Attachment 2 to Holtec Letter 5014962 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 187 Supplemental Sheet Page 2 of 5

1. b. Description (continued)

There are twelve types of MPCs: the MPC-24, MPC-24E, MPC-24EF, MPC-32, MPC-32F, MPC-32 Version 1, MPC-32M, MPC-68, MPC-68 Version 1, MPC-68F, MPC-68FF, and MPC-68M. The number suffix indicates the maximum number of fuel assemblies permitted to be loaded in the MPC. All twelve MPC models have the same external diameter.

The HI-TRAC transfer cask provides shielding and structural protection of the MPC during loading, unloading, and movement of the MPC from the spent fuel pool to the storage overpack. The transfer cask is a multi-walled (carbon steel/lead/carbon steel) cylindrical vessel with a neutron shield jacket attached to the exterior.

All transfer cask sizes have identical cavity diameters. The higher weight HI-TRAC transfer casks have thicker shielding and larger outer dimensions than the lighter HI-TRAC transfer casks.

Above Ground Systems The HI-STORM 100 or 100S storage overpack provides shielding and structural protection of the MPC during storage. The HI-STORM 100S is a variation of the HI-STORM 100 overpack design. The overpack is a heavy-walled steel and concrete, cylindrical vessel. Its side wall consists of plain (un-reinforced) concrete that is enclosed between inner and outer carbon steel shells. The overpack has air vents at the bottom and at the top to allow air to circulate naturally through the cavity to cool the MPC inside. A loaded MPC is stored within the HI-STORM 100 or 100S storage overpack in a vertical orientation. The HI-STORM 100A and 100SA are variants of the HI-STORM 100 family and are outfitted with an extended baseplate and gussets to enable the overpack to be anchored to the concrete storage pad in high seismic applications. The version E can be arrayed in a free standing or anchored configuration.

Underground Systems The HI-STORM 100U System is an underground storage system identified with the HI-STORM 100 Cask System. The HI-STORM 100U storage Vertical Ventilated Module (VVM) utilizes a storage design identified as an air-cooled vault or caisson. The HI-STORM 100U storage VVM relies on vertical ventilation instead of conduction through the soil, as it is essentially a below-grade storage cavity. Air inlets and outlets allow air to circulate naturally through the cavity to cool the MPC inside. The subterranean steel structure is seal welded to prevent ingress of any groundwater from the surrounding subgrade, and it is mounted on a stiff foundation.

The surrounding subgrade and a top surface pad provide significant radiation shielding. A loaded MPC is stored within the HI-STORM 100U storage VVM in the vertical orientation.

2. OPERATING PROCEDURES Written operating procedures shall be prepared for cask handling, loading, movement, surveillance, and maintenance. The users site-specific written operating procedures shall be consistent with the technical basis described in Chapter 8 of the FSAR.

3. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written cask acceptance tests and maintenance program shall be prepared consistent with the technical basis described in Chapter 9 of the FSAR.

Page 2 of 155

Attachment 2 to Holtec Letter 5014962 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 178 Supplemental Sheet Page 3 of 5

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

5. HEAVY LOADS REQUIREMENTS Each lift of an MPC, a HI-TRAC transfer cask, or any HI-STORM overpack must be made in accordance to the existing heavy loads requirements and procedures of the licensed facility at which the lift is made. A plant-specific review (under 10 CFR 50.59 or 10 CFR 72.48, if applicable) is required to show operational compliance with existing plant specific heavy loads requirements. Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 5.5 of Appendix A or Section 5.2 of Appendix C and Sections 3.4.6 and 3.5 (if applicable) of Appendix B or D, for above ground systems, section 5.5 of Appendix A-100U for the underground systems.

6. APPROVED CONTENTS Contents of the HI-STORM 100 Cask System must meet the fuel specifications given in Appendices B or D, as applicable, for aboveground systems or B-100U for underground systems to this certificate.

7. DESIGN FEATURES Features or characteristics for the site, cask or ancillary equipment must be in accordance with Appendices B or D, as applicable, for aboveground systems or B-100U for underground systems to this certificate.

8. CHANGES TO THE CERTIFICATE OF COMPLIANCE The holder of this certificate who desires to make changes to the certificate, which includes Appendices A, C, and A-100U (Technical Specifications) and Appendices B, D, and B-100U (Approved Contents and Design Features), shall submit an application for amendment of the certificate.

9. SPECIAL REQUIREMENTS FOR FIRST SYSTEMS IN PLACE

a. For the storage configuration, each user of a HI-STORM 100 Cask and HI-STORM 100U Cask with a heat load equal to or greater than 20 kW shall perform a thermal validation test in which the user measures the total air mass flow rate through the cask system using direct measurements of air velocity in the inlet vents. The user shall then perform an analysis of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR. The thermal validation test and analysis results shall be submitted in a letter report to the NRC pursuant to 10 CFR 72.4 within 180 days of the users loading of the first cask with a heat load equal to or greater than 20 kW. To satisfy condition 9(a) for casks of the same system type (i.e., HI-STORM 100 casks, HI-STORM 100U casks), in lieu of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed test and analysis submitted by letter report to the NRC that demonstrates validation of the analytic methods described in Chapter 4 of the FSAR.

b. For the transfer configuration, each user of the HI-STORM 100 Cask and HI-STORM 100U Cask shall procure, if necessary, a Supplemental Cooling System (SCS) capable of providing the thermal-hydraulic characteristics (coolant temperature at the annulus inlet, coolant temperature located at the annulus outlet, and coolant flow rate) that will ensure that thermal limits (described in Appendix 2.C of the FSAR) are not exceeded during transfer operations. The thermal-hydraulic characteristics of the SCS shall be determined using the analytical methods described in Chapter 4 for the transfer configuration. For the transfer configuration, each first time user shall measure the SCS thermal-hydraulic characteristics to validate the performance of the SCS. The SCS analysis and validation shall be documented in an update to the 72.212 report within 180 days of the users first transfer operation with the SCS. Condition 9(b) does not apply to the MPC-68M or the MPC-32M.

Page 3 of 155

Attachment 2 to Holtec Letter 5014962 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 178 Supplemental Sheet Page 4 of 5

10. PRE-OPERATIONAL TESTING AND TRAINING EXERCISE A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM 100 Cask System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the MPC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:

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

b. Preparation of the HI-STORM 100 Cask System for fuel loading.

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

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

including appropriate independent verification.

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

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

g. Operation of the HI-STORM 100 SCS or equivalent system, if applicable.

h. Transfer cask upending/downending on the horizontal transfer trailer or other transfer device, as applicable to the sites cask handling arrangement.

i. Transfer of the MPC from the transfer cask to the overpack/VVM.

j. Placement of the HI-STORM 100 Cask System at the ISFSI, for aboveground systems only.

k. HI-STORM 100 Cask System unloading, including flooding MPC cavity, removing MPC lid welds. (A mockup may be used for this dry-run exercise.)

11. The NRC has approved an exemption request by the CoC applicant from the requirements of 10 CFR 72.236(f), to allow a Supplemental Cooling System to provide for decay heat removal in accordance with Section 3.1.4 of Appendices A, C, and A-100U.

Page 4 of 155

Attachment 2 to Holtec Letter 5014962 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 187 Supplemental Sheet Page 5 of 5

12. AUTHORIZATION The HI-STORM 100 Cask System, which is authorized by this certificate, is hereby approved for general use by holders of 10 CFR Part 50 licenses for nuclear reactors at reactor sites under the general license issued pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR 72.212, this certificate, and the attached Appendices A, B, A-100U, B-100U, C, and D as applicable. The HI-STORM 100 Cask System may be fabricated and used in accordance with any approved amendment to CoC No. 1014 listed in 10 CFR 72.214. Each of the licensed HI-STORM 100 System components (i.e., the MPC, overpack, and transfer cask), if fabricated in accordance with any of the approved CoC Amendments, may be used with one another provided an assessment is performed by the CoC holder that demonstrates design compatibility.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION TBD, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555 Dated TBD Attachments:

1. Appendix A

2. Appendix B

3. Appendix A-100U

4. Appendix B-100U

5. Appendix C

6. Appendix D Page 5 of 155

Attachment 2 to Holtec Letter 5014962 PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100 CASK SYSTEM Page 6 of 155

Attachment 2 to Holtec Letter 5014962 TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1-1 1.1 Definitions ............................................................................................ 1.1-1 1.2 Logical Connectors .............................................................................. 1.2-1 1.3 Completion Times ................................................................................ 1.3-1 1.4 Frequency ............................................................................................ 1.4-1 2.0 NOT USED... .................................................................................................. 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY............... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............................. 3.0-2 3.1 SFSC INTEGRITY ............................................................................ 3.1.1-1 3.1.1 Multi-Purpose Canister (MPC) ............................................... 3.1.1-1 3.1.2 SFSC Heat Removal System ................................................. 3.1.2-1 3.1.3 MPC Cavity Reflooding .......................................................... 3.1.3-1 3.1.4 Supplemental Cooling System ............................................... 3.1.4-1 3.2 SFSC RADIATION PROTECTION ................................................... 3.2.1-1 3.2.1 Deleted ................................................................................... 3.2.1-1 3.2.2 TRANSFER CASK Surface Contamination ............................ 3.2.2-1 3.2.3 Deleted ................................................................................... 3.2.3-1 3.3 SFSC CRITICALITY CONTROL ....................................................... 3.3.1-1 3.3.1 Boron Concentration .............................................................. 3.3.1-1 Table 3-1a MPC Cavity Drying Limits for VENTILATED OVERPACK ................... 3.4-1 Table 3-1b MPC Cavity Drying Limits for UNVENTILATED OVERPACK .............. 3.4-3 Table 3-2a MPC Helium Backfill Limits for VENTILATED OVERPACK ................. 3.4-4 Table 3-2b MPC Helium Backfill Limits for UNVENTILATED OVERPACK ............ 3.4-6 Table 3-3 Regionalized Storage Cell Heat Load Limits........................ ..3.4-7 Table 3-4 Uniform Storage Cell Heat Load Limits.............3.4-7 Table 3-5 Completion Time for Actions to Restore SFSC Heat Removal System to Operable .........3.4-8 4.0 NOT USED ........................................................ ............................................ 4.0-1 5.0 ADMINISTRATIVE CONTROLS.................................................................... 5.0-1 5.1 Deleted ................................................................................................ 5.0-1 5.2 Deleted ................................................................................................ 5.0-1 5.3 Deleted ................................................................................................ 5.0-1 5.4 Radioactive Effluent Control Program .................................................. 5.0-1 5.5 Cask Transport Evaluation Program .................................................... 5.0-2 5.6 Deleted ................................................................................................ 5.0-4 5.7 Radiation Protection Program .............................................................. 5.0-5 5.8 Fabrication Helium Leak Test ............................................................. 5.0-8 5.9 Aging Management Program ............................................................... 5.0-9 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A i Page 7 of 155

Attachment 2 to Holtec Letter 5014962 Table 5-1 TRANSFER CASK and Free Standing OVERPACK Lifting Requirements ............................................................................ 5.0-4 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A ii Page 8 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions

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

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

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

CASK TRANSFER FACILITY A CASK TRANSFER FACILITY is an optional (CTF) aboveground or underground system used during the transfer of a loaded MPC between a transfer cask and a storage OVERPACK external to 10 CFR Part 50 controlled structures. The CASK TRANSFER FACILITY includes the following components and equipment: (1) a Cask Transfer Structure used to stabilize the OVERPACK, TRANSFER CASK and/or MPC during lifts involving spent fuel not bounded by the regulations of 10 CFR Part 50, and (2) Either a stationary lifting device or a mobile lifting device used in concert with the stationary structure to lift the OVERPACK, TRANSFER CASK, and/or MPC.

DAMAGED FUEL ASSEMBLY DAMAGED FUEL ASSEMBLIES are fuel assemblies with known or suspected cladding defects, as determined by a review of records, greater than pinhole leaks or hairline cracks, empty fuel rod locations that are not filled with dummy fuel rods, missing structural components such as grid spacers, whose structural integrity has been impaired such that geometric rearrangement of fuel or gross failure of the cladding is expected based on engineering evaluations, or that cannot be handled by normal means. Fuel assemblies that cannot be handled by normal means due to fuel cladding damage are considered FUEL DEBRIS.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-1 Page 9 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 1.1 Definitions (continued)

DAMAGED FUEL DFCs are specially designed enclosures for CONTAINER (DFC) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS which permit gaseous and liquid media to escape while minimizing dispersal of gross particulates.

DFCs authorized for use in the HI-STORM 100 System are as follows:

1. Holtec Dresden Unit 1/Humboldt Bay design

2. Transnuclear Dresden Unit 1 design

3. Holtec Generic BWR design

4. Holtec Generic PWR design DAMAGED FUEL DFIs are specially designed barriers installed at the ISOLATOR (DFI) top and bottom of the storage cell space which permit flow of gaseous and liquid media while preventing the potential migration of fissile material from fuel assemblies with cladding damage. DFIs are used ONLY with damaged fuel assemblies which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected. Damaged fuel stored in DFIs may contain missing or partial fuel rods and/or fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks.

FUEL DEBRIS FUEL DEBRIS is ruptured fuel rods, severed rods, loose fuel pellets, containers or structures that are supporting these loose fuel assembly parts, or fuel assemblies with known or suspected defects which cannot be handled by normal means due to fuel cladding damage.

FUEL BUILDING The FUEL BUILDING is the site-specific power plant facility, governed by the regulations of 10 CFR Part 50, where the loaded OVERPACK or TRANSFER CASK is transferred to or from the transporter.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-2 Page 10 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 GROSSLY BREACHED Spent nuclear fuel rod with a cladding defect that SPENT FUEL ROD could lead to the release of fuel particulate greater than the average size fuel fragment for that particular assembly. A gross cladding breach may be confirmed by visual examination, through a review of reactor operating records indicating the presence of heavy metal isotopes, or other acceptable inspection means.

INTACT FUEL ASSEMBLY INTACT FUEL ASSEMBLIES are fuel assemblies without known or suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means. Fuel assemblies without fuel rods in fuel rod locations shall not be classified as INTACT FUEL ASSEMBLIES unless dummy fuel rods are used to displace an amount of water greater than or equal to that displaced by the fuel rod(s) in the active region. INTACT FUEL ASSEMBLIES may contain integral fuel absorber rods (IFBA) in PWR fuel, or burnable poison rods in BWR fuel.

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

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

MINIMUM ENRICHMENT MINIMUM ENRICHMENT is the minimum assembly average enrichment. Natural uranium and low enrichment blankets are not considered in determining minimum enrichment.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-3 Page 11 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 1.1 Definitions (continued)

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

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

Axial Power Shaping Rods (APSRs), Wet Annular Burnable Absorbers (WABAs), Rod Cluster Control Assemblies (RCCAs), Control Element Assemblies (CEAs), Neutron Source Assemblies (NSAs), water displacement guide tube plugs, orifice rod assemblies, instrument tube tie rods (ITTRs),

vibration suppressor inserts, and components of these devices such as individual rods.

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

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

REDUNDANT PORT COVER REDUNDANT PORT COVER DESIGN refers to DESIGN two independent port cover plates per port opening, where each port cover plate contains multiple pass closure welds.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-4 Page 12 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 1.1 Definitions (continued)

SPENT FUEL STORAGE SFSCs are containers approved for the storage of CASKS (SFSCs) spent fuel assemblies at the ISFSI. The HI-STORM 100 SFSC System consists of the OVERPACK/VVM and its integral MPC.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while an SFSC containing spent fuel is situated within the ISFSI perimeter. STORAGE OPERATIONS does not include MPC TRANSFER.

TRANSFER CASK TRANSFER CASKs are containers designed to contain the MPC during and after loading of spent fuel assemblies and to transfer the MPC to or from the OVERPACK/VVM. The HI-STORM 100 System employs either the 125-Ton or the 100-Ton HI-TRAC TRANSFER CASK. For use with Appendix C, the definition of TRANSFER CASK also includes the HI-TRAC MS.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-5 Page 13 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 1.1 Definitions (continued)

UNDAMAGED FUEL UNDAMAGED FUEL ASSEMBLY is: a) a fuel ASSEMBLY assembly without known or suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means; or b) a BWR fuel assembly with an intact channel, a maximum planar average initial enrichment of 3.3 wt%

U-235, without known or suspected GROSSLY BREACHED SPENT FUEL RODS, and which can be handled by normal means. An UNDAMAGED FUEL ASSEMBLY may be a REPAIRED/

RECONSTITUTED FUEL ASSEMBLY.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an SFSC to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the OVERPACK or TRANSFER CASK is no longer suspended from or secured on the transporter and end when the last fuel assembly is removed from the SFSC. UNLOADING OPERATIONS does not include MPC TRANSFER.

UNVENTILATED OVERPACK The UNVENTILATED OVERPACK is an aboveground OVERPACK which receives and contains the sealed MPC for interim storage at the ISFSI. The UNVENTILATED OVERPACK design is characterized by its absence of inlet and outlet ventilation passages.

VENTILATED OVERPACK The VENTILATED OVERPACK is an aboveground OVERPACK which receives and contains the sealed MPC for interim storage at the ISFSI. The VENTILATED OVERPACK provides passages for airflow to promote heat transfer from the MPC.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-6 Page 14 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.1 1.1 Definitions (continued)

VERTICAL VENTILATED The VVM is a subterranean type overpack which MODULE (VVM) (HI-STORM receives and contains the sealed MPC for interim 100U SYSTEM ONLY) storage at the ISFSI. The VVM supports the MPC in a vertical orientation and provides air flow through cooling passages to promote heat transfer from the MPC to the environs.

ZR ZR means any zirconium-based fuel cladding or fuel channel material authorized for use in a commercial nuclear power plant reactor.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.1-7 Page 15 of 155

Attachment 2 to Holtec Letter 5014962 Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

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

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

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.2-1 Page 16 of 155

Attachment 2 to Holtec Letter 5014962 Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 VERIFY . . .

AND A.2 Restore . . .

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.2-2 Page 17 of 155

Attachment 2 to Holtec Letter 5014962 Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES EXAMPLE 1.2-2 (continued)

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

OR A.2.1 Verify . . .

AND A.2.2.1 Reduce . . .

OR A.2.2.2 Perform . . .

OR A.3 Remove . . .

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

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.2-3 Page 18 of 155

Attachment 2 to Holtec Letter 5014962 Completion Times 1.3 1.3 Completion Times 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operation (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the HI-STORM 100 System is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the HI-STORM 100 System is not within the LCO Applicability.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.3-1 Page 19 of 155

Attachment 2 to Holtec Letter 5014962 Completion Times 1.3 1.3 Completion Times (continued)

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

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required B.1 Perform Action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Action and associated AND Completion Time not met. B.2 Perform Action B.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.3-2 Page 20 of 155

Attachment 2 to Holtec Letter 5014962 Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-2 (continued)

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

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

associated Completion AND Time not met.

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.3-3 Page 21 of 155

Attachment 2 to Holtec Letter 5014962 Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

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

Separate Condition entry is allowed for each component.

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

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

associated Completion AND Time not met.

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

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.3-4 Page 22 of 155

Attachment 2 to Holtec Letter 5014962 Completion Times 1.3 1.3 Completion Times (continued)

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

TIME Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.3-5 Page 23 of 155

Attachment 2 to Holtec Letter 5014962 Frequency 1.4 1.4 Frequency 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

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

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.4-1 Page 24 of 155

Attachment 2 to Holtec Letter 5014962 Frequency 1.4 1.4 Frequency (continued)

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

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

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

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.4-2 Page 25 of 155

Attachment 2 to Holtec Letter 5014962 Frequency 1.4 1.4 Frequency (continued)

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

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

extension allowed by SR 3.0.2.

