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Conditions for Cask Use and Technical Specifications, Renewed Amendment 1 - Appendix a
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Issue date:	09/12/2023
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APPENDIX A NAC-MPC SYSTEM TECHNICAL SPECIFICATIONS Certificate of Compliance No. 1025 A-1 Renewed Amendment 1

Appendix A Table of Contents 1.0 USE AND APPLICATION ............................................................................................. A1-1 1.1 Definitions............................................................................................................ A1-1 1.2 Logical Connectors .............................................................................................. A1-5 1.3 Completion Times................................................................................................ A1-8 1.4 Frequency.......................................................................................................... A1-13 2.0 FUNCTIONAL AND OPERATING LIMITS.................................................................... A2-1 2.1 Functional and Operating Limits .......................................................................... A2-1 2.2 Functional and Operating Limit Violations............................................................ A2-2 Table A2-1 Fuel Assembly Limits ................................................................................ A2-3 Table A2-2 INTACT FUEL ASSEMBLY Characteristics............................................... A2-6 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ............................. A3-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............................................ A3-3 3.1 NAC-MPC SYSTEM Integrity............................................................................... A3-5 3.1.1 [Reserved]................................................................................................ A3-5 3.1.2 CANISTER Vacuum Drying Pressure....................................................... A3-7 3.1.3 CANISTER Helium Backfill Pressure........................................................ A3-8 3.1.4 CANISTER Helium Leak Rate.................................................................. A3-9 3.1.5 CANISTER Maximum Time in Vacuum Drying ....................................... A3-10 3.1.6 CANISTER Maximum Time in TRANSFER CASK ................................. A3-13 3.1.7 Fuel Cooldown Requirements ................................................................ A3-14 3.1.8 CONCRETE CASK Maximum Lifting Height .......................................... A3-16 3.1.9 TRANSFER CASK Minimum Operating Temperature ............................ A3-17 3.1.10 CANISTER Removal from the CONCRETE CASK................................. A3-18 Table A3-1 CANISTER Limits ....................................................................... A3-19 3.2 NAC-MPC SYSTEM Radiation Protection.......................................................... A3-20 3.2.1 NAC-MPC SYSTEM Average Surface Dose Rates ................................ A3-20 Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement ........................................................................ A3-22 3.2.2 CANISTER Surface Contamination ........................................................ A3-23 Certificate of Compliance No. 1025 A-2 Renewed Amendment 1

Appendix A Table of Contents (Continued) 4.0 DESIGN FEATURES.............................................................................................. A4-1 4.1 Site............................................................................................................... A4-1 4.2 Storage Features ......................................................................................... A4-1 4.3 Codes and Standards................................................................................... A4-1 4.4 Site Specific Parameters and Analyses ........................................................ A4-7 4.5 Design Specifications ................................................................................... A4-9 Table A4-1 List of ASME Code Exceptions for the NAC-MPC CANISTER ................. A4-3 5.0 ADMINISTRATIVE CONTROLS............................................................................. A5-1 5.1 NAC-MPC SYSTEM Training ....................................................................... A5-1 5.2 Dry Run Training .......................................................................................... A5-2 5.3 Special Requirements for First NAC-MPC SYSTEM Placed in Service ........ A5-3 5.4 Programs ..................................................................................................... A5-4 5.4.1 CONCRETE CASK Thermal Monitoring Programs....................................... A5-4 5.4.2 Aging Management Program......................................................................... A5-5 Certificate of Compliance No. 1025 A-3 Renewed Amendment 1

THIS PAGE INTENTIONALLY LEFT BLANK Definitions A 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.

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.

CANISTER See TRANSPORTABLE STORAGE CANISTER CONCRETE CASK See VERTICAL CONCRETE CASK DAMAGED FUEL ASSEMBLY DAMAGED FUEL ASSEMBLY is a fuel assembly having individual fuel rods with known or suspected cladding defects greater than a hairline crack or a pinhole leak.

DAMAGED FUEL ROD DAMAGED FUEL ROD is a fuel rod with known or suspected cladding defects greater than a hairline crack or a pinhole leak.

FUEL DEBRIS FUEL DEBRIS is fuel in the form of particles, loose pellets, and fragmented rods or assemblies.

INDEPENDENT SPENT FUEL The facility within the perimeter fence licensed for STORAGE INSTALLATION storage of spent fuel within NAC-MPC SYSTEMs (see also 10 CFR 72.3).

(ISFSI)

Certificate of Compliance No. 1025 A1-1 Renewed Amendment 1

Definitions A 1.1 1.1 Definitions (Continued)

INTACT FUEL ASSEMBLY INTACT FUEL ASSEMBLY is a fuel assembly without known or suspected cladding defects greater than a pinhole leak or a hairline crack and which can be handled by normal means. A fuel assembly shall not be classified as an INTACT FUEL ASSEMBLY unless solid Zircaloy or stainless steel rods are used to replace missing fuel rods and which displaces an amount of water equal to that displaced by the original fuel rod(s).

INTACT FUEL ROD INTACT FUEL ROD is a fuel rod without known or suspected cladding defects greater than a pinhole leak or a hairline crack.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an NAC-MPC SYSTEM while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the CANISTER and end when the NAC-MPC SYSTEM is secured on the transporter.

RECONFIGURED FUEL ASSEMBLY A stainless steel canister having the same external (RFA) dimensions as a standard Yankee Class spent fuel assembly that ensures criticality control geometry and which permits gaseous and liquid media to escape while minimizing dispersal of gross particulates. The RECONFIGURED FUEL ASSEMBLY may contain a maximum of 64 INTACT FUEL RODS, DAMAGED FUEL RODS or FUEL DEBRIS from any type of Yankee Class spent fuel assembly.

