Text

Application for Amendment 4 to NUHOMS Eos Certificate of Compliance No. 1042, Revision 5 (Docket 72-1042, CAC No. 001028, EPID: L-2022-LLA-0017) - Supplemental Responses to Request for Additional Information
	ML25043A122
Person / Time
Site:	07201042
Issue date:	02/12/2025
From:	Narayanan P; Orano TN Americas
To:	; Office of Nuclear Material Safety and Safeguards, Document Control Desk
Shared Package
ML25043A121	List: ML25043A122;
References
	E-64088, CAC 001028, EPID L-2022-LLA-0017
	Download: ML25043A122 (1)
	v • d • e

Columbia Office 7160 Riverwood Drive Columbia, MD 21046 Tel: (410) 910-6900

@Orano_USA Enclosures transmitted herein contain SUNSI. When separated from enclosures, this transmittal document is decontrolled.

February 12, 2025 E-64088 U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Application for Amendment 4 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 5 (Docket 72-1042, CAC No.

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

References:

[1] E-63571, dated November 6, 2024, Application for Amendment 4 to NUHOMS EOS Certificate of Compliance No. 1042, Revision 4 (Docket 72-1042, CAC No. 001028, EPID: L-2022-LLA-0017) -

Revised Response to Request for Additional Information This submittal is a supplement to Reference [1] and provides clarification responses to Request for Additional Information (RAI) 8-3, as well as responses to related structural clarifications. As a follow-up to Reference [1], the NRC and TN Americas LLC (TN) held a clarification call on November 26, 2024, for the purpose of discussing supplemental responses to RAI 8-3 (see ADAMS ML24332A047). An additional clarification call between the NRC and TN was held on January 30, 2025 to discuss additional supplemental questions from NRC (see ADAMS ML25042A034), which are also addressed in this submittal. provides a proprietary version of the aforementioned RAI supplemental responses. Each RAI clarification response has a section stating the impact of the response on the Updated Final Safety Analysis Report (UFSAR) or Technical Specifications (TS), indicating which sections, tables, or figures have been changed. provides a public version of these responses. provides a complete revision to the TS, denoted as Revision 5 with changes indicated by italicized text and revision bars. The changes are annotated with gray shading and an indication of the revised RAI or clarification item associated with the changes. provides a proprietary version of the Amendment 4, Revision 5 changed UFSAR pages. The pages include a footer on each changed or new page, annotated as 72-1042 Amendment 4, Revision 5, February 2025 with changes indicated by

E-64088 Document Control Desk Page 2 of 2 italicized text and revision bars. The changes associated with the RAI clarification response are annotated with gray shading and an indication of the RAI associated with the changes. provides a public version of Enclosure 5. provides supporting calculations relating to the RAI supplemental responses. Since contains entirely proprietary information, no public version is provided.

Lastly, Enclosure 8 provides a change to a TS note with its corresponding justification for the change. This change is not associated with the specific RAI clarification responses.

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

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

We are prepared to meet with the staff to resolve any questions the staff might have. Should the NRC staff require additional information to support review of this application, please do not hesitate to contact Mr. Doug Yates at 434-832-3101, or by email at douglas.yates@orano.group.

Sincerely, Prakash Narayanan Chief Technical Officer cc:

Chris Jacobs (NRC), Senior Project Manager, Storage and Transportation Licensing Branch, Division of Fuel Management

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390

2. RAIs and Responses (Proprietary Version)

3. RAIs and Responses (Public Version)

4. Proposed Technical Specifications, CoC 1042 Amendment 4, Revision 5

5. CoC 1042 Amendment 4, Revision 5 UFSAR Changed Pages (Proprietary Version)

6. CoC 1042 Amendment 4, Revision 5 UFSAR Changed Pages (Public Version)

7. CoC 1042 Amendment 4, Revision 5, Supporting Calculations (Proprietary)

8. Changes Not Related to Specific RAIs to E-64088 Page 1 of 1 AFFIDAVIT PURSUANT TO 10 CFR 2.390 State of Maryland:

County of HOWARD:

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

The information for which proprietary treatment is sought is listed below:

- RAIs and Responses (Proprietary)

- UFSAR Changed Pages (Proprietary)

- Supporting Calculations (Proprietary)

This document has been appropriately designated as proprietary.

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

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

1) The information sought to be withheld from public disclosure involves portions of certain RAI responses, portions of the UFSAR, and supporting calculations, all related to the design of the NUHOMS EOS System, which are owned and have been held in confidence by TN Americas LLC, or were provided in confidence to TN Americas LLC and have been held in confidence.

2) The information is of a type customarily held in confidence by TN Americas LLC, and not customarily disclosed to the public. TN Americas LLC has a rational basis for determining the types of information customarily held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position of TN Americas LLC, because the information consists of descriptions of the design and analysis of dry spent fuel storage systems, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their product to better compete with TN Americas LLC, take marketing or other actions to improve their products position or impair the position of TN Americas LLCs product, and avoid developing similar data and analyses in support of their processes, methods, or apparatus.

I declare that the statements set forth in this affidavit are true and correct to the best of my knowledge, information, and belief. I declare under penalty of perjury that the foregoing is true and correct.

Executed on February 7th, 2025 Prakash Narayanan Chief Technical Officer, TN Americas LLC to E-64088 RAIs and Responses (Proprietary Version)

Withheld Pursuant to 10 CFR 2.390

RAIs and Responses - Public to E-64088 Page 1 of 15 Materials RAI Clarifications:

RAI 8-3:

Provide the following information for the UFSAR Tables on the material properties:

1. Correct the material density in the UFSAR Tables:

8-37. ASTM A-572 Grade 60 8-38. ASTM A29 Grade 1010 through 1020 8-39. ASTM A706 Grade 60 8-40. ASTM A449 Type 1, <1 in. dia.

8-41. ASTM A449 Type 1, diameters > 1.0 in. to 1 1/2 in 8-42. Material Properties, ASTM A-572 Gr. 50 8-43. Material Properties, SA-572 Gr. 65 - Applicable to EOS-HSM-SC Only These tables list density units of lb/ft3 but the density values listed appears to be in lb/in3. For reference 0.28 lb/in3 = 484 lb/ft3.