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

New intervals start upon preparing to restart the specified activity.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 1.4-3 Page 26 of 155

Attachment 2 to Holtec Letter 5014962 2.0 2.0 This section is intentionally left blank Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 2.0-1 Page 27 of 155

Attachment 2 to Holtec Letter 5014962 LCO Applicability 3.0 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

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

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

LCO 3.0.3 Not applicable.

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

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

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.0-1 Page 28 of 155

Attachment 2 to Holtec Letter 5014962 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

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

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

Exceptions to this Specification are stated in the individual Specifications.

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

This delay period is permitted to allow performance of the Surveillance.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.0-2 Page 29 of 155

Attachment 2 to Holtec Letter 5014962 LCO Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period and the (continued) Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

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

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.0-3 Page 30 of 155

Attachment 2 to Holtec Letter 5014962 SFSC Heat Removal System 3.1.1 3.1 SFSC INTEGRITY 3.1.1 Multi-Purpose Canister (MPC)

LCO 3.1.1 The MPC shall be dry and helium filled.

Table 3-1 provides decay heat and burnup limits for forced helium dehydration (FHD) and vacuum drying. FHD is not subject to time limits. Vacuum drying of MPCs may be subject to time limits, from the end of bulk water removal until the start of helium backfill, as shown in Table 3-1.

APPLICABILITY: During TRANSPORT OPERATIONS and STORAGE OPERATIONS.

ACTIONS

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

1. Separate Condition entry is allowed for each MPC.

2. MPC helium leak rate limit for cover plate base metal listed in Condition D and SR 3.1.1.3, is not applicable to casks that were initially loaded to Amendments 2 through 7.

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

met.

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

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.1-1 Page 31 of 155

Attachment 2 to Holtec Letter 5014962 SFSC Heat Removal System 3.1.1 ACTIONS (continued)

B. MPC cavity vacuum B.1 Backfill the MPC cavity with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months drying acceptance helium to a pressure of at criteria not met during least 0.5 atm.

allowable time.

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

AND C.2.1 Develop and initiate 14 days corrective actions necessary to return the MPC to an analyzed condition by adding helium to or removing helium from the MPC.

OR C.2.2 Develop and initiate corrective actions necessary to demonstrate through analysis, using the models and methods from the HI-STORM FSAR, that all limits for cask components and contents will be met.

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

AND D.2 Develop and initiate 7 days corrective actions necessary to return the MPC to compliance with SR 3.1.1.3.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.1-2 Page 32 of 155

Attachment 2 to Holtec Letter 5014962 SFSC Heat Removal System 3.1.1 E. Required Actions and E.1 Remove all fuel assemblies 30 days associated Completion from the SFSC.

Times not met.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify that the MPC cavity has been dried in Once, prior to accordance with the applicable limits in Table TRANSPORT 3-1, within the specified vacuum drying time limits OPERATIONS as applicable.

SR 3.1.1.2 Verify MPC helium backfill quantity is within the Once, prior to limit specified in Table 3-2 for the applicable MPC TRANSPORT model. Re-performance of this surveillance is not OPERATIONS required upon successful completion of Action C.2.2.

SR 3.1.1.3 Verify that the helium leak rate through the MPC Once, prior to vent and drain port cover plates (confinement TRANSPORT welds and the base metal) meets the leaktight OPERATIONS criteria of ANSI N14.5-1997. This surveillance does not need to be performed in the MPC utilizing the REDUNDANT PORT COVER DESIGN.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.1-3 Page 33 of 155

Attachment 2 to Holtec Letter 5014962 SFSC Heat Removal System 3.1.2 3.1 SFSC INTEGRITY 3.1.2 SFSC Heat Removal System LCO 3.1.2 The SFSC Heat Removal System shall be operable

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

The SFSC Heat Removal System is operable when 50% or more of the inlet and outlet vent areas are unblocked and available for flow or when air temperature requirements are met. This LCO only applies to the VENTILATED OVERPACKs.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Heat Removal A.1 Remove blockage. N/A System operable, but partially (<50%) blocked.

B. SFSC Heat Removal B.1 Restore SFSC Heat Table 3-5 System inoperable. Removal System to operable status.

C. Required Action B.1 and C.1 Measure SFSC dose rates Immediately and associated Completion in accordance with the once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Time not met. Radiation Protection thereafter Program.

AND C.2.1 Restore SFSC Heat Table 3-5 Removal System to operable status.

OR C.2.2 Transfer the MPC into a Table 3-5 TRANSFER CASK.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.2-1 Page 34 of 155

Attachment 2 to Holtec Letter 5014962 SFSC Heat Removal System 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlets are free Table 3-5 of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature Table 3-5 monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is

< 155oF for OVERPACKS containing PWR MPCs, < 137oF for OVERPACKS containing BWR MPCs (except MPC-68M) and 164°F for OVERPACKS containing MPC-68M. For sites that have loaded in accordance with the Topical Report HI-2200343-A, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is less than or equal to the value computed using the topical report methodology for T..

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.2-2 Page 35 of 155

Attachment 2 to Holtec Letter 5014962 Fuel Cool-Down 3.1.3 3.1 SFSC INTEGRITY 3.1.3 MPC Cavity Reflooding LCO 3.1.3 The MPC cavity pressure shall be < 100 psig

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

The LCO is only applicable to wet UNLOADING OPERATIONS.

APPLICABILITY: UNLOADING OPERATIONS prior to and during re-flooding.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

COMPLETION CONDITION REQUIRED ACTION TIME A. MPC cavity pressure A.1 Stop re-flooding operations Immediately not within limit. until MPC cavity pressure is within limit.

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

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

AND Once every 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months thereafter when using direct measurement.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.3-1 Page 36 of 155

Attachment 2 to Holtec Letter 5014962 Supplemental Cooling System 3.1.4 3.1 SFSC INTEGRITY 3.1.4 Supplemental Cooling System LCO 3.1.4 A supplemental cooling system (SCS) shall be operable

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

Upon reaching steady state operation, the SCS may be temporarily disabled for a short duration (< 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ) to facilitate necessary operational evolutions, such as movement of the TRANSFER CASK through a door way, or other similar operation.

APPLICABILITY: This LCO is not applicable to the MPC-68M. For all other MPCs this LCO is applicable when the loaded MPC is in the TRANSFER CASK and:

9. a. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of the completion of MPC drying operations in accordance with LCO 3.1.1 or within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months of transferring the MPC into the TRANSFER CASK if the MPC is to be unloaded AND

b. The MPC contains one or more fuel assemblies with an average burnup > 45,000 MWD/MTU AND c1. MPC backfilled to higher helium backfill limits in Table 3-2 AND any storage cell decay heat load exceeds 90% of maximum allowable storage cell heat load defined in Appendix B, Section 2.4.1 or 2.4.2 and FSAR Section 2.1.9.1 procedures.

OR c2. MPC backfilled to lower helium backfill limits in Table 3-2 AND any storage cell heat load exceeds 90% of storage cell heat load limits defined in Tables 3-3 or 3-4.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.1.4-1 Page 37 of 155

Attachment 2 to Holtec Letter 5014962 Supplemental Cooling System 3.1.4 ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. SFSC Supplemental A.1 Restore SFSC 7 days Cooling System Supplemental Cooling inoperable. System to operable status.

B. Required Action A.1 and B.1 Remove all fuel 30 days associated Completion assemblies from the Time not met. SFSC.

SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify SCS is operable. 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.1.4-2 Page 38 of 155

Attachment 2 to Holtec Letter 5014962 Supplemental Cooling System 3.1.4 This page is intentionally left blank Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.1.4-3 Page 39 of 155

Attachment 2 to Holtec Letter 5014962 Deleted 3.2.1 3.2 SFSC RADIATION PROTECTION.

3.2.1 Deleted.

LCO 3.2.1 Deleted.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.2.1-1 Page 40 of 155

Attachment 2 to Holtec Letter 5014962 TRANSFER CASK Surface Contamination 3.2.2 3.2 SFSC RADIATION PROTECTION.

3.2.2 TRANSFER CASK Surface Contamination.

LCO 3.2.2 Removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC shall each not exceed:

9. a. 1000 dpm/100 cm2 from beta and gamma sources

b. 20 dpm/100 cm2 from alpha sources.

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

This LCO is not applicable to the TRANSFER CASK if MPC TRANSFER operations occur inside the FUEL BUILDING.

APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each TRANSFER CASK.

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

met.

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

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.2.2-1 Page 41 of 155

Attachment 2 to Holtec Letter 5014962 Deleted 3.2.3 3.2 SFSC RADIATION PROTECTION.

3.2.3 Deleted.

LCO 3.2.3 Deleted.

1Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.2.3-1 Page 42 of 155

Attachment 2 to Holtec Letter 5014962 Boron Concentration 3.3.1 3.3 SFSC CRITICALITY CONTROL 3.3.1 Boron Concentration LCO 3.3.1 As required by CoC Appendix B, Table 2.1-2, the concentration of boron in the water in the MPC shall meet the following limits for the applicable MPC model and the most limiting fuel assembly array/class and classification to be stored in the MPC:

9. a. MPC-24 with one or more fuel assemblies having an initial enrichment greater than the value in Table 2.1-2 for no soluble boron credit and < 5.0 wt% 235U: > 400 ppmb

b. MPC-24E or MPC-24EF (all INTACT FUEL ASSEMBLIES) with one or more fuel assemblies having an initial enrichment greater than the value in Table 2.1-2 for no soluble boron credit and < 5.0 wt% 235U: > 300 ppmb

c. Deleted.

d. Deleted.

9. e. MPC-24E or MPC-24EF (one or more DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS) with one or more fuel assemblies having an initial enrichment > 4.0 wt% 235U and

< 5.0 wt% 235U: > 600 ppmb

f. MPC-32/32F: Minimum soluble boron concentration as required by the table below.

One or more DAMAGED FUEL All INTACT FUEL ASSEMBLIES ASSEMBLIES or FUEL DEBRIS Array/Class Maximum Initial Maximum Initial Maximum Initial Maximum Initial Enrichment Enrichment 5.0 Enrichment Enrichment

< 4.1 wt% 235U wt% 235U < 4.1 wt% 235U 5.0 wt% 235U (ppmb) (ppmb) (ppmb) (ppmb) 14x14A/B/C/D/E 1,300 1,900 1,500 2,300 15x15A/B/C/G/I 1,800 2,500 1,900 2,700 15x15D/E/F/H 1,900 2,600 2,100 2,900 16x16A/B/C 1,400 2,000 1,500 2,300 17x17A 1,600 2,200 1,800 2,600 17x17B/C 1,900 2,600 2,100 2,900 For maximum initial enrichments between 4.1 wt% and 5.0 wt% U, the minimum soluble boron 235 concentration may be determined by linear interpolation between the minimum soluble boron concentrations at 4.1 wt% and 5.0 wt%.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-1 Page 43 of 155

Attachment 2 to Holtec Letter 5014962 Boron Concentration

3.3.1 APPLICABILITY

During PWR fuel LOADING OPERATIONS with fuel and water in the MPC AND During PWR fuel UNLOADING OPERATIONS with fuel and water in the MPC.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

COMPLETION CONDITION REQUIRED ACTION TIME A. Boron concentration not A.1 Suspend LOADING Immediately within limit. OPERATIONS or UNLOADING OPERATIONS.

AND A.2 Suspend positive reactivity Immediately additions.

AND A.3 Initiate action to restore Immediately boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

NOTE------------------------------------ Once, within 4 This surveillance is only required to be performed if the MPC is hours prior to submerged in water or if water is to be added to, or recirculated entering the through the MPC. Applicability of

this LCO.

SR 3.3.1.1 Verify boron concentration is within the AND applicable limit using two independent measurements. Once per 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-22 Page 44 of 155

Attachment 2 to Holtec Letter 5014962 MPC Helium Backfill Limits Table 3-2 Table 3-1a MPC Cavity Drying Limits for all MPC Types for VENTILATED OVERPACK Note 9 Method of Moisture Fuel Burnup MPC Heat Load (kW) Removal (MWD/MTU)

(Notes 1, 2 and 32) 26 (MPC-24/24E/24EF, MPC-32/32F, VDSNote 5 or FHDNote 6 MPC-68/68F/68FF)

All Assemblies < 45,000 36.9 (MPC-68M)Note 6 VDS or FHD 42.8 (MPC-68M)Note 7 VDS or FHD 36.9 (MPC-24/24E/24EF, All Assemblies < 45,000 MPC-32/32F, VDSNote 8 or FHD MPC-68/68F/68FF)Note 6 One or more assemblies 29 (MPC-68M) VDSNote 4

> 45,000 36.9 (MPC-24/24E/24EF/MPC-32/32F/MPC-68/68F/68FF)Note6 VDSNote8 or FHD One or more assemblies

> 45,000 36.9 (MPC-68M)Note6 VDSNote8 or FHD 42.8 (MPC-68M)Note 7 VDSNote8 or FHD Notes:

1. 1. VDS means a vacuum drying system. The acceptance criterion when using a VDS is MPC cavity pressure shall be < 3 torr for > 30 minutes.

2. 2. FHD means a forced helium dehydration system. The acceptance criterion when using an FHD system is the gas temperature exiting the demoisturizer shall be

< 21oF for > 30 minutes or the gas dew point exiting the MPC shall be < 22.9oF for > 30 minutes.

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

4. 4. The maximum allowable decay heat per fuel storage location is 0.426 kW.

5. Maximum allowable storage cell heat load is 1.083 kW (MPC-24/24E/24EF), 0.812 kW (MPC-32/32F) and 0.382 kW (MPC-68/68F/68FF).

6. Maximum per assembly allowable heat loads under uniform or regionalized storage defined in Appendix B, Section 2.4.1 or 2.4.2.

7. Maximum per assembly allowable heat loads defined in Appendix B Figures 2.4-1 through 2.4-4.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-32 Page 45 of 155

Attachment 2 to Holtec Letter 5014962 MPC Helium Backfill Limits Table 3-2

8. Vacuum drying of the MPC must be performed using cycles of the drying system, according to the guidance contained in ISG-11 Revision 3. The time limit for these cycles shall be determined based on site specific conditions. Applies when any one assembly heat load is greater than 0.426 kW.

9. Alternative heat load limits may be developed following the methodology in Topical Report HI-2200343-A, Revision 2. These patterns must have a total MPC heat load less than or equal to 50 kW. Dryness criteria are still as specified in Notes 1 or 2 as applicable to the selected drying process, and Note 3 still applies to vacuum drying.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-42 Page 46 of 155

Attachment 2 to Holtec Letter 5014962 MPC Helium Backfill Limits Table 3-2 Table 3-1b MPC Cavity Drying Limits for all MPC Types for UNVENTILATED OVERPACK Method of Moisture Fuel Burnup MPC Heat Load (kW) Removal (MWD/MTU)

(Notes 1 and 2)

All burnups 25 (MPC-68M)Note 4 VDS or FHD Notes:

1. VDS means a vacuum drying system. The acceptance criterion when using a VDS is MPC cavity pressure shall be < 3 torr for > 30 minutes.

2. FHD means a forced helium dehydration system. The acceptance criterion when using an FHD system is the gas temperature exiting the demoisturizer shall be

< 21oF for > 30 minutes or the gas dew point exiting the MPC shall be < 22.9oF for > 30 minutes.

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

4. Maximum per assembly allowable heat loads under uniform or regionalized storage defined in Appendix B, Section 2.4.5 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-52 Page 47 of 155

Attachment 2 to Holtec Letter 5014962 MPC Helium Backfill Limits Table 3-2 Table 3-2a MPC Helium Backfill Limits for VENTILATED OVERPACKNote 1,21 MPC MODEL LIMIT MPC-24/24E/24EF

i. Cask Heat Load 27.77 kW (MPC-24) 0.1212 +/-10% g-moles/l or 28.17 kW (MPC-24E/EF) - OR uniformly distributed per Table 3-4 or 29.3 psig and 48.5 psig regionalized loading per Table 3-3 ii. Cask Heat Load >27.77 kW (MPC-24) or > 28.17 kW (MPC-24E/EF) -

uniformly distributed 45.5 psig and 48.5 psig or greater than regionalized heat load limits per Table 3-3 MPC-68/68F/68FF

i. Cask Heat Load 28.19 kW - 0.1218 +/-10% g-moles/l uniformly distributed per Table 3-4 OR or regionalized loading per Table 3-3 29.3 psig and 48.5 psig ii. Cask Heat Load > 28.19 kW -

uniformly distributed or 45.5 psig and 48.5 psig greater than regionalized heat load limits per Table 3-3 MPC-32/32F

i. Cask Heat Load 28.74 kW -

uniformly distributed per Table 3-4 29.3 psig and 48.5 psig or regionalized loading per Table 3-3 ii. Cask Heat Load >28.74 kW -

uniformly distributed or 45.5 psig and 48.5 psig greater than regionalized heat load limits per Table 3-3 1

Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-62 Page 48 of 155

Attachment 2 to Holtec Letter 5014962 MPC Helium Backfill Limits Table 3-2 MPC-68M

i. Cask Heat Load 28.19 kW -

uniformly distributed per Table 3-4 0.1218 +/-10% g-moles/l or OR regionalized loading per Table 3-3 29.3 psig and 48.5 psig ii. Cask Heat Load > 28.19 kW -

uniformly distributed 45.5 psig and 48.5 psig or greater than regionalized heat load limits per Table 3-3 iii. Cask Heat Load 42.8 kW QSHL Loading Pattern shown in 43.5 psig and 46.5 psig Appendix B, Figure 2.4-1 QSHL patterns shown in Appendix B, 45.5 psig and 48.5 psig Figures 2.4-2 through2.4-4 Notes

1. Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF

2. For heat load patterns developed in accordance with Table 3-1a, Note 9, helium backfill limits shall be calculated in accordance with Topical Report HI-2200343-A Revision 2 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-72 Page 49 of 155

Attachment 2 to Holtec Letter 5014962 MPC Helium Backfill Limits Table 3-2 Table 3-2b MPC Helium Backfill Limits for UNVENTILATED OVERPACK Note 1 MPC MODEL LIMIT MPC-68M

2. i. Cask Heat Load 25 kW --

uniformly distributed per Appendix B, Section 2.4.5 0.1218 +/-10% g-moles/l or OR regionalized loading per Appendix B, 42.0 psig and 45.0 psig Section 2.4.5 Notes:

1. Helium used for backfill of MPC shall have a purity of 99.995%.

Pressure range is at a reference temperature of 70oF.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-82 Page 50 of 155

Attachment 2 to Holtec Letter 5014962 MPC Heat Load Limits Table 3-3 Table 3-3: Regionalized StorageNote 2 Cell Heat Load Limits MPC Type Number of Storage Cell Number of Storage Cell Cells in Inner Heat Load Cells in Outer Heat Load RegionNote 1 (Inner Region) RegionNote 1 (Outer (kW) Region)

(kW)

MPC-24 4 1.470 20 0.900 MPC-24E/EF 4 1.540 20 0.900 MPC-32/32F 12 1.131 20 0.600 MPC- 32 0.500 36 0.275 68/68F/68FF/68M Note 1: The location of MPC-32 and MPC-68 inner and outer region cells are defined in Appendix B Figures 2.1-3 and 2.1-4 respectively.

The MPC-24 and MPC-24E/EF cell locations are defined below:

Inner Region Cell numbers 9, 10, 15, 16 in Appendix B Figures 2.1-1 and 2.1-2 respectively.

Outer Region Cell numbers 1-8, 11-14, 17-24 in Appendix B Figures 2.1-1 and 2.1-2 respectively.

Note 2: The storage cell regionalization is defined in Note 1 in accordance with safety analyses under the heat load limits of this Table. For heat load patterns developed in accordance with Table 3-1a, Note 9, these limits do not apply.