Certificate of Compliance No. 1025 A1-2 Renewed Amendment 1

Definitions A 1.1 1.1 Definitions (Continued)

NAC-MPC SYSTEM NAC-MPC SYSTEM includes the components approved for loading and storage of spent fuel assemblies at the ISFSI. The NAC-MPC SYSTEM consists of a CONCRETE CASK, a TRANSFER CASK and a CANISTER.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI, while an NAC-MPC SYSTEM containing spent fuel is located on the storage pad within the ISFSI perimeter.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities involved in moving a loaded NAC-MPC CONCRETE CASK AND CANISTER to and from the ISFSI. TRANSPORT OPERATIONS begin when the NAC-MPC SYSTEM is first secured on the transporter and end when the NAC-MPC SYSTEM is at its destination and no longer secured on the transporter.

TRANSPORTABLE STORAGE TRANSPORTABLE STORAGE CANISTER is the CANISTER (CANISTER) sealed container that consists of a tube and disk fuel basket in a cylindrical canister shell that is welded to a baseplate, shield lid with welded port covers, and structural lid. The CANISTER provides the confinement boundary for the confined spent fuel.

TRANSFER CASK TRANSFER CASK is a shielded lifting device that holds the CANISTER during LOADING and UNLOADING OPERATIONS and during closure welding, vacuum drying, leak testing, and non-destructive examination of the CANISTER closure welds. The TRANSFER CASK is also used to transfer the CANISTER into and from the CONCRETE CASK, and into the transport cask.

Certificate of Compliance No. 1025 A1-3 Renewed Amendment 1

Definitions A 1.1 1.1 Definitions (Continued)

TRANSFER OPERATIONS TRANSFER OPERATIONS include all licensed activities involved in transferring a loaded CANISTER from a CONCRETE CASK to another CONCRETE CASK or to a TRANSPORT CASK.

UNLOADING OPERATIONS UNLOADING OPERATIONS include all licensed activities on an NAC-MPC SYSTEM to be unloaded of the contained fuel assemblies. UNLOADING OPERATIONS begin when the NAC-MPC SYSTEM is no longer secured on the transporter and end when the last fuel assembly is removed from the NAC-MPC SYSTEM. UNLOADING OPERATIONS may include transfer of a loaded CANISTER from the CONCRETE CASK to the transport cask.

VERTICAL CONCRETE CASK CONCRETE CASK is the cask that receives and (CONCRETE CASK) holds the sealed CANISTER. It provides the gamma and neutron shielding and convective cooling of the spent fuel confined in the CANISTER.

Certificate of Compliance No. 1025 A1-4 Renewed Amendment 1

Logical Connectors A 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 Technical Specifications 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 indentations 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; the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency.

Certificate of Compliance No. 1025 A1-5 Renewed Amendment 1

Logical Connectors A 1.2 1.2 Logical Connectors (Continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLES 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.

Certificate of Compliance No. 1025 A1-6 Renewed Amendment 1

Logical Connectors A 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 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 indicated that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed.

Certificate of Compliance No. 1025 A1-7 Renewed Amendment 1

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

BACKGROUND Limiting Conditions for Operations (LCOs) specify the lowest functional capability or performance levels of equipment required for safe operation of the NAC-MPC SYSTEM. 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 Time(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, provided that the NAC-MPC SYSTEM is in a specified condition stated in the Applicability of the LCO. Prior to the expiration of the specified Completion Time, Required Actions must be completed. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the NAC-MPC 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.

Certificate of Compliance No. 1025 A1-8 Renewed Amendment 1

Completion Times A 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 Action B.1 Perform Action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion AND 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 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 six hours, 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 .

Certificate of Compliance No. 1025 A1-9 Renewed Amendment 1

Completion Times A 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 within limit.

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 seven 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; therefore, the Required Actions of Condition B may be terminated.

Certificate of Compliance No. 1025 A1-10 Renewed Amendment 1

Completion Times A 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 to be 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 are tracked for each component.

Certificate of Compliance No. 1025 A1-11 Renewed Amendment 1

Completion Times A 1.3 1.3 Completion Times (Continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

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

TIME Certificate of Compliance No. 1025 A1-12 Renewed Amendment 1

Frequency A 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

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

The specified Frequency is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR)

Applicability. The specified Frequency consists of 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 a SR satisfied, SR 3.0.4 imposes no restriction.

The use of met or performed in these instances conveys specific meanings. A Surveillance is met only after the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being performed, constitutes a Surveillance not met.

Certificate of Compliance No. 1025 A1-13 Renewed Amendment 1

Frequency A 1.4 1.4 Frequency 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 , SR 3.0.2 allows an extension of the time interval to 1.25 times the interval specified in the Frequency 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.

Certificate of Compliance No. 1025 A1-14 Renewed Amendment 1

Frequency A 1.4 1.4 Frequency (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. 1025 A1-15 Renewed Amendment 1

THIS PAGE INTENTIONALLY LEFT BLANK Functional and Operating Limits A 2.0 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Functional and Operating Limits 2.1.1 Fuel to be Stored in the NAC-MPC SYSTEM INTACT FUEL ASSEMBLIES, INTACT FUEL RODS, DAMAGED FUEL RODS and FUEL DEBRIS placed in a RECONFIGURED FUEL ASSEMBLY meeting the limits specified in Table A2-1 may be stored in the NAC-MPC SYSTEM.

The values shown in Tables A2-1 and A2-2 are design nominal record values.

Preferential loading of Yankee Class fuel is used to establish reduced total decay heat loads in the CANISTER. The reduced heat load configurations allow the use of extended operating times in vacuum drying as specified in LCO 3.1.5.

The reduced heat load configurations are based on loading Yankee Class fuel assemblies having a maximum decay heat of 320 watts and the total CANISTER decay heat load.

Certificate of Compliance No. 1025 A2-1 Renewed Amendment 1

Functional and Operating Limits A 2.0 2.2 Functional and Operating Limit Violations If any Functional and Operating Limits of Table A2-1 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 that describes the cause of the violation and actions taken to restore compliance and prevent recurrence.

