Text

Attachment 2: HI-STORM FW Amendment 10 Certificate of Compliance
	ML24109A252
Person / Time
Site:	07201032
Issue date:	03/01/2024
From:	; Holtec
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML24109A249	List: ML24109A250; ML24109A251; ML24109A252; ML24109A254; ML24109A263;
References
	5018109
	Download: ML24109A252 (1)
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NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (10-2004) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Page 1

of 4

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 Date Expiration Date Docket No.

Amendment No.

Amendment Effective Date Package Identification No.

1032 June 13, 2011 June 12, 2031 72-1032 10 TBD USA/72-1032 Issued To: (Name/Address)

Holtec International Holtec Technology Campus One Holtec Blvd Camden, NJ 08104 Safety Analysis Report Title Holtec International Final Safety Analysis Report for the HI-STORM FW MPC Storage System This certificate is conditioned 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), and the conditions specified below:

APPROVED SPENT FUEL STORAGE CASK Model No.: HI-STORM FW MPC Storage System DESCRIPTION:

The HI-STORM FW MPC Storage System consists of the following components: (1) interchangeable multi-purpose canisters (MPCs), which contain the fuel; (2) a storage overpack (HI-STORM FW), which contains the MPC during storage; and (3) a transfer cask (HI-TRAC VW), which contains the MPC during loading, unloading and transfer operations. The MPC stores up to 44 pressurized water reactor fuel assemblies or up to 89 boiling water reactor fuel assemblies.

The HI-STORM FW MPC Storage 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 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. 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 provides criticality control. to Holtec Letter 5018109 Page 1 of 130

NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Supplemental Sheet Certificate No.

1032 Amendment No.

10 Page 2

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DESCRIPTION (continued)

There are five types of MPCs: the MPC-32ML, MPC-37, MPC-37P, MPC-44, and MPC-89. The number suffix indicates the maximum number of fuel assemblies permitted to be loaded in the MPC. All MPC models have the same external diameter.

The HI-TRAC VW transfer cask provides shielding and structural protection of the MPC during loading, unloading, and movement of the MPC from the cask loading area to the storage overpack. The transfer cask is a multi-walled (carbon steel/lead/carbon steel) cylindrical vessel with a neutron shield jacket or neutron shield cylinder attached to the exterior and a retractable bottom lid used during transfer operations.

The HI-STORM FW storage overpack provides shielding and structural protection of the MPC during storage.

The overpack is a heavy-walled steel and concrete, cylindrical vessel. Its side wall consists of plain (unreinforced) concrete that is enclosed between inner and outer carbon steel shells. The overpack has air inlets at the bottom and air outlets at the top to allow air to circulate naturally through the cavity to cool the stored MPC.

The HI-STORM FW UVH is an alternative version of the overpack, with a similar design, but no air vents. The HI-STORM FW Extended Configuration is an alternative version of the overpack which consists of two ventilated overpacks positioned and secured on top of each other by bolted connections. The inner shell has supports attached to its interior surface to guide the MPC during insertion and removal and provide a means to protect the MPC confinement boundary against impactive or impulsive loadings. A loaded MPC is stored within the HI-STORM FW storage overpack in a vertical orientation. The HI-STORM FW ventilated storage overpack can be arrayed in a free-standing or anchored configuration (required when the seismic event for an ISFSI site exceeds the threshold limit for the free-standing configuration). If the seismic loads for a given ISFSI site exceed the threshold limit for a free-standing configuration of the HI-STORM FW set forth in the CoC, then the cask must be installed in an anchored configuration.

CONDITIONS

1.

OPERATING PROCEDURES Written operating procedures shall be prepared for handling, loading, movement, surveillance, and maintenance.

The users site-specific written operating procedures shall be consistent with the technical basis described in Chapter 9 of the FSAR.

2.

ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written acceptance tests and a maintenance program shall be prepared consistent with the technical basis described in Chapter 10 of the FSAR. At completion of welding the MPC shell to baseplate, an MPC confinement weld helium leak test shall be performed using a helium mass spectrometer. The confinement boundary welds leakage rate test shall be performed in accordance with ANSI N14.5 to leaktight criterion. 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, Article NB-4450 requirements. Re-testing shall be performed until the leakage rate acceptance criterion is met.

3.

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 storage system

4.

HEAVY LOADS REQUIREMENTS Each lift of an MPC, a HI-TRAC VW transfer cask, or any HI-STORM FW 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 of the heavy load handling procedures (under 10 CFR 50.59 or 10 CFR 72.48, as 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 5.2 of Appendix A. to Holtec Letter 5018109 Page 2 of 130

NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Supplemental Sheet Certificate No.

1032 Amendment No.

10 Page 3

of 4

5.

APPROVED CONTENTS Contents of the HI-STORM FW MPC Storage System must meet the fuel specifications given in Appendix B to this certificate.

6.

DESIGN FEATURES Features or characteristics for the site or system must be in accordance with Appendix B to this certificate.

7.

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

8.

SPECIAL REQUIREMENTS FOR FIRST SYSTEMS IN PLACE For the storage configuration, each user of a HI-STORM FW MPC Storage System with a heat load equal to or greater than 30kW shall perform a thermal validation test in which the user measures 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 30kW. To satisfy condition 8 for casks of the same system type (i.e., HI-STORM FW 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.

This condition does not apply to the unventilated version of the system.

9.

PRE-OPERATIONAL TESTING AND TRAINING EXERCISE A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM FW MPC Storage 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 FW MPC Storage 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. Transfer of the MPC from the transfer cask to the overpack. to Holtec Letter 5018109 Page 3 of 130

NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Supplemental Sheet Certificate No.

1032 Amendment No.

10 Page 4

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h. Placement of the HI-STORM FW MPC Storage System at the ISFSI.

i.

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

Any of the above steps can be omitted if they have already been successfully carried out at a site to load a HI-STORM 100 System (USNRC Docket 72-1014).

10.

AUTHORIZATION The HI-STORM FW MPC Storage 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 and B. The HI-STORM FW MPC Storage System may be fabricated and used in accordance with any approved amendment to CoC No. 1032 listed in 10 CFR 72.214.

Each of the licensed HI-STORM FW MPC Storage 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. The HI-STORM FW MPC Storage System may be installed on an ISFSI pad with the HI-STORM 100 Cask System (USNRC Docket 72-1014) provided an assessment is performed by the CoC holder that demonstrates design compatibility.

FOR THE NUCLEAR REGULATORY COMMISSION TBD Attachments:

1. Appendix A

2. Appendix B Dated: _____________

to Holtec Letter 5018109 Page 4 of 130

CERTIFICATE OF COMPLIANCE NO. 1032 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM FW MPC STORAGE SYSTEM to Holtec Letter 5018109 Page 5 of 130

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 CONDITIONS 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 TRANSFER CASK Heat Removal System.. 3.1.4-1 3.2 SFSC RADIATION PROTECTION................................................... 3.2.1-1 3.2.1 TRANSFER CASK Surface Contamination............................ 3.2.1-1 3.3 SFSC CRITICALITY CONTROL....................................................... 3.3.1-1 3.3.1 Boron Concentration.............................................................. 3.3.1-1 Table 3-1 MPC Cavity Drying Limits.................................................................... 3.4-1 Table 3-2 MPC Helium Backfill Limits.................................................................. 3.4-4 4.0 NOT USED..................................................................................................... 4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS...................................... 5.0-1 5.1 Radioactive Effluent Control Program.................................................. 5.0-1 5.2 Transport Evaluation Program............................................................. 5.0-2 5.3 Radiation Protection Program............................................................ 5.0-43 to Holtec Letter 5018109 Page 6 of 130

1.0 USE AND APPLICATION

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

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

1.1 Definitions 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.

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.

DAMAGED FUEL CONTAINER (DFC)

DFCs are specially designed enclosures for 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 FW System are as follows:

1. Holtec Generic BWR design

2. Holtec Generic PWR design DAMAGED FUEL ISOLATOR (DFI)

DFIs are specially designed barriers installed at the 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 to Holtec Letter 5018109 Page 7 of 130

1.1 Definitions Term Definition BLEU FUEL FUEL DEBRIS 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.

Blended Low Enriched Uranium (BLEU) fuel is the same as a commercial spent fuel but with a higher cobalt impurity.

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.

GROSSLY BREACHED SPENT FUEL ROD Spent nuclear fuel rod with a cladding defect that 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.

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. to Holtec Letter 5018109 Page 8 of 130

1.1 Definitions Term Definition MULTI-PURPOSE CANISTER (MPC)

MPCs are the sealed spent nuclear fuel canisters 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.

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

REDUNDANT PORT COVER DESIGN REDUNDANT PORT COVER DESIGN refers to two independent port cover plates per port opening, where each port cover plate contains multiple pass closure welds. to Holtec Letter 5018109 Page 9 of 130

1.1 Definitions Term Definition REPAIRED/RECONSITUTED FUEL ASSEMBLY Spent nuclear fuel assembly which contains dummy fuel rods that displaces an amount of water greater than or equal to the original fuel rods and/or which contains structural repairs so it can be handled by normal means. If irradiated dummy stainless steel rods are present in the fuel assembly, the dummy/replacement rods will be considered in the site specific dose calculations.

SPENT FUEL STORAGE CASKS (SFSCs)

SFSCs are containers approved for the storage of spent fuel assemblies at the ISFSI. The HI-STORM FW SFSC System consists of the OVERPACK and its integral MPC.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI while an SFSC containing spent fuel is 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 prior to and during unloading and to transfer the MPC to or from the OVERPACK.

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.

UNDAMAGED FUEL ASSEMBLY UNDAMAGED FUEL ASSEMBLIES are: a) fuel assemblies 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 of 3.3 wt% U-235, without known or suspected GROSSLY BREACHED SPENT FUEL RODS, and which can be handled by to Holtec Letter 5018109 Page 10 of 130

1.1 Definitions Term Definition 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.

EXTENDED CONFIGURATION OVERPACK The EXTENDED CONFIGURATION OVERPACK consists of two VENTILATED OVERPACKS positioned on top of each other. Each OVERPACK receives and contains a sealed MPC for interim storage at the ISFSI. The EXTENDED CONFIGURATION is secured by anchoring the bottom OVERPACK to the ISFSI pad and by securing the upper and lower cask junction by bolted connections.

ZR ZR means any zirconium-based fuel cladding or fuel channel material authorized for use in a commercial nuclear power plant reactor. to Holtec Letter 5018109 Page 11 of 130

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) to Holtec Letter 5018109 Page 12 of 130

1.2 Logical Connectors 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) to Holtec Letter 5018109 Page 13 of 130

1.2 Logical Connectors EXAMPLES (continued)

EXAMPLE 1.2-2 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.

to Holtec Letter 5018109 Page 14 of 130

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

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

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the HI-STORM FW 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 FW 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) to Holtec Letter 5018109 Page 15 of 130

1.3 Completion Times (continued)

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

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Perform Action B.1 AND B.2 Perform Action B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

The Required Actions of Condition B are to complete action B.1 within 12 hours1.388889e-4 days 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) to Holtec Letter 5018109 Page 16 of 130

1.3 Completion Times (continued)

EXAMPLES (continued)

EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not within limit.

A.1 Restore system to within limit.

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

B.1 Complete action B.1.

AND B.2 Complete action B.2.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours When a system is determined not to meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Conditions A and B are exited, and therefore, the Required Actions of Condition B may be terminated.

(continued) to Holtec Letter 5018109 Page 17 of 130

1.3 Completion Times (continued)

EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS

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

Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 Restore compliance with LCO.

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

B.1 Complete action B.1.

AND B.2 Complete action B.2.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours The Note above the ACTIONS table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table.

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

(continued) to Holtec Letter 5018109 Page 18 of 130

1.3 Completion Times (continued)

IMMEDIATE COMPLETION TIME When "Immediately" is used as a Completion Time, the Required Action should be pursued without delay and in a controlled manner. to Holtec Letter 5018109 Page 19 of 130

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

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

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

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

(continued) to Holtec Letter 5018109 Page 20 of 130

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) to Holtec Letter 5018109 Page 21 of 130

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. to Holtec Letter 5018109 Page 22 of 130

2.0 This section is intentionally left blank to Holtec Letter 5018109 Page 23 of 130

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.

to Holtec Letter 5018109 Page 24 of 130

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) to Holtec Letter 5018109 Page 25 of 130

3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 (continued)

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

SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with Actions or that are related to the unloading of an SFSC. to Holtec Letter 5018109 Page 26 of 130

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.

APPLICABILITY: Prior to TRANSPORT OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each MPC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

MPC cavity vacuum drying pressure or demoisturizer exit gas temperature limit not met.

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

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

30 days to Holtec Letter 5018109 Page 27 of 130

ACTIONS (continued)

B.

MPC helium backfill limit not met.

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

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months AND B.2.1 Develop and initiate corrective actions necessary to return the MPC to an analyzed condition by adding helium to or removing helium from the MPC.

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

C.

MPC helium leak rate limit for vent and drain port cover plate welds not met.

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

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND C.2 Develop and initiate corrective actions necessary to return the MPC to compliance with SR 3.1.1.3.

7 days (continued) to Holtec Letter 5018109 Page 28 of 130

ACTIONS (continued)

D.

Required Actions and associated Completion Times not met.

D.1 Remove all fuel assemblies from the SFSC.

30 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify that the MPC cavity has been dried in accordance with the applicable limits in Table 3-1.

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

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

Once, prior to TRANSPORT OPERATIONS to Holtec Letter 5018109 Page 29 of 130

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 each 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 and EXTENDED CONFIGURATION OVERPACKS.

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each SFSC.

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

A.1 Remove blockage.

N/A B. SFSC Heat Removal System inoperable.

B.1 Restore SFSC Heat Removal System to operable status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (Note 1)

(continued) to Holtec Letter 5018109 Page 30 of 130

ACTIONS (continued)

C. Required Action B.1 and associated Completion Time not met.

C.1 Measure SFSC dose rates in accordance with the Radiation Protection Program.

Immediately and once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (Note 1)

AND C.2.1 Restore SFSC Heat Removal System to operable status.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Note 1)

OR C.2.2 Transfer the MPC into a TRANSFER CASK.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Note 1)

OR C.2.3 Perform an engineering evaluation to demonstrate through analysis, using the models and methods from the HI-STORM FW FSAR, that all components and contents remain below allowable temperature limits. (Note 1) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Note 1)

Note 1: For heat load patterns developed in accordance with Table 3-1, Note 6, alternate completion times shall be calculated in accordance with the methodology in FSAR Section 4.4.

to Holtec Letter 5018109 Page 31 of 130

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlets are free of blockage from solid debris or floodwater.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR For OVERPACKS with installed temperature monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is:

137oF for OVERPACKS containing MPC-37s,

152oF for OVERPACKS containing BWR

MPCs,

130 oF for OVERPACKS containing MPC-32MLs

116 oF for OVERPACKS containing MPC-37Ps

144 oF for OVERPACKS containing MPC-44s (Note 2) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Note 2)

Note 2: For heat load patterns developed in accordance with Table 3-1, Note 6, alternate completion times shall be calculated in accordance with the methodology in FSAR Section 4.4. 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 methodology in FSAR Section 4.4. to Holtec Letter 5018109 Page 32 of 130

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.

CONDITION REQUIRED ACTION COMPLETION TIME A.

MPC cavity pressure not within limit.

A.1 Stop re-flooding operations until MPC cavity pressure is within limit.

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

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3.1 Ensure via analysis or direct measurement that MPC cavity pressure is within limit.

Once, prior to MPC re-flooding operations.