Table 3-4: Uniform Storage Cell Heat Load Limits MPC Type Heat Load (kW)

MPC-24 1.157 MPC-24E/EF 1.173 MPC-68/68F/68FF/68M 0.414 MPC-32 0.898 Note: For heat load patterns developed in accordance with Table 3-1a, Note 9, these limits do not apply.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-92 Page 51 of 155

Attachment 2 to Holtec Letter 5014962 LCO Completion Time Table 3-5 Table 3-5: Completion Time for Actions to Restore SFSC Heat Removal System OperableNote 2 Decay Heat Limits per Condition B Condition C Surveillance MPC Material MPC Type Storage Location Completion Time Completion Time Frequency MPC-24/24E/24EF MPC-32/32F Appendix B, Section 2.4 Alloy X Except 8 hrs 24 hrs 24 hrs Duplex1 MPC-68/68F/68FF/68M MPC-68M Appendix B, Figures 2.4-1 through 2.4-4 MPC-24/24E/24EF Alloy X MPC-32/32F Appendix B, Section 2.4 8 hrs 16 hrs 16 hrs MPC-68/68F/68FF/68M Alloy X MPC-68M Appendix B, Figures 4 hrs 12 hrs 12 hrs 2.4-1 through 2.4-4 MPC-24 Appendix A, Table 3-3 (Regionalized)

MPC-24E/EF Alloy X Except 1 OR 8 hrs 64 hrs 24 hrs Duplex MPC-32/32F Appendix A, Table 3-4 MPC-68/68F/68FF/68M (Uniform)

MPC-24 Appendix A, Table 3-3 (Regionalized)

MPC-24E/EF Alloy X OR 8 hrs 24 hrs 24 hrs MPC-32/32F Appendix A, Table 3-4 MPC-68/68F/68FF/68M (Uniform)

MPC-24/24E/24EF 0.75 kW Alloy X MPC-32/32F 0.5 kW 24 hrs 64 hrs 30 days MPC-68/68F/68FF/68M 0.264 kW Note

1) 1) If any component of the MPC is made of duplex, these completion times are not applicable.

2) For patterns developed in accordance with Table 3-1a, Note 9, alternative completion times shall be calculated in accordance with Topical Report HI-2200343-A Revision 2 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-102 Page 52 of 155

Attachment 2 to Holtec Letter 5014962 4.0 4.0 This section is intentionally left blank Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 4.0-1 Page 53 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented and maintained.

5.1 Deleted.

5.2 Deleted.

5.3 Deleted.

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

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

Specification 3.1.1, Multi-Purpose Canister (MPC), provides assurance that there are not radioactive effluents from the SFSC.

b. This program includes an environmental monitoring program. Each general license user may incorporate SFSC operations into their environmental monitoring programs for 10 CFR Part 50 operations.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-1 Page 54 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.5 Cask Transport Evaluation Program This program provides a means for evaluating various transport configurations and transport route conditions to ensure that the design basis drop limits are met.

For lifting of the loaded TRANSFER CASK or OVERPACK using devices which are integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply. This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by a device providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...) or is being handled by a device designed in accordance with the increased safety factors of ANSI N14.6 and having redundant drop protection.

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

a. For free-standing OVERPACKS and the TRANSFER CASK, the following requirements apply:

1. The lift height above the transport route surface(s) shall not exceed the limits in Table 5-1 except as provided for in Specification 5.5.a.2. Also, if applying the limits in Table 5-1, the program shall ensure that the transport route conditions (i.e., surface hardness and pad thickness) are equivalent to or less limiting than either Set A or Set B in HI-STORM FSAR Table 2.2.9.

2. The program may determine lift heights by analysis based on the site-specific conditions to ensure that the impact loading due to design basis drop events does not exceed 45 gs at the top of the MPC fuel basket. These alternative analyses shall be commensurate with the drop analyses described in the Final Safety Analysis Report for the HI-STORM 100 Cask System. The program shall ensure that these alternative analyses are documented and controlled.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-2 Page 55 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.5 Cask Transport Evaluation Program (continued)

3. The TRANSFER CASK or OVERPACK, when loaded with spent fuel, may be lifted to any height necessary during TRANSPORT OPERATIONS, provided the lifting device is designed in accordance with applicable stress limits from ANSI N14.6, and/or NUREG-0612, and has redundant drop protection features.

4. The TRANSFER CASK and MPC, when loaded with spent fuel, may be lifted to those heights necessary to perform cask handling operations, including MPC TRANSFER, provided the lifts are made with structures and components designed in accordance with the criteria specified in Section 3.5 of Appendix B to Certificate of Compliance No. 1014, as applicable.

b. For the transport of OVERPACKS to be anchored to the ISFSI pad, the following requirements apply:

1. Except as provided in 5.5.b.2, user shall determine allowable OVERPACK lift height limit(s) above the transport route surface(s) based on site-specific transport route conditions. The lift heights shall be determined by evaluation or analysis, based on limiting the design basis cask deceleration during a postulated drop event to

< 45 gs at the top of the MPC fuel basket. Evaluations and/or analyses shall be performed using methodologies consistent with those in the HI-STORM 100 FSAR.

2. The OVERPACK, when loaded with spent fuel, may be lifted to any height necessary during TRANSPORT OPERATIONS provided the lifting device is designed in accordance with applicable stress limits from ANSI N14.6, and/or NUREG-0612, and has redundant drop protection features.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-3 Page 56 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.5 Cask Transport Evaluation Program (continued)

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

TRANSFER CASK Horizontal 42 (Notes 1 and 2)

TRANSFER CASK Vertical None Established (Note 2)

OVERPACK Horizontal Not Permitted OVERPACK Vertical 11 (Note 3)

Notes: 1. To be measured from the lowest point on the TRANSFER CASK (i.e., the bottom edge of the cask/lid assemblage)

2. See Technical Specification 5.5.a.3 and 4

3. See Technical Specification 5.5.a.3.

5.6 Deleted.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-4 Page 57 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.7 Radiation Protection Program 5.7.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded OVERPACK or TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

5.7.2 As part of its evaluation pursuant to 10 CFR 72.212(b)(2)(i)(C), the licensee shall perform an analysis to confirm that the dose limits of 10 CFR 72.104(a) will be satisfied under the actual site conditions and ISFSI configuration, considering the planned number of casks to be deployed and the cask contents.

5.7.3 Based on the analysis performed pursuant to Section 5.7.2, the licensee shall establish individual cask surface dose rate limits for the HI-TRAC TRANSFER CASK and the HI-STORM OVERPACK to be used at the site.

Total (neutron plus gamma) dose rate limits shall be established at the following locations:

a. The top of the TRANSFER CASK and the OVERPACK.

b. The side of the TRANSFER CASK and OVERPACK

c. The inlet and outlet ducts on the OVERPACK (applicable only for VENTILATED OVERPACKs) 5.7.4 Notwithstanding the limits established in Section 5.7.3, the measured dose rates on a loaded OVERPACK shall not exceed the following values:

a. 30 mrem/hr (gamma + neutron) on the top of the OVERPACK

b. 300 mrem/hr (gamma + neutron) on the side of the OVERPACK, excluding inlet and outlet ducts

c. 4000 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.7.5 The licensee shall measure the TRANSFER CASK and OVERPACK surface neutron and gamma dose rates as described in Section 5.7.8 for comparison against the limits established in Section 5.7.3 or Section 5.7.4, whichever are lower.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-5 Page 58 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 (continued)

ADMINISTRATIVE CONTROLS AND PROGRAMS 5.7 Radiation Protection Program (contd) 5.7.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.7.3 or Section 5.7.4, the licensee shall:

a. Administratively verify that the correct contents were loaded in the correct fuel storage cell locations.

b. Perform a written evaluation to verify whether an OVERPACK at the ISFSI containing the as-loaded MPC will cause the dose limits of 10 CFR 72.104 to be exceeded.

c. Perform a written evaluation within 30 days to determine why the surface dose rate limits were exceeded.

5.7.7 If the evaluation performed pursuant to Section 5.7.6 shows that the dose limits of 10 CFR 72.104 will be exceeded, the MPC shall not be placed into storage or, in the case of the OVERPACK loaded at the ISFSI, the MPC shall be removed from storage until appropriate corrective action is taken to ensure the dose limits are not exceeded.

5.7.8 TRANSFER CASK and OVERPACK surface dose rates shall be measured at approximately the following locations:

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

b. A minimum of four (4) TRANSFER CASK top lid dose rates shall be measured at locations approximately half way between the edge of the hole in the top lid and the outer edge of the top lid, 90 degrees apart around the circumference of the top lid.

c. A minimum of twelve (12) dose rate measurements shall be taken on the side of the OVERPACK in three sets of four measurements.

One measurement set shall be taken approximately at the cask mid-height plane, 90 degrees apart around the circumference of the cask. The second and third measurement sets shall be taken approximately 60 inches above and below the mid-height plane, respectively, also 90 degrees apart around the circumference of the cask.

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-6 Page 59 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.7 Radiation Protection Program (contd)

d. A minimum of five (5) dose rate measurements shall be taken on the top of the OVERPACK. One dose rate measurement shall be taken at approximately the center of the lid and four measurements shall be taken at locations on the top concrete shield, approximately half way between the center and the edge of the top concrete shield, 90 degrees apart around the circumference of the lid.

e. A dose rate measurement shall be taken on contact at the surface of each inlet and outlet vent duct screen of the OVERPACK (applicable only for VENTILATED OVERPACK).

(continued)

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-7 Page 60 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 5.8 Fabrication Helium Leak Test At completion of welding the MPC shell to baseplate, an MPC confinement weld helium leak test shall be performed using a helium mass spectrometer. This test shall include the base metals of the MPC shell and baseplate. A helium leak test shall also be performed on the base metal of the fabricated MPC lid. The confinement boundary leakage rate tests shall be performed in accordance with ANSI N14.5 to leaktight criteria. If a leakage rate exceeding the acceptance criteria is detected, then the area of leakage shall be determined and the area repaired per ASME Code Section III, Subsection NB requirements. Re-testing shall be performed until the leakage rate acceptance criterion is met.

Casks initially loaded to Amendments No. 2 through 7 must meet the following:

Casks fabricated on or after July 1, 2009 a fabrication helium leak test at completion of the welding of the MPC shell to baseplate must be performed in accordance with the above requirements.

Casks loaded before July 1, 2009 must meet the fabrication helium leak test requirements of the lid base metal of the amendment to which they were originally loaded.

Casks loaded before July 1, 2009 do not meet the above fabrication helium leak test requirements after MPC shell to baseplate welding. These casks may be upgraded to Amendment 15.

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-8 Page 61 of 155

Attachment 2 to Holtec Letter 5014962 Programs 5.0 5.9 Aging Management Program Each general licensee shall have a program to establish, implement, and maintain written procedures for each AMP described in the FSAR. The program shall include provisions for changing AMP elements, as necessary, and within the limitations of the approved licensing bases to address new information on aging effects based on inspection findings and/or industry operating experience provided to the general licensee during the renewal period.

The general licensee shall establish and implement these written procedures within 365 days after the effective date of the renewal of the CoC or 365 days of the 20th anniversary of the loading of the first dry storage system at its site, whichever is later.

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

Certificate of Compliance No. 1014 Amendment No. 16 Appendix A 5.0-9 Page 62 of 155

Attachment 2 to Holtec Letter 5014962 PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX B APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM 100 CASK SYSTEM Page 63 of 155

Attachment 2 to Holtec Letter 5014962 TABLE OF CONTENTS 1.0 DEFINITIONS ..................................................................................................................... 1-1 2.0 APPROVED CONTENTS ................................................................................................... 2-1 2.1 Fuel Specification and Loading Conditions .................................................................... 2-1 2.2 Violations ........................................................................................................................ 2-2 2.3 Not Used ......................................................................................................................... 2-2 2.4 Decay Heat, Burnup & Cooling Time Limits for ZR Clad Fuel ...................................... 2-50 Figure 2.1-1 Fuel Loading Regions - MPC-24 ................................................................... 2-3 Figure 2.1-2 Fuel Loading Regions - MPC-24E/24EF ....................................................... 2-4 Figure 2.1-3 Fuel Loading Regions - MPC-32/32F ............................................................ 2-5 Figure 2.1-4 Fuel Loading Regions - MPC-68/68FF/68M.................................................. 2-6 Figure 2.4-1 QSHL-2 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M..2-61 Figure 2.4-2 QSHL-2 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M..2-62 Figure 2.4-3 QSHL-3 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M..2-63 Figure 2.4-4 QSHL-4 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M..2-64 Table 2.1-1 Fuel Assembly Limits ..................................................................................... 2-7 Table 2.1-2 PWR Fuel Assembly Characteristics ........................................................... 2-37 Table 2.1-3 BWR Fuel Assembly Characteristics ........................................................... 2-42 Table 2.1-4 Table Deleted Table 2.1-5 Table Deleted Table 2.1-6 Table Deleted Table 2.1-7 Table Deleted Table 2.1-8 Non-Fuel Hardware Cooling and Average Burnup....................................... 2-48 Table 2.1-9 Restrictions for Partial Gadolinium Credit in MPC-68M ............................... 2-49 Table 2.4-1 Maximum Allowable Decay Heat per Fuel Storage Location ....................... 2-50 Table 2.4-2 Fuel Storage Locations per MPC ................................................................. 2-52 Table 2.4-3 PWR Fuel Assembly Burnup and Cooling Time Limits for VENTILATED OVERPACK .......................................................................... 2-56 Table 2.4-4 BWR Fuel Assembly Burnup and Cooling Time Limits for VENTILATED OVERPACK .......................................................................... 2-57 Table 2.4-5 Heat Load for Damaged Fuel Assemblies and Fuel Debris under Regionalized Loading ..................................................................................2-52 Table 2.4-6a MPC-68M Heat Load Data for UNVENTILATED OVERPACK .................... 2-58 Table 2.4-6b MPC-68M Requirements on Developing Regionalized Heat Load Patterns for UNVENTILATED OVERPACK.......................................... .... .......................2-58 Table 2.4-7 Section Heat Load Calculations for MPC-68M for UNVENTILATED OVERPACK ................................................................................................. 2-59 Table 2.4-8 DFC and DFI Storage Locations with Heat Load penalties for MPC-68M for UNVENTILATED OVERPACK ..................................................................... 2-59 Table 2.4-9 Burnup and Cooling Time Fuel Qualification Requirements for MPC-68M for UNVENTILATED OVERPACK ............................................................... 2-61 3.0 DESIGN FEATURES .......................................................................................................... 3-1 3.1 Site ................................................................................................................................. 3-1 3.2 Design Features Important for Criticality Control ........................................................... 3-1 3.3 Codes and Standards .................................................................................................... 3-2 Certificate of Compliance No. 1014 Amendment No. 186 Appendix B i Page 64 of 155

Attachment 2 to Holtec Letter 5014962 3.4 Site Specific Parameters and Analyses ....................................................................... 3-13 3.5 Cask Transfer Facility (CTF) ........................................................................................ 3-17 3.6 Forced Helium Dehydration System ............................................................................ 3-20 3.7 Supplemental Cooling System ..................................................................................... 3-22 3.8 Combustible Gas Monitoring During MPC Lid Welding and Cutting ............................ 3-25 3.9 Environmental Temperature Requirements ................................................................. 3-25 Table 3-1 List of ASME Code Alternatives for HI-STORM 100 Cask System .................... 3-4 Table 3-2 Load Combinations and Service Condition Definitions for the CTF Structure ................................................................................................... 3-19 Table 3-3 Requirements for Supplemental Cooling System ............................................. 3-24 Certificate of Compliance No. 1014 Amendment No. 186 Appendix B ii Page 65 of 155

Attachment 2 to Holtec Letter 5014962 Definitions 1.0 1.0 Definitions Refer to Appendix A for Definitions.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 1-1 Page 66 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 2.0 APPROVED CONTENTS 2.1 Fuel Specifications and Loading Conditions 2.1.1 Fuel To Be Stored In The HI-STORM 100 SFSC System

a. INTACT FUEL ASSEMBLIES, UNDAMAGED FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, FUEL DEBRIS, and NON-FUEL HARDWARE meeting the limits specified in Table 2.1-1 and other referenced tables may be stored in the HI-STORM 100 SFSC System.

b. For MPCs partially loaded with stainless steel clad fuel assemblies, all remaining fuel assemblies in the MPC shall meet the decay heat generation limit for the stainless steel clad fuel assemblies.

c. For MPCs partially loaded with array/class 6x6A, 6x6B, 6x6C, 7x7A, or 8x8A fuel assemblies, all remaining ZR clad INTACT FUEL ASSEMBLIES in the MPC shall meet the decay heat generation limits for the 6x6A, 6x6B, 6x6C, 7x7A and 8x8A fuel assemblies.

d. All BWR fuel assemblies may be stored with or without ZR channels with the exception of array/class 10x10D and 10x10E fuel assemblies, which may be stored with or without ZR or stainless steel channels.

2.1.2 Uniform Fuel Loading Any authorized fuel assembly may be stored in any fuel storage location, subject to other restrictions related to DAMAGED FUEL, FUEL DEBRIS, and NON-FUEL HARDWARE specified in the CoC.

(continued)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-1 Page 67 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 2.0 Approved Contents 2.1 Fuel Specifications and Loading Conditions (contd) 2.1.3 Regionalized Fuel Loading Users may choose to store fuel using regionalized loading in lieu of uniform loading to allow higher heat emitting fuel assemblies to be stored than would otherwise be able to be stored using uniform loading. Figures 2.1-1 through 2.1-4 define the regions for the MPC-24, MPC-24E, MPC-24EF, MPC-32, MPC-32F, MPC-68, MPC-68FF, and MPC-68M models, respectively 1. Fuel assemblydecay heat limits for regionalized loading are specified in Section 2.4.2 for VENTILATED OVERPACK, and Section 2.4.5 for UNVENTILATED OVERPACK. Fuel assemblies used in regionalized loading shall meet all other applicable limits specified in Tables 2.1-1 through 2.1-3.

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

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

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

2.2.3 Within 30 days, submit a special report which describes the cause of the violation, and actions taken to restore compliance and prevent recurrence.

2.3 Not Used 1

These figures are only intended to distinguish the fuel loading regions. Other details of the basket design are illustrative and may not reflect the actual basket design details.

The design drawings should be consulted for basket design details.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-2 Page 68 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Figure 2.1-1 Fuel Loading Regions - MPC-24 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-3 Page 69 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Figure 2.1-2 Fuel Loading Regions - MPC-24E/24EF Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-4 Page 70 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Figure 2.1-3 Fuel Loading Regions - MPC-32/32F Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-5 Page 71 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Figure 2.1-4 Fuel Loading Regions - MPC-68/68FF/68M Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-6 Page 72 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 1 of 30)

Fuel Assembly Limits I. MPC MODEL: MPC-24 A. Allowable Contents

1. Uranium oxide, PWR INTACT FUEL ASSEMBLIES listed in Table 2.1-2, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type: ZR or Stainless Steel (SS) as specified in Table 2.1-2 for the applicable fuel assembly array/class.

b. Initial Enrichment: As specified in Table 2.1-2 for the applicable fuel assembly array/class.

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. Array/Classes Cooling time 8 years and an average 14x14D,14x14E, and burnup 40,000 MWD/MTU.