Certificate of Compliance No. 1025 A2-2 Renewed Amendment 1

Functional and Operating Limit A 2.2 Table A2-1 Fuel Assembly Limits I. NAC-MPC CANISTER A. Allowable Contents

1. Uranium oxide Yankee Class INTACT FUEL ASSEMBLIES listed in Table A2-2 and meet the following specifications:

a. Cladding Type: Zircaloy or Stainless Steel as specified in Table A2-2 for the applicable fuel assembly class (Note: Type A and Type B configurations in Table A2-2 identify variations in the arrangement of the outer row of fuel rods that accommodate the insertion of control blades in the reactor.)

b. Enrichment: As specified in Table A2-2 for the applicable fuel assembly type.

c. Decay Heat Per Assembly:

i. Zircaloy-Clad Fuel: < 347 Watts ii. Stainless Steel-Clad Fuel: < 264 Watts

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

i. Zircaloy-Clad Fuel: As specified in Table A2-2 for the applicable fuel assembly type.

ii. Stainless Steel-Clad Fuel: As specified in Table A2-2 for the applicable fuel assembly type.

Certificate of Compliance No. 1025 A2-3 Renewed Amendment 1

Functional and Operating Limit A 2.2 Table A2-1 Fuel Assembly Limits (Continued)

f. Nominal Fuel Assembly Length: Maximum = 111.8 inches Minimum = 109.0 inches

g. Nominal Fuel Assembly Width: < 7.64 inches

h. Fuel Assembly Weight:

i. Zircaloy-Clad Fuel: < 850 lbs ii. Stainless Steel-Clad Fuel: < 900 lbs

i. Minimum Length of Bottom Fuel Nozzle: 6.7 inches (17.0 cm)

2. Uranium oxide Yankee Class INTACT FUEL RODS, DAMAGED FUEL RODS or FUEL DEBRIS placed in RECONFIGURED FUEL ASSEMBLIES (RFA).

The original fuel assemblies for the INTACT FUEL RODS, DAMAGED FUEL RODS and FUEL DEBRIS shall meet the criteria specified in Table A2-2 for the fuel assembly class, and meet the following additional specifications:

a. Cladding Type: Zircaloy or Stainless Steel as specified in Table A2-2 for the applicable fuel assembly type.

b. Enrichment: As specified in Table A2-2 for the applicable fuel assembly type.

c. Decay Heat Per RFA: < 102 Watts

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

i. Zircaloy-Clad Fuel: As specified in Table A2-2 for the applicable fuel assembly type.

Certificate of Compliance No. 1025 A2-4 Renewed Amendment 1

Functional and Operating Limits A 2.0 Table A2-1 Fuel Assembly Limits (Continued) ii. Stainless Steel-Clad Fuel: As specified in Table A2-2 for the applicable fuel assembly type.

e. Nominal Original Fuel Assembly Length: < 111.8 inches

f. Nominal Original Fuel Assembly Width: < 7.64 inches

g. Maximum Weight: < 850 lbs, including RFA

h. Maximum mass U per RFA: 66.33 kg

3. Uranium oxide Yankee Class fuel requiring preferential loading to meet CANISTER reduced heat load configurations.

a. Fuel shall be as described in Items A1 and/or A2, except that the maximum fuel assembly decay heat is limited to 320 watts.

b. Fuel assemblies having a decay heat up to 320 watts may be loaded in any fuel loading position.

B. Quantity per CANISTER:

Up to 36 INTACT FUEL ASSEMBLIES and RFAs to the maximum content weight limit of 30,600 pounds.

C. INTACT FUEL ASSEMBLIES and RFAs shall not contain control components.

D. INTACT FUEL ASSEMBLIES shall not contain empty fuel rod positions. A solid Zircaloy or stainless steel rod that would displace an equivalent amount of water as an intact fuel rod shall replace any missing fuel rods.

Certificate of Compliance No. 1025 A2-5 Renewed Amendment 1

Functional and Operating Limits A 2.0 Table A2-2 INTACT FUEL ASSEMBLY Characteristics Fuel Assembly Type Combustion Combustion United United Engineering Engineering Exxon Exxon Exxon Exxon Westinghouse Westinghouse Nuclear Nuclear Type A Type B Type A Type B Type A Type B Type A Type B Type A Type B ASSEMBLY CONFIGURATION2 Assembly Length (cm) 283.9 283.9 283.3 283.3 283.9 283.9 282.6 282.6 282.4 282.4 Assembly Width (cm) 19.2 19.2 19.3 19.3 19.3 19.3 19.3 19.3 19.4 19.4 Assembly Weight (kg) 352 350.6 372 372 372 372 408.2 408.2 385.5 385.5 Enrichment-wt. % 235U Maximum 3.90 3.90 4.00 4.00 4.00 4.00 4.94 4.94 4.00 4.00 Minimum 3.70 3.70 3.50 3.50 3.50 3.50 4.94 4.94 4.00 4.00 Max. Burnup (MWD/MTU) 36,0001 36,0001 36,000 36,000 36,000 36,000 32,000 32,000 32,000 32,000 Max. Initial Heavy 239.4 238.4 239.4 238.4 239.4 238.4 286.9 286.0 245.6 244.6 Metal KgU/assembly Min. Cool Time (yr) 8.11 8.11 16.0 16.0 9.0 9.0 21.0 21.0 13.0 13.0 1 1 Max. Decay Heat (kW) 0.347 0.347 0.269 0.269 0.331 0.331 0.264 0.264 0.257 0.257 FUEL ROD CONFIGURATION Fuel Rod Pitch (cm) 1.20 1.20 1.20 1.20 1.20 1.20 1.07 1.07 1.19 1.19 Active Fuel Length 231.1 231.1 231.1 231.1 231.1 231.1 234.0 234.0 231.1 231.1 (cm)

Rod OD (cm) 0.93 0.93 0.93 0.93 0.93 0.93 0.86 0.86 0.93 0.93 Clad ID (cm) 0.81 0.81 0.81 0.81 0.81 0.81 0.76 0.76 0.81 0.81 Clad Material Zircaloy Zircaloy Zircaloy Zircaloy Zircaloy Zircaloy SS SS Zircaloy Zircaloy Pellet OD (cm) 0.79 0.79 0.79 0.79 0.79 0.79 0.75 0.75 0.79 0.79 Rods per Assembly 231 230 231 230 231 230 305 304 237 236

1. Combustion Engineering fuel may be loaded at a maximum burnup of 32,000 MWD/MTU, a 235 minimum enrichment of 3.5 wt% U and cool time of 8.0 years. The maximum decay heat for this assembly is 0.304 kW.