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

to Holtec Letter 5018109 Page 33 of 130

3.1 SFSC INTEGRITY 3.1.4 TRANSFER CASK Heat Removal System LCO 3.1.4 The HI-TRAC VW Version V or V2 Heat Removal System shall be operable

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

The HI-TRAC Version V or V2 Heat Removal System is operable when 100% of the inlet and outlet vent areas are unblocked and available for flow. If surveillance shows partial blockage ( 100%) of the duct areas, the blockage shall be removed.

APPLICABILITY: This LCO is applicable when a loaded MPC is in the HI-TRAC VW Version V or V2 TRANSFER CASK AND completion of MPC drying operations in accordance with LCO 3.1.1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. HI-TRAC VW Version V or V2 Heat Removal System inoperable.

A.1 Restore HI-TRAC VW Version V or V2 Heat Removal System to operable status 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (Note 1)

B. Required Action A.1 and associated Completion Time not met B.1 Continue to restore HI-TRAC VW Version V or V2 Heat Removal System to operable status 64 hours7.407407e-4 days 0.0178 hours 1.058201e-4 weeks 2.4352e-5 months for Version V 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Version V2 (Note 1)

C. Required Action B.1 and associated Completion Time not met.

C.1 Provide supplemental cooling OR C.2 Remove MPC from HI-TRAC Immediately (Note 1)

Note 1: For heat load patterns developed in accordance with FSAR Section 4.4 alternate completion times shall be computed in accordance with the methodology in FSAR Section 4.6. to Holtec Letter 5018109 Page 34 of 130

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4 Verify all HI-TRAC VW Version V or V2 inlets and outlets are free of blockage from debris.

Immediately and once every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (Note 1)

Note 1: For heat load patterns developed in accordance with FSAR Section 4.4 alternate surveillance frequency times shall be computed in accordance with the methodology in FSAR Section 4.6. to Holtec Letter 5018109 Page 35 of 130

3.2 SFSC RADIATION PROTECTION.

3.2.1 TRANSFER CASK Surface Contamination.

LCO 3.2.1 Removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC shall each not exceed:

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

b. 20 dpm/100 cm2 from alpha sources.

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.

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

A.1 Restore removable surface contamination to within limits.

7 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify that the removable contamination on the exterior surfaces of the TRANSFER CASK and accessible portions of the MPC containing fuel is within limits.

Once, prior to TRANSPORT OPERATIONS to Holtec Letter 5018109 Page 36 of 130

3.3 SFSC CRITICALITY CONTROL 3.3.1 Boron Concentration LCO 3.3.1 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 to be stored in the MPC:

MPC-37, MPC-32ML, MPC-37P, or MPC-44: Minimum soluble boron concentration as required by the table below.

MPC Array/Class All Undamaged Fuel Assemblies One or more Damaged Fuel Assemblies or Fuel Debris Maximum Initial Enrichment 4.0 wt% 235U (ppmb)

Maximum Initial Enrichment 5.0 wt% 235U (ppmb)

Maximum Initial Enrichment 4.0 wt% 235U (ppmb)

Maximum Initial Enrichment 5.0 wt% 235U (ppmb)

MPC-37 All 14x14 and 16x16A, B, C 1000 1600 1300 1800 All 15x15 and 17x17 1500 2000 1800 2300 MPC-32ML 16x16D 1500 2000 1600 2100 MPC-37P 15x15I 1500 2000 1800 2300 MPC-44 14x14A,B 1400 1900 1500 2000 For maximum initial enrichments between 4.0 wt% and 5.0 wt% 235U, the minimum soluble boron concentration may be determined by linear interpolation between the minimum soluble boron concentrations at 4.0 wt% and 5.0 wt%.

For 16 x 16E assembly class, the soluble boron requirement is 1500 ppmb.

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

This LCO does not apply if burnup credit as described in Section 2.4 of Appendix B is utilized in selecting assemblies prior to loading.

14x14 classes must use soluble boron as described in this LCO.

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.

to Holtec Letter 5018109 Page 37 of 130

ACTIONS

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

Separate Condition entry is allowed for each MPC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

Boron concentration not within limit.

A.1 Suspend LOADING OPERATIONS or UNLOADING OPERATIONS.

Immediately AND A.2 Suspend positive reactivity additions.

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

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

This surveillance is only required to be performed if the MPC is submerged in water or if water is to be added to, or recirculated through the MPC.

SR 3.3.1.1 Verify boron concentration is within the applicable limit using two independent measurements.

Once, within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to entering the Applicability of this LCO.

AND Once per 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter. to Holtec Letter 5018109 Page 38 of 130

Table 3-1 MPC Cavity Drying Limits Fuel Burnup (MWD/MTU)

MPC Type MPC Heat Load (kW)

(Note 6)

Method of Moisture Removal (Notes 1 and 2)

All Assemblies 45,000 MPC-37 29 (Table 2.3-9A of Appendix B or pattern developed in accordance with Table 2.3-9B of Appendix B) 44.09 (Pattern A in Tables 2.3-1A, B, C of Appendix B) 45.00 (Pattern B in Table 2.3-1A of Appendix B) 37.4 (Figures 2.3-1 through 2.3-3 of Appendix B) 39.95 (Figures 2.3-4 through 2.3-6 of Appendix B) 44.85 (Figures 2.3-7 through 2.3-9 of Appendix B)

VDS (Notes 3 and 4) or FHD (Note 4)

MPC-32ML 44.16 (Pattern A in Table 2.3-5 of Appendix B)

MPC-37P 44.09 (Pattern A in Tables 2.3-1A of Appendix B) 45.00 (Pattern B in Table 2.3-1A of Appendix B) 45.00 (Table 2.3-7A of Appendix B)

MPC-44 28 (Table 2.3-13 of Appendix B) 44 (Table 2.3-8A of Appendix B)

MPC-89 29 (Table 2.3-10A of Appendix B or pattern developed in accordance with Table 2.3-10B of Appendix B) 46.36 (Table 2.3-2A of Appendix B) 46.2 (Figures 2.3-10 and 2.3-11 of Appendix B) 46.14 (Figures 2.3-12 and 2.3-13 of Appendix B) to Holtec Letter 5018109 Page 39 of 130

Fuel Burnup (MWD/MTU)

MPC Type MPC Heat Load (kW)

(Note 6)

Method of Moisture Removal (Notes 1 and 2)

One or more assemblies

> 45,000 MPC-37 29 (Table 2.3-9A of Appendix B or pattern developed in accordance with 2.3-9B of Appendix B) 29.6 (Table 2.3-3 of Appendix B)

VDS (Notes 3 and 4) or FHD (Note 4)

MPC-32ML 28.70 (Pattern B in Table 2.3-5 of Appendix B)

MPC-37P 33.3 (Table 2.3-7B of Appendix B)

MPC-44 28 (Table 2.3-13 of Appendix B) 30 (Table 2.3-8B of Appendix B)

MPC-89 29 (Table 2.3-10A of Appendix B or pattern developed in accordance with and 2.3-10B of Appendix B) 30.0 (Table 2.3-4 of Appendix B)

One or more assemblies

> 45,000 MPC-37 44.09 (Pattern A in Tables 2.3-1A, B, C of Appendix B) 45.00 (Pattern B in Table 2.3-1A of Appendix B) 37.4 (Figures 2.3-1 through 2.3-3 of Appendix B) 39.95 (Figures 2.3-4 through 2.3-6 of Appendix B) 44.85 (Figures 2.3-7 through 2.3-9 of Appendix B)

VDS (Notes 3, 4, and 5) or FHD (Note 4)

MPC-32ML 44.16 (Pattern A in Table 2.3-5 of Appendix B)

MPC-37P 44.09 (Pattern A in Tables 2.3-1A, B, C of Appendix B) 45.00 (Pattern B in Table 2.3-1A of Appendix B) 45.00 (Table 2.3-7A of Appendix B)

MPC-44 44 (Table 2.3-8A of Appendix B) to Holtec Letter 5018109 Page 40 of 130

Fuel Burnup (MWD/MTU)

MPC Type MPC Heat Load (kW)

(Note 6)

Method of Moisture Removal (Notes 1 and 2)

MPC-89 46.36 (Table 2.3-2A of Appendix B) 46.2 (Figures 2.3-10 and 2.3-11 of Appendix B) 46.14 (Figures 2.3-12 and 2.3-13 of Appendix B)

Notes:

1.

VDS means a vacuum drying system. The acceptance criterion when using a VDS is the MPC cavity pressure shall be 3 torr for 30 minutes while the MPC is isolated from the vacuum pump.

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 MPC must be performed with the annular gap between the MPC and the TRANSFER CASK filled with water.

4.

Heat load limits are set for each cell; see Appendix B Section 2.3.

5.

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.

6.

Alternative heat load limits may be developed following the methodology in the Section 4.4 of the HI-STORM FW FSARs. For PWR MPCs these patterns must satisfy the requirements in Table 2.3-14 of Appendix B. For MPC-89 these patterns must satisfy the requirements in Table 2.3-15 of Appendix B. 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. to Holtec Letter 5018109 Page 41 of 130

Table 3-2.

MPC Helium Backfill Limits1,2 MPC Model Decay Heat Limits Applied (per Appendix B Section 2.3)

Pressure range (psig)

MPC-37 Table 2.3-1C Table 2.3-3 42.0 and 50.0 Table 2.3-1B 42.0 and 47.8 Table 2.3-1A, Pattern A 42.0 and 45.5 Table 2.3-1A, Pattern B 41.0 and 46.0 Figure 2.3-1 Figure 2.3-2 Figure 2.3-3 45.5 and 49.0 Figure 2.3-4 Figure 2.3-5 Figure 2.3-6 44.0 and 47.5 Figure 2.3-7 Figure 2.3-8 Figure 2.3-9 44.5 and 48.0 Table 2.3-9A Table 2.3-9B 41.0 and 44.0 MPC-89 Table 2.3-2B Table 2.3-4 42.0 and 50.0 Table 2.3-2A 42.5 and 47.5 Figure 2.3-10 Figure 2.3-11 Figure 2.3-12 Figure 2.3-13 42.0 and 47.0 Table 2.3-10A Table 2.3-10B 42.5 and 45.5 MPC-32ML Table 2.3-5, All Patterns 41.5 and 45.5 MPC-37P Table 2.3-1A, Pattern A 42.0 and 45.5 Table 2.3-1A, Pattern B 41.0 and 46.0 Table 2.3-7A Table 2.3-7B 44.0 and 47.0 MPC-44 Table 2.3-8A Table 2.3-8B Table 2.3-8C Table 2.3-13 41.0 and 44.0 1 Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF 12 For heat load patterns developed in accordance with Table 3-1, Note 6, helium back fill limits shall be calculated in accordance with FSAR Section 4.4. to Holtec Letter 5018109 Page 42 of 130

4.0 This section is intentionally left blank to Holtec Letter 5018109 Page 43 of 130

5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented and maintained.

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

a.

The HI-STORM FW MPC Storage System does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents and annual reporting in accordance with 10 CFR 72.44(d)(3) 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.

to Holtec Letter 5018109 Page 44 of 130

5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program

a. For lifting of the loaded MPC, TRANSFER CASK, or OVERPACK using equipment which is integral to a structure governed by 10 CFR Part 50 regulations, 10 CFR 50 requirements apply.

b. This program is not applicable when the TRANSFER CASK or OVERPACK is in the FUEL BUILDING or is being handled by equipment providing support from underneath (i.e., on a rail car, heavy haul trailer, air pads, etc...).

c. The TRANSFER CASK or OVERPACK, when loaded with spent fuel, may be lifted to and carried at any height necessary during TRANSPORT OPERATIONS and MPC TRANSFER, provided the lifting equipment is designed in accordance with items 1, 2, and 3 below.

1. The metal body and any vertical columns of the lifting equipment shall be designed to comply with stress limits of ASME Section III, Subsection NF, Class 3 for linear structures. All vertical compression loaded primary members shall satisfy the buckling criteria of ASME Section III, Subsection NF.

2. The horizontal cross beam and any lifting attachments used to connect the load to the lifting equipment shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with applicable sections and guidance of NUREG-0612, Section 5.1. For lifting attachments, this includes applicable stress limits from ANSI N14.6.

3. The lifting equipment shall have redundant drop protection features which prevent uncontrolled lowering of the load.

4. For existing handling equipment which does not meet the above criteria:

a. lift height for TRANSFER CASKS OR VENTILATED OVERPACKS shall not exceed the limits in Table 5-1, and for all lift heights for UNVENTILATED OVERPACK, a site-specific drop analysis shall be performed in accordance with Section 3.4, item No.7. of Appendix B to demonstrate the safe operation of the system.

b. If lift heights for TRANSFER CASKS or VENTILATED OVERPACKS exceed the limits in Table 5-1, and for all heights for UNVENTILATED OVERPACK, a site-specific drop analysis shall be performed in accordance with Section 3.4 item No.7. of Appendix B to demonstrate the safe operation of the system.

to Holtec Letter 5018109 Page 45 of 130

5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program (continued)

Table 5-1. TRANSFER CASK and VENTILATED OVERPACK Lifting Requirements.

ITEM ORIENTATION LIFTING HEIGHT LIMIT (in.)

TRANSFER CASK VERTICAL 11 TRANSFER CASK HORIZONTAL None Established (Note 1)

VENTILATED OVERPACK VERTICAL 11 VENTILATED OVERPACK HORIZONTAL Not Permitted to Holtec Letter 5018109 Page 46 of 130

5.3 Radiation Protection Program 5.3.1 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.

5.3.2 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.

5.3.3 Based on the analysis performed pursuant to Section 5.3.2, the licensee shall establish individual cask surface dose rate limits for the TRANSFER CASK and the 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 OVERPACK.

b.

The side OVERPACK

c.

The side of the TRANSFER CASK

d.

The inlet and outlet ducts on the OVERPACK (applicable only for VENTILATED OVERPACK) 5.3.4 Notwithstanding the limits established in Section 5.3.3, the measured dose rates on a loaded OVERPACK or TRANSFER CASK shall not exceed the following values:

a.

15 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.

3500 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.3.5 The licensee shall measure the TRANSFER CASK and OVERPACK surface neutron and gamma dose rates as described in Section 5.3.8 for comparison against the limits established in Section 5.3.3 or Section 5.3.4, whichever are lower. to Holtec Letter 5018109 Page 47 of 130

5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.3.3 or Section 5.3.4, 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.

5.3.7 If the evaluation performed pursuant to Section 5.3.6 shows that the dose limits of 10 CFR 72.104 will be exceeded, the OVERPACK shall not be moved to the ISFSI or, in the case of the OVERPACK loaded at the ISFSI, the MPC shall be removed from the ISFSI until appropriate corrective action is taken to ensure the dose limits are not exceeded.

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

a.

A dose rate measurement shall be taken on the top of the OVERPACK at approximately the center of the lid.

b.

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. to Holtec Letter 5018109 Page 48 of 130

5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued)

c.

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. For a TRANSFER CASK with a neutron shield cylinder, dose rates shall be measured between the radial ribs of the neutron shield cylinder.

d.

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).

5.3.9 The methodology defined in the Topical Report on the Radiological Fuel Qualification Methodology for Dry Storage Systems (Topical Report),

Report HI-2210161, Revision 4 (ML23104A379) may be used to qualify fuel content and to comply with 10 CFR 72.236 (a). The qualification must be documented in a qualification report as specified in the Topical Report and its corresponding Safety Evaluation, with further clarifications in Appendix 5.B of the HI-STORM FW FSAR. The dose rates used as acceptance criteria, and the corresponding locations, are as follows:

a.

4000 mrem/hr on the side of the TRANSFER CASK next to the bottom of the active region of the assemblies (PWR baskets with NFH only) 30b.