15x15G ii. All Other Array/Classes Cooling time and average burnup as specified in Section 2.4.

ii. NON-FUEL HARDWARE As specified in Table 2.1-8.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-7 Page 73 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 2 of 30)

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

A. Allowable Contents (continued)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D, 710 Watts 14x14E, and 15x15G ii. All Other Array/Classes As specified in Section 2.4.

e. Fuel Assembly Length: 176.8 inches (nominal design)

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

g. Fuel Assembly Weight: 1720 lbs (including NON-FUEL HARDWARE) for assemblies that do not require fuel spacers, otherwise 1680 lbs (including NON-FUEL HARDWARE)

B. Quantity per MPC: Up to 24 fuel assemblies.

C. Deleted.

D. DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS are not authorized for loading into the MPC-24.

E. One NSA is authorized for loading into the MPC-24.

Note 1: Fuel assemblies containing BPRAs, TPDs, WABAs, water displacement guide tube plugs, orifice rod assemblies, or vibration suppressor inserts with or without ITTRs, may be stored in any fuel storage location. Fuel assemblies containing APSRs or NSAs may only be loaded in fuel storage locations 9, 10, 15, and/or 16. Fuel assemblies containing CRAs, RCCAs, CEAs may only be stored in fuel storage locations 4, 5, 8 - 11, 14 - 17, 20 and/or 21 (see Figure 2.1-1). These requirements are in addition to any other requirements specified for uniform or regionalized fuel loading.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-8 Page 74 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 3 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F A. Allowable Contents

1. Uranium oxide, BWR INTACT FUEL ASSEMBLIES, with or without ZR channels. Uranium oxide BWR INTACT FUEL ASSEMBLIES shall meet the criteria specified in Table 2.1-3 for fuel assembly array class 6x6A, 6x6C, 7x7A or 8x8A, and meet the following specifications:

a. Cladding Type: ZR

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

c. Initial Maximum Rod Enrichment: As specified in Table 2.1-3 for the applicable fuel assembly array/class.

d. Post-irradiation Cooling Time and Cooling time 18 years and an average Average Burnup Per Assembly: burnup 30,000 MWD/MTU.

e. Decay Heat Per Assembly 115 Watts

f. Fuel Assembly Length: 135.0 inches (nominal design)

g. Fuel Assembly Width: 4.70 inches (nominal design)

h. Fuel Assembly Weight: 400 lbs, including channels Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-9 Page 75 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 4 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

A. Allowable Contents (continued)

2. Uranium oxide, BWR DAMAGED FUEL ASSEMBLIES, with or without ZR channels, placed in DAMAGED FUEL CONTAINERS. Uranium oxide BWR DAMAGED FUEL ASSEMBLIES shall meet the criteria specified in Table 2.1-3 for fuel assembly array/class 6x6A, 6x6C, 7x7A, or 8x8A, and meet the following specifications:

a. Cladding Type: ZR

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

c. Initial Maximum Rod Enrichment: As specified in Table 2.1-3 for the applicable fuel assembly array/class.

d. Post-irradiation Cooling Time and Cooling time 18 years and an average Average Burnup Per Assembly: burnup 30,000 MWD/MTU.

e. Decay Heat Per Assembly: 115 Watts

f. Fuel Assembly Length: 135.0 inches (nominal design)

g. Fuel Assembly Width: 4.70 inches (nominal design)

h. Fuel Assembly Weight: 550 lbs, including channels and DFC Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-10 Page 76 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 5 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

A. Allowable Contents (continued)

3. Uranium oxide, BWR FUEL DEBRIS, with or without ZR channels, placed in DAMAGED FUEL CONTAINERS. The original fuel assemblies for the uranium oxide BWR FUEL DEBRIS shall meet the criteria specified in Table 2.1-3 for fuel assembly array/class 6x6A, 6x6C, 7x7A, or 8x8A, and meet the following specifications:

a. Cladding Type: ZR

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

c. Initial Maximum Rod Enrichment: As specified in Table 2.1-3 for the applicable original fuel assembly array/class.

d. Post-irradiation Cooling Time and Cooling time 18 years and an average Average Burnup Per Assembly burnup 30,000 MWD/MTU for the original fuel assembly.

e. Decay Heat Per Assembly 115 Watts

f. Original Fuel Assembly Length 135.0 inches (nominal design)

g. Original Fuel Assembly Width 4.70 inches (nominal design)

h. Fuel Debris Weight 550 lbs, including channels and DFC Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-11 Page 77 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 6 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

A. Allowable Contents (continued)

4. Mixed oxide (MOX), BWR INTACT FUEL ASSEMBLIES, with or without ZR channels. MOX BWR INTACT FUEL ASSEMBLIES shall meet the criteria specified in Table 2.1-3 for fuel assembly array/class 6x6B, and meet the following specifications:

a. Cladding Type: ZR

b. Maximum PLANAR-AVERAGE As specified in Table 2.1-3 for fuel INITIAL ENRICHMENT: assembly array/class 6x6B.

c. Initial Maximum Rod Enrichment: As specified in Table 2.1-3 for fuel assembly array/class 6x6B.

d. Post-irradiation Cooling Time and Cooling time 18 years and an average Average Burnup Per Assembly: burnup 30,000 MWD/MTIHM.

e. Decay Heat Per Assembly 115 Watts

f. Fuel Assembly Length: 135.0 inches (nominal design)

g. Fuel Assembly Width: 4.70 inches (nominal design)

h. Fuel Assembly Weight: 400 lbs, including channels Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-12 Page 78 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 7 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

A. Allowable Contents (continued)

5. Mixed oxide (MOX), BWR DAMAGED FUEL ASSEMBLIES, with or without ZR channels, placed in DAMAGED FUEL CONTAINERS. MOX BWR DAMAGED FUEL ASSEMBLIES shall meet the criteria specified in Table 2.1-3 for fuel assembly array/class 6x6B, and meet the following specifications:

a. Cladding Type: ZR

b. Maximum PLANAR-AVERAGE As specified in Table 2.1-3 for fuel INITIAL ENRICHMENT: assembly array/class 6x6B.

c. Initial Maximum Rod Enrichment: As specified in Table 2.1-3 for fuel assembly array/class 6x6B.

d. Post-irradiation Cooling Time and Cooling time 18 years and an average Average Burnup Per Assembly: burnup 30,000 MWD/MTIHM.

e. Decay Heat Per Assembly 115 Watts

f. Fuel Assembly Length: 135.0 inches (nominal design)

g. Fuel Assembly Width: 4.70 inches (nominal design)

h. Fuel Assembly Weight: 550 lbs, including channels and DFC Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-13 Page 79 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 8 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

A. Allowable Contents (continued)

6. Mixed Oxide (MOX), BWR FUEL DEBRIS, with or without ZR channels, placed in DAMAGED FUEL CONTAINERS. The original fuel assemblies for the MOX BWR FUEL DEBRIS shall meet the criteria specified in Table 2.1-3 for fuel assembly array/class 6x6B, and meet the following specifications:

a. Cladding Type: ZR

b. Maximum PLANAR-AVERAGE As specified in Table 2.1-3 for original INITIAL ENRICHMENT: fuel assembly array/class 6x6B.

c. Initial Maximum Rod Enrichment: As specified in Table 2.1-3 for original fuel assembly array/class 6x6B.

d. Post-irradiation Cooling Time and Cooling time 18 years and an average Average Burnup Per Assembly: burnup 30,000 MWD/MTIHM for the original fuel assembly.

e. Decay Heat Per Assembly 115 Watts

f. Original Fuel Assembly Length: 135.0 inches (nominal design)

g. Original Fuel Assembly Width: 4.70 inches (nominal design)

h. Fuel Debris Weight: 550 lbs, including channels and DFC Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-14 Page 80 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 9 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

A. Allowable Contents (continued)

7. Thoria rods (ThO2 and UO2) placed in Dresden Unit 1 Thoria Rod Canisters and meeting the following specifications:

a. Cladding Type: ZR

b. Composition: 98.2 wt.% ThO2, 1.8 wt. % UO2 with an enrichment of 93.5 wt. % 235U.

OR 98.5 wt.% ThO2, 1.5 wt.% UO2 with an enrichment of 93.5 wt.% 235U

c. Number of Rods Per Thoria Rod 18 Canister:

d. Decay Heat Per Thoria Rod 115 Watts Canister:

e. Post-irradiation Fuel Cooling Time A fuel post-irradiation cooling time 18 and Average Burnup Per Thoria years and an average burnup 16,000 Rod Canister: MWD/MTIHM.

f. Initial Heavy Metal Weight: 27 kg/canister

g. Fuel Cladding O.D.: 0.412 inches

h. Fuel Cladding I.D.: 0.362 inches

i. Fuel Pellet O.D.: 0.358 inches

j. Active Fuel Length: 111 inches

k. Canister Weight: 550 lbs, including fuel Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-15 Page 81 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 10 of 30)

Fuel Assembly Limits II. MPC MODEL: MPC-68F (continued)

B. Quantity per MPC (up to a total of 68 assemblies):

(All fuel assemblies must be array/class 6x6A, 6x6B, 6x6C, 7x7A, or 8x8A):

Up to four (4) DFCs containing uranium oxide BWR FUEL DEBRIS or MOX BWR FUEL DEBRIS. The remaining MPC-68F fuel storage locations may be filled with fuel assemblies of the following type, as applicable:

1. Uranium oxide BWR INTACT FUEL ASSEMBLIES;

2. MOX BWR INTACT FUEL ASSEMBLIES;

3. Uranium oxide BWR DAMAGED FUEL ASSEMBLIES placed in DFCs;

4. MOX BWR DAMAGED FUEL ASSEMBLIES placed in DFCs; or

5. Up to one (1) Dresden Unit 1 Thoria Rod Canister.

C. Fuel assemblies with stainless steel channels are not authorized for loading in the MPC-68F.

D. Dresden Unit 1 fuel assemblies with one Antimony-Beryllium neutron source are authorized for loading in the MPC-68F. The Antimony-Beryllium source material shall be in a water rod location.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-16 Page 82 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 11 of 30)

Fuel Assembly Limits III. MPC MODEL: MPC-68 and MPC-68FF A. Allowable Contents

1. Uranium oxide or MOX BWR INTACT FUEL ASSEMBLIES listed in Table 2.1-3, with or without channels and meeting the following specifications:

a. Cladding Type: ZR or Stainless Steel (SS) as specified in Table 2.1-3 for the applicable fuel assembly array/class

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

c. Initial Maximum Rod Enrichment As specified in Table 2.1-3 for the applicable fuel assembly array/class.

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

i. Array/Classes 6x6A, 6x6B, Cooling time 18 years and an average 6x6C, 7x7A, and 8x8A burnup 30,000 MWD/MTU (or MWD/MTIHM).

ii. Array/Class 8x8F Cooling time 10 years and an average burnup 27,500 MWD/MTU.

iii. Array/Classes 10x10D Cooling time 10 years and an average and 10x10E burnup 22,500 MWD/MTU.

iv. All Other Array/Classes As specified in Section 2.4.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-17 Page 83 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 12 of 30)

Fuel Assembly Limits III. MPC MODEL: MPC-68 and MPC-68FF (continued)

A. Allowable Contents (continued)

e. Decay Heat Per Assembly

i. Array/Classes 6x6A, 6X6B, 115 Watts 6x6C, 7x7A, and 8x8A ii. Array/Class 8x8F 183.5 Watts iii. Array/Classes 10x10D 95 Watts and 10x10E iv. All Other Array/Classes As specified in Section 2.4.

f. Fuel Assembly Length

i. Array/Class 6x6A, 6x6B, 135.0 inches (nominal design) 6x6C, 7x7A, or 8x8A ii. All Other Array/Classes 176.5 inches (nominal design)

g. Fuel Assembly Width

i. Array/Class 6x6A, 6x6B, 4.70 inches (nominal design) 6x6C, 7x7A, or 8x8A ii. All Other Array/Classes 5.85 inches (nominal design)

h. Fuel Assembly Weight

i. Array/Class 6x6A, 6x6B, 400 lbs, including channels 6x6C, 7x7A, or 8x8A ii. All Other Array/Classes 730 lbs, including channels Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-18 Page 84 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 13 of 30)

Fuel Assembly Limits III. MPC MODEL: MPC-68 and MPC-68FF (continued)

A. Allowable Contents (continued)

2. Uranium oxide or MOX BWR DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS, with or without channels, placed in DAMAGED FUEL CONTAINERS.

Uranium oxide and MOX BWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS shall meet the criteria specified in Table 2.1-3, and meet the following specifications:

a. Cladding Type: ZR or Stainless Steel (SS) in accordance with Table 2.1-3 for the applicable fuel assembly array/class.

b. Maximum PLANAR-AVERAGE INITIAL ENRICHMENT:

i. Array/Classes 6x6A, 6x6B, As specified in Table 2.1-3 for the 6x6C, 7x7A, and 8x8A. applicable fuel assembly array/class.

ii. All Other Array Classes 4.0 wt.% 235U.

c. Initial Maximum Rod Enrichment As specified in Table 2.1-3 for the applicable fuel assembly array/class.

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

i. Array/Class 6x6A, 6x6B, Cooling time 18 years and an average 6x6C, 7x7A, or 8x8A burnup 30,000 MWD/MTU (or MWD/MTIHM).

ii. Array/Class 8x8F Cooling time 10 years and an average burnup 27,500 MWD/MTU.

iii. Array/Class 10x10D and Cooling time 10 years and an average 10x10E burnup 22,500 MWD/MTU.

iv. All Other Array/Classes As specified in Section 2.4.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-19 Page 85 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 14 of 30)

Fuel Assembly Limits III. MPC MODEL: MPC-68 and MPC-68FF (continued)

A. Allowable Contents (continued)

e. Decay Heat Per Assembly

i. Array/Class 6x6A, 6x6B, 115 Watts 6x6C, 7x7A, or 8x8A ii. Array/Class 8x8F 183.5 Watts iii. Array/Classes 10x10D 95 Watts and 10x10E iv. All Other Array/Classes As specified in Section 2.4.

f. Fuel Assembly Length

i. Array/Class 6x6A, 6x6B, 135.0 inches (nominal design) 6x6C, 7x7A, or 8x8A ii. All Other Array/Classes 176.5 inches (nominal design)

g. Fuel Assembly Width

i. Array/Class 6x6A, 6x6B, 4.70 inches (nominal design) 6x6C, 7x7A, or 8x8A ii. All Other Array/Classes 5.85 inches (nominal design)

h. Fuel Assembly Weight

i. Array/Class 6x6A, 6x6B, 550 lbs, including channels and DFC 6x6C, 7x7A, or 8x8A ii. All Other Array/Classes 830 lbs, including channels and DFC Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-20 Page 86 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 15 of 30)

Fuel Assembly limits III. MPC MODEL: MPC-68 and MPC-68FF (continued)

A. Allowable Contents (continued)

3. Thoria rods (ThO2 and UO2) placed in Dresden Unit 1 Thoria Rod Canisters and meeting the following specifications:

a. Cladding type ZR

b. Composition 98.2 wt.% ThO2, 1.8 wt.% UO2 with an enrichment of 93.5 wt.% 235U.

OR 98.5 wt.% ThO2, 1.5 wt.% UO2 with an enrichment of 93.5% wt.% 235U

c. Number of Rods per Thoria Rod 18 Canister:

d. Decay Heat Per Thoria Rod 115 Watts Canister:

e. Post-irradiation Fuel Cooling Time A fuel post-irradiation cooling time 18 and Average Burnup per Thoria years and an average burnup 16,000 Rod Canister: MWD/MTIHM

f. Initial Heavy Metal Weight: 27 kg/canister

g. Fuel Cladding O.D.: 0.412 inches

h. Fuel Cladding I.D.: 0.362 inches

i. Fuel Pellet O.D.: 0.358 inches

j. Active Fuel Length: 111 inches

k. Canister Weight: 550 lbs, including fuel Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-21 Page 87 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 16 of 30)

Fuel Assembly Limits III. MPC MODEL: MPC-68 and MPC-68FF (continued)

B. Quantity per MPC (up to a total of 68 assemblies)

1. For fuel assembly array/classes 6x6A, 6X6B, 6x6C, 7x7A, or 8x8A, up to 68 BWR INTACT FUEL ASSEMBLIES and/or DAMAGED FUEL ASSEMBLIES.

Up to eight (8) DFCs containing FUEL DEBRIS from these array/classes may be stored.

2. For all other array/classes, up to sixteen (16) DFCs containing BWR DAMAGED FUEL ASSEMBLIES and/or up to eight (8) DFCs containing FUEL DEBRIS. DFCs shall be located only in fuel storage locations 1, 2, 3, 8, 9, 16, 25, 34, 35, 44, 53, 60, 61, 66, 67, and/or 68. The remaining fuel storage locations may be filled with fuel assemblies of the following type:

i. Uranium Oxide BWR INTACT FUEL ASSEMBLIES; or ii. MOX BWR INTACT FUEL ASSEMBLIES.

3. Up to one (1) Dresden Unit 1 Thoria Rod Canister C. Dresden Unit 1 fuel assemblies with one Antimony-Beryllium neutron source are authorized for loading. The Antimony-Beryllium source material shall be in a water rod location.

D. Array/Class 10x10D and 10x10E fuel assemblies in stainless steel channels must be stored in fuel storage locations 19 - 22, 28 - 31, 38 -41, and/or 47 -

50 (see Figure 2.1-4).

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-22 Page 88 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 17 of 30)

Fuel Assembly Limits IV. MPC MODEL: MPC-24E and MPC-24EF A. Allowable Contents

1. Uranium oxide, PWR INTACT FUEL ASSEMBLIES listed in Table 2.1-2, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type: ZR or Stainless Steel (SS) as specified in Table 2.1-2 for the applicable fuel assembly array/class

b. Initial Enrichment: As specified in Table 2.1-2 for the applicable fuel assembly array/class.

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. Array/Classes 14x14D, Cooling time 8 years and an average 14x14E, and 15x15G burnup 40,000 MWD/MTU.

ii. All Other Array/Classes As specified in Section 2.4.

iii. NON-FUEL HARDWARE As specified in Table 2.1-8.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-23 Page 89 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 18 of 30)

Fuel Assembly Limits IV. MPC MODEL: MPC-24E and MPC-24EF (continued)

A. Allowable Contents (continued)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D, 710 Watts.

14x14E, and 15x15G ii. All other Array/Classes As specified in Section 2.4.

e. Fuel Assembly Length: 176.8 inches (nominal design)

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

g. Fuel Assembly Weight: 1,720 lbs (including NON-FUEL HARDWARE) for assemblies that do not require fuel spacers, otherwise, 1,680 lbs (including NON-FUEL HARDWARE)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-24 Page 90 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 19 of 30)

Fuel Assembly Limits IV. MPC MODEL: MPC-24E and MPC-24EF (continued)

A. Allowable Contents (continued)

2. Uranium oxide, PWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS, with or without NON-FUEL HARDWARE, placed in DAMAGED FUEL CONTAINERS.

Uranium oxide PWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS shall meet the criteria specified in Table 2.1-2 and meet the following specifications (Note 1):

a. Cladding Type: ZR or Stainless Steel (SS) as specified in Table 2.1-2 for the applicable fuel assembly array/class

b. Initial Enrichment: As specified in Table 2.1-2 for the applicable fuel assembly array/class.

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. Array/Classes 14x14D, Cooling time 8 years and an average 14x14E, and 15x15G burnup 40,000 MWD/MTU.

ii. All Other Array/Classes As specified in Section 2.4.

iii. NON-FUEL HARDWARE As specified in Table 2.1-8.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-25 Page 91 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 20 of 30)

Fuel Assembly Limits IV. MPC MODEL: MPC-24E and MPC-24EF (continued)

A. Allowable Contents (continued)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D, 710 Watts.

14x14E, and 15x15G ii. All Other Array/Classes As specified in Section 2.4.

e. Fuel Assembly Length 176.8 inches (nominal design)

f. Fuel Assembly Width 8.54 inches (nominal design)

g. Fuel Assembly Weight 1,720 lbs (including NON-FUEL HARDWARE and DFC) for assemblies that do not require fuel spacers, otherwise, 1,680 lbs (including NON-FUEL HARDWARE and DFC)

B. Quantity per MPC: Up to four (4) DAMAGED FUEL ASSEMBLIES and/or FUEL DEBRIS in DAMAGED FUEL CONTAINERS, stored in fuel storage locations 3, 6, 19 and/or 22. The remaining fuel storage locations may be filled with PWR INTACT FUEL ASSEMBLIES meeting the applicable specifications.