2. Type A and Type B configurations identify variations in the arrangement of the outer row of fuel rods that accommodate the insertion of control blades in the reactor.

Certificate of Compliance No. 1025 A2-6 Renewed Amendment 1

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

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

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

LCO 3.0.3 Not applicable to an NAC-MPC SYSTEM.

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 NAC-MPC SYSTEM.

Exceptions to this Specification are stated in the individual Specifications. These exceptions allow entry into specified conditions in the Applicability where the associated ACTIONS to be entered allow operation in the specified conditions in the Applicability only for a limited period of time.

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

Certificate of Compliance No. 1025 A3-1 Renewed Amendment 1

LCO Applicability A 3.0 LCO 3.0.6 Not applicable to an NAC-MPC SYSTEM.

LCO 3.0.7 Not applicable to an NAC-MPC SYSTEM.

Certificate of Compliance No. 1025 A3-2 Renewed Amendment 1

SR Applicability A 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 a 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.

Certificate of Compliance No. 1025 A3-3 Renewed Amendment 1

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

SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made, unless the LCOs 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 NAC-MPC SYSTEM.

Certificate of Compliance No. 1025 A3-4 Renewed Amendment 1

A 3.1.1 3.1 NAC-MPC SYSTEM Integrity 3.1.1 [Reserved]

Certificate of Compliance No. 1025 A3-5 Renewed Amendment 1

A 3.1.1 THIS PAGE INTENTIONALLY LEFT BLANK Certificate of Compliance No. 1025 A3-6

CANISTER Vacuum Drying Pressure A 3.1.2 3.1 NAC-MPC SYSTEM Integrity 3.1.2 CANISTER Vacuum Drying Pressure LCO 3.1.2 The CANISTER vacuum drying pressure shall meet the limit specified in Table A3-1.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER vacuum drying A.1 Establish CANISTER 25 days pressure limit not met. cavity vacuum drying pressure within limit.

B. Required Action and B.1 Remove all fuel 5 days Associated Completion assemblies from the Time not met. NAC-MPC SYSTEM.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify CANISTER cavity vacuum drying Prior to TRANSPORT pressure is within limit OPERATIONS.

Certificate of Compliance No. 1025 A3-7 Renewed Amendment 1

CANISTER Helium Backfill Pressure A 3.1.3 3.1 NAC-MPC SYSTEM Integrity 3.1.3 CANISTER Helium Backfill Pressure LCO 3.1.3 The CANISTER helium backfill pressure shall meet the limit specified in Table A3-1.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER helium backfill A.1 Establish CANISTER 25 days pressure limit not met. helium backfill pressure within limit.

B. Required Action and B.1 Remove all fuel 5 days Associated Completion assemblies from the Time not met. NAC-MPC SYSTEM.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Verify CANISTER helium backfill pressure Prior to TRANSPORT is within limit OPERATIONS.

Certificate of Compliance No. 1025 A3-8 Renewed Amendment 1

CANISTER Helium Leak Rate A 3.1.4 3.1 NAC-MPC SYSTEM Integrity 3.1.4 CANISTER Helium Leak Rate LCO 3.1.4 There shall be no indication of a helium leak at a test sensitivity of 4 x

-8 3 10 cm /sec (helium) through the CANISTER shield lid to CANISTER shell confinement weld to demonstrate a helium leak rate less than 8 x

-8 3 10 cm /sec (helium) as specified in Table A3-1.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER helium leak A.1 Establish CANISTER 25 days rate limit not met. helium leak rate within limit.

B. Required Action and B.1 Remove all fuel 5 days Associated Completion assemblies from the Time not met. NAC-MPC SYSTEM.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4.1 Verify CANISTER helium leak rate is within Prior to TRANSPORT limit OPERATIONS.

Certificate of Compliance No. 1025 A3-9 Renewed Amendment 1

CANISTER Maximum Time in Vacuum Drying A 3.1.5 3.1 NAC-MPC SYSTEM Integrity 3.1.5 CANISTER Maximum Time in Vacuum Drying LCO 3.1.5 The following limits for vacuum drying time shall be met, as appropriate:

1. The time duration from completion of draining the CANISTER through completion of vacuum dryness testing and the introduction of helium backfill shall not exceed the time shown for the specified heat loads:

Total Heat Load (L) (kW) Time Limit (Hours) 10.5 < L 12.5 38 8.5 < L 10.5 48 6.5 < L 8.5 58 4.5 < L 6.5 83 L 4.5 Not Limited

2. The time duration from end of external forced air or in-pool cooling of the CANISTER through completion of vacuum dryness testing and the introduction of helium backfill shall not exceed the time shown for the specified heat loads:

Time Limit (Hours)

Total Heat Load (L) (kW) Forced Air In-pool 10.5 < L 12.5 10 10 8.5 < L 10.5 12 12 6.5 < L 8.5 16 16 4.5 < L 6.5 40 40 APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

Certificate of Compliance No. 1025 A3-10 Renewed Amendment 1

CANISTER Maximum Time in Vacuum Drying A 3.1.5 3.1 NAC-MPC SYSTEM Integrity 3.1.5 CANISTER Maximum Time in Vacuum Drying (Continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO time limits A.1 Commence filling CANISTER with 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months not met helium AND A.1.1Place TRANSFER CASK with Not limited helium filled loaded CANISTER in spent fuel pool.