4000 mrem/hr on the side of the TRANSFER CASK

c.

4000 mrem/hr on the side of the TRANSFER CASK next to the top of the assemblies (PWR baskets with NFH only)

d.

2000 mrem/hr on the top of the TRANSFER CASK

e.

8000 mrem/hr on the bottom of the TRANSFER CASK

f.

30 mrem/hr on the top of the OVERPACK.

g.

300 mrem/hr on the side OVERPACK All values are for the combined contribution of gamma and neutron dose rates.

to Holtec Letter 5018109 Page 49 of 130

CERTIFICATE OF COMPLIANCE NO. 1032 APPENDIX B APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM FW MPC STORAGE SYSTEM to Holtec Letter 5018109 Page 50 of 130

TABLE OF CONTENTS 1.0 DEFINITIONS........................................................................................................ 1-1 2.0 APPROVED CONTENTS...................................................................................... 2-1 2.1 Fuel Specifications and Loading Conditions...................................................... 2-1 2.2 Violations........................................................................................................... 2-1 2.3 Decay Heat Limits........................................................................................... 2-27 2.4 Burnup Credit.................................................................................................. 2-53 2.5 Burnup and Cooling Time Qualification Requirements.................................... 2-57 Figure 2.1-1 MPC-37 Region-Cell Identification...................................................... 2-2 Figure 2.1-2 MPC-89 Region-Cell Identification...................................................... 2-3 Figure 2.1-3 MPC-32ML Cell Identification............................................................. 2-4 Figure 2.1-4 MPC-37P Cell Identification................................................................ 2-5 Figure 2.1-5 MPC-44 Cell Identification.................................................................. 2-6 Table 2.1-1 Fuel Assembly Limits.......................................................................... 2-7 Table 2.1-2 PWR Fuel Assembly Characteristics................................................ 2-17 Table 2.1-3 BWR Fuel Assembly Characteristics................................................ 2-22 Table 2.3-1A MPC-37 Heat Load Data................................................................... 2-29 Table 2.3-1B MPC-37 Heat Load Data................................................................... 2-29 Table 2.3-1C MPC-37 Heat Load Data................................................................... 2-29 Table 2.3-2A MPC-89 Heat Load Data................................................................... 2-30 Table 2.3-2B MPC-89 Heat Load Data................................................................... 2-30 Table 2.3-3 MPC-37 Heat Load Data................................................................... 2-30 Table 2.3-4 MPC-89 Heat Load Data................................................................... 2-31 Table 2.3-5 MPC-32ML Heat Load Data.............................................................. 2-31 Table 2.3-6 PWR Fuel Length Categories...2-31 Table 2.3-7A MPC-37P Heat Load Data for VENTILATED OVERPACK............... 2-32 Table 2.3-7B MPC-37P Heat Load Data for VENTILATED OVERPACK............... 2-32 Table 2.3-8A MPC-44 Heat Load Data for VENTILATED OVERPACK................. 2-33 Table 2.3-8B MPC-44 Heat Load Data for VENTILATED OVERPACK................. 2-33 Table 2.3-9A MPC-37 Heat Load Data for UNVENTILATED OVERPACK............ 2-34 Table 2.3-9B MPC-37 Requirements on Developing Regionalized Heat Load Patterns for UNVENTILATED OVERPACK................................................................... 2-34 Table 2.3-10A MPC-89 Heat Load Data for UNVENTILATED OVERPACK............ 2-35 Table 2.3-10B MPC-89 Requirements on Developing Regionalized Heat Load Patterns for UNVENTILATED OVERPACK................................................................... 2-35 Table 2.3-11 Section Heat Load Calculations for MPC-37..................................... 2-36 Table 2.3-12 Section Heat Load Calculations for MPC-89..................................... 2-37 Table 2.3-13 MPC-44 Heat Load Data for UNVENTILATED OVERPACK............ 2-37 to Holtec Letter 5018109 Page 51 of 130

Figure 2.3-1 Loading Pattern 37C1 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Short Fuel per Cell Heat Load Limits

.......................................................................................................... 2-38 Figure 2.3-2 Loading Pattern 37C2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Short Fuel per Cell Heat Load Limits

.......................................................................................................... 2-39 Figure 2.3-3 Loading Pattern 37C3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Short Fuel per Cell Heat Load Limits

.......................................................................................................... 2-40 Figure 2.3-4 Loading Pattern 37D1 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Standard Fuel per Cell Heat Load

.......................................................................................................... 2-41 Figure 2.3-5 Loading Pattern 37D2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Standard Fuel per Cell Heat Load Limits

.......................................................................................................... 2-42 Figure 2.3-6 Loading Pattern 37D3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Standard Fuel per Cell Heat Load Limits......................................................... 2-43 Figure 2.3-7 Loading Pattern 37E1 for MPC-37 Loading Pattern for MPCs Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits..................... 2-44 Figure 2.3-8 Loading Pattern 37E2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Long Fuel per Cell Heat Load Limits

.......................................................................................................... 2-45 Figure 2.3-9 Loading Pattern 37E3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits................................................................. 2-46 Figure 2.3-10 Loading Pattern 89A1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits...................................................................................... 2-47 Figure 2.3-11 Loading Pattern 89A2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits.................................................................................2-48 Figure 2.3-12 Loading Pattern 89B1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per cell Heat Load Limits 2-49 Figure 2.3-13 Loading Pattern 89B2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits 2-50 Figure 2.3-14 Loading Pattern 1 for MPC-37P............ 2-51 Figure 2.3-15 Loading Pattern 2 for MPC-37P............ 2-52 to Holtec Letter 5018109 Page 52 of 130

Table 2.4-1 Polynomial Functions for Minimum Burnup as a Function of Initial Enrichment..2-54 Table 2.4-2 Burnup Credit Configurations..2-55 Table 2.4-3 In-Core Operating Requirements...................................................... 2-56 Table 2.5-1 Burnup and Cooling Time Fuel Qualification Requirements for MPC-32ML................................................................................................. 2-58 Table 2.5-2 Burnup and Cooling Time Fuel Qualification Requirements for MPC-37 and MPC-89...................................................................................... 2-58 Table 2.5-3 Burnup and Cooling Time Fuel Qualification Requirements for MPC-37P and MPC-44.............................................................................. 2-59 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 3.4 Site Specific Parameters and Analyses........................................................... 3-11 3.5 Combustible Gas Monitoring During MPC Lid Welding and Cutting................ 3-14 Table 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)..... 3-4 Table 3-2 REFERENCE ASME CODE PARAGRAPHS FOR HI-STORM FW OVERPACK and HI-TRAC VW TRANSFER CASK, PRIMARY LOAD BEARING PARTS................................................................................ 3-10 to Holtec Letter 5018109 Page 53 of 130

1.0 Definitions Refer to Appendix A for Definitions.

to Holtec Letter 5018109 Page 54 of 130

2.0 APPROVED CONTENTS 2.1 Fuel Specifications and Loading Conditions 2.1.1 Fuel to Be Stored in the HI-STORM FW MPC Storage System

a.

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 FW MPC Storage System.

b.

All BWR fuel assemblies may be stored with or without ZR channels.

2.1.2 Fuel Loading Figures 2.1-1 and 2.1-2 define the regions for the MPC-37 and MPC-89 models, respectively. Figures 2.1-3 defines the cell identifications for the MPC-32ML. Figures 2.1-4 and 2.1-5 defines the cell identifications for the MPC-37P and MPC-44 models, respectively. Fuel assembly decay heat limits are specified in Section 2.3.1. Fuel assemblies 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. to Holtec Letter 5018109 Page 55 of 130

3-1 3-2 3-3 3-4 2-1 2-2 2-3 3-5 3-6 2-4 1-1 1-2 1-3 2-5 3-7 3-8 2-6 1-4 1-5 1-6 2-7 3-9 3-10 2-8 1-7 1-8 1-9 2-9 3-11 3-12 2-10 2-11 2-12 3-13 3-14 3-15 3-16 Legend Region-Cell ID Figure 2.1-1 MPC-37 Region-Cell Identification to Holtec Letter 5018109 Page 56 of 130

3-1 3-2 3-3 3-4 3-5 3-6 2-1 3-7 3-8 3-9 3-10 3-11 2-2 2-3 2-4 2-5 2-6 3-12 3-13 3-14 2-7 2-8 2-9 2-10 2-11 2-12 2-13 3-15 3-16 3-17 2-14 2-15 1-1 1-2 1-3 2-16 2-17 3-18 3-19 3-20 2-18 2-19 2-20 1-4 1-5 1-6 2-21 2-22 2-23 3-21 3-22 3-23 2-24 2-25 1-7 1-8 1-9 2-26 2-27 3-24 3-25 3-26 2-28 2-29 2-30 2-31 2-32 2-33 2-34 3-27 3-28 3-29 2-35 2-36 2-37 2-38 2-39 3-30 3-31 3-32 3-33 3-34 2-40 3-35 3-36 3-37 Legend Region-Cell ID 3-38 3-39 3-40 Figure 2.1-2 MPC-89 Region-Cell Identification to Holtec Letter 5018109 Page 57 of 130

1-1 1-2 1-3 1-4 1-5 1-6 1-7 1-8 1-9 1-10 1-11 1-12 1-13 1-14 1-15 1-16 1-17 1-18 1-19 1-20 1-21 1-22 1-23 1-24 1-25 1-26 1-27 1-28 1-29 1-30 1-31 1-32 Figure 2.1-3 MPC-32ML Cell Identification to Holtec Letter 5018109 Page 58 of 130

3-1 3-2 3-3 3-4 2-1 2-2 2-3 3-5 3-6 2-4 1-1 1-2 1-3 2-5 3-7 3-8 2-6 1-4 1-5 1-6 2-7 3-9 3-10 2-8 1-7 1-8 1-9 2-9 3-11 3-12 2-10 2-11 2-12 3-13 3-14 3-15 3-16 Figure 2.1-4 MPC-37P Cell Identification Quadrant 1 Quadrant 3 Quadrant 4 Quadrant 2 to Holtec Letter 5018109 Page 59 of 130

1-1 1-2 1-3 1-4 1-5 1-6 1-7 1-8 1-9 1-10 1-11 1-12 1-13 1-14 1-15 1-16 1-17 1-18 1-19 1-20 1-21 1-22 1-23 1-24 1-25 1-26 1-27 1-28 1-29 1-30 1-31 1-32 1-33 1-34 1-35 1-36 1-37 1-38 1-39 1-40 1-41 1-42 1-43 1-44 Figure 2.1-5 MPC-44 Cell Identification to Holtec Letter 5018109 Page 60 of 130

Table 2.1-1 (page 1 of 10)

Fuel Assembly Limits I. MPC MODEL: MPC-37 A. Allowable Contents

1. Uranium oxide PWR UNDAMAGED FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES meeting the criteria in Table 2.1-2 and/or FUEL DEBRIS, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type:

ZR

b. Maximum Initial Enrichment:

5.0 wt. % U-235 with soluble boron credit per LCO 3.3.1 OR burnup credit per Section 2.4

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

Cooling Time 1 years and meeting the equation requirements in Section 2.5 Assembly Average Burnup 68.2 GWD/MTU

d. Decay Heat Per Fuel Storage Location:

As specified in Section 2.3

e. Fuel Assembly Length:

188 (nominal design including NON-FUEL HARDWARE and DFC) - EXTENDED CONFIGURATION 199.2 inches (nominal design including NON-FUEL HARDWARE and DFC) - all other variants 188 (nominal design including NON-FUEL HARDWARE and DFC) - EXTENDED CONFIGURATION1 199.2 inches (nominal design including NON-FUEL HARDWARE and DFC) - all other OVERPACK variants

f. Fuel Assembly Width:

8.54 inches (nominal design)

g. Fuel Assembly Weight:

2050 lbs (including NON-FUEL HARDWARE and DFC)

1) The maximum fuel assembly length of 188 inches is applicable to PWR fuel use in the HI-STORM FW EXTENDED CONFIGURATION to Holtec Letter 5018109 Page 61 of 130

Table 2.1-1 (page 2 of 10)

Fuel Assembly Limits I. MPC MODEL: MPC-37 (continued)

B. Quantity per MPC: 37 FUEL ASSEMBLIES with up to twelve (12) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs). DFCs may be stored in fuel storage locations 3-1, 3-3 through 3-7, 3-10 through 3-14, and 3-16 (see Figure 2.1-1), OR in fuel storage locations 2-1, 2-3, 2-4, 2-5, 2-8, 2-9, 2-10, and 2-12 (see Figure 2.1-1), depending on heat load pattern, see Section 2.3.1.

The remaining fuel storage locations may be filled with PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications. For MPCs utilizing burnup credit, the MPC and DFC loading configuration must also meet the additional requirements of Section 2.4.

C. One (1) Neutron Source Assembly (NSA) is authorized for loading in the MPC-37.

D. Up to thirty (30) BPRAs are authorized for loading in the MPC-37.

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, RCCAs, CEAs, CRAs (including, but not limited to those with hafnium), or NSAs may only be loaded in fuel storage Regions 1 and 2 (see Figure 2.1-1).

Note 2: DAMAGED FUEL ASSEMBLIES which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected, may be stored in storage locations designated for DFCs using DFIs or DFCs. 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. to Holtec Letter 5018109 Page 62 of 130

Table 2.1-1 (page 3 of 10)

Fuel Assembly Limits II. MPC MODEL: MPC-89 A. Allowable Contents

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

a. Cladding Type:

ZR

b. Maximum PLANAR-AVERAGE INITIAL ENRICHMENT(Note 1):

As specified in Table 2.1-3 for the applicable fuel assembly array/class.

c. Initial Maximum Rod Enrichment 5.0 wt. % U-235

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

i. Array/Class 8x8F Cooling time 10 years and an assembly average burnup 27.5 GWD/MTU.

ii. All Other Array Classes Cooling Time 1 years and meeting the equation requirement in Section 2.5 and an assembly average burnup 65 GWD/MTU

e. Decay Heat Per Assembly

i. Array/Class 8x8F 183.5 Watts ii. All Other Array Classes As specified in Section 2.3

f. Fuel Assembly Length 176.5 inches (nominal design) - all other variants181.5 inches (including DFC)

g. Fuel Assembly Width 5.95 inches (nominal design)

h. Fuel Assembly Weight 850 lbs, including a DFC as well as a channel

1) The fuel assembly length of 181.5 inches is applicable to only MPC-89 use in the HI-STORM FW EXTENDED CONFIGURATION to Holtec Letter 5018109 Page 63 of 130

Table 2.1-1 (page 4 of 10)

Fuel Assembly Limits II. MPC MODEL: MPC-89 (continued)

B. Quantity per MPC: 89 FUEL ASSEMBLIES with up to sixteen (16) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs).

DFCs may be stored in fuel storage locations 3-1, 3-3, 3-4, 3-9, 3-10, 3-13, 3-16, 3-19, 3-22, 3-25, 3-28, 3-31, 3-32, 3-37, 3-38, and 3-40 (see Figure 2.1-2), OR in fuel storage locations 2-1, 2-2, 2-6, 2-7, 2-13, 2-18, 2-23, 2-28, 2-34, 2-35, 2-39, and 2-40 (see Figure 2.1-2), depending on heat load pattern, see Section 2.3.1. The remaining fuel storage locations may be filled with BWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

Note 1: The lowest maximum allowable enrichment of any fuel assembly loaded in an MPC-89, based on fuel array class and fuel classification, is the maximum allowable enrichment for the remainder of the assemblies loaded in that MPC.