C. One NSA is permitted for loading.

Note 1: Fuel assemblies containing BPRAs, TPDs, WABAs, water displacement guide tube plugs, orifice rod assemblies, or vibration suppressor inserts, with or without ITTRs, may be stored in any fuel storage location. Fuel assemblies containing APSRs or NSAs may only be loaded in fuel storage locations 9, 10, 15, and/or 16 (see Figure 2.1-2). Fuel assemblies containing CRAs, RCCAs, or CEAs may only be stored in fuel storage locations 4, 5, 8 - 11, 14 - 17, 20 and/or 21 (see Figure 2.1-2). These requirements are in addition to any other requirements specified for uniform or regionalized fuel loading.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-26 Page 92 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 21 of 30)

Fuel Assembly Limits V. MPC MODEL: MPC-32 and MPC-32F A. Allowable Contents

1. Uranium oxide, PWR INTACT FUEL ASSEMBLIES listed in Table 2.1-2, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type: ZR or Stainless Steel (SS) as specified in Table 2.1-2 for the applicable fuel assembly array/class

b. Initial Enrichment: As specified in Table 2.1-2 for the applicable fuel assembly array/class.

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. Array/Classes 14x14D, Cooling time 9 years and an average 14x14E, and 15x15G burnup 30,000 MWD/MTU or cooling time 20 years and an average burnup 40,000 MWD/MTU.

ii. All Other Array/Classes As specified in Section 2.4.

iii. NON-FUEL HARDWARE As specified in Table 2.1-8.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-27 Page 93 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 22 of 30)

Fuel Assembly Limits V. MPC MODEL: MPC-32 and MPC-32F (contd)

A. Allowable Contents (contd)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D, 500 Watts.

14x14E, and 15x15G ii. All Other Array/Classes As specified in Section 2.4.

e. Fuel Assembly Length 176.8 inches (nominal design)

f. Fuel Assembly Width 8.54 inches (nominal design)

g. Fuel Assembly Weight 1,720 lbs (including NON-FUEL HARDWARE) for assemblies that do not require fuel spacers, otherwise, 1,680 lbs (including NON-FUEL HARDWARE)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-28 Page 94 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 23 of 30)

Fuel Assembly Limits V. MPC MODEL: MPC-32 and MPC-32F (contd)

A. Allowable Contents (contd)

2. Uranium oxide, PWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS, with or without NON-FUEL HARDWARE, placed in DAMAGED FUEL CONTAINERS. Uranium oxide PWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS shall meet the criteria specified in Table 2.1-2 and meet the following specifications (Note 1):

a. Cladding Type: ZR or Stainless Steel (SS) as specified in Table 2.1-2 for the applicable fuel assembly array/class

b. Initial Enrichment: As specified in Table 2.1-2 for the applicable fuel assembly array/class.

c. Post-irradiation Cooling Time and Average Burnup Per Assembly:

i. Array/Classes 14x14D, Cooling time 9 years and an average 14x14E, and 15x15G burnup 30,000 MWD/MTU or cooling time 20 years and an average burnup 40,000 MWD/MTU.

ii. All Other Array/Classes As specified in Section 2.4.

iii. NON-FUEL HARDWARE As specified in Table 2.1-8.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-29 Page 95 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 24 of 30)

Fuel Assembly Limits V. MPC MODEL: MPC-32 and MPC-32F (contd)

A. Allowable Contents (contd)

d. Decay Heat Per Fuel Storage Location:

i. Array/Classes 14x14D, 500 Watts.

14x14E, and 15x15G ii. All Other Array/Classes As specified in Section 2.4.

e. Fuel Assembly Length 176.8 inches (nominal design)

f. Fuel Assembly Width 8.54 inches (nominal design)

g. Fuel Assembly Weight 1,720 lbs (including NON-FUEL HARDWARE and DFC) for assemblies that do not require fuel spacers, otherwise, 1,680 lbs (including NON-FUEL HARDWARE and DFC)

B. Quantity per MPC: Up to eight (8) DAMAGED FUEL ASSEMBLIES and/or FUEL DEBRIS in DAMAGED FUEL CONTAINERS, stored in fuel storage locations 1, 4, 5, 10, 23, 28, 29, and/or 32. The remaining fuel storage locations may be filled with PWR INTACT FUEL ASSEMBLIES meeting the applicable specifications.

C. One NSA is permitted for loading.

Note 1: Fuel assemblies containing BPRAs, TPDs, WABAs, water displacement guide tube plugs, orifice rod assemblies, or vibration suppressor inserts, with or without ITTRs, may be stored in any fuel storage location. Fuel assemblies containing NSAs may only be loaded in fuel storage locations 13, 14, 19 and/or 20 (see Figure 2.1-3). Fuel assemblies containing CRAs, RCCAs, CEAs or APSRs may only be loaded in fuel storage locations 7, 8, 12-15, 18-21, 25 and/or 26 (see Figure 2.1-3). These requirements are in addition to any other requirements specified for uniform or regionalized fuel loading.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-30 Page 96 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 25 of 30)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M A. Allowable Contents

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

a. Cladding Type: ZR

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

c. Initial Maximum Rod Enrichment As specified in Table 2.1-3 for the applicable fuel assembly array/class.

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

i. Array/Class 8x8F Cooling time 10 years and an average burnup 27,500 MWD/MTU.

ii. All Other Array/Classes As specified in Section 2.4.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-31 Page 97 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 26 of 30)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M (continued)

A. Allowable Contents (continued)

e. Decay Heat Per Assembly

i. Array/Class 8x8F 183.5 Watts ii. All Other Array/Classes As specified in Section 2.4.

f. Fuel Assembly Length 176.5 inches (nominal design)

g. Fuel Assembly Width 5.85 inches (nominal design)

h. Fuel Assembly Weight 730 lbs, including channels Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-32 Page 98 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 27 of 30)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M (continued)

A. Allowable Contents (continued)

2. Uranium oxide BWR DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS, with or without channels, placed in DAMAGED FUEL CONTAINERS. Uranium oxide BWR DAMAGED FUEL ASSEMBLIES whose damage is limited such that the fuel assembly is able to be handled by normal means and whose structural integrity remains intact to the extent that geometric rearrangement of fuel is not expected, with or without channels, placed in basket cell locations containing top and bottom DAMAGED FUEL ISOLATORS. BWR DAMAGED FUEL ASSEMBLIES used with DFIs may contain missing or partial fuel rods and/or fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks. Uranium oxide BWR DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS shall meet the criteria specified in Table 2.1-3, and meet the following specifications:

a. Cladding Type: ZR

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

c. Initial Maximum Rod Enrichment As specified in Table 2.1-3 for the applicable fuel assembly array/class.

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

i. Array/Class 8x8F Cooling time 10 years and an average burnup 27,500 MWD/MTU.

ii. All Other Array/Classes Cooling time 1 year and an average burnup 65,000 MWD/MTU.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-33 Page 99 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 28 of 30)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M (continued)

A. Allowable Contents (continued)

e. Decay Heat Per Assembly

i. Array/Class 8x8F 183.5 Watts ii. All Other Array/Classes As specified in Section 2.4.

f. Fuel Assembly Length 176.5 inches (nominal design)

g. Fuel Assembly Width 5.85 inches (nominal design)

h. Fuel Assembly Weight 830 lbs, including channels and DFC/DFIs Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-34 Page 100 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 29 of 30)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M (continued)

A. Allowable Contents (continued)

3. Thoria rods (ThO2 and UO2) placed in Dresden Unit 1 Thoria Rod Canisters and meeting the following specifications:

a. Cladding Type: ZR

b. Composition 98.2 wt.% ThO2, 1.8 wt.% UO2 with an 235 enrichment of 93.5 wt.% U OR 98.5 wt.% ThO2, 1.5 wt.% UO2 with an 235 enrichment of 93.5% wt.% U

c. Number of Rods per Thoria Rod 18 Canister:

d. Decay Heat Per Thoria Rod 115 Watts Canister:

e. Post-irradiation Fuel Cooling Time A fuel post-irradiation cooling time 18 and Average Burnup per Thoria years and an average burnup 16,000 Rod Canister: MWD/MTIHM

f. Initial Heavy Metal Weight: 27 kg/canister

g. Fuel Cladding O.D.: 0.412 inches

h. Fuel Cladding I.D.: 0.362 inches

i. Fuel Pellet O.D.: 0.358 inches

j. Active Fuel Length: 111 inches

k. Canister Weight: 550 lbs, including fuel Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-35 Page 101 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-1 (page 30 of 30)

Fuel Assembly Limits VI. MPC MODEL: MPC-68M (continued)

B. Quantity per MPC (up to a total of 68 assemblies)

1. Up to sixteen (16) DFCs or DFIs containing BWR DAMAGED FUEL ASSEMBLIES and/or up to eight (8) DFCs containing FUEL DEBRIS.

DFCs/DFIs shall be located only in fuel storage locations 1, 2, 3, 8, 9, 16, 25, 34, 35, 44, 53, 60, 61, 66, 67, and/or 68. Alternatively BWR DAMAGED FUEL ASSEMBLIES using DFCs/DFIs may be stored in inner locations when using the loading pattern in Figure 2.4-4. The remaining fuel storage locations may be filled with Uranium Oxide BWR UNDAMAGED FUEL ASSEMBLIES.

2. Up to one (1) Dresden Unit 1 Thoria Rod Canister.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-36 Page 102 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-2 (page 1 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 14x14A 14x14B 14x14C 14x14D 14x14E Array/Class Clad Material ZR ZR ZR SS SS Design Initial U 365 412 438 400 206 (kg/assy.) (Note 3)

Initial Enrichment (MPC-24, 24E and 4.6 (24) 4.6 (24) 4.6 (24) 4.0 (24) 5.0 (24) 24EF without soluble boron 5.0 5.0 5.0 5.0 5.0 credit) (wt % 235U) (24E/24EF) (24E/24EF) (24E/24EF) (24E/24EF) (24E/24EF)

(Note 7)

Initial Enrichment (MPC-24, 24E, 24EF, 32, or 32F 5.0 5.0 5.0 5.0 5.0 with soluble boron credit - see Note 5)

(wt % 235U)

No. of Fuel Rod Locations 179 179 176 180 173 (Note 11)

Fuel Rod Clad 0.400 0.417 0.440 0.422 0.3415 O.D. (in.)

Fuel Rod Clad I.D.

0.3514 0.3734 0.3880 0.3890 0.3175 (in.)

Fuel Pellet Dia.

0.3444 0.3659 0.3805 0.3835 0.3130 (in.)(Note 8)

Fuel Rod Pitch (in.) 0.556 0.556 0.580 0.556 Note 6 Active Fuel Length 150 150 150 144 102 (in.)

No. of Guide and/or Instrument 17 17 5 (Note 4) 16 0 Tubes Guide/Instrument Tube Thickness 0.017 0.017 0.038 0.0145 N/A (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-37 Page 103 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-2 (page 2 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 15x15A 15x15B 15x15C 15x15D 15x15E 15x15F Array/Class Clad Material ZR ZR ZR ZR ZR ZR Design Initial U

< 473 < 473 < 473 < 495 < 495 < 495 (kg/assy.) (Note 3)

Initial Enrichment (MPC-24, 24E and < 4.1 (24) < 4.1 (24) < 4.1 (24) < 4.1 (24) < 4.1 (24) < 4.1 (24) 24EF without soluble boron credit) < 4.5 < 4.5 < 4.5 < 4.5 < 4.5 < 4.5 (wt % 235U) (24E/24EF) (24E/24EF) (24E/24EF) (24E/24EF) (24E/24EF) (24E/24EF)

(Note 7)

Initial Enrichment (MPC-24, 24E, 24EF, 32, or 32F

< 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 with soluble boron credit - see Note 5)(wt % 235U)

No. of Fuel Rod Locations 204 204 204 208 208 208 (Note 11)

Fuel Rod Clad

> 0.418 > 0.420 > 0.417 > 0.430 > 0.428 > 0.428 O.D. (in.)

Fuel Rod Clad I.D.

< 0.3660 < 0.3736 < 0.3640 < 0.3800 < 0.3790 < 0.3820 (in.)

Fuel Pellet Dia.

< 0.3580 < 0.3671 < 0.3570 < 0.3735 < 0.3707 < 0.3742 (in.) (Note 8)

Fuel Rod Pitch

< 0.550 < 0.563 < 0.563 < 0.568 < 0.568 < 0.568 (in.)

Active Fuel Length

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

No. of Guide and/or Instrument 21 21 21 17 17 17 Tubes Guide/Instrument Tube Thickness > 0.0165 > 0.015 > 0.0165 > 0.0150 > 0.0140 > 0.0140 (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-38 Page 104 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-2 (page 3 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 15x15I 15x15G 15x15H 16x16A 16x16B 16x16C Array/ Class Clad Material SS ZR ZR ZR ZR ZR Design Initial U 495

< 420 < 495 < 448 < 448 < 448 (kg/assy.)(Note 3)

Initial Enrichment < 4.0 N/A

< 3.8 (24) < 4.6 (24) < 4.6 (24) < 4.6 (24)

(MPC-24, 24E, (24) (Note 9) and 24EF without soluble boron < 4.2 < 5.0 < 5.0 < 5.0

< 4.5 credit)(wt % 235U) (24E/24E (24E/24E (24E/24E (24E/24E (24E/24 (Note 7) F) F) F) F)

EF)

Initial Enrichment 5.0 (MPC-24, 24E, (Note 9) 24EF, 32, or 32F with soluble < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 boron credit - see Note 5) (wt %

235 U)

No. of Fuel Rod 216 Locations 204 208 236 236 235 (Note 11)

Fuel Rod Clad 0.413

> 0.422 > 0.414 > 0.382 > 0.374 > 0.374 O.D. (in.)

Fuel Rod Clad < 0.367

< 0.3700 < 0.3350 < 0.3290 < 0.3290 I.D. (in.) 0.3890 Fuel Pellet Dia. < 0.360

< 0.3622 < 0.3255 < 0.3225 < 0.3225 (in.) (Note 8) 0.3825 Fuel Rod Pitch 0.550

< 0.563 < 0.568 < 0.506 < 0.506 < 0.485 (in.)

Active Fuel 150

< 144 < 150 < 150 < 150 < 150 Length (in.)

No. of Guide 9 and/or Instrument 21 17 (Note 10) 5 (Note 4) 5 (Note 4) 21 Tubes Guide/Instrument 0.0140 Tube Thickness > 0.0140 > 0.0350 > 0.0400 > 0.0157 0.0145 (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-39 Page 105 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-2 (page 4 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly Array/ Class 17x17A 17x17B 17x17C Clad Material ZR ZR ZR Design Initial U (kg/assy.)(Note

< 433 < 474 < 480 3)

Initial Enrichment (MPC-24, < 4.0 (24) < 4.0 (24) < 4.0 (24) 24E, and 24EF without soluble boron credit)(wt % 235U) (Note

< 4.4 < 4.4 < 4.4 7)

(24E/24EF) (24E/24EF) (24E/24EF)

Initial Enrichment (MPC-24, 24E, 24EF, 32, or 32F with

< 5.0 < 5.0 < 5.0 soluble boron credit - see Note

5) (wt % 235U)

No. of Fuel Rod Locations 264 264 264 (Note 11)

Fuel Rod Clad O.D. (in.) > 0.360 > 0.372 > 0.377 Fuel Rod Clad I.D. (in.) < 0.3150 < 0.3310 < 0.3330 Fuel Pellet Dia. (in.) (Note 8) < 0.3088 < 0.3232 < 0.3252 Fuel Rod Pitch (in.) < 0.496 < 0.496 < 0.502 Active Fuel Length (in.) < 150 < 150 < 150 No. of Guide and/or Instrument 25 25 25 Tubes Guide/Instrument Tube

> 0.016 > 0.014 > 0.020 Thickness (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-40 Page 106 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-2 (page 5 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS Notes:

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

2. Deleted.

3. Design initial uranium weight is the nominal uranium weight specified for each assembly by the fuel manufacturer or reactor user. For each PWR fuel assembly, the total uranium weight limit specified in this table may be increased up to 2.0 percent for comparison with users fuel records.

4. Each guide tube replaces four fuel rods.

5. Soluble boron concentration per LCO 3.3.1.

6. This fuel assembly array/class includes only the Indian Point Unit 1 fuel assembly.

This fuel assembly has two pitches in different sectors of the assembly. These pitches are 0.441 inches and 0.453 inches.

7. For those MPCs loaded with both INTACT FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS, the maximum initial enrichment of the INTACT FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES and FUEL DEBRIS is 4.0 wt.% 235U.

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

9. This fuel assembly array/class can only be loaded in MPC-32.

10. One Instrument Tube and eight Guide Bars (Solid ZR).

11. Any number of fuel rods in an assembly can be replaced by irradiated or unirradiated Steel or Zirconia rods. If the rods are irradiated, the site specific dose and dose rate analyses performed under 10 CFR 72.212 should include considerations for the presence of such rods.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-41 Page 107 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-3 (page 1 of 6)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 6x6A 6x6B 6x6C 7x7A 7x7B 8x8A Array/Class Clad Material ZR ZR ZR ZR ZR ZR Design Initial U

< 110 < 110 < 110 < 100 < 198 < 120 (kg/assy.) (Note 3)

Maximum PLANAR- < 2.7 for AVERAGE the UO2 INITIAL rods.

ENRICHMENT < 2.7 See Note < 2.7 < 2.7 < 4.2 < 2.7 (MPC-68, 68F, 4 for and 68FF) MOX (wt.% 235U) rods (Note 14)

Maximum PLANAR-AVERAGE INITIAL Note 18 Note 18 Note 18 Note 18 4.8 Note 18 ENRICHMENT (MPC-68M)

(wt.% 235U)

(Note 16, 19)

Initial Maximum Rod Enrichment < 4.0 < 4.0 < 4.0 < 5.5 < 5.0 < 4.0 (wt.% 235U)

No. of Fuel Rod 35 or 36 Locations (Note 20) 35 or 36 (up to 9 36 49 49 63 or 64 MOX rods)

Fuel Rod Clad O.D.

> 0.5550 > 0.5625 > 0.5630 > 0.4860 > 0.5630 > 0.4120 (in.)

Fuel Rod Clad I.D.

< 0.5105 < 0.4945 < 0.4990 < 0.4204 < 0.4990 < 0.3620 (in.)

Fuel Pellet Dia. (in.) < 0.4980 < 0.4820 < 0.4880 < 0.4110 < 0.4910 < 0.3580 Fuel Rod Pitch (in.) < 0.710 < 0.710 < 0.740 < 0.631 < 0.738 < 0.523 Active Fuel Length

< 120 < 120 < 77.5 < 80 < 150 < 120 (in.)

No. of Water Rods 1 or 0 1 or 0 0 0 0 1 or 0 (Note 11)

Water Rod

>0 >0 N/A N/A N/A >0 Thickness (in.)