AND A.1.2Commence supplying water to the TRANSFER CASK fill lines at not less than 1 GPM and a maximum temperature of 100°F AND A.1.3Maintain TRANSFER CASK and CANISTER in spent fuel pool for Prior to restart of a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . LOADING OPERATIONS OR A.2 Commence filling CANISTER 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months with helium AND A.2.1 Commence supplying air to the Not limited TRANSFER CASK bottom eight fill/drain lines at a rate of 250 CFM and a maximum temperature of 75°F AND A.2.2 Maintain airflow for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Prior to restart of LOADING OPERATIONS Certificate of Compliance No. 1025 A3-11 Renewed Amendment 1

CANISTER Maximum Time in Vacuum Drying A 3.1.5 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Monitor elapsed time from completion of Once at completion of canister draining until start of helium canister draining backfill. AND 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months thereafter.

SR 3.1.5.2 Monitor elapsed time from completion of Once at completion of canister draining following in-pool or forced canister draining air cooling until start of helium backfill. AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter.

Certificate of Compliance No. 1025 A3-12 Renewed Amendment 1

CANISTER Maximum Time in TRANSFER CASK A 3.1.6 3.1 NAC-MPC SYSTEM Integrity 3.1.6 CANISTER Maximum Time in TRANSFER CASK LCO 3.1.6 The following limits for CANISTER time in TRANSFER CASK shall be met, as appropriate:

1. The time duration from the introduction of helium backfill of the CANISTER through completion of the CANISTER transfer operation from the TRANSFER CASK to the CONCRETE CASK is not limited.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

Certificate of Compliance No. 1025 A3-13 Renewed Amendment 1

Fuel Cooldown Requirements A 3.1.7 3.1 NAC-MPC SYSTEM Integrity 3.1.7 Fuel Cooldown Requirements LCO 3.1.7 A loaded CANISTER and its fuel contents shall be cooled down in accordance with the following specifications:

a. Nitrogen gas flush for a minimum of 10 minutes

b. Minimum cooling water temperature of 70°F

c. Cooling water flow rate of 5 (+3, -0) gallons per minute at inlet pressure of 25 (+10, -0) psig

d. Maintain cooling water flow through CANISTER until outlet water temperature < 200°F

e. Maximum canister pressure 50 psig APPLICABILITY: During UNLOADING OPERATIONS

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

The LCO is only applicable to wet UNLOADING OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER cooldown A.1 Initiate actions to meet Immediately requirements not met. CANISTER cooldown requirements.

Certificate of Compliance No. 1025 A3-14 Renewed Amendment 1

Fuel Cooldown Requirements A 3.1.7 3.1 NAC-MPC SYSTEM Integrity 3.1.7 Fuel Cooldown Requirements (Continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.7.1 Initiate CANISTER cooldown flow to loaded Within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months after removal CANISTER. of CANISTER from CONCRETE CASK and placement in Transfer Cask.

SR 3.1.7.2 Verify that the cooldown water temperature Once within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to and flow rate are within limits. initiating cooldown AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months thereafter.

Certificate of Compliance No. 1025 A3-15 Renewed Amendment 1

CONCRETE CASK Maximum Lifting Height A 3.1.9 3.1 NAC-MPC SYSTEM Integrity 3.1.8 CONCRETE CASK Maximum Lifting Height LCO 3.1.8 A CONCRETE CASK containing a CANISTER loaded with INTACT FUEL ASSEMBLYs or RECONFIGURED FUEL ASSEMBLYs shall be lifted in accordance with the following requirement

a. A lift height < 6 inches APPLICABILITY: During TRANSPORT OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. NAC-MPC SYSTEM lifting A.1 Initiate actions to meet Immediately requirements not met. CONCRETE CASK maximum lifting height.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.8.1 Verify CONCRETE CASK lifting After the CONCRETE CASK requirements are met. is raised to install or remove air pad and prior to TRANSPORT OPERATIONS Certificate of Compliance No. 1025 A3-16 Renewed Amendment 1

CANISTER Removal from the CONCRETE CASK A 3.1.10 3.1 NAC-MPC SYSTEM Integrity 3.1.9 TRANSFER CASK Minimum Operating Temperature LCO 3.1.9 The TRANSFER CASK shall not be used for loaded CANISTER transfer operations outside of the fuel handling facility when the external ambient temperature is 0°F.

APPLICABILITY: During LOADING or UNLOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. External ambient A.1 Do not perform TRANSFER Immediately temperature below CASK operations external to LCO limit the facility.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.9.1 Measure external ambient temperature. Prior to start of LOADING or UNLOADING OPERATIONS AND 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months thereafter.

Certificate of Compliance No. 1025 A3-17 Renewed Amendment 1

CANISTER Removal from the CONCRETE CASK A 3.1.10 3.1 NAC-MPC SYSTEM Integrity 3.1.10 CANISTER Removal from the CONCRETE CASK LCO 3.1.10 The following limits for TRANSFER OPERATIONS shall be met, as appropriate:

1. The time duration for holding the CANISTER in the TRANSFER CASK is not limited.

APPLICABILITY: During TRANSFER OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

Certificate of Compliance No. 1025 A3-18 Renewed Amendment 1

NAC-MPC SYSTEM Average Surface Dose Rate A 3.2.1 Table A3-1 CANISTER Limits CANISTER LIMITS NAC-MPC CANISTER

a. CANISTER Vacuum Drying Pressure < 3 mm of Mercury for > 30 min

-8

b. CANISTER Helium Leak Rate < 8x10 std cc/sec (helium)

c. CANISTER Helium Backfill Pressure 0 (+1, -0) psig Certificate of Compliance No. 1025 A3-19 Renewed Amendment 1

NAC-MPC SYSTEM Average Surface Dose Rate A 3.2.1 3.2 NAC-MPC SYSTEM Radiation Protection 3.2.1 NAC-MPC SYSTEM Average Surface Dose Rates LCO 3.2.1 CONCRETE CASK dose rates shall be measured at the locations shown in Figure A3-1. The average surface dose rates of each CONCRETE CASK shall not exceed:

a. 50 mrem/hour (neutron + gamma) on the side (on the concrete surfaces)

b. 35 mrem/hour (neutron + gamma) on the top;

c. 100 mrem/hour (neutron + gamma) at air inlet and outlet vents.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

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

limits not met.