2. Provide the material specification, elastic modulus, yield strength, tensile strength, and source for the tensile and yield values in UFSAR Table 8-38. This table identifies the material as ASTM A29 Grade 1010 through 1020. The staff notes that ASTM A29, Specification for General Requirements for Steel Bars, Carbon and Alloy, Hot-Wrought, calls out a number of ASTM specifications. ASTM A29 is included in ASME Section II Part A but the mechanical properties are not listed in ASME Section II Part D Table U and Table Y-

1. ASTM grades identified in ASTM A29 that are incorporated into ASME Section II that are included in Part D Table U and Table Y-1 do not match the material grade or the properties identified in UFSAR Table 8-38.

3. Provide the material specification, yield strength, tensile strength, and source for the tensile and yield strength values in UFSAR Table 8-39. This table identifies the material as ASTM A706 Grade 60, Standard Specification for Deformed and Plain Low-Alloy Steel Bars for Concrete Reinforcement, that is not listed in ASME Section II Part D. The staff note that the footnotes to Table 8-39 Identity the source of information as ASME Section II Part D tables, but ASME Section II, Part D, Table U or Table Y-1 does not include material property data for any grade of this material.

4. Clarify the intended application of the material properties for ASTM A706 Grade 60 in Tables 8-24, Material Properties, ASTM A615 Grade 60 and ASTM A706 Grade 60 Reinforcing Steel, and Table 8-39, Material Properties, ASTM A706 Gr. 60. The staff notes that both tables include material properties for ASTM A706 Grade 60, but the material property values and sources referenced for these values are different.

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

RAIs and Responses - Public to E-64088 Page 2 of 15 Revised Response to RAI 8-3:

Temperature dependent material properties in UFSAR Tables 8-37 through 8-41 have been revised to reflect those available in the 2023 ASME Boiler and Pressure Vessel Code (BPVC),

Section II, Part D (UFSAR reference [8-63]), as recommended in Section NB3.3 of N690-18.

Analyses affected by these material property changes are documented in the responses to RAIs 4-1, 4-2, 4-8, 4-12, and 4-18. Calculations EOS01-0262, -0263, -0265, -0320, and -0330 (included in Enclosure 10 of this submittal) have been revised to consider the updated material properties, and affected results are updated accordingly in the relevant RAI responses. In addition to the changes discussed in the above mentioned RAIs, UFSAR Sections 3.9.8.10.4 and 3.9.8.10.5, and UFSAR Figures 3.9.8-5 through 3.9.8-10 have been revised to reflect the updated analyses considering material properties from the 2023 ASME BPVC. The appropriate references to the source of the material property values given for UFSAR Tables 8-37 through 8-41 have been added to Section 8.7 of the UFSAR. Furthermore, each of the tables listed in this RAI have been updated to include notes and callouts to the necessary references.

Revisions made to UFSAR Tables 8-14a and 8-15 in earlier revisions of this Amendment submittal are reverted, except that missing material property reference callouts were added to UFSAR Table 8-14a. Material properties for the EOS-HSM-SC FPS DSC support structure are added as UFSAR Table 8-43, so Tables 8-14a and 8-15 are not relevant to this amendment submittal. Material properties in UFSAR Tables 8-14a and 8-15 remain applicable to the evaluations of the EOS-HSM-RC FPS DSC support structure, and I-beam style DSC support structure, respectively, which are designed and licensed prior to the release of the 2023 ASME BPVC.

Material Properties tables which reference the Mark Fintel Handbook of Concrete Engineering, Second Edition (UFSAR Reference [8-12]) have had their notes revised to more accurately state that the highest rate of reduction (greatest decrease as function of temperature) is considered for yield strength, and that the rate of reduction for tensile strength is based on that given for high strength alloy bars in Figure 7-6 of UFSAR Reference [8-12]. The lowest qualifier is removed for notes pertaining to elastic modulus and thermal expansion rates of reduction, as only a single reduction curve is provided for these properties in the referenced figures. This change is purely editorial and does not affect any analyses. The tables with revised notes are UFSAR Tables 8-14a and 8-15.

RAIs and Responses - Public to E-64088 Page 3 of 15 The title for Reference 8-3 has been edited for minor inconsistencies.

Impact:

UFSAR Sections 3.9.8.1, 3.9.8.10.2, 3.9.8.10.4, 3.9.8.10.5, 8.2.2.3, and 8.7, Tables 8-14a, 8-15, 8-37, 8-38, 8-39, 8-40, and 8-41, and Drawing EOS01-3300-SAR have been revised as described in the response.

UFSAR Tables 3.9.8-11, 3.9.8-12, 3.9.8-13, and 8-43 have been added as described in the response.

Figures 3.9.8-5 through 3.9.8-10 have been revised as described in the response.

Supplemental Response to RAI 8-3:

Item 1:

UFSAR Tables 8-37 through 8-43 have been revised to show the correct units (i.e., lb/in3) for the material density.

Item 2:

UFSAR Table 8-38 has been revised to show that the mechanical properties for the EOS-HSM-SC studs are based on Type B studs as per Table 7.1 of AWS D1.1 (added to UFSAR Section 8.7 as Reference [8-64]). The mechanical properties at elevated temperatures are based on rates of reduction found in UFSAR Section 8.7, Reference [8-12].

Item 3:

UFSAR Table 8-39 has been revised to show that the mechanical properties for the EOS-HSM-SC ties at room temperature are based on UFSAR Section 8.7 Reference [8-60]

and, at elevated temperatures, are based on rates of reduction found in UFSAR Section 8.7, Reference [8-12].

Item 4:

UFSAR Tables 8-24 and 8-39 have been revised to clarify the applicability of the properties of each table.

Information in Addition to the Responses to Items 1 through 4 Above:

Appendix 4 of AISC 360-16, and particularly Tables A-4.2.1 and Tables A-4.2.3, were reviewed for properties of steel components at elevated temperatures.

The ratios of yield and ultimate strength for ASTM A29 and A706, based on the reduction factors from Appendix A of AISC 360-16, are shown in the following table.

RAIs and Responses - Public to E-64088 Page 4 of 15 From UFSAR Table A-4.2.1 (AISC 360-16)

Table A-4.2.3 (AISC 360-16)

Temp Sy Su ky ku Sy Su ku Su

(°F)

(ksi)

From Table 8-38 ASTM A29 70 51.00 65.00 1.00 1.00 51.00 65.00 1.00 65.00 100 49.50 65.00 1.00 1.00 51.00 65.00 0.99 64.55 200 46.90 65.00 1.00 1.00 51.00 65.00 0.97 63.05 300 44.90 65.00 1.00 1.00 51.00 65.00 0.95 61.75 400 43.40 65.00 1.00 1.00 51.00 65.00 0.93 60.45 500 42.30 65.00 1.00 1.00 51.00 65.00 0.91 58.83 600 41.80 62.40 1.00 1.00 51.00 65.00 0.88 57.20 From Table 8-39 ASTM A706 Gr.