Channel Thickness

< 0.060 < 0.060 < 0.060 < 0.060 < 0.120 < 0.100 (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-42 Page 108 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-3 (2 of 6)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 8x8B 8x8C 8x8D 8x8E 8x8F 9x9A Array/Class Clad Material ZR ZR ZR ZR ZR ZR Design Initial U

< 192 < 190 < 190 < 190 < 191 < 180 (kg/assy.) (Note 3)

Maximum PLANAR-AVERAGE INITIAL ENRICHMENT < 4.2 < 4.2 < 4.2 < 4.2 < 4.0 < 4.2 (MPC-68, 68F, and 68FF)

(wt.% 235U)

(Note 14)

Maximum PLANAR-AVERAGE INITIAL 4.5 4.8 4.8 4.8 4.8 4.8 ENRICHMENT (Note 15)

(MPC-68M)

(wt.% 235U)

(Note 16, 19)

Initial Maximum Rod Enrichment < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 (wt.% 235U)

No. of Fuel Rod 74/66 Locations (Note 20) 63 or 64 62 60 or 61 59 64 (Note 5)

Fuel Rod Clad O.D.

> 0.4840 > 0.4830 > 0.4830 > 0.4930 > 0.4576 > 0.4400 (in.)

Fuel Rod Clad I.D.

< 0.4295 < 0.4250 < 0.4230 < 0.4250 < 0.3996 < 0.3840 (in.)

Fuel Pellet Dia. (in.) < 0.4195 < 0.4160 < 0.4140 < 0.4160 < 0.3913 < 0.3760 Fuel Rod Pitch (in.) < 0.642 < 0.641 < 0.640 < 0.640 < 0.609 < 0.566 Design Active Fuel

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

No. of Water Rods 1-4 N/A (Note 11) 1 or 0 2 5 2 (Note 7) (Note 12)

Water Rod

> 0.034 > 0.00 > 0.00 > 0.034 > 0.0315 > 0.00 Thickness (in.)

Channel Thickness

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

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-43 Page 109 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-3 (page 3 of 6)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 9x9B 9x9C 9x9D 9x9E 9x9F 9x9G Array/Class (Note 13) (Note 13)

Clad Material ZR ZR ZR ZR ZR ZR Design Initial U < 180 < 182 < 182 < 183 < 183 < 164 (kg/assy.)(Note 3)

Maximum PLANAR-AVERAGE INITIAL ENRICHMENT < 4.2 < 4.2 < 4.2 < 4.0 < 4.0 < 4.2 (MPC-68, 68F, and 68FF)

(wt.% 235U)

(Note 14)

Maximum PLANAR-AVERAGE INITIAL 4.5 4.5 4.8 4.8 4.8 4.8 ENRICHMENT (Note 15) (Note 15)

(MPC-68M)

(wt.% 235U)

(Note 16, 19)

Initial Maximum < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Rod Enrichment (wt.% 235U)

No. of Fuel Rod 72 80 79 76 76 72 Locations (Note 20)

Fuel Rod Clad O.D. > 0.4330 > 0.4230 > 0.4240 > 0.4170 > 0.4430 > 0.4240 (in.)

Fuel Rod Clad I.D. < 0.3810 < 0.3640 < 0.3640 < 0.3640 < 0.3860 < 0.3640 (in.)

Fuel Pellet Dia. (in.) < 0.3740 < 0.3565 < 0.3565 < 0.3530 < 0.3745 < 0.3565 Fuel Rod Pitch (in.) < 0.572 < 0.572 < 0.572 < 0.572 < 0.572 < 0.572 Design Active Fuel < 150 < 150 < 150 < 150 < 150 < 150 Length (in.)

No. of Water Rods 1 (Note 6) 1 2 5 5 1 (Note 6)

(Note 11)

Water Rod > 0.00 > 0.020 > 0.0300 > 0.0120 > 0.0120 > 0.0320 Thickness (in.)

Channel Thickness < 0.120 < 0.100 < 0.100 < 0.120 < 0.120 < 0.120 (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-44 Page 110 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-3 (page 4 of 6)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly 10x10A 10x10B 10x10C 10x10D 10x10E 10x10F 10x10G Array/Class Clad Material ZR ZR ZR SS SS ZR ZR Design Initial U (kg/assy.) < 188 < 188 < 179 < 125 < 125 192 188 (Note 3)

Maximum PLANAR-AVERAGE INITIAL ENRICHMENT(MPC- < 4.2 < 4.2 < 4.2 < 4.0 < 4.0 Note 17 Note 17 68, 68F, and 68FF)

(wt.% 235U) (Note 14)

Maximum PLANAR-AVERAGE INITIAL 4.7 4.75 ENRICHMENT (MPC- (Note 15) (Note 21) 4.8 4.8 4.8 Note 18 Note 18 68M) 5.0 5.0 (wt.% 235U) (Note 26) (Note 26)

(Note 16, 19)

Initial Maximum Rod

< 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 < 5.0 Enrichment (wt.% 235U)

No. of Fuel Rod 92/78 91/83 92/78 96/84 96 100 96 Locations (Note 20) (Note 8) (Note 9) (Note 8)

Fuel Rod Clad O.D. > > > >

> 0.3780 0.4035 0.387 (in.) 0.4040 0.3957 0.3960 0.3940 Fuel Rod Clad I.D. (in.) < < < <

< 0.3294 0.3570 0.340 0.3520 0.3480 0.3560 0.3500 Fuel Pellet Dia. (in.) < < < <

< 0.3224 0.3500 0.334 0.3455 0.3420 0.3500 0.3430 Fuel Rod Pitch (in.) < 0.510 < 0.510 < 0.488 < 0.565 < 0.557 0.510 0.512 Design Active Fuel

< 150 < 150 < 150 < 83 < 83 150 150 Length (in.)

No. of Water Rods 1 5 5 2 0 4 2 (Note 11) (Note 6) (Note 10) (Note 10)

Water Rod Thickness

> 0.030 > 0.00 > 0.031 N/A > 0.022 0.030 0.031 (in.)

Channel Thickness

< 0.120 < 0.120 < 0.055 < 0.080 < 0.080 0.120 0.060 (in.)

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-45 Page 111 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-3 (page 5 of 6)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1)

Fuel Assembly Array 10x10I 10x10J 11x11A and Class (Note 17, 22) (Note 17, 23) (Note 17, 24)

Clad Material Zr Zr Zr Design Initial U (kg/assy.) 194 194 194 (Note 3)

Maximum Planar-Average 4.8 4.8 4.8 Initial Enrichment (wt.%

235 U) (Note 16, 19)

Maximum Planar-Average Initial Enrichment with 5.0 5.0 5.0 Partial Gadolinium Credit (wt.%235U) (Note 26)

Initial Rod Maximum 5.0 5.0 5.0 Enrichment (wt.% 235U)

No. of Fuel Rod Locations 91/79 96/80 112/92 (Note 20)

Fuel Clad O.D. (in.) > 0.4047 >0.3999 >0.3701 Fuel Clad I.D. (in.) < 0.3559 < 0.3603 < 0.3252 Fuel Pellet Dia. (in.) < 0.3492 0.3531 < 0.3193 Fuel Rod Pitch (in.) < 0.5100 0.5149 < 0.4705 Design Active Fuel < 150 < 150 < 150 Length (in.)

No. of Water Rods 1 1 1 (Note 25)

Water Rod Thickness (in.) > 0.0315 > 0.0297 > 0.0340 Channel Thickness (in.) < 0.100 0.0938 < 0.100 Notes:

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

2. Deleted.

3. Design initial uranium weight is the nominal uranium weight specified for each assembly by the fuel manufacturer or reactor user. For each BWR fuel assembly, the total uranium weight limit specified in this table may be increased up to 1.5 percent for comparison with users fuel records.

4. 0.635 wt. % 235U and 1.578 wt. % total fissile plutonium (239Pu and 241Pu), (wt. % of total fuel weight, i.e., UO2 plus PuO2).

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

6. Square, replacing nine fuel rods.

7. Variable.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-46 Page 112 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-3 (page 6 of 6)

BWR FUEL ASSEMBLY CHARACTERISTICS

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

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

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

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

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

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

14. For MPC-68, 68F, and 68FF loaded with both INTACT FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS, the maximum PLANAR AVERAGE INITIAL ENRICHMENT for the INTACT FUEL ASSEMBLIES is limited to 3.7 wt.% 235U, as applicable.

15. Fuel assemblies classified as damaged fuel assemblies are limited to 4.6 wt.% 235U for the 10x10F arrays/classes. Fuel assemblies classified as damaged fuel assemblies are limited to 4.0 wt.% 235U for the 8x8F, 9x9E and 9x9F arrays/classes except when loaded to Figure 2.4.4. Fuel assemblies classified as damaged fuel assemblies are limited to 4.5 wt.% 235U for the 8x8F, 9x9E and 9x9F when loaded to Figure 2.4.4.

16. For MPC-68M loaded with both UNDAMAGED FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS, the maximum PLANAR AVERAGE INITIAL ENRICHMENT for the UNDAMAGED FUEL ASSEMBLIES is limited to the enrichment limit of the damaged assembly.

17. This fuel assembly array/class is not allowable contents in MPC-68, 68F, or 68FF.

18. This fuel assembly array/class is not allowable contents in MPC-68M.

19. In accordance with the definition of UNDAMAGED FUEL ASSEMBLY, certain assemblies may be limited to up to 3.3 wt.% U-235. When loading these fuel assemblies, all other undamaged fuel assemblies in the MPC are limited to enrichments as specified in this table.

20. Any number of fuel rods in an assembly can be replaced by irradiated or unirradiated Steel or Zirconia rods. If the rods are irradiated, the site specific dose and dose rate analyses performed under 10 CFR 72.212 should include considerations for the presence of such rods.

21. Fuel assemblies classified as damaged fuel assemblies are limited to 4.6 wt.% 235U for the 10x10G array/class escept when loaded to Figure 2.4.4. Fuel assemblies classified as damaged fuel assemblies are limited to 4.5 wt.% 235U for the 10x10G array/class when loaded to Figure 2.4.4.

22. Contains in total 91 fuel rods; 79 full length rods, 12 partial length rods, and one square water rod, replacing 9 fuel rods.

23. Contains in total 96 fuel rods; 80 full length rods, 8 long partial length rods, 8 short partial length rods and one water rod replacing 4 fuel rods.

24. Contains in total 112 fuel rods; 92 full length rods, 8 long partial length rods, 12 short partial length rods, and one square water rod replacing 9 fuel rods.

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

26. The restrictions in Table 2.1-9 apply.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-47 Page 113 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-8 NON-FUEL HARDWARE COOLING AND AVERAGE BURNUP (Notes 1, 2, 3, and 7)

Post- NSA with NFH NSA without APSR irradiation INSERTS NFH, GUIDE BURNUP Cooling Time TUBE (MWD/MTU)

(Note 4)

(years) BURNUP HARDWARE, or (MWD/MTU) CONTROL COMPONENT (Note 5)

BURNUP (MWD/MTU) 3 24,635 NA (Note 6) NA 4 30,000 NA NA 5 36,748 630,000 45,000 6 44,102 - 54,500 7 52,900 - 68,000 8 60,000 - 83,000 9 79,784 - 111,000 10 101,826 - 180,000 11 141,982 - 630,000 12 360,000 - -

Notes: 1. Burnups for NON-FUEL HARDWARE are to be determined based on the burnup and uranium mass of the fuel assemblies in which the component was inserted during reactor operation.

2. Linear interpolation between points is permitted, except that APSR burnups > 180,000 MWD/MTU and < 630,000 MWD/MTU must be cooled > 11 years.

3. Applicable to uniform loading and regionalized loading.

4. Includes Burnable Poison Rod Assemblies (BPRAs), Wet Annular Burnable Absorbers (WABAs), vibration suppressor inserts and Neutron Source Assemblies (NSAs) in combination with other control components (i.e. BPRAs, TPDs, and/or RCCAs).

5. Includes Thimble Plug Devices (TPDs), water displacement guide tube plugs, orifice rod assemblies, Control Rod Assemblies (CRAs), Control Element Assemblies (CEAs), Rod Cluster Control Assemblies (RCCAs) and NSAs without other forms of control components.

6. NA means not authorized for loading at this cooling time.

7. Non-fuel hardware burnup and cooling times are not applicable to ITTRs since they are installed post irradiation.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-48 Page 114 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.1-9 RESTRICTIONS FOR PARTIAL GADOLINIUM CREDIT IN MPC-68M FUEL ASSEMBLY ARRAY RESTRICTION AND CLASS All 10x10 and The gadolinium rod loading is not less than 11x11 3.0 wt% Gd2O3 All 10x10 and The gadolinium rods located in the peripheral row 11x11 of the fuel lattice cannot be credited All 10x10 and 11x11 Gadolinium rods are NOT required to be present in damaged fuel in DFIs or damaged fuel/fuel debris in DFCs 10x10A, 10x10B, 10x10F, At least one gadolinium rod must be present.

10x10I, 10x10J, and 11x11A 10x10C and 10x10G At least two gadolinium rods must be present Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-49 Page 115 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 2.4 Decay Heat Limits for ZR-Clad Fuel This section provides the limits on ZR-clad fuel assembly decay heat, burnup, and cooling time for storage in the HI-STORM 100 System. The method to calculate the limits and verify compliance, including examples, is provided in Chapter 12 of the HI-STORM 100 FSAR.

2.4.1 Uniform Fuel Loading Decay Heat Limits for ZR-clad fuel for VENTILATED OVERPACK Table 2.4-1 provides the maximum allowable decay heat per fuel storage location for ZR-clad fuel in uniform fuel loading for each MPC model.

Table 2.4-1 Maximum Allowable Decay Heat per Fuel Storage Location (Uniform Loading, ZR-Clad)

Decay Heat per Fuel Storage Location MPC Model (kW)

Intact or Undamaged Damaged Fuel Assemblies Fuel Assemblies and Fuel Debris MPC-24 < 1.416 Not Permitted MPC-24E/24EF < 1.416 < 1.114 MPC-32/32F < 1.062 < 0.718 MPC-68/68FF/68M < 0.500 < 0.393 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-50 Page 116 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 2.4.2 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for VENTILATED OVERPACK The maximum allowable decay heat per fuel storage location for intact or undamaged fuel assemblies in regionalized loading is determined using the following equations:

Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:

Q0 = Maximum uniform storage MPC decay heat (34 kW)

X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.4-2.

n2 = Number of storage locations in outer region from Table 2.4-2.

Allowable heat loads for Damaged Fuel and Fuel Debris in regionalized loading are shown in Table 2.4-5.

Optional loading patterns for MPC-68M are shown in Figures 2.4-1 through 2.4-4.

Alternatively to the heat load patterns in Sections 2.4.1 and 2.4.2, per cell allowable heat loads may be determined per Topical Report HI-2200343-A Revision 2.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-51 Page 117 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.4-2 Fuel Storage Regions per MPC MPC Model Number of Storage Locations Number of Storage in Inner Region (Region 1) Locations in Outer Region (Region 2)

MPC-24 and MPC-24E/EF 12 12 MPC- 32/32F 12 20 MPC-68/68FF/68MNote1 32 36 Note 1: For an optional regionalized loading pattern for MPC-68M, see Figures 2.4-1 through 2.4-4.

Table 2.4-5 Allowable Heat Load for Damaged Fuel Assemblies and Fuel Debris under Regionalized Loading Maximum Per Cell Allowable Heat Load for MPC Model Damaged Fuel Assemblies and Fuel Debris in DFCs Note 1,3 MPC-24E/24EF 0.75*q2 MPC- 32/32F 0.65*q2 MPC-68/68FF/68MNote 2 0.75*q2 Note 1: q2 is the maximum permissible heat load in Region 2 for intact fuel assemblies.

Note 2: Optional QSHL loading patterns for MPC-68M including Damaged Fuel and Fuel Debris are shown in Figures 2.4-1 through 2.4-4.

Note 3: Damaged fuel stored with DFIs can be stored up to q2 limits.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-52 Page 118 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 2.4.3 Burnup Limits as a Function of Cooling Time for ZR-Clad Fuel for VENTILATED OVERPACK The maximum allowable ZR-clad fuel assembly average burnup varies with the minimum required fuel assembly cooling time. Tables 2.4-3 and 2.4-4 provide for each MPC the allowable maximum burnup based on the assemblys particular cooling time.These same limits apply for heat load patterns developed in accordance with the topical report, HI-2200343-A, Revision 2.

2.4.3.1 2.4.3.1 Linear interpolation of burnups between cooling times is permitted. For example, the allowable burnup for a cooling time of 4.5 years may be interpolated between those burnups calculated for 4 year and 5 years.

2.4.3.12.4.3.2 Calculated burnup limits shall be rounded down to the nearest integer.

2.4.3.22.4.3.3 2.4.3.3 Calculated burnup limits greater than 68,200 MWD/MTU for PWR fuel and 65,000 MWD/MTU for BWR must be reduced to be equal to these values.

2.4.4 When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.

2.4.5 Fuel Loading Decay Heat Limits for UNVENTILATED OVERPACK Tables 2.4-6a and 2.4-6b provide the maximum allowable decay heat per fuel storage location for MPC-68M in an UNVENTILATED OVERPACK.

A minor deviation from the prescribed loading pattern in an MPCs permissible contents to allow one slightly thermally-discrepant fuel assembly per quadrant to be loaded as long as the peak cladding temperature for the MPC remains below the ISG-11 Rev 3 requirements is permitted for essential dry storage campaigns to support decommissioning.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-53 Page 119 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 2.4.6 Burnup and Cooling Time Qualifications for the MPC-68M for UNVENTILATED OVERPACK The burnup and cooling time for every fuel loaded into the MPC-68M must satisfy the following equation:

= 3 + 2 + +

where, Ct = Minimum cooling time (years),

Bu = Assembly-average burnup (MWd/mtU),

A, B, C, D= Polynomial coefficients listed in Table 2.4-9 Revision 2 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-54 Page 120 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.4-3 PWR Fuel Assembly Burnup and Cooling Time Limits for VENTILATED OVERPACK (ZR-Clad Fuel)

Minimum Maximum Cooling Time Allowable Burnup, (years) MWd/mtU MPC-24/24E/24EF 1.0 5,000 1.4 15,000 1.8 25,000 2.0 35,000 2.2 40,000 2.4 45,000 2.6 50,000 2.8 55,000 3.0 60,000 4.0 69,000 5.0 75,000 MPC-32/32F 1.0 5,000 1.4 10,000 1.8 20,000 2.0 25,000 2.2 30,000 2.4 35,000 2.6 40,000 3.0 45,000 4.0 60,000 5.0 69,000 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-55 Page 121 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 Table 2.4-4 BWR Fuel Assembly Burnup and Cooling Time Limits for VENTILATED OVERPACK (ZR-Clad Fuel)

Minimum Maximum Cooling Time Allowable Burnup, (years) MWd/mtU MPC-68/68FF/68M 1.0 10,000 1.2 15,000 1.4 20,000 2.0 25,000 2.2 30,000 2.4 35,000 2.6 40,000 3.0 50,000 4.0 62,000 5.0 65,000 6.0 70,000 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-56 Page 122 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 TABLE 2.4-6a MPC-68M HEAT LOAD DATA for UNVENTILATED OVERPACK Number of Regions: 2 Number of Storage Cells: 68 Maximum Total Heat Load (kW): 25 Maximum Section Heat Load (kW): 3.125 (Note 1)

Region No. Decay Heat Limit per Number of Cells per Decay Heat Limit per Cell, kW Region Region, kW 1 (Inner) 0.368 32 11.765 2 (Outer) 0.368 36 13.325 Note 1: Figure 2.1-4 identifies the MPC basket regions and cell locations, and Table 2.4-7 identifies the cells included in each Heat Load for each section.