AND Certificate of Compliance No. 1025 A3-20 Renewed Amendment 1

NAC-MPC SYSTEM Average Surface Dose Rate A 3.2.1 3.2 NAC-MPC SYSTEM Radiation Protection 3.2.1 NAC-MPC SYSTEM Average Surface Dose Rates (Continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2 Verify that the dose rate Prior to TRANSPORT from the cask will not OPERATIONS cause the ISFSI to exceed the offsite radiation protection requirements of 10 CFR 20 and 10 CFR 72.

B. Required Action and B.1 Remove all fuel 30 days Associated Completion assemblies from the Time not met. NAC-MPC SYSTEM.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify average surface dose rates of Prior to TRANSPORT CONCRETE CASK containing fuel OPERATIONS assemblies are within limits.

Certificate of Compliance No. 1025 A3-21 Renewed Amendment 1

NAC-MPC SYSTEM Average Surface Dose Rate A 3.2.1 Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement Certificate of Compliance No. 1025 A3-22 Renewed Amendment 1

CANISTER Surface Contamination A 3.2.2 3.2 NAC-MPC SYSTEM Radiation Protection 3.2.2 CANISTER Surface Contamination LCO 3.2.2 Removable contamination on the accessible exterior surfaces of the CANISTER or accessible interior surfaces of the TRANSFER CASK shall each not exceed:

2

a. 10,000 dpm/100 cm from beta and gamma sources and

b. 100 dpm/100 cm2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER or A.1 Restore CANISTER and Prior to TRANSPORT TRANSFER CASK TRANSFER CASK OPERATIONS removable surface removable surface contamination limits not contamination to within met. limits.

Certificate of Compliance No. 1025 A3-23 Renewed Amendment 1

CANISTER Surface Contamination A 3.2.2 3.2 NAC-MPC SYSTEM Radiation Protection 3.2.2 CANISTER Surface Contamination (Continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify that the removable contamination on Prior to TRANSPORT the accessible exterior surfaces of the OPERATIONS CANISTER containing fuel is within limits.

SR 3.2.2.2 Verify that the removable contamination on Prior to TRANSPORT the accessible interior surfaces of the OPERATIONS TRANSFER CASK do not exceed limits.

Certificate of Compliance No. 1025 A3-24 Renewed Amendment 1

Design Features A 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location Not applicable 4.2 Storage Features 4.2.1 Storage Cask The NAC-MPC SYSTEM consists of the VERTICAL CONCRETE CASK (CONCRETE CASK) and its integral TRANSPORTABLE STORAGE CANISTER (CANISTER).

4.2.2 Storage Capacity The total storage capacity of the ISFSI is limited by plant-specific license conditions.

4.2.3 Storage Pad(s)

Not applicable 4.3 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 1995 Edition with Addenda, is the governing Code for the NAC-MPC CANISTER.

The American Concrete Institute Specifications ACI-349 and ACI-318 govern the NAC-MPC Vertical Concrete Cask design and construction, respectively.

The American National Standards Institute ANSI N14.6 and NUREG-0612 govern the NAC-MPC Transfer Cask design and construction.

Certificate of Compliance No. 1025 A4-1 Renewed Amendment 1

Design Features A 4.0 4.1 Site (Continued) 4.3.1 Exceptions to the ASME Code Codes and Standards The NAC-MPC CANISTER and fuel basket structure are designed and fabricated in accordance with the ASME Code,Section III, Division 1, Subsections NB and NG, respectively. Exceptions to the applicable ASME Code requirements are listed in Table A4-1.

Proposed alternatives to ASME Code Section III, 1995 Edition with Addenda, including exceptions allowed by Table A4-1 may be used as authorized by the Director of the Office of Nuclear Material Safety and Safeguards or Designee. The justification in Table A4-1 demonstrates that:

1. The proposed alternatives will provide an acceptable level of quality and safety, or

2. Compliance with the specified requirements of ASME Code,Section III, 1995 Edition with Addenda would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Certificate of Compliance No. 1025 A4-2 Renewed Amendment 1

CANISTER Exceptions Table A4-1 Table A4-1 List of ASME Code Exceptions for the NAC-MPC CANISTER Component Reference ASME Code Code Requirement Exception, Justification and Section/Article Compensatory Measures CANISTER NB-1100 Statement of requirements for CANISTER is designed and will be fabricated in Code stamping of accordance with ASME Code,Section III, components. Subsection NB to the maximum practical extent, but Code stamping is not required.

CANISTER Shield Lid NB-4243 Full penetration welds required Shield lid and structural lid to canister shell and Structural Lid for Category C joints (flat head welds are not full penetration welds. These Welds to main shell per NB-3352.3). field welds are performed independently to provide a redundant closure. Leaktightness of the canister is verified by testing.

CANISTER Structural NB-4421 Requires removal of backing Structural lid to canister shell weld uses a Lid Weld ring. backing ring that is not removed. The backing ring permits completion of the groove weld; it is not considered in any analyses; it has no detrimental effect on the canisters function.

CANISTER Vent Port NB-5230 Radiographic (RT) or Root and final surface liquid penetrant Cover and Drain Port ultrasonic (UT) examination examination to be performed per ASME Code Cover to Shield Lid required. Section V, Article 6, with acceptance in Welds; Shield Lid to accordance with NB-5350.