60 70 60.00 80.00 1.00 1.00 60.00 80.00 1.00 80.00 100 58.20 80.00 1.00 1.00 60.00 80.00 0.99 79.45 200 55.20 80.00 1.00 1.00 60.00 80.00 0.97 77.60 300 52.80 80.00 1.00 1.00 60.00 80.00 0.95 76.00 400 51.00 80.00 1.00 1.00 60.00 80.00 0.93 74.40 500 49.80 80.00 1.00 1.00 60.00 80.00 0.91 72.40 600 49.20 76.80 1.00 1.00 60.00 80.00 0.88 70.40 AISC 360-16 Appendix 4 Table A-4.2.1 provides factors and which represent the ratios of the yield and ultimate strengths at an elevated temperature relative to their respective values at room temperature. This table shows no reduction in the yield and ultimate strength up to a temperature of 750 °F (i.e., = = 1).

AISC 360-16 Appendix 4 Table A-4.2.3 provides reduction factors for the tensile and shear strength of bolts. The tensile and shear strength of bolts is based only on the ultimate strength of the material as per the commentary for Chapter J of the AISC 360-16. Therefore, these reduction factors may substitute the reduction factors for ultimate strength only. Furthermore, this table applies specifically to Group A and Group B bolts whose specifications are shown below. These materials are not used for the ties and studs of the EOS-HSM-SC and therefore these reduction factors are not applicable.

Group AASTM F3125/F3125M Grades A325, A325M, F1852 and ASTM A354 Grade BC Group BASTM F3125/F3125M Grades A490, A490M, F2280 and ASTM A354 Grade BD The reduction factors in AISC 360-16 Appendix 4 Table A-4.2.1 provide higher strengths at temperature relative to the reduction factors used in UFSAR Tables 8-38 and 8-39 based on UFSAR Reference [8-12].

Hence, the use of UFSAR Reference [8-12] for yield and ultimate strengths at elevated temperatures is conservative and the values in UFSAR Tables 8-38 and 8-39 remain unchanged.

RAIs and Responses - Public to E-64088 Page 5 of 15 The yield and ultimate strengths at elevated temperatures based on AISC 360-16 Table A-4.2.1 will be considered to justify potential non-conformances and future aging management.

Impact:

UFSAR Section 8.7, and Tables 8-24 and 8-37 through 8-43 have been revised as described in the response.

RAIs and Responses - Public to E-64088 Page 6 of 15 Supplemental Responses for Structural Clarifications:

Clarification S-1:

Since the design of the Flat Plate Support (FPS) structure for the EOS-HSM-SC has now changed as a result of this amendment, please submit the design calculations that support the values reported in UFSAR Tables 3.9.8-11 to 3.9.8-13.

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

Response to Clarification S-1:

The requested design calculation, EOS01-0269, Revision 1, supporting the EOS-HSM-SC Flat Plate Support (FPS) change, has been included in Enclosure 7.

Impact:

No change as a result of this clarification.

RAIs and Responses - Public to E-64088 Page 7 of 15 Clarification S-2:

For the revision of the FPS structure, verify that adding Note 22 to revision 0E of Drawing EOS01-3300-SAR (for the EOS-HSM-SC) to increase the thickness of stiffener plates 113 and 114 shown on Drawing EOS01-3000-SAR (for FPS structure) will be sufficient to invoke this change in the fabrication of the FPS rails, when no revision is made to Drawing EOS01-3000-SAR.

This information is needed to satisfy the requirements of 10 CFR Part 72.150, 72.236(b) and (l).

Response to Clarification S-2:

No response required based on November 26, 2024 clarification call.

Impact:

No change as a result of this clarification.

RAIs and Responses - Public to E-64088 Page 8 of 15 Clarification S-3:

In UFSAR section 3.9.8.10.2, a 12 x 1 plate is mentioned in a list of FPS items designed per the AISC 360 Code. Provide an item number(s) from drawing EOS01-3000-SAR to help identify the function of this item for staff.

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

Response to Clarification S-3:

No response required based on November 26, 2024 clarification call.

Impact:

No change as a result of this clarification.

RAIs and Responses - Public to E-64088 Page 9 of 15 Clarification S-4:

In UFSAR sections 2.1.2, 2.4.2.2, and 8.2.1.3 a change was made from the previous version to say that the EOS-HSM-SC is designed per AISC N690 Code but constructed per AISC 360. A statement was added that important-to-safety welding is performed per AWS D1.1 Code.

Explain why these two changes were made.

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

Response to Clarification S-4:

The code of construction for the steel-plate composite horizontal storage module (EOS-HSM-SC) has been revised to clarify that the steel components are to be constructed in accordance with the provisions of AISC N690 with alternatives described in Section 4.4.4 of the Technical Specifications (TS). Previously, while the code of design for the EOS-HSM-SC was specified as AISC N690, the code of construction for the steel components was limited to requirements outlined in AISC 360, and did not include any of the additional provisions specified in Section NM and Section NN of the AISC N690 code. This was because, at the time, those sections of the code were assumed to not be applicable to the EOS-HSM-SC system. However, after review of these appendices, it was determined that several of the requirements outlined in those sections should be applicable to the EOS-HSM-SC and should be captured in the code of construction provided in the UFSAR. But there are also several requirements in these sections that may be too stringent for a Quality Category B system like an HSM and some that are not feasible given the design of the EOS-HSM-SC. Those alternatives to Sections NM and NN of the AISC N690 code have been added to Section 4.4.4 of the TS and are summarized below.

Section NM addresses the requirements for fabrication and erection of the safety-related steel structures for nuclear facilities. Alternatives and exceptions are provided for several requirements outlined in this section, such as those for material traceability and commercial grade dedication, which are not required for important to safety (ITS) Category B items, as per Chapter 14 of the UFSAR. Additionally, there are dimensional requirements that are not practical to achieve given the specific design of the EOS-HSM-SC system. For example, there is a requirement (NM2.7.(d).(1)) in which the maximum tolerance for perpendicular distance between the faceplates at tie locations be tsc/200, rounded up to the nearest 1/16 (where tsc is the thickness of the composite wall member). This means that for portions of the EOS-HSM-SC side walls (thickness of 12), the tolerance would be plus or minus 1/16, which is not seen as practically achievable. However, since these formulas were developed for composite walls of at least 24 in thickness, an exception is provided stating that any wall less than 24 shall be required to meet a tolerance at tie locations of plus or minus 1/8. For a full list of the alternatives taken to Section NM, refer to Section 4.4.4 of the TS.