Note 2: DAMAGED FUEL ASSEMBLIES which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected, may be stored in storage locations designated for DFCs using DFIs or DFCs. 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. to Holtec Letter 5018109 Page 64 of 130

Table 2.1-1 (page 5 of 10)

Fuel Assembly Limits III. MPC MODEL: MPC-32ML A. Allowable Contents

1. Uranium oxide PWR UNDAMAGED FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES meeting the criteria for array/class 16x16D in Table 2.1-2 and/or FUEL DEBRIS, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type:

ZR

b. Maximum Initial Enrichment:

5.0 wt. % U-235 with soluble boron credit per LCO 3.3.1

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

Cooling Time 1 years and meeting the equation requirement in Section 2.5 Assembly Average Burnup 68.2 GWD/MTU

d. Decay Heat Per Fuel Storage Location:

As specified in Section 2.3

e. Fuel Assembly Length:

188 (nominal design including NON-FUEL HARDWARE and DFC) - EXTENDED CONFIGURATION 193 inches (nominal design including NON-FUEL HARDWARE and DFC) - all other variants 188 (nominal design including NON-FUEL HARDWARE and DFC) - EXTENDED CONFIGURATION 193 inches (nominal design including NON-FUEL HARDWARE and DFC) - all other OVERPACK variants

f. Fuel Assembly Width:

9.04 inches (nominal design) 8.54 inches (nominal design) - EXTENDED CONFIGURATION

g. Fuel Assembly Weight:

1858 lbs (including NON-FUEL HARDWARE and DFC) to Holtec Letter 5018109 Page 65 of 130

Table 2.1-1 (page 6 of 10)

Fuel Assembly Limits III. MPC MODEL: MPC-32ML (continued)

B. Quantity per MPC: 32 FUEL ASSEMBLIES with up to eight (8) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs). DFCs may be stored in fuel storage locations 1-1, 1-4, 1-5, 1-10, 1-23, 1-28, 1-29, and 1-32 (see Figure 2.1-3). The remaining fuel storage locations may be filled with PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

C. One (1) Neutron Source Assembly (NSA) is authorized for loading in the MPC-32ML.

D. Up to thirty-two (32) BPRAs are authorized for loading in the MPC-32ML.

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, RCCAs, CEAs, CRAs, or NSAs may only be loaded in fuel cells 1-6 through 1-9, 1-12 through 1-15, 1-18 through 1-21, and 1-24 through 1-27.

Note 2: DAMAGED FUEL ASSEMBLIES which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected, may be stored in storage locations designated for DFCs using DFIs or DFCs. 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. to Holtec Letter 5018109 Page 66 of 130

Table 2.1-1 (page 7 of 10)

Fuel Assembly Limits IV. MPC MODEL: MPC-37P A. Allowable Contents

1. Uranium oxide PWR UNDAMAGED FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES meeting the criteria for array/class 15x15I in Table 2.1-2 and/or FUEL DEBRIS, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type:

ZR

b. Maximum Initial Enrichment:

5.0 wt. % U-235 with soluble boron credit per LCO 3.3.1

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

Cooling Time 1.6 years and meeting the equation requirement in Section 2.5 Assembly Average Burnup 68.2 GWD/MTU

d. Decay Heat Per Fuel Storage Location:

As specified in Section 2.3

e. Fuel Assembly Length:

160.5 inches (nominal design including NON-FUEL HARDWARE and DFC)

f. Fuel Assembly Width:

8.52 inches (nominal design)

g. Fuel Assembly Weight:

1610 lbs (including NON-FUEL HARDWARE and DFC) to Holtec Letter 5018109 Page 67 of 130

Table 2.1-1 (page 8 of 10)

Fuel Assembly Limits IV. MPC MODEL: MPC-37P (continued)

B. Quantity per MPC: 37 FUEL ASSEMBLIES with up to twelve (12) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs). DFCs may be stored in fuel storage locations 3-1, 3-3 through 3-7, 3-10 through 3-14, and 3-16, OR DFCs may be stored in fuel storage locations 2-1, 2-3, 2-10, and 2-12 (see Figure 2.1-4). The remaining fuel storage locations may be filled with PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

Note 1: Fuel assemblies containing 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, RCCAs, CEAs, CRAs (including, but not limited to those with hafnium), or NSAs may only be loaded in fuel storage Regions 1 and 2 (see Figure 2.1-4).

Note 2: DAMAGED FUEL ASSEMBLIES which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected, may be stored in storage locations designated for DFCs using DFIs or DFCs. 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. to Holtec Letter 5018109 Page 68 of 130

Table 2.1-1 (page 9 of 10)

Fuel Assembly Limits V. MPC MODEL: MPC-44 A. Allowable Contents

1. Uranium oxide PWR UNDAMAGED FUEL ASSEMBLIES and DAMAGED FUEL ASSEMBLIES meeting the criteria for array/class 14x14A and 14x14B in Table 2.1-2 and/or FUEL DEBRIS, with or without NON-FUEL HARDWARE and meeting the following specifications (Note 1):

a. Cladding Type:

ZR

b. Maximum Initial Enrichment:

5.0 wt. % U-235

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

Cooling Time 3 1 years and meeting the equation requirement in Section 2.5 Assembly Average Burnup 60.0 GWD/MTU

d. Decay Heat Per Fuel Storage Location:

As specified in Section 2.3

e. Fuel Assembly Length:

170.5 inches (nominal design including DFC)

f. Fuel Assembly Width:

7.81 inches (nominal design)

g. Fuel Assembly Weight:

1250 lbs (including DFC)

B. Quantity per MPC: 44 FUEL ASSEMBLIES with up to twelve (12) DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS in DAMAGED FUEL CONTAINERS (DFCs). DFCs may be stored in fuel storage locations 3-1 through 3-3, 3-6, 3-9 through 3-12, 3-15, and 3-18 through 3-20 (see Figure 2.1-5). The remaining fuel storage locations may be filled with PWR UNDAMAGED FUEL ASSEMBLIES meeting the applicable specifications.

C. Up to twenty-two (22) BPRAs are authorized for loading in the MPC-44. to Holtec Letter 5018109 Page 69 of 130

Table 2.1-1 (page 10 of 10)

Fuel Assembly Limits 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.

Note 2: DAMAGED FUEL ASSEMBLIES which can be handled by normal means and whose structural integrity is such that geometric rearrangement of fuel is not expected, may be stored in storage locations designated for DFCs using DFIs or DFCs. 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.

to Holtec Letter 5018109 Page 70 of 130

Table 2.1-2 (page 1 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1, 7)

Fuel Assembly Array/ Class 14x14 A 14x14 B 14x14 C 15x15 B 15x15 C No. of Fuel Rod Locations (Note 6) 179 179 176 204 204 Fuel Clad O.D. (in.)

0.400 0.417 0.440 0.420 0.417 Fuel Clad I.D. (in.)

0.3514 0.374 0.3880 0.3736 0.3640 Fuel Pellet Dia. (in.)

(Note 3) 0.3444 0.367 0.3805 0.3671 0.3570 Fuel Rod Pitch (in.)

0.556 0.566 0.580 0.563 0.563 Active Fuel Length (in.)

150 150 150 150 150 No. of Guide and/or Instrument Tubes 17 17 5

(Note 2) 21 21 Guide/Instrument Tube Thickness (in.)

0.017 0.017 0.038 0.015 0.0165 to Holtec Letter 5018109 Page 71 of 130

Table 2.1-2 (page 2 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1,7)

Fuel Assembly Array/Class 15x15 D 15x15 E 15x15 F 15x15 H 15x15 I No. of Fuel Rod Locations (Note 6) 208 208 208 208 216 (Note

4)

Fuel Clad O.D. (in.)

0.430 0.428 0.428 0.414 0.413 Fuel Clad I.D. (in.)

0.3800 0.3790 0.3820 0.3700 0.3670 Fuel Pellet Dia. (in.)

(Note 3) 0.3735 0.3707 0.3742 0.3622 0.3600 Fuel Rod Pitch (in.)

0.568 0.568 0.568 0.568 0.550 Active Fuel Length (in.)

150 150 150 150 150 No. of Guide and/or Instrument Tubes 17 17 17 17 9 (Note 4)

Guide/Instrument Tube Thickness (in.)

0.0150 0.0140 0.0140 0.0140 0.0140 to Holtec Letter 5018109 Page 72 of 130

Table 2.1-2 (page 3 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1,7)

Fuel Assembly Array and Class 16x16 A 16x16B 16x16C 16x16D (Note5) 16x16E No. of Fuel Rod Locations (Note 6) 236 236 235 236 235 Fuel Clad O.D. (in.)

0.382 0.374 0.374 0.423 0.359 Fuel Clad I.D. (in.)

0.3350 0.3290 0.3290 0.366 0.3326 Fuel Pellet Dia.

(in.) (Note 3) 0.3255 0.3225 0.3225 0.359 0.3225 Fuel Rod Pitch (in.)

0.506 0.506 0.485 0.563 0.485 Active Fuel length (in.)

150 150 150 154.5 150 No. of Guide and/or Instrument Tubes 5

(Note 2) 5 (Note 2) 21 20 21 Guide/Instrument Tube Thickness (in.)

0.0350 0.04 0.0157 0.015 0.0157 to Holtec Letter 5018109 Page 73 of 130

Table 2.1-2 (page 4 of 5)

PWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1,7)

Fuel Assembly Array and Class 17x17A 17x17 B 17x17 C 17x17 D (Note 8) 17x17 E (Note 8)

No. of Fuel Rod Locations (Note 6) 264 264 264 264 265 Fuel Clad O.D. (in.)

0.360 0.372 0.377 0.372 0.372 Fuel Clad I.D. (in.)

0.3150 0.3310 0.3330 0.3310 0.3310 Fuel Pellet Dia. (in.)

(Note 3) 0.3088 0.3232 0.3252 0.3232 0.3232 Fuel Rod Pitch (in.)

0.496 0.496 0.502 0.496 0.496 Active Fuel length (in.)

150 150 150 170 170 No. of Guide and/or Instrument Tubes 25 25 25 25 24 Guide/Instrument Tube Thickness (in.)

0.016 0.014 0.020 0.014 0.014 to Holtec Letter 5018109 Page 74 of 130

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. Each guide tube replaces four fuel rods.

3. Annular fuel pellets are allowed in the top and bottom 12 of the active fuel length, except as noted below.

4. Assemblies have one Instrument Tube and eight Guide Bars (Solid ZR). Some assemblies have up to 16 fuel rods removed or replaced by Guide Tubes

5. This fuel array/class only allowable for loading in the MPC-32ML.

6. 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.

7. Any number of fuel rods in an assembly can contain BLEU fuel. If the BLEU rods are present, the site specific dose and dose rate analyses performed under 10 CFR 72.212 should include considerations for the presence of such rods.

8. Fuel assembly array and class 17x17D and 17x17E are not permitted for use in the EXTENDED CONFIGURATION.

to Holtec Letter 5018109 Page 75 of 130

Table 2.1-3 (page 1 of 5)

BWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1,17)

Fuel Assembly Array and Class 7x7 B 7x7 C 8x8 B 8x8 C 8x8 D 8x8 E Maximum Planar-Average Initial Enrichment (wt.%

235U) (Note 14)

< 4.8

< 4.8 No. of Fuel Rod Locations (Full Length or Total/Full Length)

(Note 16) 49 48 63 or 64 62 60 or 61 59 Fuel Clad O.D. (in.)

> 0.5630

> 0.4840

> 0.4830

> 0.4930 Fuel Clad I.D. (in.)

< 0.4990

< 0.4295

< 0.4250

< 0.4230

< 0.4250 Fuel Pellet Dia. (in.)

< 0.4910

< 0.4195

< 0.4160

< 0.4140

< 0.4160 Fuel Rod Pitch (in.)

< 0.738

< 0.642

< 0.641

< 0.640

< 0.640 Design Active Fuel Length (in.)

< 150

< 150 No. of Water Rods (Note 10) 0 1 (Note

15) 1 or 0 2

1 - 4 (Note 6) 5 Water Rod Thickness (in.)

N/A N/A

> 0.034

> 0.00

> 0.034 Channel Thickness (in.)

< 0.120

< 0.100 to Holtec Letter 5018109 Page 76 of 130

Table 2.1-3 (2 of 5)

BWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1, 17)

Fuel Assembly Array and Class 8x8F 8x8G 9x9 A 9x9 B 9x9 C 9x9 D Maximum Planar-Average Initial Enrichment (wt.%

235U) (Note 14)

< 4.5 (Note 12)

< 4.8

< 4.8 No. of Fuel Rod Locations (Note 16) 64 60 74/66 (Note 4) 72 80 79 Fuel Clad O.D. (in.)

> 0.4576

> 0.5015

> 0.4400

> 0.4330

> 0.4230

> 0.4240 Fuel Clad I.D. (in.)

< 0.3996

< 0.4295

< 0.3840

< 0.3810

< 0.3640

< 0.3640 Fuel Pellet Dia. (in.)

< 0.3913

< 0.4195

< 0.3760

< 0.3740

< 0.3565

< 0.3565 Fuel Rod Pitch (in.)

< 0.609

< 0.642

< 0.566

< 0.572

< 0.572 Design Active Fuel Length (in.)

< 150

< 150 No. of Water Rods (Note 10)

N/A (Note 2) 4 (Note 15) 2 1

(Note 5) 1 2

Water Rod Thickness (in.)

> 0.025 N/A

> 0.00

> 0.020

> 0.0300 Channel Thickness (in.)

< 0.055

< 0.120

< 0.100

< 0.100 to Holtec Letter 5018109 Page 77 of 130

Table 2.1-3 (page 3 of 5)

BWR FUEL ASSEMBLY CHARACTERISTICS (Notes 1, 17)

Fuel Assembly Array and Class 9x9 E (Note 2) 9x9 F (Note 2) 9x9 G 10x10 A 10x10 B Maximum Planar-Average Initial Enrichment (wt.%

235U) (Note 14)

< 4.5 (Note

12)

< 4.5 (Note

12)

< 4.8

< 4.8 No. of Fuel Rod Locations (Note 16) 76 76 72 92/78 (Note 7) 91/83 (Note 8)

Fuel Clad O.D. (in.)

>0.4170

>0.4430

>0.4240

>0.4040

>0.3957 Fuel Clad I.D. (in.)

<0.3640

<0.3860

<0.3640

< 0.3520

< 0.3480 Fuel Pellet Dia. (in.)

<0.3530

<0.3745

<0.3565

< 0.3455

< 0.3420 Fuel Rod Pitch (in.)

< 0.572

< 0.510

< 0.510 Design Active Fuel Length (in.)

< 150

< 150 No. of Water Rods (Note 10) 5 5

1 (Note 5) 2 1

(Note 5)

Water Rod Thickness (in.)

>0.0120

>0.0320

>0.0300

> 0.00 Channel Thickness (in.)

< 0.120

< 0.120 to Holtec Letter 5018109 Page 78 of 130

Table 2.1-3 (page 4 of 5)

BWR FUEL ASSEMBLY CHARACTERISTICS (Note 1,17 )

Fuel Assembly Array and Class 10x10 C 10x10 F 10x10 G 10x10 I 10x10 J 11x11 A Maximum Planar-Average Initial Enrichment (wt.%

235U) (Note 14)

< 4.8

< 4.7 (Note 13)

< 4.6 (Note 12)

< 4.8

< 4.8 No. of Fuel Rod Locations (Note 16) 96 92/78 (Note 7) 96/84 91/79 (Note 18) 96/80 (Note 19) 112/92 (Note 20)

Fuel Clad O.D. (in.)

> 0.3780

> 0.4035

> 0.387

> 0.4047

> 0.3999

> 0.3701 Fuel Clad I.D. (in.)