Canister Shell Weld Certificate of Compliance No. 1025 A4-3 Renewed Amendment 1

CANISTER Exceptions Table A4-1 Table A4-1 List of ASME Code Exceptions for the NAC-MPC CANISTER (Continued)

Component Reference ASME Code Code Requirement Exception, Justification and Section/Article Compensatory Measures CANISTER Structural NB-5230 Radiographic (RT) or The CANISTER structural lid to canister shell Lid to Shell Weld ultrasonic (UT) examination closure weld is performed in the field following required. fuel assembly loading. The structural lid-to-shell weld will be verified by either ultrasonic (UT) or progressive liquid penetrant (PT) examination. If progressive PT examination is used, at a minimum, it will include the root and final surfaces and sufficient intermediate layers to detect critical flaws. If UT examination is used, it will be followed by a final surface PT examination. For either UT or PT examination, the maximum, undetectable flaw size is demonstrated to be smaller than the critical flaw size. The critical flaw size is determined in accordance with ASME Section XI methods.

The examination of the weld will be performed by qualified personnel per ASME Code Section V, Articles 5 (UT) and 6 (PT) with acceptance per ASME Code Section III, NB-5330 (UT) and NB-5350 for (PT).

Certificate of Compliance No. 1025 A4-4 Renewed Amendment 1

CANISTER Exceptions Table A4-1 Table A4-1 List of ASME Code Exceptions for the NAC-MPC CANISTER (Continued)

Component Reference ASME Code Code Requirement Exception, Justification and Section/Article Compensatory Measures CANISTER Vessel NB-6111 All completed pressure The CANISTER shield lid to shell weld is and Shield Lid retaining systems shall be performed in the field following fuel assembly pressure tested. loading. The CANISTER, including the shield lid weld, is then pneumatically (air-over-water) pressure tested as defined in Chapter 9 and described in Chapter 8. Accessibility for leakage inspections precludes a Code compliant hydrostatic test. The shield lid-to-shell weld is re-examined by liquid penetrant (PT) examination following the pneumatic pressure test. The shield lid weld is also leak tested to leak-tight criteria of ANSI N14.5. The vent port and drain port cover welds are examined by root and final PT examination.

The structural lid secondary enclosure weld is not pressure tested, but is examined by UT and final surface PT or progressive PT.

CANISTER Vessel NB-7000 Vessels are required to have No overpressure protection is provided. The overpressure protection. function of the CANISTER is to confine radioactive contents under normal, off-normal, and accident conditions of storage. The CANISTER vessel is designed to withstand a maximum internal pressure considering 100%

fuel rod failure and maximum accident temperatures.

Certificate of Compliance No. 1025 A4-5 Renewed Amendment 1

CANISTER Exceptions Table A4-1 Table A4-1 List of ASME Code Exceptions for the NAC-MPC CANISTER (Continued)

Component Reference ASME Code Code Requirement Exception, Justification and Section/Article Compensatory Measures CANISTER Vessel NB-8000 States requirements for The NAC-MPC SYSTEM is marked and nameplates, stamping and identified in accordance with 10 CFR 72 reports per NCA-8000. requirements. Code stamping is not required.

The QA data package will be in accordance with NACs approved QA program.

CANISTER Basket NG-8000 States requirements for The NAC-MPC SYSTEM will be marked and Assembly nameplates, stamping and identified in accordance with 10 CFR 72 reports per NCA-8000. requirements. No Code stamping is required.

The CANISTER basket data package will be in conformance with NACs approved QA program.

CANISTER Vessel NB-2130/ NG-2130 States requirements for The NAC-MPC CANISTER Vessel and Basket and Basket Assembly certification of material to Assembly component materials are procured in Material NCA-3861 and NCA-3862 accordance with the specifications for materials in ASME Code Section II. The component materials will be obtained from NAC approved Suppliers in accordance with NACs approved QA program.

Certificate of Compliance No. 1025 A4-6 Renewed Amendment 1

Site Specific Parameters and Analyses A 4.4 4.4 Site Specific Parameters and Analyses Site-specific parameters and analyses that will need verification by the NAC-MPC SYSTEM user, are as a minimum, as follows:

1. The temperature of 75°F is the maximum average yearly temperature. The average daily ambient temperature shall be 100°F or less.

2. The temperature extremes of 125°F with incident solar radiation and -40°F for storage of the CANISTER inside the CONCRETE CASK.

3. The design basis earthquake horizontal and vertical seismic acceleration levels are bounded by the values shown below:

Design-Basis Earthquake Input on the Top Surface of an ISFSI Pad Horizontal g-level in each of Corresponding Vertical Two Orthogonal Directions g-level (upward) 0.25g 0.25 x 0.667 = 0.167g

4. The analyzed flood condition of 15 fps water velocity and a height of 50 feet of water (full submergence of the loaded cask) are not exceeded.

5. The potential for fire and explosion shall be addressed, based on site-specific considerations. This includes the condition that the fuel tank of the cask handling equipment used to move the loaded CONCRETE CASK onto the ISFSI site contains no more than 50 gallons of fuel.

Certificate of Compliance No. 1025 A4-7 Renewed Amendment 1

Site Specific Parameters and Analyses A 4.4 4.4 Site Specific Parameters and Analyses (Continued)

6. In addition to the requirement of 10 CFR 72.212(b)(2)(ii), the ISFSI pad and foundation shall include the following characteristics as applicable to the end drop and tip-over analyses:

a. Concrete thickness 36 inch maximum

b. Pad Subsoil thickness 72 inch minimum

c. Concrete compressive strength 4,000 psi at 28 days 3

d. Concrete density () 125 150 lbs/ft

e. Soil density () 85 130 lbs/ft3

f. Soil Stiffness (k) k 300 psi/in.

The concrete pad maximum thickness excludes the ISFSI pad footer. The compressive strength of concrete should be determined according to the test method given in Section 5.6 of ACI 318. Steel reinforcement is used in the pad. The placement of the reinforcement, including its area and spacing, are determined by analysis and installed in accordance with ACI 318. The soil stiffness should be determined according to the test method described in th Chapter 9 of the Civil Engineering Reference Manual, 6 Edition.

7. In cases where engineered features (i.e., berms, shield walls) are used to ensure that requirements of 10 CFR 72.104(a) are met, such features are to be considered important to safety and must be evaluated to determine the applicable Quality Assessment Category on a site specific basis.