TABLE 2.4-6b MPC-68M REQUIREMENTS ON DEVELOPING REGIONALIZED HEAT LOAD PATTERNS for UNVENTILATED OVERPACK (See Figure 2.1-4)

1. Total MPC aggregate Heat Load must be equal to 25 kW

2. Maximum Section Heat Load must be equal to 3.125 kW, calculated per Table 2.4-7, and pattern must be 1/8th symmetric

3. Maximum Heat Load per Cell in Region 1 is 0.368 kW

4. Maximum Heat Load per Cell in Region 2 is 0.735 kW

5. Pattern-specific Heat Load in a storage cell may need to be adjusted to meet items 1 and 2

6. Pattern-specific Heat Load for storage cells may be determined by reducing the allowable heat load in any Region 1 cell in Table 2.4-6a by a certain amount () and adding the same to a single cell or distributed amongst multiple cells in Region 2.

i.e. Any reduction of total allowable heat load in Region 1 must be compensated by an equivalent addition in Region 2.

General Notes -

1. Any assembly with a Heat Load less than the limits defined above can be loaded in the applicable cell, provided it meets all other CoC requirements.

2. DFCs/DFIs are permitted in locations denoted in Table 2.4-8 with the applicable Heat Load penalties identified therein.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-57 Page 123 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 TABLE 2.4-7 SECTION HEAT LOAD CALCULATIONS FOR MPC-68M for UNVENTILATED OVERPACK Section Equation for Section Heat Load1 Section 1 Q21 + Q13 + Q14 + Q6 + Q7 + Q8 + Q2 + 1/2Q30 + 1/2Q22 + 1/2Q15 Section 2 Q31 + Q32 + Q23 + Q33 + Q24 + Q16 + Q34 + 1/2Q30 + 1/2Q22 + 1/2Q15 Section 3 Q41 + Q42 + Q51 + Q43 + Q52 + Q60 + Q44 + 1/2Q40 + 1/2Q50 + 1/2Q59 Section 4 Q49 + Q58 + Q57 + Q64 + Q65 + Q66 + Q68 + 1/2Q40 + 1/2Q50 + 1/2Q59 Section 5 Q48 + Q56 + Q55 + Q61 + Q62 + Q63 + Q67 + 1/2Q39 + 1/2Q47 + 1/2Q54 Section 6 Q38 + Q46 + Q37 + Q36 + Q45 + Q53 + Q35 + 1/2Q39 + 1/2Q47 + 1/2Q54 Section 7 Q28 + Q27 + Q18 + Q9 + Q17 + Q26 + Q25 + 1/2Q29 + 1/2Q19 + 1/2Q10 Section 8 Q20 + Q11 + Q12 + Q3 + Q4 + Q5 + Q1 + 1/2Q29 + 1/2Q19 + 1/2Q10 Notes 1.) QX-Y is the heat load in kW in cell ID (X-Y), identified in Figure 2.1-4 Table 2.4-8 DFC and DFI Storage Locations with Heat Load penalties for MPC-68M for UNVENTILATED OVERPACK Locations/Storage Cell Heat Load DFC/DFI Min. Soluble Boron MPC Type Numbers Penalty (Note 1) Content (Note 2) (Note 3)

DFI 25%

DFC 1, 2, 3, 8, 9, 16, 25, 34, 35, 25%

MPC-68M N/A 44, 53, 60, 61, 66, 67, 68 DFCs - 25%

DFC or DFI DFIs - 25%

Notes 1: Damaged fuel assemblies or fuel debris can be loaded in DFCs while only damaged fuel assemblies that can be handled by normal means can be loaded in DFIs.

2: DFCs/DFIs are allowed for storage in certain basket peripheral locations as defined herein. Basket storage cell numbers are identified in Figure 2.1-4 for the MPC-68M.

3: Heat load penalties are applicable to ONLY those cells where DFCs/DFIs are located and are applied to the allowable undamaged fuel assembly decay heat limit in that storage cell location. The penalties remain the same for all regionalized patterns and discrete loading patterns.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-58 Page 124 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 TABLE 2.4-9 Burnup and Cooling Time Fuel Qualification Requirements for MPC-68M for UNVENTILATED OVERPACK Polynomial Coefficients, see Subsection 2.4.5 Cell Decay Heat Load Limit (kW) A B C D 0.382 9.44656e-14 -8.01992e-09 2.79524e-04 -4.10441e-01

>0.382 < decay heat 8.59250e-15 -1.40950e-09 9.57523e-05 -1.02585e+00 1.625 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-59 Page 125 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0 1 2 0.5* 0.5*

3 4 5 6 7 8 0.5* 0.5 1.2 1.2 0.5 0.5*

9 10 11 12 13 14 15 16 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

17 18 19 20 21 22 23 24 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 25 26 27 28 29 30 31 32 33 34 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

35 36 37 38 39 40 41 42 43 44 0.5* 1.2 0.4 0.4 0.4 0.4 0.4 0.4 1.2 0.5*

45 46 47 48 49 50 51 52 0.5 1.2 0.4 0.4 0.4 0.4 1.2 0.5 53 54 55 56 57 58 59 60 0.5* 0.5 1.2 0.4 0.4 1.2 0.5 0.5*

61 62 63 64 65 66 0.5* 0.5 1.2 1.2 0.5 0.5*

Cell ID 67 68 Heat Load 0.5* 0.5*

(kW)

When DAMAGED FUEL or FUEL DEBRIS is stored in this location (in a DFC),

the allowable heat load of the cell is limited to 0.35 kW. When DFIs are utilized for DAMAGED FUEL, the value in the figure applies.

Figure 2.4-1 QSHL Pattern Per Cell Allowable Heat Loads (kW) - MPC-68M Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-60 Page 126 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0

DFCs/DFIs are allowed in shaded cells. When DAMAGED FUEL or FUEL DEBRIS (in a DFC) is stored in this location, the allowable heat load of the cell is reduced by 25%. When DFIs are utilized for DAMAGED FUEL, the value in the figure applies.

Figure 2.4-2 QSHL-2 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-61 Page 127 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0

DFCs/DFIs are allowed in shaded cells. When DAMAGED FUEL or FUEL DEBRIS (in a DFC) is stored in this location, the allowable heat load of the cell is reduced by 25%. When DFIs are utilized for DAMAGED FUEL, the value in the figure applies.

Figure 2.4-3 QSHL-3 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-62 Page 128 of 155

Attachment 2 to Holtec Letter 5014962 Approved Contents 2.0

DFCs/DFIs are allowed in shaded cells. Cell IDs 19, 22, 47 and 50 must remain empty.

Figure 2.4-4 QSHL-4 Pattern, Per Cell Allowable Heat Loads (kW) - MPC-68M Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-63 Page 129 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 3.0 DESIGN FEATURES 3.1 Site 3.1.1 Site Location The HI-STORM 100 Cask System is authorized for general use by 10 CFR Part 50 license holders at various site locations under the provisions of 10 CFR 72, Subpart K.

3.2 Design Features Important for Criticality Control 3.2.1 MPC-24

1. Flux trap size: 1.09 in.

2. 10 B loading in the neutron absorbers: 0.0267 g/cm2 (Boral) and 0.0223 g/cm2 (METAMIC) 3.2.2 MPC-68 and MPC-68FF

1. Fuel cell pitch: 6.43 in.

2. 10 B loading in the neutron absorbers: 0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.3 MPC-68F

1. Fuel cell pitch: 6.43 in.

2. 10 B loading in the Boral neutron absorbers: 0.01 g/cm2 3.2.4 MPC-24E and MPC-24EF

1. Flux trap size:

i. Cells 3, 6, 19, and 22: 0.776 inch ii. All Other Cells: 1.076 inches

2. 10 B loading in the neutron absorbers: 0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC) 3.2.5 MPC-32 and MPC-32F

1. Fuel cell pitch: 9.158 inches

2. 10 B loading in the neutron absorbers: 0.0372 g/cm2 (Boral) and 0.0310 g/cm2 (METAMIC)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-1 Page 130 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.2 Design features Important for Criticality Control (contd) 3.2.6 MPC-68M

1. Basket Cell wall thickness 0.4 in. (nom.)

2. B4C content in METAMIC-HT shall be 10 wt. %

3.2.7 Fuel spacers shall be sized to ensure that the active fuel region of intact or undamaged fuel assemblies remains within the neutron poison region of the MPC basket with water in the MPC.

3.2.8 The B4C content in METAMIC shall be 33.0 wt.%.

3.2.9 Neutron Absorber Tests Boral and Metamic Classic Section 9.1.5.3 of the HI-STORM 100 FSAR is hereby incorporated by reference into the HI-STORM 100 CoC. For each MPC model specified in Sections 3.2.1 through 3.2.5 above, the neutron absorber shall meet the minimum requirements for 10B areal density or B4C content, as applicable.

Metamic-HT (Section 3.2.6 above)

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

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

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

3. If the B-10 areal density criterion in the tested panels fails to meet the specific minimum, then the manufacturer has the option to reject the entire lot or to test a statistically significant number of panels and perform statistical analysis for acceptance.

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

3.3 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 1995 Edition with Addenda through 1997, is the governing Code for the HI-STORM 100 System MPCs, OVERPACKs, and TRANSFER CASKs, as clarified in Specification 3.3.1 below, except for Code Sections V and IX. The latest effective editions of ASME Code Sections V and IX, including addenda, may be used for activities governed by those sections, provided a written reconciliation of the later edition against the 1995 Edition, including addenda, is performed by the certificate holder. American Concrete Institute (ACI) 349-85 is the governing Code for plain concrete as clarified in Appendix 1.D of the Final Safety Analysis Report for the HI-STORM 100 Cask System.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-2 Page 131 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.3.1 Alternatives to Codes, Standards, and Criteria Table 3-1 lists approved alternatives to the ASME Code for the design of the MPCs, OVERPACKs, and TRANSFER CASKs of the HI-STORM 100 Cask System.

3.3.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code, Sections II and III, 1995 Edition with Addenda through 1997 including modifications to the alternatives allowed by Specification 3.3.1 may be used on a case-specific basis when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternative should demonstrate that:

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

2. Compliance with the specified requirements of the ASME Code,Section III, 1995 Edition with Addenda through 1997, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-3 Page 132 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 1 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC, MPC Subsection General Because the MPC, OVERPACK, and basket NCA Requirements. TRANSFER CASK are not ASME Code stamped assembly, Requires vessels, none of the specifications, reports, HI-STORM preparation of a certificates, or other general requirements OVERPACK Design specified by NCA are required. In lieu of a Design steel Specification, Specification and Design Report, the HI-STORM structure, Design Report, FSAR includes the design criteria, service and HI- Overpressure conditions, and load combinations for the design TRAC Protection Report, and operation of the HI-STORM 100 System as TRANSFER Certification of well as the results of the stress analyses to CASK steel Construction demonstrate that applicable Code stress limits structure Report, Data are met. Additionally, the fabricator is not Report, and other required to have an ASME-certified QA program.

administrative All important-to-safety activities are governed by controls for an the NRC-approved Holtec QA program.

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

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

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-4 Page 133 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 2 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC basket NB-1130 NB-1132.2(d) The MPC basket supports (nonpressure-supports requires that the retaining structural attachments)and lift lugs and lift lugs first connecting (nonstructural attachments (relative to the weld of a function of lifting a loaded MPC) that are used nonpressure- exclusively for lifting an empty MPC) are welded retaining structural to the inside of the pressure-retaining MPC attachment to a shell, but are not designed in accordance with component shall Subsection NB. The basket supports and be considered part associated attachment welds are designed to of the component satisfy the stress limits of Subsection NG and unless the weld is the lift lugs and associated attachment welds more than 2t from are designed to satisfy the stress limits of the pressure- Subsection NF, as a minimum. These retaining portion of attachments and their welds are shown by the component, analysis to meet the respective stress limits for where t is the their service conditions. Likewise, non-structural nominal thickness items, such as shield plugs, spacers, etc. if of the pressure- used, can be attached to pressure-retaining retaining material. parts in the same manner.

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

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

MPC NB-2121 Provides permitted Certain duplex stainless steels are not included material in Section II, Part D, Tables 2A and 2B. UNS specification for S31803 duplex stainless steel alloy is evaluated pressure-retaining in the HI-STORM 100 FSAR and meets the material, which required design criteria for use in the HI-STORM must conform to 100 system per ASME Code Case N-635-1.

Section II, Part D, Tables 2A and 2B Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-5 Page 134 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 3 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC, MPC NB-3100 Provides These requirements are not applicable. The HI-basket NG-3100 requirements for STORM FSAR, serving as the Design assembly, NF-3100 determining Specification, establishes the service conditions HI-STORM design loading and load combinations for the storage system.

OVERPACK conditions, such and HI- as pressure, TRAC temperature, and TRANSFER mechanical loads.

CASK MPC NB-3350 NB-3352.3 Due to MPC basket-to-shell interface requires, for requirements, the MPC shell-to-baseplate weld Category C joints, joint design (designated Category C) does not that the minimum include a reinforcing fillet weld or a bevel in the dimensions of the MPC baseplate, which makes it different than any welds and throat of the representative configurations depicted in thickness shall be Figure NB-4243-1. The transverse thickness of as shown in Figure this weld is equal to the thickness of the adjoining NB-4243-1. shell (1/2 inch). The weld is designed as a full penetration weld that receives VT and RT or UT, as well as final surface PT examinations.

Because the MPC shell design thickness is considerably larger than the minimum thickness required by the Code, a reinforcing fillet weld that would intrude into the MPC cavity space is not included. Not including this fillet weld provides for a higher quality radiographic examination of the full penetration weld.

From the standpoint of stress analysis, the fillet weld serves to reduce the local bending stress (secondary stress) produced by the gross structural discontinuity defined by the flat plate/shell junction. In the MPC design, the shell and baseplate thicknesses are well beyond that required to meet their respective membrane stress intensity limits.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-6 Page 135 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 4 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC, MPC NB-4120 NB-4121.2, NG- In-shop operations of short duration that apply Basket NG-4120 4121.2, and NF- heat to a component, such as plasma cutting of Assembly, NF-4120 4121.2 provide plate stock, welding, machining, coating, and HI-STORM requirements for pouring of lead are not, unless explicitly stated by OVERPACK repetition of tensile the Code, defined as heat treatment operations.

steel or impact tests for structure, material subjected For the steel parts in the HI-STORM 100 and HI- to heat treatment System components, the duration for which a TRAC during fabrication part exceeds the off-normal temperature limit TRANSFER or installation. defined in Chapter 2 of the FSAR shall be CASK steel limited to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in a particular manufacturing structure process (such as the HI-TRAC lead pouring process).

MPC, MPC NB-4220 Requires certain The cylindricity measurements on the rolled basket NF-4220 forming tolerances shells are not specifically recorded in the shop assembly, to be met for travelers, as would be the case for a Code-HI-STORM cylindrical, conical, stamped pressure vessel. Rather, the OVERPACK or spherical shells requirements on inter-component clearances steel of a vessel. (such as the MPC-to-TRANSFER CASK) are structure, guaranteed through fixture-controlled and HI- manufacturing. The fabrication specification TRAC and shop procedures ensure that all TRANSFER dimensional design objectives, including inter-CASK steel component annular clearances are satisfied.

structure The dimensions required to be met in fabrication are chosen to meet the functional requirements of the dry storage components. Thus, although the post-forming Code cylindricity requirements are not evaluated for compliance directly, they are indirectly satisfied (actually exceeded) in the final manufactured components.

MPC Lid NB-4243 Full penetration MPC lid and closure ring are not full penetration and Closure welds required for welds. They are welded independently to Ring Welds Category C Joints provide a redundant seal. Additionally, a weld (flat head to main efficiency factor of 0.45 has been applied to the shell per NB- analyses of these welds.

3352.3).

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-7 Page 136 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 5 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC Lid to NB-5230 Radiographic (RT) Only UT or multi-layer liquid penetrant (PT)

Shell Weld or ultrasonic (UT) examination is permitted. If PT alone is used, at examination a minimum, it will include the root and final weld required layers and each approximately 3/8 inch of weld depth.

MPC NB-5230 Radiographic (RT) Root (if more than one weld pass is required)

Closure or ultrasonic (UT) and final liquid penetrant examination to be Ring, Vent examination performed in accordance with NB-5245. The and Drain required closure ring provides independent redundant Cover Plate closure for vent and drain cover plates. Vent Welds and drain port cover plate welds are helium leakage tested. As an alternative, the helium leakage test does not have to be performed if the REDUNDANT PORT COVER DESIGN is used.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-8 Page 137 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

MPC NB-6111 All completed The MPC enclosure vessel is seal welded in the Enclosure pressure retaining field following fuel assembly loading. The MPC Vessel and systems shall be enclosure vessel shall then be pressure tested Lid pressure tested. as defined in Chapter 9. Accessibility for leakage inspections precludes a Code compliant pressure test. Since the shell welds of the MPC cannot be checked for leakage during this pressure test, the shop leakage test to 10-7 ref-cc/sec provides reasonable assurance as to its leak tightness. All MPC enclosure vessel welds (except closure ring and vent/drain cover plate) are inspected by volumetric examination, except the MPC lid-to-shell weld shall be verified by volumetric or multi-layer PT examination. If PT alone is used, at a minimum, it must include the root and final layers and each approximately 3/8 inch of weld depth. For either UT or PT, the maximum undetectable flaw size must be demonstrated to be less than the critical flaw size. The critical flaw size must be determined in accordance with ASME Section XI methods.

The critical flaw size shall not cause the primary stress limits of NB-3000 to be exceeded.

The inspection results, including relevant findings (indications), shall be made a permanent part of the users records by video, photographic, or other means which provide an equivalent retrievable record of weld integrity.

The video or photographic records should be taken during the final interpretation period described in ASME Section V, Article 6, T-676.

The vent/drain cover plate and the closure ring welds are confirmed by liquid penetrant examination. The inspection of the weld must be performed by qualified personnel and shall meet the acceptance requirements of ASME Code Section III, NB-5350 for PT or NB-5332 for UT.

Table 3-1 (page 6 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC NB-7000 Vessels are No overpressure protection is provided. The Enclosure required to have function of the MPC enclosure vessel is to Vessel overpressure contain the radioactive contents under normal, protection off-normal, and accident conditions. The MPC vessel is designed to withstand maximum internal pressure considering 100% fuel rod failure and maximum accident temperatures.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-9 Page 138 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

MPC NB-8000 States The HI-STORM100 System is to be marked and Enclosure requirements for identified in accordance with 10CFR71 and Vessel nameplates, 10CFR72 requirements. Code stamping is not stamping and required. QA data package to be in accordance reports per NCA- with Holtec approved QA program.

8000.

MPC Basket NG-2000 Requires materials Materials will be supplied by Holtec-approved Assembly to be supplied by supplier with CMTRs in accordance with ASME-approved NG-2000 requirements.

material supplier.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-10 Page 139 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 7 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article MPC basket NG-4420 NG-4427(a) allows Modify the Code requirement (intended for core assembly a fillet weld in any support structures) with the following text single continuous prepared to accord with the geometry and stress weld to be less analysis imperatives for the fuel basket: For the than the specified longitudinal MPC basket fillet welds, the following fillet weld criteria apply: 1) The specified fillet weld throat dimension by not dimension must be maintained over at least 92 more than 1/16 percent of the total weld length. All regions of inch, provided that undersized weld must be less than 3 inches long the total undersize and separated from each other by at least 9 portion of the weld inches. 2) Areas of undercuts and porosity does not exceed beyond that allowed by the applicable ASME 10 percent of the Code shall not exceed 1/2 inch in weld length.

length of the weld. The total length of undercut and porosity over any Individual 1-foot length shall not exceed 2 inches. 3) The undersize weld total weld length in which items (1) and (2) apply portions shall not shall not exceed a total of 10 percent of the exceed 2 inches in overall weld length. The limited access of the length. MPC basket panel longitudinal fillet welds makes it difficult to perform effective repairs of these welds and creates the potential for causing additional damage to the basket assembly (e.g.,

to the neutron absorber and its sheathing) if repairs are attempted. The acceptance criteria provided in the foregoing have been established to comport with the objectives of the basket design and preserve the margins demonstrated in the supporting stress analysis.