< 0.3294

< 0.3570

< 0.340

< 0.3559

< 0.3603

< 0.3252 Fuel Pellet Dia. (in.)

< 0.3224

< 0.3500

< 0.334

< 0.3492

< 0.3531

< 0.3193 Fuel Rod Pitch (in.)

< 0.488

< 0.510

< 0.512

< 0.5100

< 0.5149

< 0.4705 (Note 21)

Design Active Fuel Length (in.)

< 150

< 150 No. of Water Rods (Note

10) 5 (Note 9) 2 5

(Note 9) 1 (Note 5) 1 1

(Note 5)

Water Rod Thickness (in.)

> 0.031

> 0.030

> 0.031

> 0.0315

> 0.0297

> 0.0320 Channel Thickness (in.)

< 0.055

< 0.120

< 0.060

< 0.100

< 0.0938

< 0.100 to Holtec Letter 5018109 Page 79 of 130

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.

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

3.

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

4.

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

5.

Square, replacing nine fuel rods.

6.

Variable.

7.

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

8.

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

9.

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

10.

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

11.

Not used.

12.

When loading fuel assemblies classified as DAMAGED FUEL, all assemblies in the MPC are limited to 4.0 wt.% U-235.

13.

When loading fuel assemblies classified as DAMAGED FUEL, all assemblies in the MPC are limited to 4.6 wt.% U-235.

14.

In accordance with the definition of UNDAMAGED FUEL, certain assemblies may be limited to 3.3 wt.% U-235. When loading these fuel assemblies, all assemblies in the MPC are limited to 3.3 wt.% U-235.

15.

These fuel designs do not have water rods, but instead contain solid zirc rods.

16.

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.

17.

Any number of fuel rods in an assembly can be contain BLEU fuel. If the BLEU rods are present, the site specific dose and dose rate analyses performed under 10 CFR 72.212 should include considerations for the presence of such rods.

18.

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

19.

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 or 12 fuel rods.

20.

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.

to Holtec Letter 5018109 Page 80 of 130

2.3 Decay Heat Limits This section provides the limits on fuel assembly decay heat for storage in the HI-STORM FW System. The method to verify compliance, including examples, is provided in Chapter 13 of the HI-STORM FW FSAR.

2.3.1 Fuel Loading Decay Heat Limits for VENTILATED OVERPACK (NOTE 1)

Tables 2.3-1A, 2.3-1B, and 2.3-1C provide the maximum allowable decay heat per fuel storage location for MPC-37. Tables 2.3-2A and 2.3-2B provide the maximum allowable decay heat per fuel storage location for MPC-89. Tables 2.3-1A and 2.3-7A provides the maximum allowable decay heat per fuel storage location for MPC-37P. Table 2.3-8A provide the maximum allowable decay heat per fuel storage location for MPC-44. No drying time limits are required for decay heat values meeting the limits in these tables when using FHD to dry moderate or high burnup fuel and when using VDS to dry moderate burnup fuel. Drying time limits apply when using VDS to dry high burnup fuel with decay heat values meeting the limits in these tables. Tables 2.3-3 and 2.3-4 provide the maximum allowable decay heat per fuel storage location for MPC-37 and MPC-89, respectively, with no drying time limits imposed, when using VDS to dry high burnup fuel. Table 2.3-5 provides the maximum allowable decay heat per fuel storage location for the MPC-32ML for both FHD and VDS drying. Tables 2.3-7B and 2.3-8B provide the maximum allowable decay heat per fuel storage location for the MPC-37P and MPC-44, respectively, with no drying time limits imposed, when using VDS to dry high burnup fuel. The per cell limits in these tables apply to cells containing undamaged fuel or damaged fuel in DFCs/DFIs or fuel debris in DFCs.

Figures 2.3-1 through 2.3-14 provide alternative loading patterns for the MPC-37 and MPC-89, with undamaged fuel and a combination of undamaged fuel and damaged fuel in DFCs/DFIs and fuel debris in DFCs. The per cell limits in these figures are applicable when using vacuum drying or FHD to dry moderate or high burnup fuel in accordance with Table 3-1 of Appendix A of the CoC. The MPC-37 patterns are based on the fuel length to be stored in the MPC, see Table 2.3-6.

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.

2.3.2 Fuel Loading Decay Heat Limits for UNVENTILATED OVERPACK Tables 2.3-9A and 2.3-9B provide the maximum allowable decay heat per fuel storage location for MPC-37. Tables 2.3-10A and 2.3-10B provide the maximum allowable decay heat per fuel storage location for MPC-89. Table 2.3-13 provides the maximum allowable decay heat per fuel storage location to Holtec Letter 5018109 Page 81 of 130

for MPC-44. The per cell limits in these tables apply to cells containing undamaged fuel or damaged fuel in DFCs/DFIs or fuel debris in DFCs.

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.

2.3.3 Variable Fuel Height for MPC-37 and MPC-44 2.3.3.1 For fuel with a longer active fuel length than the reference fuel (144 inches), the maximum total heat load, maximum quadrant heat load limits and specific heat load limits in each cell, may be increased by the ratio SQRT(L/144), where L is the active length of the fuel in inches.

2.3.3.2 For fuel with a shorter active fuel length than the reference fuel (144 inches), the maximum total heat load, maximum quadrant heat load limits and specific heat load limits in each cell, shall be reduced linearly by the ratio L/144, where L is the active fuel length of the fuel in inches.

2.3.4 Variable Fuel Height for MPC-89 2.3.4.1 For fuel with a longer active fuel length than the reference fuel (150 inches), the maximum total heat load, maximum quadrant heat load limits and specific heat load limits in each cell, may be increased by the ratio SQRT(L/150), where L is the active length of the fuel in inches.

2.3.4.2 For fuel with a shorter active fuel length than the reference fuel (150 inches), the total heat load, quadrant heat load limits and specific heat load limits in each cell, shall be reduced linearly by the ratio L/150, where L is the active fuel length of the fuel in inches.

2.3.5 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.

2.3.6 Fuel Loading Decay Heat Limits for EXTENDED CONFIGURATION OVERPACK (NOTE 1)

The decay heat limits discussed in subsection 2.3.1 for VENTILATED OVERPACK apply to the EXTENDED CONFIGURATION OVERPACK.

However, there are restrictions on the use of the MPC-37P and the MPC-44.

The MPC-37P is not certified for use within the EXTENDED CONFIGURATION OVERPACK. MPC-44 allowable decay heat limits within the EXTENDED CONFIGURATION OVERPACK can be found below in Table to Holtec Letter 5018109 Page 82 of 130

2.3-.8C.

Note 1: Alternative heat load limits may be developed following the methodology in Section 4.4 of the HI-STORM FW FSAR. For PWR MPCs these patterns must satisfy the requirements in Table 2.3-14. For MPC-89 these patterns must satisfy the requirements in Table 2.3-15.

to Holtec Letter 5018109 Page 83 of 130

TABLE 2.3-1A MPC-37 HEAT LOAD DATA (See Figure 2.1-1)

Number of Regions:

3 Number of Storage Cells: 37 Maximum Design Basis Heat Load (kW):

44.09 (Pattern A); 45.0 (Pattern B)

Region No.

Decay Heat Limit per Cell, kW Number of Cells per Region Decay Heat Limit per Region, kW Pattern A Pattern B Pattern A Pattern B 1

1.05 1.0 9

9.45 9.0 2

1.70 1.2 12 20.4 14.4 3

0.89 1.35 16 14.24 21.6 TABLE 2.3-1B MPC-37 HEAT LOAD DATA (See Figure 2.1-1)

Number of Regions:

3 Number of Storage Cells: 37 90% of Pattern A - Sub-design Heat Load (kW):

39.68 Region No.

Decay Heat Limit per Cell, kW Number of Cells per Region Decay Heat Limit per Region, kW 1

0.945 9

8.505 2

1.530 12 18.36 3

0.801 16 12.816 TABLE 2.3-1C MPC-37 HEAT LOAD DATA (See Figure 2.1-1)

Number of Regions:

3 Number of Storage Cells: 37 80% of Pattern A - Sub-design Heat Load (kW):

35.27 Region No.

Decay Heat Limit per Cell, kW Number of Cells per Region Decay Heat Limit per Region, kW 1

0.84 9

7.56 2

1.36 12 16.32 3

0.712 16 11.392 to Holtec Letter 5018109 Page 84 of 130

TABLE 2.3-2A MPC-89 HEAT LOAD DATA (See Figure 2.1-2)

Number of Regions:

3 Number of Storage Cells: 89 Maximum Design Basis Heat Load:

46.36 kW Region No.

Decay Heat Limit per Cell, kW Number of Cells per Region Decay Heat Limit per Region, kW 1

0.44 9

3.96 2

0.62 40 24.80 3

0.44 40 17.60 TABLE 2.3-2B MPC-89 HEAT LOAD DATA (See Figure 2.1-2)

Number of Regions:

3 Number of Storage Cells: 89 80% Sub-design Heat Load (kW):

37.1 Region No.

Decay Heat Limit per Cell, kW Number of Cells per Region Decay Heat Limit per Region, kW 1

0.352 9

3.168 2

0.496 40 19.84 3

0.352 40 14.08 TABLE 2.3-3 MPC-37 HEAT LOAD DATA (See Figure 2.1-1)

Number of Regions:

3 Number of Storage Cells: 37 Maximum Heat Load:

29.6 Region No.

Decay Heat Limit per Cell, W Number of Cells per Region Decay Heat Limit per Region, kW 1

800 9

7.2 2

800 12 9.6 3

800 16 12.8 to Holtec Letter 5018109 Page 85 of 130

TABLE 2.3-4 MPC-89 HEAT LOAD DATA (See Figure 2.1-2)

Number of Regions:

3 Number of Storage Cells: 89 Maximum Heat Load:

30.0kW Region No.

Decay Heat Limit per Cell, W Number of Cells per Region Decay Heat Limit per Region, kW 1

337 9

3.03 2

337 40 13.48 3

337 40 13.48 TABLE 2.3-5 MPC-32ML HEAT LOAD DATA Number of Regions:

1 Number of Storage Cells: 32 Pattern Maximum Heat Load, kW Decay Heat Limit per Cell, kW Pattern A 44.16 1.380 Pattern B 28.70 0.897 TABLE 2.3-6 PWR FUEL LENGTH CATEGORIES Category Length Range Short Fuel 128 inches L < 144 inches Standard Fuel 144 inches L < 168 inches Long Fuel L 168 inches Notes:

1.

L means "nominal active fuel length". The nominal, unirradiated active fuel length of the PWR fuel assembly is used to designate it as short, standard and long.

to Holtec Letter 5018109 Page 86 of 130

TABLE 2.3-7A MPC-37P HEAT LOAD DATA for VENTILATED OVERPACK (see Figure 2.1-4)

Number of Storage Cells:

37 Maximum Design Basis Heat Load (kW):

45 Maximum Quadrant Heat Load (kW):

11.25 Decay Heat Limit per Cell (kW):

See Figures 2.3-14 and 2.3-15 Notes:

(1) Decay heat limit per cell for cells containing damaged fuel or fuel debris is equal to the decay heat limit per cell of the region where the damaged fuel or fuel debris is permitted to be stored.

TABLE 2.3-7B MPC-37P HEAT LOAD DATA for VENTILATED OVERPACK (See Figure 2.1-4)

Number of Regions:

3 Number of Storage Cells: 37 Maximum Heat Load:

33.3 Region No.

Decay Heat Limit per Cell, W Number of Cells per Region Decay Heat Limit per Region, kW 1

900 9

8.1 2

900 12 10.8 3

900 16 14.4 to Holtec Letter 5018109 Page 87 of 130

TABLE 2.3-8A MPC-44 HEAT LOAD DATA for VENTILATED OVERPACK (See Figure 2.1-5)

Number of Regions:

1 Number of Storage Cells: 44 Maximum Total Heat Load (kW): 44 Maximum Decay Heat Limit per Cell (kW): 1.0 Notes:

(1) There is a 5% decay heat penalty per cell for cells containing DFCs and/or DFIs.

TABLE 2.3-8B MPC-44 HEAT LOAD DATA for VENTILATED OVERPACK (See Figure 2.1-5)

Number of Regions:

1 Number of Storage Cells: 44 Maximum Total Heat Load (kW): 30 Maximum Decay Heat Limit per Cell (kW): 0.682 TABLE 2.3-8C MPC-44 HEAT LOAD DATA for EXTENDED CONFIGURATION OVERPACK (See Figure 2.1-5)

Number of Regions:

1 Number of Storage Cells: 44 Maximum Total Heat Load (kW): 43.12 Maximum Decay Heat Limit per Cell (kW): 0.98 to Holtec Letter 5018109 Page 88 of 130

TABLE 2.3-9A MPC-37 HEAT LOAD DATA for UNVENTILATED OVERPACK(See Figure 2.1-1)

Number of Regions:

3 Number of Storage Cells: 37 Maximum Total Heat Load (kW): 29 Maximum Section Heat Load (kW): 3.625 (Note 1)

Region No.

Decay Heat Limit per Cell, kW (Note 2)

Number of Cells per Region Decay Heat Limit per Region, kW 1

0.784 9

7.054 2

0.784 12 9.405 3

0.784 16 12.541 Note 1: Figure 2.1-1 identifies the cell locations, and Table 2.3-11 identifies the cells included in the heat load for each section.

Note 2: Maximum total heat load, maximum section heat load and specific cell heat load limits may need to be adjusted in accordance with Section 2.3.3.

Note 3: This pattern can be modified to develop regionalized patterns in accordance with the requirements in Table 2.3-9B.

TABLE 2.3-9B MPC-37 REQUIREMENTS ON DEVELOPING REGIONALIZED HEAT LOAD PATTERNS for UNVENTILATED OVERPACK (See Figure 2.1-1)

1. Pattern-specific total heat load must be equal to 29 kW

2. Section Heat Load must be equal to 3.625 kW, calculated per Table 2.3-11, and pattern must be 1/8th symmetric

3. Maximum Allowable Decay Heat per Cell in Region 1 is 0.784 kW

4. Maximum Allowable Decay Heat per Cell in Region 2 is 1.568 kW

5. Maximum Allowable Decay Heat per Cell in Region 3 is 1.568 kW

6. Pattern-specific Decay Heat in a storage cell may need to be adjusted to meet items 1 and 2

7. Pattern-specific decay heat for any storage cell in Region 1 may be determined by reducing the allowable in Region 1 of Table 2.3-9A by and pattern-specific decay heat for any storage cell in Regions 2 and 3 may be determined by increasing the allowable in Region 2 and/or Region 3 of Table 2.3-9A by the same.

8. Pattern-specific decay heat for any storage cell in Region 2 may be determined by reducing the allowable in Region 2 of Table 2.3-9A by and pattern-specific decay heat for any storage cell in Region 3 may be determined by increasing the allowable in Region 3 of Table 2.3-9A by the same. This may not be added to other cells in Region 2.

9. Items 1 through 8 need to be scaled in accordance with Section 2.3.4 for non-standard active fuel lengths.

General Note - The limits developed for the patterns are maximums, and any assembly with a heat load less than those limits can be loaded in the applicable cell, provided it meets all other CoC requirements. to Holtec Letter 5018109 Page 89 of 130

TABLE 2.3-10A MPC-89 HEAT LOAD DATA for UNVENTILATED OVERPACK (See Figure 2.1-2)

Number of Regions:

3 Number of Storage Cells: 89 Maximum Total Heat Load (kW): 29 Maximum Section Heat Load (kW): 3.625 (Note 1)

Region No.