Section NN addresses requirements for quality control, quality assurance, and nondestructive evaluations for safety-related structural steel systems and steel elements of composite members for nuclear facilities. Since the EOS-HSM-SC is not a safety-related item, as specified in the code, Section NN and its requirements do not apply and are replaced by the requirements set forth in AISC 360-16. However, the one exception to this is the nondestructive examination of the welded joints described in Section NN5.5, which shall apply to the EOS-HSM-SC.

Additionally, wording in UFSAR Sections 2.1.2, 8.2.1.3, 8.7, 10.1.3.2, and Drawing EOS01-3300-SAR, along with Section 4.4.1 of the TS have been updated to reflect the correct code of construction as described above.

RAIs and Responses - Public to E-64088 Page 10 of 15 Furthermore, a code alternative is being added to TS Section 4.4.4 for ACI 349 (Appendix E, Section E.4) for the concrete temperature limit. This is the same alternative that was added and approved for Amendments 1, 2, and 3, which is now being incorporated into Amendment 4.

Impact:

UFSAR Sections 2.1.2, 8.2.1.3, 8.7, and 10.1.3.2 have been revised as described in the response.

UFSAR Drawing EOS01-3300-SAR, Revision 0E has been revised as described in the response.

TS Sections 4.4.1 and 4.4.4 have been revised as described in the response.

RAIs and Responses - Public to E-64088 Page 11 of 15 Structural Clarification S-4-1:

In response to the NRC clarification question S-4, TN Americas LLC (TN) provided pre-submittal draft information for NRC consideration, via email on January 6, 2025, the Code Exception Table for the AISC N690 (see following pages), which TN intends to include in the Technical Specification. The NRC staff has several clarification questions for TN on the proposed AISC N690 Code exceptions:

1. For AISC N690 Code requirement NM2.7(2), TN takes exception to a paragraph addressing dimensional tolerances of SC modules after concrete curing. The Code requirement first imposes ACI 349 or ACI 117 concrete construction tolerances for cured concrete. It then imposes an additional limitation on SC faceplate waviness after concrete curing. TNs initial statements in their justification for taking the Code exception is that units of HSMs are typically poured in groups and therefore this requirement cannot be verified. Due to the construction process of the EOS-HSM-SC, most walls are inaccessible after pouring. The NRC requests responses to the following questions on TNs justifications:

a. Clarify whether these statements are taking exception to the ACI 349/117 tolerances, or the N690 waviness limit, or both. If taking exception to all Code-imposed tolerances, what alternative tolerance/limit is TN proposing? If TN is not proposing an alternative, what requirements are preventing the structure from being egregiously out-of-tolerance such that it impacts structural performance?

b. Explain why a mass production approach to SC component fabrication precludes the imposition of construction tolerances, and why most walls are inaccessible after pouring.

c. Provide a more complete technical justification explaining why excessive waviness does not have a significant structural impact. TNs justification simply states, as suggested in the commentary for N690-18.

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

Response to Structural Clarification S-4-1 Item a:

TN does not take exception to dimensional tolerances indicated in ACI 349/117 and the faceplate waviness requirement imposed by Eq. NM2-1 of AISC N690-18 but from the inspection of these requirements due to inaccessibility of the walls after concrete pouring. The Code Alternatives table in Section 4.0 of Technical Specifications (TS) has been updated to indicate this justification.

RAIs and Responses - Public to E-64088 Page 12 of 15 ANSYS finite element models are prepared to demonstrate that the waviness of the EOS-HSM-SC faceplates meet the requirements of Eq. NM2-1 of AISC N690. [

]

The maximum deflection from the FEM is extracted and compared to the waviness requirement of Equation NM2-1 of AISC N690-18. The table below shows the components with the bounding results. The results demonstrate that the deflection due to the hydrostatic pressure of wet concrete is much less than the allowable waviness. Therefore, the EOS-HSM-SC components are within the tolerance imposed by Equation NM2-1 of AISC N690-18 and their structural performance is not affected. Calculation ST-20001 Revision 0, which contains details on the analyses of all components, is included in Enclosure 7.

TN is planning to perform a full-scale demonstration of the EOS-HSM-SC. This demonstration will verify the analytical results.

Item b:

TN envisions two methods for the fabrication and installation of the EOS-HSM-SC:

1. Method 1: Fabricate Shells Deliver to Site Pour Concrete

a. The fabrication and inspection of the steel shells of the EOS-HSM-SC is performed at a facility away from the independent spent fuel storage installation (ISFSI) pad.

b. The steel shells are shipped to the ISFSI pad and installed to form the horizontal storage module (HSM) array.

c. The steel shells of the bottom segments of the HSMs are placed first. Concrete is then poured, in a controlled way, in each bottom segment.

d. Then, the steel shells of the top segments of the HSMs are installed. Concrete is then poured, in a controlled way, in each top segment.

e. The steel shells of the roofs are then placed on top of the assembled HSM bases.

Concrete is then poured, in a controlled way, in each roof.

RAIs and Responses - Public to E-64088 Page 13 of 15

2. Method 2: Fabricate Shells Pour Concrete Deliver to Site

a. The fabrication and inspection of the steel shells of the EOS-HSM-SC is performed at a facility away from the ISFSI pad.

b. Concrete is poured in each HSM segment (i.e., bottom, top, and roof) off-site.

c. The steel-composite (SC) HSM segments are shipped to the ISFSI pad and installed to form the HSM array.

d. The bottom segments of the HSMs are placed first.

e. Then top segments of the HSMs are installed.

f.

The roofs are then placed on top of the assembled HSM bases.

g. The sequence of installation can also be performed per HSM, i.e., bottom segment of the first HSM is installed, then its top segment, then its roof; the bottom segment of the adjacent HSM is installed, then its top segment, then its roof, etc.

Method 1 is the preferred approach by TN due to cost considerations. In this method, the HSMs are so closely spaced that the walls are inaccessible for inspection after concrete pouring.

Item c:

As per the response in S-4-1a, the components of the EOS-HSM-SC meet the faceplate waviness criterion by a large margin and the structural performance of the components is not affected. Therefore, the sentence As suggested in the commentary for N690-18, waviness does not have a large effect on the structural integrity of the steel-composites walls will be removed from the Justification and Compensatory Measures column of TS Code Exceptions.