Certificate of Compliance No. 1025 A4-8 Renewed Amendment 1

Design Specification A 4.5 4.5 Design Specifications 4.5.1 Specification Important for Thermal Performance

1. The spacing of the NAC-MPC SYSTEM shall be a minimum of 15 feet (center-to-center).

2. Helium shall have a minimum purity of 99.9%.

4.5.2 Specification Important to CANISTER Lifting The minimum distance from the master link of the CANISTER lifting slings to the top of the CANISTER shall be 67 inches.

Certificate of Compliance No. 1025 A4-9 Renewed Amendment 1

THIS PAGE INTENTIONALLY LEFT BLANK ADMINISTRATIVE CONTROLS NAC-MPC SYSTEM TRAINING A 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 NAC-MPC SYSTEM Training Training modules shall be developed under the general licensees training program as required by 10 CFR 72.212(b)(6). Training modules shall require a comprehensive, program for the operation and maintenance of the NAC-MPC SYSTEM and the Independent Spent Fuel Storage Installation (ISFSI). The training modules shall include the following elements, at a minimum:

Regulatory Requirements Overview

NAC-MPC SYSTEM Design and Operational Features

ISFSI Facility Design (overview)

Certificate of Compliance Conditions

Technical Specifications, Controls, Limits and Conditions of Use

Identification of Components and Equipment Important to Safety

Surveillance Requirements

NAC-MPC SYSTEM and ISFSI procedures, including:

Documentation, Inspection and Compliance Requirements

Handling the CONCRETE CASK and Empty CANISTER

Handling the Transfer Cask

Loading and Closing the CANISTER

Loading the CONCRETE CASK

Moving the CONCRETE CASK and CANISTER and Placement on the ISFSI

Special Processes and Equipment, including Leak Testing, Welding and Weld Examination

Auxiliary Equipment, including Lifting Yokes and Slings

Off-Normal and Accident Conditions, Response and Corrective Actions

Radiological Safety and ALARA

Operating Experience Training session participation should be documented as required to establish qualification to performed the designated tasks.

Certificate of Compliance No. 1025 A5-1 Renewed Amendment 1

Dry Run Training A 5.2 5.2 Dry Run Training A dry run training exercise of the loading, closure, handling, unloading, and transfer of the NAC-MPC Storage System shall be conducted by the licensee before the system is initially loaded.

This demonstrates equipment fitup and interfacing, provides the opportunity to illustrate key features, operations, inspections and test conditions. It also allows comparison of procedural steps to component handling requirements. 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:

Moving the Concrete Cask into its Designated Loading Area

Moving the Transfer Cask Holding the Empty Canister into the Spent Fuel Pool

Loading One or More Dummy Fuel Assemblies into the Canister, Including Independent Verification

Installing the Shield Lid

Removal of the Transfer Cask from the Spent Fuel Pool

Closing and Sealing of the Canister to Demonstrate Pressure Testing, Vacuum Drying, Helium Backfilling, Welding, Weld Inspection and Documentation, and Leak Testing

Transfer Cask Movement Through the Designated Load Path

Transfer Cask Installation on the Concrete Cask

Placement of the Canister in the Concrete Cask

Transport of the Concrete Cask to the ISFSI

Canister Unloading, Including Reflooding and Weld Removal or Cutting Demonstration of closing and sealing the canister may be performed using a mockup of the canister. The mockup should closely approximate the actual canister to allow qualification of personnel in the welding and testing tasks as required. The closed mockup is also used to demonstrate the activities necessary to open and unload the canister.

Participation in dry run training should be documented as required to establish qualification to perform designated tasks.

Certificate of Compliance No. 1025 A5-2 Renewed Amendment 1

Special Requirements for First NAC-MPC SYSTEM Placed in Service A 5.3 5.3 Special Requirements for First NAC-MPC SYSTEM Placed in Service The heat transfer characteristics of the NAC-MPC SYSTEM will be recorded by temperature measurements of the first NAC-MPC SYSTEM placed in service with a heat load equal to or greater than 7.5 kW.

Certificate of Compliance No. 1025 A5-3 Renewed Amendment 1

Programs A 5.4 5.4 Programs 5.4.1 CONCRETE CASK Thermal Monitoring Program The following programs shall be established, implemented and maintained.

This program provides guidance for the temperature measurement and visual inspection activities that are used to monitor the thermal performance of each CONCRETE CASK.

a. The ambient air temperature and the air outlet temperatures are measured and compared every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The temperature difference between the air outlet temperatures and the ambient air temperature is calculated and recorded.

b. If any air outlet temperature, or temperature difference between air outlet and ambient temperature shows an unexplained reading, appropriate actions are taken to determine the cause and to return the outlet temperatures to acceptable values. One of the immediate actions will be to increase the frequency of temperature monitoring until normal conditions are returned.

c. If an air outlet temperature exceeds the ambient air temperature by 92°F, the NRC will be notified and actions will be taken to evaluate the effects and impact of the elevated temperature on the CONCRETE CASK and CANISTER. A temperature differential of 92°F corresponds to a concrete temperature of 165°F. The long-term normal concrete temperature limit for the CONCRETE CASK is 200°F and the short-term bulk concrete temperature limit is 350°F.

Certificate of Compliance No. 1025 A5-4 Renewed Amendment 1

Programs A 5.5 5.4 Programs 5.4.2 Aging Management Program Each general licensee shall have a program to establish, implement, and maintain written procedures for each aging management program (AMP) described in the updated final safety analysis report (UFSAR). 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 program document shall contain a reference to the specific aspect of the AMP element implemented by that program document, and that reference shall be maintained even if the program document is modified.

The general licensee shall establish and implement this program document prior to entering the period of extended operation or no later than one year after the effective date of the CoC renewal, whichever is later. The general licensee shall maintain the program document for as long as the general licensee continues to operate NAC-MPC Storage Systems in service for longer than 20 years.

Certificate of Compliance No. 1025 A5-5 Renewed Amendment 1

ML23255A245

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