Decay Heat Limit per Cell, kW (Note 2)

Number of Cells per Region Decay Heat Limit per Region, kW 1

0.326 9

2.932 2

0.326 40 13.034 3

0.326 40 13.034 Note 1: Figure 2.1-2 identifies the cell locations, and Table 2.3-12 identifies the cells included in the heat load for each section.

Note 2: Maximum total heat load, maximum section heat load and specific cell heat load limits may need to be adjusted in accordance with Section 2.3.4.

Note 3: This pattern can be modified to develop regionalized patterns in accordance with the requirements in Table 2.3-10B.

TABLE 2.3-10B MPC-89 REQUIREMENTS ON DEVELOPING REGIONALIZED HEAT LOAD PATTERNS for UNVENTILATED OVERPACK (See Figure 2.1-2)

1. Pattern-specific total heat load must be equal to 29 kW

2. Section Heat Load must be equal to 3.625 kW, calculated per Table 2.3-12, and pattern must be 1/8th symmetric

3. Maximum Allowable Decay Heat per Cell in Region 1 is 0.326 kW

4. Maximum Allowable Decay Heat per Cell in Region 2 is 0.652 kW

5. Maximum Allowable Decay Heat per Cell in Region 3 is 0.652 kW

6. Pattern-specific Decay Heat in a storage cell may need to be adjusted to meet items 1 and 2

7. Pattern-specific decay heat for any storage cell in Region 1 may be determined by reducing the allowable in Region 1 of Table 2.3-10A by and pattern-specific decay heat for any storage cell in Regions 2 and 3 may be determined by increasing the allowable in Region 2 and/or Region 3 of Table 2.3-10A by the same.

8. Pattern-specific decay heat for any storage cell in Region 2 may be determined by reducing the allowable in Region 2 of Table 2.3-10A by and pattern-specific decay heat for any storage cell in Region 3 may be determined by increasing the allowable in Region 3 of Table 2.3-10A by the same. This may not be added to other cells in Region 2.

9. Items 1 through 8 need to be scaled in accordance with Section 2.3.4 for non-standard active fuel lengths.

General Note - The limits developed for the patterns are maximums, and any assembly with a heat load less than those limits can be loaded in the applicable cell, provided it meets all other CoC requirements. to Holtec Letter 5018109 Page 90 of 130

TABLE 2.3-11 SECTION HEAT LOAD CALCULATIONS FOR MPC-37 Section Equation for Section Heat Load1 Section 1 Q3-1 + Q2-1 + 1/2Q3-2 + 1/2Q3-4 + 1/2Q2-2 + 1/2Q1-1 + 1/2Q1-2 + 1/8Q1-5 Section 2 Q3-3 + Q2-3 + 1/2Q3-2 + 1/2Q3-5 + 1/2Q2-2 + 1/2Q1-3 + 1/2Q1-2 + 1/8Q1-5 Section 3 Q2-5 + Q3-7 + 1/2Q1-6 + 1/2Q3-5 + 1/2Q2-7 + 1/2Q1-3 + 1/2Q3-9 + 1/8Q1-5 Section 4 Q2-9 + Q3-11 + 1/2Q1-6 + 1/2Q1-9 + 1/2Q2-7 + 1/2Q3-13 + 1/2Q3-9 + 1/8Q1-5 Section 5 Q2-12 + Q3-16 + 1/2Q1-8 + 1/2Q1-9 + 1/2Q2-11 + 1/2Q3-13 + 1/2Q3-15 + 1/8Q1-5 Section 6 Q2-10 + Q3-14 + 1/2Q1-8 + 1/2Q1-7 + 1/2Q2-11 + 1/2Q3-12 + 1/2Q3-15 + 1/8Q1-5 Section 7 Q2-8 + Q3-10 + 1/2Q1-4 + 1/2Q1-7 + 1/2Q2-6 + 1/2Q3-12 + 1/2Q3-8 + 1/8Q1-5 Section 8 Q2-4 + Q3-6 + 1/2Q1-4 + 1/2Q1-1 + 1/2Q2-6 + 1/2Q3-4 + 1/2Q3-8 + 1/8Q1-5 Notes 1.)

QX-Y is the heat load in kW in cell ID (X-Y), identified in Figure 2.1-1 to Holtec Letter 5018109 Page 91 of 130

TABLE 2.3-12 SECTION HEAT LOAD CALCULATIONS FOR MPC-89 Section Equation for Section Heat Load1 Section 1 Q3-1 + Q3-4 +Q3-5 + Q3-6 +Q2-2 + Q2-3 + Q2-9 + 1/2Q3-2 + 1/2Q2-1 + 1/2Q2-4 + 1/2Q2-10 + 1/2Q1-1/2Q1-1 + 1/2Q2-8 + 1/2Q2-11 + 1/8Q1-5 Section 2 Q3-3 + Q3-7 +Q3-8 + Q3-9 +Q2-5 + Q2-6 + Q2-11 + 1/2Q3-2 + 1/2Q2-1 + 1/2Q2-4 + 1/2Q2-10 +

1/2Q1-2 + 1/2Q1-3 + 1/2Q2-12 + 1/2Q3-12 + 1/8Q1-5 Section 3 Q3-13 + Q2-13 +Q3-15 + Q2-16 +Q2-17 + Q3-18 + Q3-19 + 1/2Q1-6 + 1/2Q2-21 + 1/2Q2-22 + 1/2Q2-23 + 1/2Q3-21 + 1/2Q1-3 + 1/2Q2-12 + 1/2Q3-12 + 1/8Q1-5 Section 4 Q2-26 + Q2-27 +Q3-24 + Q3-25 +Q2-34 + Q3-27 + Q3-31 + 1/2Q1-6 + 1/2Q2-21 + 1/2Q2-22 + 1/2Q2-23 + 1/2Q3-21 + 1/2Q1-9 + 1/2Q2-33 + 1/2Q3-30 + 1/8Q1-5 Section 5 Q2-32 + Q2-38 +Q2-39 + Q3-35 +Q2-36 + Q3-37 + Q3-40 + 1/2Q1-8 + 1/2Q2-31 + 1/2Q2-37 + 1/2Q2-40 + 1/2Q3-39 + 1/2Q1-9 + 1/2Q2-33 + 1/2Q3-30 + 1/8Q1-5 Section 6 Q2-30 + Q2-35 +Q2-36 + Q3-32 +Q2-33 + Q3-34 + Q3-38 + 1/2Q1-8 + 1/2Q2-31 + 1/2Q2-37 + 1/2Q2-40 + 1/2Q3-39 + 1/2Q1-7 + 1/2Q2-29 + 1/2Q3-29 + 1/8Q1-5 Section 7 Q2-25 + Q2-24 +Q3-23 + Q3-22 +Q2-28 + Q3-26 + Q3-28 + 1/2Q1-4 + 1/2Q2-20 + 1/2Q2-19 + 1/2Q2-18 + 1/2Q3-20 + 1/2Q1-7 + 1/2Q2-29 + 1/2Q3-29 + 1/8Q1-5 Section 8 Q2-15 + Q2-14 +Q3-17 + Q3-16 +Q2-7 + Q3-14 + Q3-10 + 1/2Q1-4 + 1/2Q2-20 + 1/2Q2-19 + 1/2Q2-18

+ 1/2Q3-20 + 1/2Q1-1 + 1/2Q2-8 + 1/2Q3-11 + 1/8Q1-5 Notes 1.) QX-Y is the heat load in kW in cell ID (X-Y), identified in Figure 2.1-2 TABLE 2.3-13 MPC-44 HEAT LOAD DATA for UNVENTILATED OVERPACK (See Figure 2.1-5)

Number of Regions:

1 Number of Storage Cells: 44 Maximum Total Heat Load (kW): 28 Maximum Decay Heat Limit per Cell (kW): 0.636 to Holtec Letter 5018109 Page 92 of 130

Table 2.3-14 MAX. ALLOWABLE HEAT LOADS FOR PWR MPCs1 MPC Type Max. Allowable Total MPC Heat Load, kW Max. Allowable Heat Load per Storage Location, kW MPC-32ML 59.0 5.0 MPC-37 59.0 5.0 MPC-37P 59.0 5.0 MPC-44 59.0 5.0 Table 2.3-15 MAX. ALLOWABLE HEAT LOAD FOR THE MPC-891 MPC Type Max. Allowable Total MPC Heat Load, kW Max. Allowable Heat Load per Storage Location, kW MPC-89 60.8

2.7 Notes

1.)

Table 2.3-14 and Table 2.3-15 are the maximum allowable heat loads for alternative heat loads developed following the methodology in Section 4.4 of the HI-STORM FW FSAR. The maximum allowable heat loads per storage cell for MPC-37 and MPC-44 are based on the active length of the standard-length fuel (Table 2.3-6). The maximum allowable heat loads per storage cell for MPC-89 are based on the active length of the standard-length fuel defined in Section 2.3.4. Maximum allowable heat load per storage location for fuels with shorter or longer active fuels than the standard active fuel length should be determined using the methodology in HI-STORM FW FSAR Chapter 4.

to Holtec Letter 5018109 Page 93 of 130

0.45 (D/F) 0.45 0.45 (D/F) 0.45 (D/F) 3.2 0.5 3.2 0.45 (D/F) 0.6 (D/F) 2.4 0.5 0.6 0.5 2.4 0.6 (D/F) 0.6 0.5 0.6 0.5 0.6 0.5 0.6 0.6 (D/F) 2.4 0.5 0.6 0.5 2.4 0.6 (D/F) 0.45 (D/F) 3.2 0.5 3.2 0.45 (D/F) 0.45 (D/F) 0.45 0.45 (D/F)

Figure 2.3-1:

Loading Pattern 37C1 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC Short Fuel per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.)

to Holtec Letter 5018109 Page 94 of 130

0.45 0.45 0.45 0.45 3.2 (D)

Empty 3.2 (D) 0.45 0.6 2.4 (D)

Empty 0.6 Empty 2.4 (D) 0.6 0.6 0.5 0.6 0.5 0.6 0.5 0.6 0.6 2.4 (D)

Empty 0.6 Empty 2.4 (D) 0.6 0.45 3.2 (D)

Empty 3.2 (D) 0.45 0.45 0.45 0.45 Figure 2.3-2:

Loading Pattern 37C2 for MPC-37 Containing Undamaged and Damaged Fuel in DFC/DFI/, Short Fuel per Cell Heat Load Limits (All storage cell heat loads are in kW, Undamaged Fuel or Damaged Fuel in a DFC and/or using DFIs may be stored in cells denoted by D. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell) to Holtec Letter 5018109 Page 95 of 130

0.45 0.45 0.45 0.45 3.2 (D/F)

Empty 3.2 (D/F) 0.45 0.6 2.4 Empty 0.6 Empty 2.4 0.6 0.6 0.5 0.6 0.5 0.6 0.5 0.6 0.6 2.4 Empty 0.6 Empty 2.4 0.6 0.45 3.2 (D/F)

Empty 3.2 (D/F) 0.45 0.45 0.45 0.45 Figure 2.3-3:

Loading Pattern 37C3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Short Fuel per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell) to Holtec Letter 5018109 Page 96 of 130

0.55 (D/F) 0.55 0.55 (D/F) 0.55 (D/F) 3.2 0.55 3.2 0.55 (D/F) 0.75 (D/F) 2.4 0.55 0.65 0.55 2.4 0.75 (D/F) 0.75 0.55 0.65 0.55 0.65 0.55 0.75 0.75 (D/F) 2.4 0.55 0.65 0.55 2.4 0.75 (D/F) 0.55 (D/F) 3.2 0.55 3.2 0.55 (D/F) 0.55 (D/F) 0.55 0.55 (D/F)

Figure 2.3-4:

Loading Pattern 37D1 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFCs, Standard Fuel per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.)

to Holtec Letter 5018109 Page 97 of 130

0.55 0.55 0.55 0.55 3.2 (D)

Empty 3.2 (D) 0.55 0.75 2.4 (D)

Empty 0.65 Empty 2.4 (D) 0.75 0.75 0.55 0.65 0.55 0.65 0.55 0.75 0.75 2.4 (D)

Empty 0.65 Empty 2.4 (D) 0.75 0.55 3.2 (D)

Empty 3.2 (D) 0.55 0.55 0.55 0.55 Figure 2.3-5:

Loading Pattern 37D2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs,Standard Fuel per Cell Heat Load Limits (All storage cell heat loads are in kW, D Undamaged Fuel or Damaged Fuel in a DFC and/or using DFIs may be stored in cells denoted by D. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell) to Holtec Letter 5018109 Page 98 of 130

0.55 0.55 0.55 0.55 3.2 (D/F)

Empty 3.2 (D/F) 0.55 0.75 2.4 Empty 0.65 Empty 2.4 0.75 0.75 0.55 0.65 0.55 0.65 0.55 0.75 0.75 2.4 Empty 0.65 Empty 2.4 0.75 0.55 3.2 (D/F)

Empty 3.2 (D/F) 0.55 0.55 0.55 0.55 Figure 2.3-6:

Loading Pattern 37D3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Standard Fuel per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell.) to Holtec Letter 5018109 Page 99 of 130

0.65 (D/F) 0.65 0.65 (D/F) 0.65 (D/F) 3.5 0.65 3.5 0.65 (D/F) 0.85 (D/F) 2.6 0.65 0.75 0.65 2.6 0.85 (D/F) 0.85 0.65 0.75 0.65 0.75 0.65 0.85 0.85 (D/F) 2.6 0.65 0.75 0.65 2.6 0.85 (D/F) 0.65 (D/F) 3.5 0.65 3.5 0.65 (D/F) 0.65 (D/F) 0.65 0.65 (D/F)

Figure 2.3-7:

Loading Pattern 37E1 for MPC-37 Loading Pattern for MPCs Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFCs, Long Fuel per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.)

to Holtec Letter 5018109 Page 100 of 130

0.65 0.65 0.65 0.65 3.5 (D)

Empty 3.5 (D) 0.65 0.85 2.6 (D)

Empty 0.75 Empty 2.6 (D) 0.85 0.85 0.65 0.75 0.65 0.75 0.65 0.85 0.85 2.6 (D)

Empty 0.75 Empty 2.6 (D) 0.85 0.65 3.5 (D)

Empty 3.5 (D) 0.65 0.65 0.65 0.65 Figure 2.3-8:

Loading Pattern 37E2 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, Long Fuel per Cell Heat Load Limits (All storage cell heat loads are in kW, D means Undamaged Fuel or Damaged Fuel in a DFC and/or using DFIs may be stored in cells denoted by D. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell) to Holtec Letter 5018109 Page 101 of 130

0.65 0.65 0.65 0.65 3.5 (D/F)

Empty 3.5 (D/F) 0.65 0.85 2.6 Empty 0.75 Empty 2.6 0.85 0.85 0.65 0.75 0.65 0.75 0.65 0.85 0.85 2.6 Empty 0.75 Empty 2.6 0.85 0.65 3.5 (D/F)

Empty 3.5 (D/F) 0.65 0.65 0.65 0.65 Figure 2.3-9:

Loading Pattern 37E3 for MPC-37 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, Long Fuel per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell) to Holtec Letter 5018109 Page 102 of 130