Impact:

The TS have been revised as described in the response to Clarification S-4.

RAIs and Responses - Public to E-64088 Page 14 of 15 Clarification S-5:

Assumption 5 of calc EOS01-0262 R2 says that the reductions in temperature-dependent material properties for the A29 headed studs and A706 or A449 tie bars are scaled to those of the A572 Grade 60 materials. Is this statement still true, or are the temperature-dependent properties tabulated in FSAR section 8 now being employed?

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

Response to Clarification S-5:

Assumption 5 of Calculation EOS01-0262 Revision 2 and mention of scaling factors based on A572 Gr. 60 in Section 4.2 of Calculations EOS01-0262 Revision 2 and EOS01-0263 Revision 3 are not applicable and have been removed in the updated revisions of the design calculations.

Impact:

No change as a result of this Clarification.

RAIs and Responses - Public to E-64088 Page 15 of 15 Clarification Ops/QA-1:

1. For AISC N690 Code requirement NM2.15, TN takes exception to a section addressing material identification requirements for meeting the contract documents of procured materials. TN states that the justification as material traceability is not required for ITS Category B items. The staff agrees that traceability is not required for ITS Category B items and materials, however, the Code requirement goes beyond traceability to verification the material received meets the contract documents. Material verification to contract documents at receipt is required for ITS Category B materials.

Clarify whether TN is taking exception to all the requirements in NM2.15 or only the traceability aspects. If it is to all the requirements, provide further justification.

This information is needed to satisfy the requirements of 10 CFR 72.236(b) and 72.154.

Response to Clarification Ops/QA-1:

The proposed code alternative for NM2.15 is only for the material traceability of the EOS-HSM-SC components. This is because horizontal storage modules (HSMs) are not safety-related components as outlined in AISC N690-18, and as per Section 14.2 of the UFSAR, important to safety (ITS) Category B items do not require material traceability. TN is not taking exception to any other aspect of NM2.15, including the material identification requirements. The justification in the proposed code alternatives for Section 4.4.4 of the Technical Specifications (TS) (see Clarification S-4) for NM2.15 has been revised to clarify this.

Impact:

The TS have been revised as described in the response to Clarification S-4.

to E-64088 Proposed Technical Specifications, CoC 1042 Amendment 4, Revision 5

Revision 5 to Amendment 4 Proposed Technical Specifications CoC 1042 APPENDIX A NUHOMS EOS SYSTEM GENERIC TECHNICAL SPECIFICATIONS Amendment 4

TABLE OF CONTENTS (continued)

PAGE EOS System Amendment 4 Proposed Technical Specifications - Revision 5 ii 1.0 Use and Application................................................................................................. 1-1 1.1 Definitions..................................................................................................... 1-1 1.2 Logical Connectors....................................................................................... 1-5 1.3 Completion Times......................................................................................... 1-7 1.4 Frequency................................................................................................... 1-10 2.0 Functional and Operating Limits............................................................................... 2-1 2.1 Fuel to be Stored in the EOS-37PTH DSC................................................... 2-1 2.2 Fuel to be Stored in the EOS-89BTH DSC................................................... 2-5 2.3 Fuel to be stored in the 61BTH Type 2 DSC................................................ 2-8 2.4 Functional and Operating Limits Violations................................................ 2-11 3.0 Limiting Condition for Operation (LCO) and Surveillance Requirement (SR)

Applicability.............................................................................................................. 3-1 3.1 DSC Fuel Integrity........................................................................................ 3-3 3.1.1 Fuel Integrity during Drying............................................................. 3-3 3.1.2 DSC Helium Backfill Pressure......................................................... 3-5 3.1.3 Time Limit for Completion of DSC Transfer.................................... 3-7 3.2 Cask Criticality Control............................................................................... 3-10 3.2.1 Soluble Boron Concentration........................................................ 3-10 3.3 Radiation Protection................................................................................... 3-12 3.3.1 DSC and TRANSFER CASK (TC) Surface Contamination........... 3-12 4.0 Design Features....................................................................................................... 4-1 4.1 Site............................................................................................................... 4-1 4.1.1 Site Location.................................................................................... 4-1 4.2 Storage System Features............................................................................. 4-1 4.2.1 Storage Capacity............................................................................. 4-1 4.2.2 Storage Pad.................................................................................... 4-1 4.3 Canister Criticality Control............................................................................ 4-1 4.3.1 Neutron Absorber Tests.................................................................. 4-2 4.3.2 High Strength Low Alloy Steel for Basket Structure for EOS-37PTH and EOS-89BTH DSCs....................................................... 4-2 4.4 Codes and Standards................................................................................... 4-3 4.4.1 HORIZONTAL STORAGE MODULE (HSM)................................... 4-3 4.4.2 DRY SHIELDED CANISTER (DSC) (EOS-37PTH, EOS-89BTH, and 61BTH Type 2)............................................................ 4-4 4.4.3 TRANSFER CASK.......................................................................... 4-4 4.4.4 Alternatives to Codes and Standards.............................................. 4-4 4.5 Storage Location Design Features............................................................. 4-18 4.5.1 Storage Configuration................................................................... 4-18 4.5.2 Concrete Storage Pad Properties to Limit DSC Gravitational Loadings Due to Postulated Drops................................................ 4-18 4.5.3 Site Specific Parameters and Analyses........................................ 4-18 5.0 Administrative Controls............................................................................................ 5-1 5.1 Programs...................................................................................................... 5-1 5.1.1 Radiological Environmental Monitoring Program............................ 5-1 5.1.2 Radiation Protection Program......................................................... 5-1 5.1.3 HSM Thermal Monitoring Program.................................................. 5-3 5.2 Lifting Controls.............................................................................................. 5-7 5.2.1 TC/DSC Lifting Height and Temperature Limits.............................. 5-7 5.2.2 Cask Drop....................................................................................... 5-7

TABLE OF CONTENTS (continued)