From the structural standpoint, the weld acceptance criteria are established to ensure that any departure from the ideal, continuous fillet weld seam would not alter the primary bending stresses on which the design of the fuel baskets is predicated. Stated differently, the permitted weld discontinuities are limited in size to ensure that they remain classifiable as local stress elevators (peak stress, F, in the ASME Code for which specific stress intensity limits do not apply).

MPC Basket NG-8000 States The HI-STORM100 System is to be marked and Assembly requirements for identified in accordance with 10CFR71 and nameplates, 10CFR72 requirements. Code stamping is not stamping and required. The MPC basket data package to be reports per in accordance with Holtec approved QA NCA-8000. program.

OVERPACK NF-2000 Requires materials Materials will be supplied by Holtec-approved Steel to be supplied by supplier with CMTRs in accordance with Structure ASME-approved NF-2000 requirements.

material supplier.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-11 Page 140 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 8 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article TRANSFER NF-2000 Requires materials Materials will be supplied by Holtec-approved CASK Steel to be supplied by supplier with CMTRs in accordance with Structure ASME-approved NF-2000 requirements.

material supplier.

OVERPACK NF-4441 Requires special The margins of safety in these welds under Baseplate examinations or loads experienced during lifting operations or and Lid Top requirements for accident conditions are quite large. The Plate welds where a OVERPACK baseplate welds to the inner shell, primary member of pedestal shell, and radial plates are only loaded thickness 1 inch or during lifting conditions and have large safety greater is loaded factors during lifting. Likewise, the top lid plate to transmit loads in to lid shell weld has a large structural margin the through under the inertia loads imposed during a non-thickness mechanistic tipover event.

direction.

OVERPACK NF-3256 Provides Welds for which no structural credit is taken are Steel NF-3266 requirements for identified as Non-NF welds in the design Structure welded joints. drawings. These non-structural welds are specified in accordance with the pre-qualified welds of AWS D1.1. These welds shall be made by welders and weld procedures qualified in accordance with AWS D1.1 or ASME Section IX.

Welds for which structural credit is taken in the safety analyses shall meet the stress limits for NF-3256.2, but are not required to meet the joint configuration requirements specified in these Code articles. The geometry of the joint designs in the cask structures are based on the fabricability and accessibility of the joint, not generally contemplated by this Code section governing supports.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-12 Page 141 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-1 (page 9 of 9)

LIST OF ASME CODE ALTERNATIVES FOR HI-STORM 100 CASK SYSTEM Component Reference Code Alternative, Justification & Compensatory ASME Code Requirement Measures Section/Article HI-STORM NF-3320 NF-3324.6 and These Code requirements are applicable to linear OVERPACK NF-4720 NF-4720 provide structures wherein bolted joints carry axial, and HI- requirements for shear, as well as rotational (torsional) loads. The TRAC bolting OVERPACK and TRANSFER CASK bolted TRANSFER connections in the structural load path are CASK qualified by design based on the design loadings defined in the FSAR. Bolted joints in these components see no shear or torsional loads under normal storage conditions. Larger clearances between bolts and holes may be necessary to ensure shear interfaces located elsewhere in the structure engage prior to the bolts experiencing shear loadings (which occur only during side impact scenarios).

Bolted joints that are subject to shear loads in accident conditions are qualified by appropriate stress analysis. Larger bolt-to-hole clearances help ensure more efficient operations in making these bolted connections, thereby minimizing time spent by operations personnel in a radiation area. Additionally, larger bolt-to-hole clearances allow interchangeability of the lids from one particular fabricated cask to another.

HI-STORM Section II, SA- Table 1 - All SA-516 material used in the HI-STORM 100 OVERPACK 516/516A Chemical system is required to meet the material and HI- requirements composition described in ASME Code Section TRAC II, 2007 edition. This edition allows for a TRANSFER different manganese content from the 1995 CASK edition, but does not change the structural or thermal properties of the material.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-13 Page 142 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.4 Site-Specific Parameters and Analyses Site-specific parameters and analyses that will require verification by the system user are, as a minimum, as follows:

1. The temperature of 80o F is the maximum average yearly temperature for the VENTILATED OVERPACK. The temperature of 70°F is the maximum average yearly temperature for the UNVENTILATED OVERPACK.

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

3. a. For storage in freestanding OVERPACKs, the resultant horizontal acceleration (vectorial sum of two horizontal Zero Period Accelerations (ZPAs) at a three-dimensional seismic site), GH, and vertical ZPA, GV, on the top surface of the ISFSI pad, expressed as fractions of g, shall satisfy the following inequality:

GH + µGV µ where µ is either the Coulomb friction coefficient for the cask/ISFSI pad interface or the ratio r/h, where r is the radius of the cask and h is the height of the cask center-of-gravity above the ISFSI pad surface. The above inequality must be met for both definitions of µ,

but only applies to ISFSIs where the casks are deployed in a freestanding configuration. Unless demonstrated by appropriate testing that a higher coefficient of friction value is appropriate for a specific ISFSI, the value used shall be 0.53. If acceleration time-histories on the ISFSI pad surface are available, GH and GV may be the coincident values of the instantaneous net horizontal and vertical accelerations. If instantaneous accelerations are used, the inequality shall be evaluated at each time step in the acceleration time history over the total duration of the seismic event.

If this static equilibrium based inequality cannot be met, a dynamic analysis of the cask/ISFSI pad assemblage with appropriate recognition of soil/structure interaction effects shall be performed to ensure that the casks will not tip over or undergo excessive sliding under the sites Design Basis Earthquake.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-14 Page 143 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.4 Site-Specific Parameters and Analyses (continued)

b. For free-standing casks, under environmental conditions that may degrade the pad/cask interface friction (such as due to icing) the response of the casks under the sites Design Basis Earthquake shall be established using the best estimate of the friction coefficient in an appropriate analysis model. The analysis should demonstrate that the earthquake will not result in cask tipover or cause a cask to fall off the pad. In addition, impact between casks should be precluded, or should be considered an accident for which the maximum g-load experienced by the stored fuel shall be limited to 45 gs.

c. For those ISFSI sites with design basis seismic acceleration values that may overturn or cause excessive sliding of free-standing casks, the HI-STORM 100 System OVERPACKs shall be anchored to the ISFSI pad. The site seismic characteristics and the anchorage system shall meet the following requirements:

i. The site acceleration response spectra at the top of the ISFSI pad shall have ZPAs that meet the following inequalities:

GH 2.12 AND GV 1.5 Where:

GH is the vectorial sum of the two horizontal ZPAs at a three-dimensional seismic site (or the horizontal ZPA at a two-dimensional site) and GV is the vertical ZPA.

ii. Each HI-STORM 100 dry storage cask shall be anchored with twenty-eight (28), 2-inch diameter studs and compatible nuts of material suitable for the expected ISFSI environment. The studs shall meet the following requirements:

Yield Strength at Ambient Temperature: 80 ksi Ultimate Strength at Ambient Temperature: 125 ksi Initial Tensile Pre-Stress: 55 ksi AND 65 ksi (continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-15 Page 144 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.4 Site-Specific Parameters and Analyses (continued)

NOTE: The above anchorage specifications are required for the seismic spectra defined in item 3.4.3.c.i. Users may use fewer studs or those of different diameter to account for site-specific seismic spectra less severe than those specified above. The embedment design shall comply with Appendix B of ACI-349-97. A later edition of this Code may be used, provided a written reconciliation is performed.

iii. Embedment Concrete Compressive Strength: 4,000 psi at 28 days

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

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

6. a. For freestanding casks, the ISFSI pad shall be verified by analysis to limit cask deceleration during design basis drop and non-mechanistic tip-over events to 45 gs at the top of the MPC fuel basket. Analyses shall be performed using methodologies consistent with those described in the HI-STORM 100 FSAR. A restriction on the lift and/or drop height is not required if the cask is lifted with a device designed in accordance with applicable stress limits from ANSI N14.6, and/or NUREG-0612, and has redundant drop protection features.

b. For anchored casks, the ISFSI pad shall be designed to meet the embedment requirements of the anchorage design. A cask tip-over event for an anchored cask is not credible. The ISFSI pad shall be verified by analysis to limit cask deceleration during a design basis drop event to 45 gs at the top of the MPC fuel basket, except as provided for in this paragraph below. Analyses shall be performed using methodologies consistent with those described in the HI-STORM 100 FSAR. A restriction on the lift and/or drop height is not required to be established if the cask is lifted with a device designed in accordance with applicable stress limits from ANSI N14.6, and/or NUREG-0612, and has redundant drop protection features.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-16 Page 145 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.4 Site-Specific Parameters and Analyses (continued)

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

8. LOADING OPERATIONS, OVERPACK TRANSPORT OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area ambient temperatures 0o F for all MPC heat loads, and

a. 90oF (averaged over a 3-day period) for operations subjected to direct solar heating

b. 110oF (averaged over a 3-day period) for operations not subjected to direct solar heating for all MPC heat loads.

If the reference ambient temperature exceeds the corresponding Threshold Temperature then a site specific analysis shall be performed using the actual heat load and reference ambient temperature equal to the three day average to demonstrate that the steady state peak fuel cladding temperature will remain below the 400°C limit.

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

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

11. Site ambient temperature under HI-TRAC TRANSPORT OPERATIONS shall be evaluated in accordance with Section 3.9 requirements.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-17 Page 146 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.5 Cask Transfer Facility (CTF) 3.5.1 TRANSFER CASK and MPC Lifters Lifting of a loaded TRANSFER CASK and MPC using devices that are not integral to structures governed by 10 CFR Part 50 shall be performed with a CTF that is designed, operated, fabricated, tested, inspected, and maintained in accordance with the guidelines of NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, as applicable, and the below clarifications. The CTF Structure requirements below do not apply to heavy loads bounded by the regulations of 10 CFR Part 50 or to the loading of an OVERPACK in a belowground restraint system which permits MPC TRANSFER near grade level and does not require an aboveground CTF.

3.5.2 CTF Structure Requirements 3.5.2.1 Cask Transfer Station and Stationary Lifting Devices

1. The metal weldment structure of the CTF structure shall be designed to comply with the stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. The applicable loads, load combinations, and associated service condition definitions are provided in Table 3-2. All compression loaded members shall satisfy the buckling criteria of ASME Section III, Subsection NF.

2. If a portion of the CTF structure is constructed of reinforced concrete, then the factored load combinations set forth in ACI-318 (89) for the loads defined in Table 3-2 shall apply.

3. The TRANSFER CASK and MPC lifting device used with the CTF shall be designed, fabricated, operated, tested, inspected and maintained in accordance with NUREG-0612, Section 5.1.

4. The CTF shall be designed, constructed, and evaluated to ensure that if the MPC is dropped during inter-cask transfer operations, its confinement boundary would not be breached. This requirement applies to CTFs with either stationary or mobile lifting devices.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-18 Page 147 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.5 Cask Transfer Facility (CTF) (continued) 3.5.2.2 Mobile Lift Devices If a mobile lifting device is used as the lifting device, in lieu of a stationary lifting device, it shall meet the guidelines of NUREG-0612, Section 5.1, with the following clarifications:

1. Mobile lifting devices shall have a minimum safety factor of two over the allowable load table for the lifting device in accordance with the guidance of NUREG-0612, Section 5.1.6(1)(a) and shall be capable of stopping and holding the load during a Design Basis Earthquake (DBE) event.

2. Mobile lifting devices shall conform to meet the requirements of ANSI B30.5, Mobile and Locomotive Cranes, in lieu of the requirements of ANSI B30.2, Overhead and Gantry Cranes.

3. Mobile cranes are not required to meet the requirements of NUREG-0612, Section 5.1.6(2) for new cranes.

4. Horizontal movements of the TRANSFER CASK and MPC using a mobile crane are prohibited.

(continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-19 Page 148 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.5 Cask Transfer Facility (CTF)(continued)

Table 3-2 Load Combinations and Service Condition Definitions for the CTF Structure (Note 1)

Load Combination ASME III Service Condition Comment for Definition of Allowable Stress D* All primary load bearing Level A members must satisfy Level A D+S stress limits D + M + W (Note 2)

D+F Level D Factor of safety against overturning shall be 1.1 D+E D+Y D = Dead load D* = Apparent dead load S = Snow and ice load for the CTF site M = Tornado missile load for the CTF site W = Tornado wind load for the CTF site F = Flood load for the CTF site E = Seismic load for the CTF site Y = Tsunami load for the CTF site Notes: 1. The reinforced concrete portion of the CTF structure shall also meet the factored combinations of loads set forth in ACI-318(89).

2. Tornado missile load may be reduced or eliminated based on a PRA for the CTF site.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-20 Page 149 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.6 Forced Helium Dehydration System 3.6.1 System Description Use of a forced helium dehydration (FHD) system, (a closed-loop system) is an alternative to vacuum drying the MPC for moderate burnup fuel (

45,000 MWD/MTU) with lower MPC heat load and for drying MPCs containing one or more high burnup fuel assemblies or higher MPC heat loads as indicated in Appendix A Table 3-1. The FHD system shall be designed for normal operation (i.e., excluding startup and shutdown ramps) in accordance with the criteria in Section 3.6.2.

3.6.2 Design Criteria 3.6.2.1 The temperature of the helium gas in the MPC shall be at least 15oF higher than the saturation temperature at coincident pressure.

3.6.2.2 The pressure in the MPC cavity space shall be 60.3 psig (75 psia) during drying. Backfill pressures shall be as described in Appendix A.

3.6.2.3 The hourly recirculation rate of helium shall be 10 times the nominal helium mass backfilled into the MPC for fuel storage operations.

3.6.2.4 The partial pressure of the water vapor in the MPC cavity will not exceed 3 torr. The limit is met if the gas temperature at the demoisturizer outlet is verified by measurement to remain 21oF for a period of 30 minutes or if the dew point of the gas exiting the MPC is verified by measurement to remain 22.9oF for 30 minutes.

3.6.2.5 The condensing module shall be designed to de-vaporize the recirculating helium gas to a dew point 120oF.

3.6.2.6 The demoisturizing module shall be configured to be introduced into its helium conditioning function after the condensing module has been operated for the required length of time to assure that the bulk moisture vaporization in the MPC (defined as Phase 1 in FSAR Appendix 2.B) has been completed.

3.6.2.7 The helium circulator shall be sized to effect the minimum flow rate of circulation required by these design criteria.

3.6.2.8 The pre-heater module shall be engineered to ensure that the temperature of the helium gas in the MPC meets these design criteria.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-21 Page 150 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.6 Forced Helium Dehydration System (continued) 3.6.3 Fuel Cladding Temperature A steady-state thermal analysis of the MPC under the forced helium flow scenario shall be performed using the methodology described in HI-STORM 100 FSAR Section 4.4, with due recognition of the forced convection process during FHD system operation. This analysis shall demonstrate that the peak temperature of the fuel cladding, under the most adverse condition of FHD system operation, is below the peak cladding temperature limit for normal conditions of storage for the applicable fuel type (PWR or BWR) and cooling time at the start of dry storage.

3.6.4 Pressure Monitoring During FHD Malfunction During an FHD malfunction event, described in HI-STORM 100 FSAR Chapter 11 as a loss of helium circulation, the system pressure must be monitored to ensure that the conditions listed therein are met.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-22 Page 151 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.7 Supplemental Cooling System 3.7.1 System Description A supplemental cooling system (SCS) is an external system for cooling the MPC inside the HI-TRAC transfer cask during on-site transport. The SCS is required for transport of high burnup fuel under certain heat load conditions defined in Table 3-3. The SCS shall be designed for normal operation (i.e., excluding startup and shutdown ramps) in accordance with the criteria in Section 3.7.2.

3.7.2 Design Criteria 3.7.2.1 Not Used.

3.7.2.2 If water is used as the coolant, the system shall be sized to limit the coolant temperature to below 180ºF under steady-state conditions for the design basis heat load at an ambient air temperature of 110ºF. Any electric motors shall have a backup power supply for uninterrupted operation.

3.7.2.3 The system shall utilize a contamination-free fluid medium in contact with the external surfaces of the MPC and inside surfaces of the HI -TRAC transfer cask to minimize corrosion.

3.7.2.4 All passive components such as tubular heat exchangers, manually operated valves and fittings shall be designed to applicable standards (TEMA, ANSI).

3.7.2.5 The heat dissipation capacity of the SCS shall be equal to or greater than the minimum necessary to ensure that the peak cladding temperature is below 400ºC (752ºF). All heat transfer surfaces in heat exchangers shall be assumed to be fouled to the maximum limits specified in a widely used heat exchange equipment standard such as the Standards of Tubular Exchanger Manufacturers Association.

3.7.2.6 The coolant utilized to extract heat from the MPC shall be high purity water or air. Antifreeze may be used to prevent water from freezing if warranted by operating conditions. (continued)

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-23 Page 152 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.7 Supplemental Cooling System (continued) 3.7.2.7 All pressure boundaries (as defined in the ASME Boiler and Pressure Vessel Code,Section VIII Division 1) shall have pressure ratings that are greater than the maximum system operating pressure by at least 15 psi.

3.7.2.8 All ASME Code components shall comply with Section VIII Division 1 of the ASME Boiler and Pressure Vessel Code.

3.7.2.9 All gasketed and packed joints shall have a minimum design pressure rating of the pump shut-off pressure plus 15 psi.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-24 Page 153 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued)

Table 3-3 Requirements for Supplemental Cooling System Criteria for use of SCS Requirement MPC-68M Not required MPC containing one or more high Burnup fuel assemblies (> 45,000 MWD/MTU) and Yes Heat loads more than 90% of maximum permissible heat loads defined in Section 2.4 under higher helium backfill limits in Table 3-2 of Appendix A MPC containing one or more high Burnup Yes fuel assemblies (> 45,000 MWD/MTU) and Heat loads more than 90% of heat load limits in Tables 3-3 or 3-4 of Appendix A under lower helium backfill limits in Table 3-2 of Appendix A Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-25 Page 154 of 155

Attachment 2 to Holtec Letter 5014962 Design Features 3.0 DESIGN FEATURES (continued) 3.8 Combustible Gas Monitoring During MPC Lid Welding and Cutting During MPC lid-to-shell welding and cutting operations, combustible gas monitoring of the space under the MPC lid is required, to ensure that there is no combustible mixture present.

3.9 Environmental Temperature Requirements TRANSPORT OPERATIONS operations involving the HI-TRAC transfer cask can be carried out if the reference ambient temperature (three day average around the cask) is above 0°F and below the Threshold Temperature of 110 deg. F ambient temperature, applicable during HI-TRAC transfer operations inside the 10 CFR Part 50 or 10 CFR Part 52 structural boundary and 90 deg. F outside of it. The determination of the Threshold Temperature compliance shall be made based on the best available thermal data for the site.

If the reference ambient temperature exceeds the corresponding Threshold Temperature then a site specific analysis shall be performed using the actual heat load and reference ambient temperature equal to the three day average to ensure that the steady state peak fuel cladding temperature will remain below the 400°C limit. If the peak fuel cladding temperature exceeds 400°C limit then the operation of a Supplemental Cooling System (SCS) in accordance with LCO 3.1.4 is mandatory.

SCS operation is mandatory if site data is not available or if a user elects to deploy Supplemental Cooling in lieu of site ambient temperature evaluation.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix B 3-26 Page 155 of 155

ML23146A141

Text

3.3.1 APPLICABILITY

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