0.25 (D/F) 0.25 0.25 (D/F) 0.25 (D/F) 0.25 0.25 1.45 0.25 0.25 0.25 (D/F) 0.25 (D/F) 0.25 1.45 0.9 0.9 0.9 1.45 0.25 0.25 (D/F) 0.25 1.45 0.32 0.32 0.32 0.32 0.32 1.45 0.25 0.25 (D/F) 0.25 0.9 0.32 0.32 0.32 0.32 0.32 0.9 0.25 0.25 (D/F) 0.25 1.45 0.9 0.32 0.32 0.32 0.32 0.32 0.9 1.45 0.25 0.25 (D/F) 0.25 0.9 0.32 0.32 0.32 0.32 0.32 0.9 0.25 0.25 (D/F) 0.25 1.45 0.32 0.32 0.32 0.32 0.32 1.45 0.25 0.25 (D/F) 0.25 1.45 0.9 0.9 0.9 1.45 0.25 0.25 (D/F) 0.25 (D/F) 0.25 0.25 1.45 0.25 0.25 0.25 (D/F) 0.25 (D/F) 0.25 0.25 (D/F)

Figure 2.3-10:

Loading Pattern 89A1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.) to Holtec Letter 5018109 Page 103 of 130

0.25 0.25 0.25 0.25 0.25 0.25 1.45 (D/F) 0.25 0.25 0.25 0.25 0.25 1.45 (D/F) 0.9 0.9 0.9 1.45 (D/F) 0.25 0.25 0.25 1.45 (D/F)

Empty 0.32 0.32 0.32 Empty 1.45 (D/F) 0.25 0.25 0.25 0.9 0.32 0.32 0.32 0.32 0.32 0.9 0.25 0.25 0.25 1.45 (D/F) 0.9 0.32 0.32 0.32 0.32 0.32 0.9 1.45 (D/F) 0.25 0.25 0.25 0.9 0.32 0.32 0.32 0.32 0.32 0.9 0.25 0.25 0.25 1.45 (D/F)

Empty 0.32 0.32 0.32 Empty 1.45 (D/F) 0.25 0.25 0.25 1.45 (D/F) 0.9 0.9 0.9 1.45 (D/F) 0.25 0.25 0.25 0.25 0.25 1.45 (D/F) 0.25 0.25 0.25 0.25 0.25 0.25 Figure 2.3-11: Loading Pattern 89A2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFCs, per Cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell.) to Holtec Letter 5018109 Page 104 of 130

0.11 (D/F) 0.47 0.11 (D/F) 0.19 (D/F) 0.23 0.68 1.46 0.68 0.23 0.19 (D/F) 0.25 (D/F) 0.27 1.42 1.05 0.40 1.05 1.42 0.27 0.25 (D/F) 0.23 1.44 0.29 0.31 0.33 0.31 0.29 1.44 0.23 0.10 (D/F) 0.71 0.72 0.36 0.28 0.21 0.28 0.36 0.72 0.71 0.10 (D/F) 0.40 1.46 0.47 0.33 0.21 0.10 0.21 0.33 0.47 1.46 0.40 0.10 (D/F) 0.71 0.72 0.36 0.28 0.21 0.28 0.36 0.72 0.71 0.10 (D/F) 0.23 1.44 0.29 0.31 0.33 0.31 0.29 1.44 0.23 0.25 (D/F) 0.27 1.42 1.05 0.40 1.05 1.42 0.27 0.25 (D/F) 0.19 (D/F) 0.23 0.68 1.46 0.68 0.23 0.19 (D/F) 0.11 (D/F) 0.47 0.11 (D/F)

Figure 2.3-12: Loading Pattern 89B1 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per cell Heat Load Limits (All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F. ) to Holtec Letter 5018109 Page 105 of 130

0.11 0.47 0.11 0.19 0.23 0.68 1.46 (D/F) 0.68 0.23 0.19 0.25 0.27 1.42 (D/F) 1.05 0.40 1.05 1.42 (D/F) 0.27 0.25 0.23 1.44 (D/F) Empty 0.31 0.33 0.31 Empty 1.44 (D/F) 0.23 0.10 0.71 0.72 0.36 0.28 0.21 0.28 0.36 0.72 0.71 0.10 0.40 1.46 (D/F) 0.47 0.33 0.21 0.10 0.21 0.33 0.47 1.46 (D/F) 0.40 0.10 0.71 0.72 0.36 0.28 0.21 0.28 0.36 0.72 0.71 0.10 0.23 1.44 (D/F) Empty 0.31 0.33 0.31 Empty 1.44 (D/F) 0.23 0.25 0.27 1.42 (D/F) 1.05 0.40 1.05 1.42 (D/F) 0.27 0.25 0.19 0.23 0.68 1.46 (D/F) 0.68 0.23 0.19 0.11 0.47 0.11 Figure 2.3-13: Loading Pattern 89B2 for MPC-89 Containing Undamaged and Damaged Fuel in DFCs/DFIs, and/or Fuel Debris in DFC, per Cell Heat Load Limits(

All Storage cell heat loads are in kW, Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F. Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell.) to Holtec Letter 5018109 Page 106 of 130

0.64 (D/F) 0.95 0.64 (D/F) 1.37 (D/F) 3.03 1.7 3.03 1.37 (D/F) 0.86 (D/F) 2.64 Empty 0.73 Empty 2.64 0.86 (D/F) 0.95 2.43 0.79 0.22 0.79 2.43 0.95 0.86 (D/F) 2.64 Empty 0.73 Empty 2.64 0.86 (D/F) 1.37 (D/F) 3.03 1.7 3.03 1.37 (D/F) 0.64 (D/F) 0.95 0.64 (D/F)

Figure 2.3-14:

Loading Pattern 1 for MPC-37P (All Storage cell heat loads are in kW. Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.

Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell.)

to Holtec Letter 5018109 Page 107 of 130

0.64 0.95 0.64 1.37 3.03 (D/F) 1.7 3.03 (D/F) 1.37 0.86 2.64 Empty 0.73 Empty 2.64 0.86 0.95 2.43 0.79 0.22 0.79 2.43 0.95 0.86 2.64 Empty 0.73 Empty 2.64 0.86 1.37 3.03 (D/F) 1.7 3.03 (D/F) 1.37 0.64 0.95 0.64 Figure 2.3-15:

Loading Pattern 2 for MPC-37P (All Storage cell heat loads are in kW. Undamaged Fuel, or Damaged Fuel in DFCs and/or using DFIs, and/or Fuel Debris in a DFC may be stored in cells denoted by D/F.

Cells denoted as Empty must remain empty regardless of the contents of the adjacent cell.)

to Holtec Letter 5018109 Page 108 of 130

2.4 Burnup Credit Criticality control during loading of the MPC-37 and MPC-37P is achieved through either meeting the soluble boron limits in LCO 3.3.1 OR verifying that the assemblies meet the minimum burnup requirements in Table 2.4-1.

For those spent fuel assemblies that need to meet the burnup requirements specified in Table 2.4-1, a burnup verification shall be performed in accordance with either Method A OR Method B described below.

Method A: Burnup Verification Through Quantitative Burnup Measurement For each assembly in the MPC-37 and MPC-37P where burnup credit is required, the minimum burnup is determined from the burnup requirement applicable to the loading configuration chosen for the cask (see Table 2.4-1). A measurement is then performed that confirms that the fuel assembly burnup exceeds this minimum burnup.

The measurement technique may be calibrated to the reactor records for a representative set of assemblies. The assembly burnup value to be compared with the minimum required burnup should be the measured burnup value as adjusted by reducing the value by a combination of the uncertainties in the calibration method and the measurement itself.

Method B: Burnup Verification Through an Administrative Procedure and Qualitative Measurements Depending on the location in the basket, assemblies loaded into a specific MPC-37 and MPC-37P can either be fresh, or have to meet a single minimum burnup value.

The assembly burnup value to be compared with the minimum required burnup should be the reactor record burnup value as adjusted by reducing the value by the uncertainties in the reactor record value. An administrative procedure shall be established that prescribes the following steps, which shall be performed for each cask loading:

Based on a review of the reactor records, all assemblies in the spent fuel pool that have a burnup that is below the minimum required burnup of the loading curve for the cask to be loaded are identified.

After the cask loading, but before the release for shipment of the cask, the presence and location of all those identified assemblies is verified, except for those assemblies that have been loaded as fresh assemblies into the cask.

An independent, third-party verification of the loading process, including the fuel selection process and generation of the fuel move instructions Additionally, for all assemblies to be loaded that are required to meet a minimum burnup, a qualitative verification shall be performed that verifies that the assembly is not a fresh assembly.

to Holtec Letter 5018109 Page 109 of 130

TABLE 2.4-1 POLYNOMIAL FUNCTIONS FOR THE MINIMUM BURNUP AS A FUNCTION OF INITIAL ENRICHMENT Assembly Classes Configuration1 Cooling

Time, years Minimum Burnup (GWd/mtU) as a Function of the Initial Enrichment (wt% 235U) 15x15B, C, D, E, F, H, I and 17x17A, B, C, D, E Uniform 3.0 and

<7.0 f(x) = -7.9224e-02

x^3 -7.6419e-01

x^2

+2.2411e+01

x^1 -4.1183e+01 7.0 f(x) = +1.3212e-02

x^3 -1.6850e+00

x^2

+2.4595e+01

x^1 -4.2603e+01 Regionalized 3.0 and

<7.0 f(x) = +3.6976e-01

x^3 -5.8233e+00

x^2

+4.0599e+01

x^1 -5.8346e+01 7.0 f(x) = +3.3423e-01

x^3 -5.1647e+00

x^2

+3.6549e+01

x^1 -5.2348e+01 16x16A, B, C

Uniform 3.0 and

<7.0 f(x) = -1.0361e+00

x^3 +1.1386e+01

x^2

-2.9174e+01

x^1 +2.0850e+01 7.0 f(x) = -9.6572e-01

x^3 +1.0484e+01

x^2

-2.5982e+01

x^1 +1.7515e+01 Regionalized 3.0 and

<7.0 f(x) = -2.1456e-01

x^3 +2.4668e+00

x^2

+2.1381e+00

x^1 -1.2560e+01 7.0 f(x) = -5.9154e-01

x^3 +5.8403e+00

x^2

-6.9339e+00

x^1 -4.7951e+00 Combined2

(>3.0) f(x) = -4.9680e-01

x^3 +4.9471e+00

x^2

-4.2373e+00

x^1 -7.3936e+00 1 Uniform configuration refers to Configuration 1 in Table 2.4-2. Regionalized configuration refers to Configuration 2, 3, or 4 in Table 2-4-2.

2 The combined cooling time loading curve is applicable for fuel with above 3 years cooling time. to Holtec Letter 5018109 Page 110 of 130

TABLE 2.4-2 BURNUP CREDIT CONFIGURATIONS Configuration Description Configuration 1 Spent UNDAMAGED fuel assemblies are placed in all positions of the basket Configuration 2 Fresh UNDAMAGED fuel assemblies are placed in locations 3-4, 3-5, 3-12, and 3-13 (see Figure 2.1-1); spent UNDAMAGED fuel assemblies are placed in the remaining positions Configuration 3 Damaged Fuel Containers (DFCs) and/or Damaged Fuel Isolators (DFIs) with spent DAMAGED fuel assemblies are placed in locations 3-1, 3-3, 3-4, 3-5, 3-6, 3-7, 3-10, 3-11, 3-12, 3-13, 3-14, and 3-16 (see Figure 2.1-1); spent UNDAMAGED fuel assemblies are placed in the remaining positions Configuration 4 DFCs with Damaged Fuel and/or fresh FUEL DEBRIS are placed in locations 3-1, 3-7, 3-10, and 3-16 with locations 2-1, 2-5, 2-8, and 2-12 (see Figure 2.1-1) empty; spent UNDAMAGED fuel assemblies are placed in the remaining positions to Holtec Letter 5018109 Page 111 of 130

TABLE 2.4-3 IN-CORE OPERATING REQUIREMENTS Assembly Type Specific Power (MW/mtU)

Moderator Temperature (K)

Fuel Temperature (K)

Soluble Boron (ppm)

Bounding Values (for Design Basis Calculations) 15x15D, E, F, H

47.36 604 1169 1000 15x15B, C (Note 1) 52.33 620 1219 1000 16x16A, B 51.90 608 1113 1000 17x17A, B, C, D, E 61.61 620 1181 1000 NOTES:

1. The same core operating parameters are assumed for the 15x15I and 16x16C fuel assembly types. to Holtec Letter 5018109 Page 112 of 130

2.5 Burnup and Cooling Time Qualification Requirements Burnup and cooling time limits must either meet the requirements specified in Sections 2.5.1 or, 2.5.2, or 2.5.3, as applicable to the basket version, orversion or be determined based on the methodology specified in Appendix B to Chapter 5 of HI-STORM FW FSAR.-2114830, Revision 11.

2.5.1 Burnup and cooling time limits for fuel assemblies authorized for loading into the MPC-32ML are provided in Table 2.5-1. Burnup and cooling time limits for fuel assemblies authorized for loading according to only the alternative loading patterns shown in Figures 2.3-1 through 2.3-9 (MPC-37) and Figures 2.3-10 through 2.3-13 (MPC-89) are provided in Table 2.5-2.

The burnup and cooling time for every fuel loaded into the MPC-32 ML, MPC-37, and MPC-89 must satisfy the following equation:

Ct = A Bu3 + BBu2 + C Bu + D

where, Ct

= Minimum cooling time (years)

Bu

= Assembly-average burnup (MWd/mtU)

A,B,C,D =Polynomial coefficients listed in Tables 2.5-1 and 2.5-2 Minimum cooling time must also meet limits specified in Table 2.1-1. If the calculated Ct is less than the cooling time limit in Table 2.1-1, the minimum cooling time in Table 2.1-1 is used.

2.5.2 Burnup and cooling time limits for fuel assemblies authorized for loading into the MPC-37P and MPC-44 are provided in Table 2.5-3.

The burnup and cooling time for every fuel assembly loaded into the MPC-37P and MPC-44 must satisfy the following equation:

Ct = A Bu4 + B Bu3 + C Bu2 + D Bu + E

where, Ct

= Minimum cooling time (years),

Bu

= Assembly-average burnup (MWd/mtU),

A, B, C, D, E

= Polynomial coefficients listed in Table 2.5-3. to Holtec Letter 5018109 Page 113 of 130

TABLE 2.5-1 BURNUP AND COOLING TIME FUEL QUALIFICATION REQUIREMENTS FOR MPC-32ML A

B C

D 6.7667E-14

-36736E-09 8.1319E-05 2.7951E+00 TABLE 2.5-2 BURNUP AND COOLING TIME FUEL QUALIFICATION REQUIREMENTS FOR MPC-37 AND MPC-89 Cell Decay Heat Load Limit (kW)

Polynomial Coefficients A

B C

D (Note 1)

MPC-37 0.85 1.68353E-13

-9.65193E-09 2.69692E-04 2.95915E-01 0.85 < decay heat 3.5 1.19409E-14

-1.53990E-09 9.56825E-05

-3.98326E-01 MPC-89 0.32 1.65723E-13

-9.28339E-09 2.57533E-04 3.25897E-01 0.32 < decay heat 0.5 3.97779E-14

-2.80193E-09 1.36784E-04 3.04895E-01 0.5 < decay heat 0.75 1.44353E-14

-1.21525E-09 8.14851E-05 3.31914E-01 0.75 < decay heat 1.1

-7.45921E-15 1.09091E-09

-1.14219E-05 9.76224E-01 1.1 < decay heat 1.45 3.10800E-15

-7.92541E-11 1.56566E-05 6.47040E-01 1.45 < decay heat 1.6

-8.08081E-15 1.23810E-09

-3.48196E-05 1.11818E+00 NOTES:

1. For BLEU fuel, coefficient D is increased by 1.

to Holtec Letter 5018109 Page 114 of 130

TABLE 2.5-3 BURNUP AND COOLING TIME FUEL QUALIFICATION REQUIREMENTS FOR MPC-37P AND MPC-44 Cell Decay Heat Load Limit (kW)

Polynomial Coefficients A

B C

D E

MPC-37P 0.79

-7.95196E-18 1.45069E-12

-7.94501E-08 1.81131E-03 -1.09897E+01 0.79 < decay heat 0.95

-1.25365E-19 2.60073E-13

-2.20748E-08 7.29884E-04 -4.89153E+00 0.95 < decay heat 1.37

-5.32045E-18 1.07046E-12

-7.62281E-08 2.40535E-03 -2.51659E+01 1.37 < decay heat 2.64

-1.78154E-21 1.30015E-15 1.74063E-10 1.65882E-05 1.36110E+00 2.64 < decay heat 3.03 3.36123E-20 2.18480E-15 1.42012E-10 9.23077E-06 6.00000E-01 MPC-44 1.0 2.30737E-18

-1.72421E-13 3.59688E-09 9.41169E-05 6.41653E-01 to Holtec Letter 5018109 Page 115 of 130

3.0 DESIGN FEATURES 3.1 Site 3.1.1 Site Location The HI-STORM FW 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-37

1.