PAGE EOS System Amendment 4 Proposed Technical Specifications - Revision 5 iii 5.3 Concrete Testing.......................................................................................... 5-8 5.4 Hydrogen Gas Monitoring............................................................................. 5-9 5.5 EOS-HSM Wind Deflectors.......................................................................... 5-9 List of Tables Table 1 Fuel Assembly Design Characteristics for the EOS-37PTH DSC........................... T-1 Table 2 Maximum Uranium Loading per FFC for Failed PWR Fuel..................................... T-1 Table 3 Co-60 Equivalent Activity for CCs Stored in the EOS-37PTH DSC........................ T-1 Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH................................ T-2 Table 5 Minimum B-10 Content in the Neutron Poison Plates of the EOS-37PTH DSC..... T-4 Table 6 Fuel Assembly Design Characteristics for the EOS-89BTH DSC........................... T-5 Table 7A PWR Minimum Enrichments as a Function of Burnup............................................ T-6 Table 7B EOS-37PTH DSC Fuel Qualification Table for Storage in the HSM-MX, All Fuel......................................................................................................................... T-7 Table 7C EOS-37PTH DSC Fuel Qualification Table for Storage in the EOS-HSM, All Fuel.................................................................................................................... T-8 Table 8 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the EOS-89BTH DSC............................................................................ T-9 Table 9 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Intact Fuel).................................................. T-10 Table 10 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Damaged Fuel)........................................... T-11 Table 11 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Failed and Damaged Fuel).......................... T-12 Table 12 Maximum Lattice Average Initial Enrichments and Minimum B-10 Areal Density for the 61BTH Type 2 DSC for > 16 Damaged Fuel Assemblies............. T-13 Table 13 BWR Fuel Assembly Design Characteristics for the 61BTH Type 2 DSC............ T-14 Table 14 Maximum Uranium Loading per FFC for Failed 61BTH Type 2 Fuel.................... T-15 Table 15 Deleted.................................................................................................................. T-16 Table 16 Deleted.................................................................................................................. T-17 Table 17 System Configurations for 61BTH Type 2 HLZCs................................................. T-18 Table 18 BWR Minimum Enrichments as a Function of Burnup (EOS-89BTH DSC and 61BTH Type 2 DSC)............................................................................................. T-19 Table 19 61BTH Type 2 DSC Fuel Qualification Table, All Fuel.......................................... T-20 Table 20 61BTH Type 2 DSC Fuel Qualification Table, HLZC 2, 4, 5, 6, 7, and 8, Peripheral Locations.............................................................................................. T-21 Table 21 EOS-89BTH DSC Fuel Qualification Table, All Fuel............................................. T-22 Table 22 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125...... T-23 Table 23 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108...... T-24 Table 24 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125/135 AND Storage in the EOS-HSM.................................................. T-25 Table 25 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108...... T-26

TABLE OF CONTENTS (continued)

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

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

Transferred in the EOS-TC125/135 AND Stored in the EOS-HSM....................... F-31 Figure 13 Damaged and Failed Fuel Configurations for the EOS-37PTH DSC.................... F-32 Figure 14 EOS-37PTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108........................................................................................................... F-33

Definitions 1.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-1 1.0 USE AND APPLICATION 1.1 Definitions

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

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

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

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

CONTROL COMPONENTS (CCs)

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

(continued)

Definitions 1.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-2 1.1 Definitions (continued)

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

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

DRY SHIELDED CANISTER (DSC)

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

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

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

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

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

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

(continued)

Definitions 1.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-3 1.1 Definitions (continued)

HORIZONTAL STORAGE MODULE (HSM)

An HSM is either a reinforced concrete structure (RC) or a steel-plate composite (SC) for storage of a loaded DSC at a spent fuel storage installation.

Where the term HSM is used without distinction, this term shall apply to both the EOS-HSM and HSM-MX.

The term EOS-HSM refers to the base unit for storage of a single DSC as a single piece (EOS-HSM) or as a split base (EOS-HSMS). When used without distinction, the term EOS-HSM shall refer to both the reinforced concrete and the steel-plate composite variants of the HSM.

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

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

The facility within a perimeter fence licensed for storage of spent fuel within HSMs.

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

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

LOW-ENRICHED OUTLIER FUEL (LEOF)

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

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

(continued)

Definitions 1.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-4 1.1 Definitions (continued)

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

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

TRANSFER CASK (TC)

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

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

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

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

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

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

Logical Connectors 1.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-5 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.

EXAMPLES The following examples illustrate the use of logical connectors:

EXAMPLE 1.2-1 ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A.

LCO (Limiting Condition for Operation) 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)

Logical Connectors 1.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-6 1.2 Logical Connectors (continued)

EXAMPLES (continued)

EXAMPLE 1.2-2 ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A.

LCO not met.

A.1 Stop OR A.2 A.2.1 Verify AND A.2.2 A.2.2.1 Reduce OR A.2.2.2 Perform OR A.3 Remove This example represents a more complicated use of logical connectors.

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

Completion Times 1.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-7 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 are not met. Specified with each stated Condition are Required Action(s) and Completion Times(s).

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

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

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

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B.

Required Action 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 (continued)

Completion Times 1.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-8 1.3 Completion Times (continued)

EXAMPLES (continued)

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 .

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

(continued)

Completion Times 1.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-9 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 Perform Action B.1.

AND B.2 Perform 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.

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

Frequency 1.4 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-10 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, Limiting Condition for Operation (LCO) and Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain Notes in the Surveillance column that modify performance requirements.

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

(continued)

Frequency 1.4 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-11 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 stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is determined to not meet the LCO, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

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

(continued)

Frequency 1.4 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-12 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 prior to starting the activity.

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

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

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

(continued)

Frequency 1.4 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 1-13 1.4 Frequency (continued)

EXAMPLES (continued)

EXAMPLE 1.4-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

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

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

Verify EOS DSC vacuum drying pressure is within limit.

Once after verifying the helium leak rate is within limit.

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

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

Fuel to be Stored in the EOS-37PTH DSC 2.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-1 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Fuel to be Stored in the EOS-37PTH DSC PHYSICAL PARAMETERS:

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

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

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

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

FAILED FUEL:

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

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

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

Fuel to be Stored in the EOS-37PTH DSC 2.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-2 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

BLENDED LOW ENRICHED URANIUM (BLEU) FUEL Assemblies:

Number of BLEU FUEL Assemblies per DSC 37 THERMAL PARAMETERS:

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

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

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

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

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

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

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

(continued)

Fuel to be Stored in the EOS-37PTH DSC 2.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-3 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

THERMAL PARAMETERS (continued)

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

FA Bounding eff FA Short eff FA Bounding a

FA Short a

FA Bounding FA Short k

k L

L SF SF q

q

=

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

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

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

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

Fuel to be Stored in the EOS-37PTH DSC 2.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-4 2.1 Fuel to be Stored in the EOS-37PTH DSC (continued)

RADIOLOGICAL PARAMETERS:

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

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

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

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

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

CONTROL COMPONENTS (CCs)

Maximum Co-60 equivalent activity for the CCs.

As specified in Table 3

Fuel to be Stored in the EOS-89BTH DSC 2.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-5 2.0 FUNCTIONAL AND OPERATING LIMITS 2.2 Fuel to be Stored in the EOS-89BTH DSC PHYSICAL PARAMETERS:

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

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

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

Limits for transfer in the EOS-TC125 Per Table 22 Limits for transfer in the EOS-TC108 Per Table 23 BLENDED LOW ENRICHED URANIUM (BLEU) FUEL ASSEMBLIES:

Number of BLEU FUEL Assemblies per DSC 89 (continued)

Fuel to be Stored in the EOS-89BTH DSC 2.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-6 2.2 Fuel to be Stored in the EOS-89BTH DSC (continued)

THERMAL PARAMETERS:

Maximum Heat Load Configuration (MHLC) and Decay Heat Calculations Per Figure 2 for transfer in the EOS-TC108.

Per Figure 11, which specifies maximum allowable heat loads in a six-zone configuration, for transfer in the EOS-TC125.

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

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

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

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

FA Bounding eff FA Short eff FA Bounding a

FA Short a

FA Bounding FA Short k

k L

L SF SF q

q

=

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

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

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

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

Fuel to be Stored in the EOS-89BTH DSC 2.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-7 2.2 Fuel to be Stored in the EOS-89BTH DSC continued)

RADIOLOGICAL PARAMETERS:

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

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

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

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

Fuel to be stored in the 61BTH Type 2 DSC 2.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-8 2.0 FUNCTIONAL AND OPERATING LIMITS 2.3 Fuel to be stored in the 61BTH Type 2 DSC PHYSICAL PARAMETERS:

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

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

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

FAILED FUEL:

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

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

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

Fuel to be stored in the 61BTH Type 2 DSC 2.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-9 Maximum number of irradiated stainless steel rods per RECONSTITUTED FUEL ASSEMBLY Loading restrictions for locations within the basket 10 Inner and peripheral loading locations are defined in Figure 6.

Inner Loading Locations:

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

Peripheral Loading Locations:

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

RECONSTITUTED FUEL ASSEMBLIES with

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

BLENDED LOW ENRICHED URANIUM (BLEU) FUEL Assemblies:

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

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

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

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

(continued)

Fuel to be stored in the 61BTH Type 2 DSC 2.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-10 Minimum Assembly Average Initial Fuel Enrichment As specified in Table 18 as a function of assembly average burnup.

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

Functional and Operating Limits Violations 2.4 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 2-11 2.0 FUNCTIONAL OPERATING LIMITS 2.4 Functional and Operating Limits Violations If any Functional and Operating Limit of 2.1 or 2.2 or 2.3 is violated, the following ACTIONS shall be completed:

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

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

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

LCO and SR Applicability 3.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) AND SURVEILLANCE REQUIREMENT (SR) APPLICABILITY LIMITING CONDITION FOR OPERATION LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

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

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

LCO 3.0.3 Not applicable to a spent fuel storage cask.

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

Exceptions to this Specification are stated in the individual Specifications.

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

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

LCO 3.0.6 Not applicable to a spent fuel storage cask.

LCO 3.0.7 Not applicable to a spent fuel storage cask.

(continued)

LCO and SR Applicability 3.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-2 SURVEILLANCE REQUIREMENTS SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits.

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

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

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 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.

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

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

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-3 3.1 DSC Fuel Integrity 3.1.1 Fuel Integrity during Drying LCO 3.1.1 Medium:

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

Pressure:

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

APPLICABILITY:

During LOADING OPERATIONS but before TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A.

If the required vacuum drying pressure cannot be obtained.

A.1 A.1.1 Confirm that the vacuum drying system is properly installed. Check and repair the vacuum drying system as necessary.

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

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

30 days (continued)

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-4 3.1 DSC Fuel Integrity (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1 Verify that the DSC vacuum drying pressure is less than or equal to 3 Torr (3 mm Hg) absolute for at least 30 minutes following evacuation.

Once per DSC, after an acceptable NDE of the inner top cover plate to DSC shell weld.

(continued)

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-5 3.1 DSC Fuel Integrity (continued) 3.1.2 DSC Helium Backfill Pressure LCO 3.1.2 DSC helium backfill pressure shall be 2.5 +/- 1 psig (stable for 30 minutes after filling) after completion of vacuum drying.

APPLICABILITY:

During LOADING OPERATIONS but before TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME

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

Not applicable until SR 3.1.2 is performed.

A.

The required backfill pressure cannot be obtained or stabilized.

A.1 A.1.1 Maintain helium atmosphere in the DSC cavity.

AND A.1.2 Confirm, check and repair or replace as necessary the vacuum drying system, helium source and pressure gauge.

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

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

OR 30 days (continued)

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-6 3.1 DSC Fuel Integrity (continued)

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

30 days SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify that the DSC helium backfill pressure is 2.5 +/- 1 psig stable for 30 minutes after filling.

Once per DSC, after the completion of SR 3.1.1 requirement.

(continued)

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-7 3.1 DSC Fuel Integrity (continued) 3.1.3 Time Limit for Completion of DSC Transfer LCO 3.1.3 The time to transfer the DSC to the HSM shall be within the limits.

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

DSC MODEL APPLICABLE HLZC TIME LIMITS (HOURS)

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

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

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

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

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

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

1.

The time limit for completion of a DSC transfer is defined as the time elapsed in hours after the initiation of draining of TC/DSC annulus water until the completion of insertion of the DSC into the HSM. For transfer of an EOS-DSC, the time limit for transfer operations is determined based on the EOS-37PTH DSC in EOS-TC125 with the maximum allowable heat load of 50 kW or EOS-89BTH DSC in EOS-TC125 with the maximum allowable heat load of 48.2 kW. If the maximum heat load of a DSC is less than 50 kW for EOS-37PTH DSC or 48.2 kW for the EOS-89BTH DSC, a new time limit can be determined to provide additional time for transfer operations. The calculated time limit shall not be less than the time limit specified in LCO 3.1.3. The calculation should be performed using the same methodology documented in the UFSAR.

2.