Minimum basket cell ID: 8.92 in. (nominal)

2.

Minimum basket cell wall thickness: 0.57 in. (nominal)

3.

B4C in the Metamic-HT: 10.0 wt % (min.)

3.2.2 MPC-89

1.

Minimum basket cell ID: 5.99 in. (nominal)

2.

Minimum basket cell wall thickness: 0.38 in. (nominal)

3.

B4C in the Metamic-HT: 10.0 wt % (min.)

3.2.3 Neutron Absorber Tests

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.

to Holtec Letter 5018109 Page 116 of 130

3.2.4 MPC-32ML

1.

Minimum basket cell ID: 9.53 (nominal)

2.

Minimum basket cell wall thickness: 0.57 in (nominal)

3.

B4C in the Metamic-HT: 10.0wt% (min.)

3.2.5 MPC-37P

1.

Minimum basket cell ID: 8.70 (nominal)

2.

Minimum basket cell wall thickness: 0.77 in (nominal)

3.

B4C in the Metamic-HT: 10.0wt% (min.)

3.2.6 MPC-44

1.

Minimum basket cell ID: 8.00 (nominal)

2.

Minimum basket cell wall thickness: 0.49 in (nominal)

3.

B4C in the Metamic-HT: 10.0wt% (min.)

3.3 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2007 Edition, is the governing Code for the HI-STORM FW System MPC as clarified in Specification 3.3.1 below, except for Code Sections V and IX. The ASME Code paragraphs applicable to the HI-STORM FW OVERPACK and TRANSFER CASK are listed in Table 3-2. 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 2007 Edition, including any 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.

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 of the HI-STORM FW Cask System.

3.3.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the ASME Code,Section III, 2007 Edition, 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 to Holtec Letter 5018109 Page 117 of 130

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, 2007 Edition, 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) to Holtec Letter 5018109 Page 118 of 130

3.0 DESIGN FEATURES (continued)

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Enclosure Vessel Subsection NCA General Requirements.

Requires preparation of a Design Specification, Design Report, Overpressure Protection Report, Certification of Construction Report, Data Report, and other administrative controls for an ASME Code stamped vessel.

Because the MPC is not an ASME Code stamped vessel, none of the specifications, reports, certificates, or other general requirements specified by NCA are required. In lieu of a Design Specification and Design Report, the HI-STORM FSAR includes the design criteria, service conditions, and load combinations for the design and operation of the MPCs as well as the results of the stress analyses to demonstrate that applicable Code stress limits are met. Additionally, the fabricator is not required to have an ASME-certified QA program. All important-to-safety activities are governed by the NRC-approved Holtec QA program.

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 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 Enclosure Vessel NB-1100 Statement of requirements for Code stamping of components.

MPC Enclosure Vessel is designed and will be fabricated in accordance with ASME Code,Section III, Subsection NB to the maximum practical extent, but Code stamping is not required. to Holtec Letter 5018109 Page 119 of 130

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC basket supports and lift lugs NB-1130 NB-1132.2(d) requires that the first connecting weld of a non-pressure retaining structural attachment to a component shall be considered part of the component unless the weld is more than 2t from the pressure retaining portion of the component, where t is the nominal thickness of the pressure retaining material.

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.

The lugs that are used exclusively for lifting an empty MPC are welded to the inside of the pressure-retaining MPC shell, but are not designed in accordance with Subsection NB. The lug-to-Enclosure Vessel Weld is required to meet the stress limits of Reg. Guide 3.61 in lieu of Subsection NB of the Code.

MPC Enclosure Vessel NB-2000 Requires materials to be supplied by ASME-approved material supplier.

Materials will be supplied by Holtec approved suppliers with Certified Material Test Reports (CMTRs) in accordance with NB-2000 requirements.

MPC Enclosure Vessel NB-2121 Provides permitted material specification for pressure-retaining material, which must conform to Section II, Part D, Tables 2A and 2B Certain duplex stainless steels are not included in Section II, Part D, Tables 2A and 2B. These stainless steel alloys are evaluated in the HI-STORM FW FSAR and meet the required design criteria for use in the HI-STORM FW system.

MPC Enclosure Vessel NB-3100 NF-3100 Provides requirements for determining design loading conditions, such as pressure, temperature, and mechanical loads.

These requirements are subsumed by the HI-STORM FW FSAR, serving as the Design Specification, which establishes the service conditions and load combinations for the storage system.

MPC Enclosure Vessel NB-4120 NB-4121.2 and NF-4121.2 provide requirements for repetition of tensile or impact tests for material subjected to heat treatment during fabrication or installation.

In-shop operations of short duration that apply heat to a component, such as plasma cutting of plate stock, welding, machining, and coating are not, unless explicitly stated by the Code, defined as heat treatment operations. to Holtec Letter 5018109 Page 120 of 130

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Enclosure Vessel NB-4220 Requires certain forming tolerances to be met for cylindrical, conical, or spherical shells of a vessel.

The cylindricity measurements on the rolled shells are not specifically recorded in the shop travelers, as would be the case for a Code-stamped pressure vessel. Rather, the requirements on inter-component clearances (such as the MPC-to-transfer cask) are guaranteed through fixture-controlled manufacturing. The fabrication specification and shop procedures ensure that all dimensional design objectives, including inter-component annular clearances are satisfied. 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 Enclosure Vessel NB-4122 Implies that with the exception of studs, bolts, nuts and heat exchanger tubes, CMTRs must be traceable to a specific piece of material in a component.

MPCs are built in lots. Material traceability on raw materials to a heat number and corresponding CMTR is maintained by Holtec through markings on the raw material. Where material is cut or processed, markings are transferred accordingly to assure traceability. As materials are assembled into the lot of MPCs being manufactured, documentation is maintained to identify the heat numbers of materials being used for that item in the multiple MPCs being manufactured under that lot. A specific item within a specific MPC will have a number of heat numbers identified as possibly being used for the item in that particular MPC of which one or more of those heat numbers (and corresponding CMTRS) will have actually been used. All of the heat numbers identified will comply with the requirements for the particular item.

MPC Lid and Closure Ring Welds NB-4243 Full penetration welds required for Category C Joints (flat head to main shell per NB-3352.3)

MPC lid and closure ring are not full penetration welds. They are welded independently to provide a redundant seal. to Holtec Letter 5018109 Page 121 of 130

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Closure Ring, Vent and Drain Cover Plate Welds NB-5230 Radiographic (RT) or ultrasonic (UT) examination required.

Root (if more than one weld pass is required) and final liquid penetrant examination to be performed in accordance with NB-5245. The closure ring provides independent redundant closure for vent and drain cover plates.

Vent 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.

MPC Lid to Shell Weld NB-5230 Radiographic (RT) or ultrasonic (UT) examination required.

Only progressive liquid penetrant (PT) examination is permitted. PT examination will include the root and final weld layers and each approx. 3/8" of weld depth. to Holtec Letter 5018109 Page 122 of 130

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Enclosure Vessel and Lid NB-6111 All completed pressure retaining systems shall be pressure tested.

The MPC vessel is welded in the field following fuel assembly loading.

Pressure tests (Hydrostatic or pneumatic) will not be performed because lack of accessibility for leakage inspections precludes a meaningful pressure retention capability test. The different models of MPCs available in the industry are not subject to pressure tests because of the dose to the crew, the proven ineffectiveness of the pressure tests to reveal any leaks and the far more effective tests performed on the MPC confinement boundary, such as: All MPC enclosure vessel welds (except closure ring and vent/drain cover plate) are inspected by volumetric examination. All MPC shell and baseplate materials are UT tested.

Finally,the MPC lid-to-shell weld shall be verified by progressive PT examination. PT must include the root and final layers and each approximately 3/8 inch of weld depth.

The inspection results, including relevant findings (indications) shall be made a permanent part of the users records by video, photographic, of other means which provide an equivalent 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.

MPC Enclosure Vessel NB-7000 Vessels are required to have overpressure protection.

No overpressure protection is provided.

Function of MPC enclosure vessel is to contain radioactive contents under normal, off-normal, and accident conditions of storage. MPC vessel is designed to withstand maximum internal pressure considering 100% fuel rod failure and maximum accident temperatures. to Holtec Letter 5018109 Page 123 of 130

TABLE 3-1 List of ASME Code Alternatives for Multi-Purpose Canisters (MPCs)

MPC Enclosure Vessel NB-8000 States requirements for nameplates, stamping and reports per NCA-8000.

The HI-STORM FW system is to be marked and identified in accordance with 10CFR71 and 10CFR72 requirements. Code stamping is not required. QA data package to be in accordance with Holtec approved QA program.

to Holtec Letter 5018109 Page 124 of 130

TABLE 3-2 REFERENCE ASME CODE PARAGRAPHS FOR HI-STORM FW OVERPACK and HI-TRAC VW TRANSFER CASK, PRIMARY LOAD BEARING PARTS Item Code Paragraph Notes, Explanation and Applicability

1.

Definition of primary and secondary members NF-1215

2.

Jurisdictional boundary NF-1133 The intervening elements are termed interfacing SSCs in this FSAR.

3.

Certification of material NF-2130 (b) and (c)

Materials for ITS components shall be certified to the applicable Section II of the ASME Code or equivalent ASTM Specification.

4.

Heat treatment of material NF-2170 and NF-2180

5.

Storage of welding material NF-2440, NF-4411

6.

Welding procedure specification Section IX Acceptance Criteria per Subsection NF

7.

Welding material Section II

8.

Definition of Loading conditions NF-3111

9.

Allowable stress values NF-3112.3

10.

Rolling and sliding supports NF-3124

11.

Differential thermal expansion NF-3127

12.

Stress analysis NF-3143 NF-3380 NF-3522 NF-3523 Provisions for stress analysis for Class 3 linear structures is applicable for overpack top lid and the overpack and transfer cask shells.

13.

Cutting of plate stock NF-4211 NF-4211.1

14.

Forming NF-4212

15.

Forming tolerance NF-4221 All cylindrical parts.

16.

Fitting and Aligning Tack Welds NF-4231 NF-4231.1

17.

Alignment NF-4232

18.

Cleanliness of Weld Surfaces NF-4412 Applies to structural and non-structural welds

19.

Backing Strips, Peening NF-4421 NF-4422 Applies to structural and non-structural welds

20.

Pre-heating and Interpass Temperature NF-4611 NF-4612 NF-4613 Applies to structural and non-structural welds

21.

Non-Destructive Examination NF-5360 InvokesSection V, Applies to Code welds only

22.

NDE Personnel Certification NF-5522 NF-5523 NF-5530 Applies to Code welds only All references to the ASME Code refer to applicable sections of the 2007 edition. to Holtec Letter 5018109 Page 125 of 130

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 80°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 and EXTENDED CONFIGURATION OVERPACK. A Sites yearly average ambient temperature may be used for site-specific analysis.

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 a free-standing OVERPACK, the resultant horizontal acceleration (vectorial sum of two horizontal Zero Period Accelerations (ZPAs) at a three-dimensional seismic site), aH, and vertical ZPA, aV, on the top surface of the ISFSI pad, expressed as fractions of a, shall satisfy the following inequalities:

aH f (1 - aV); and aH r (1 - aV) / h where f is the Coulomb friction coefficient for the cask/ISFSI pad interface, r is the radius of the cask, and h is the height of the cask center-of-gravity above the ISFSI pad surface. 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, aH and aV may be the coincident values of the instantaneous net horizontal and vertical accelerations. If instantaneous accelerations are used, the inequalities 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. to Holtec Letter 5018109 Page 126 of 130

b. For a free-standing OVERPACK 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 excessive sliding such that impact between casks could occur. Any impact between casks should be considered an accident for which the maximum total deflection, d, in the active fuel region of the basket panels shall be limited by the following inequality: d 0.005 l, where I is the basket cell inside dimension.

c.

For those ISFSI sites with design basis seismic acceleration values that may overturn or cause excessive sliding of free-standing casks, the anchored OVERPACK shall be utilized. Each OVERPACK shall be anchored with studs and compatible nuts of material suitable for the expected ISFSI environment. 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.

d. TFor storage in the HI-STORM FW EXTENDED CONFIGURATION is an anchored system and the Design Basis Earthquake is a Reg.

Guide 1.60 earthquake with the horizontal ZPA (zero period acceleration) scaled to 0.5g, and the vertical ZPA scaled to 0.35g.

Sites not bounded by these values may design a site specific anchorage configuration using the methodology described in 3.II.4.4 of the HI-STORM FW FSAR.

4.

The maximum permitted depth of submergence under water shall not exceed 125 feet.

5.

The maximum permissible velocity of floodwater, V, for a flood of height, h, shall be the lesser of V1 or V2, where:

V1 = (1.876 W*)1/2 / h V2 = (1.876 f W*/ D h)1/2 and W* is the apparent (buoyant weight) of the loaded overpack (in pounds force), D is the diameter of the overpack (in feet), and f is the interface coefficient of friction between the ISFSI pad and the overpack, as used in step 3.a above. Use the height of the overpack, H, if h>H.

6.

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. to Holtec Letter 5018109 Page 127 of 130

7.

a.

For storage in a free-standing OVERPACK, the user shall demonstrate that the ISFSI pad parameters used in the non-mechanistic tipover analysis are bounding for the site or a site specific non-mechanistic tipover analysis shall be performed using the dynamic model described in FSAR Section 3.4. The maximum total deflection, d, in the active fuel region of the basket panels shall be limited by the following inequality: d 0.005 l, where l is basket cell inside dimension.

b.

For storage in an anchored OVERPACK, a tipover event is not credible. However, the ISFSI pad shall be designed to meet the embedment requirements of the anchored design.

8.

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.

9.

LOADING OPERATIONS, TRANSPORT OPERATIONS, and UNLOADING OPERATIONS shall only be conducted with working area ambient temperatures 0o F.

10.

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.

11.

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.

12.

The entire haul route shall be evaluated to ensure that the route can support the weight of the loaded system and its conveyance.

13.

The loaded system and its conveyance shall be evaluated to ensure under the site specific Design Basis Earthquake the system does not tipover or slide off the haul route.

14.

The HI-STORM FW/HI-TRAC VW stack which occurs during MPC TRANSFER shall be evaluated to ensure under the site specific Design Basis Earthquake the system does not tipover. A probabilistic risk to Holtec Letter 5018109 Page 128 of 130

assessment cannot be used to rule out the occurrence of the earthquake during MPC TRANSFER.

(continued) to Holtec Letter 5018109 Page 129 of 130

3.0 DESIGN FEATURES (continued) 3.5 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.

to Holtec Letter 5018109 Page 130 of 130

ML24109A252

Text

2.7 Notes

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