HLZC 2, 4-6 (shown in Figures 1B, 1D-1F) time limits apply for the EOS-37PTH DSC transferred in the EOS-TC108 only. HLZC 7-9 time limits apply for storage in the HSM-MX. If transferring the EOS-37PTH with HLZC 2, 4-6, or 11 in the EOS-TC125/135 and storing in the EOS-HSM, the limits for Figure 12 apply. Time limits also apply for HLZC 1, 2, and 4-11 when storing WE 14 x 14.

3. HLZC 2 and 3 (shown in Figure 2) time limits apply for the EOS-89BTH transferred in the EOS-TC108 only. If transferring the EOS-89BTH with HLZC 2 or 3 in the EOS-TC125, the limits for Figure 11 apply.

(continued)

All Indicated Changes are in response Enclosure 8, Item 1

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-8 3.1 DSC Fuel Integrity (continued)

APPLICABILITY:

During LOADING OPERATIONS AND TRANSFER OPERATIONS.

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME

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

Not applicable until SR 3.1.3 is performed.

A.

The required time limit for completion of a DSC transfer not met.

A.1 If the TC is in the cask handling area in a vertical orientation, remove the TC top cover plate and fill the TC/DSC annulus with clean water.

OR 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months A.2 If the TC is in a horizontal orientation on the transfer skid, initiate air circulation in the TC/DSC annulus by starting one of the redundant blowers.

OR 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (1) (2)

A.3 Return the TC to the cask handling area and follow required action A.1 above.

5 hours5.787037e-5 days 0.00139 hours 8.267196e-6 weeks 1.9025e-6 months (1) (2)

1.

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

2.

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

(continued)

DSC Fuel Integrity 3.1 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-9 3.1 DSC Fuel Integrity (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.3 Verify that the time limit for completion of DSC transfer is met.

Once per DSC, after the initiation of draining of TC/DSC annulus water.

Cask Criticality Control 3.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-10 3.2 Cask Criticality Control 3.2.1 Soluble Boron Concentration LCO 3.2.1 The boron concentration of the spent fuel pool water and the water added to the cavity of a loaded EOS-37PTH DSC shall be at least the boron concentration shown in Table 4 for the basket type and fuel enrichment selected.

APPLICABILITY:

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

ACTIONS:

CONDITION REQUIRED ACTION COMPLETION TIME A.

Soluble boron concentration limit not met.

A.1 Suspend loading of fuel assemblies into DSC.

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

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

Immediately

Cask Criticality Control 3.2 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify soluble boron concentration limit in spent fuel pool water and water to be added to the DSC cavity is met using two independent measurements (two samples analyzed by different individuals) for LOADING OPERATIONS.

Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before insertion of the first fuel assembly into the DSC.

AND Every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter while the DSC is in the spent fuel pool or until the fuel has been removed from the DSC.

SR 3.2.1.2 Verify soluble boron concentration limit in spent fuel pool water and water to be added to the DSC cavity is met using two independent measurements (two samples analyzed by different individuals) for UNLOADING OPERATIONS.

Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to flooding DSC during UNLOADING OPERATIONS.

AND Every 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months thereafter while the DSC is in the spent fuel pool or until the fuel has been removed from the DSC.

Radiation Protection 3.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-12 3.3 Radiation Protection 3.3.1 DSC and TRANSFER CASK (TC) Surface Contamination LCO 3.3.1 Removable surface contamination on the outer top 1 foot surface of the DSC AND the exterior surfaces of the TC shall not exceed:

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

b. 220 dpm/100 cm2 from alpha sources.

APPLICABILITY:

During LOADING OPERATIONS ACTIONS:

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

Separate condition entry is allowed for each DSC and TC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

Top 1 foot exterior surface of the DSC removable surface contamination limits not met.

A.1 Decontaminate the DSC to bring the removable contamination to within limits.

Prior to TRANSFER OPERATIONS B.

TC removable surface contamination limits not met.

B.1 Decontaminate the TC to bring the removable contamination to within limits Prior to TRANSFER OPERATIONS

Radiation Protection 3.3 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 3-13 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify that the removable contamination on the top 1 foot exterior surface of the DSC is within limits.

Once, prior to TRANSFER OPERATIONS.

SR 3.3.1.2 Verify by either direct or indirect methods that the removable contamination on the exterior surfaces of the TC is within limits.

Once, prior to TRANSFER OPERATIONS.

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-1 4.0 DESIGN FEATURES The specifications in this section include the design characteristics of special importance to each of the physical barriers and to the maintenance of safety margins in the NUHOMS EOS System design.

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

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

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

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

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

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

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

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

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

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-2 4.0 Design Features (continued)

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

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

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

Borated aluminum (61BTH Type 2 DSC only)

Acceptance Testing (MMC, BORAL, and borated aluminum)

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

Finished panels are subject to visual and dimensional inspection.

Qualification Testing (MMC only)

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

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

The form is with or without an aluminum skin.

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

The boron carbide content is 50% by volume.

The porosity is 3%.

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

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

A.

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

B.

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-3 4.0 Design Features (continued)

C.

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

i.

If quenched and tempered, the tempering temperature shall be at no less than 1000 °F, ii.

Qualified prior to first use by testing at least two lots and demonstrating that the fracture toughness value KJIc 150 ksi in at -40 °F with 95%

confidence.

iii.

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

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

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

a.

Charpy testing per ASTM A370, minimum absorbed energy 25 ft-lb average, 20 ft-lb lowest of three (for sub-size specimens, reduce these criteria per ASTM A370-17 Table 9), or

b.

Dynamic tear testing per ASTM E604 with acceptance criterion minimum 80%

shear fracture appearance.

4.4 Codes and Standards 4.4.1 HORIZONTAL STORAGE MODULE (HSM)

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

06. The steel structure of the steel-plate composite HSM is designed and constructed in accordance with the provisions of ANSI/AISC N690-18. The concrete of the steel-plate composite HSM is designed in accordance with provisions of ACI 349-13 and constructed in accordance with ACI 318-08. Code alternatives are discussed in Technical Specification 4.4.4. Load combinations specified in ANSI 57.9-1984, Section 6.17.3.1 are used for combining normal operating, off-normal, and accident loads for the HSM.

(continued)

All Indicated Changes are in response to Clarification S-4

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-4 4.0 Design Features (continued) 4.4.2 DRY SHIELDED CANISTER (DSC) (EOS-37PTH, EOS-89BTH, and 61BTH Type

2)

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

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

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-5 4.0 Design Features (continued)

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

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

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

NB-4121 Material Certification by Certificate Holder NB-2300 Fracture toughness requirements for material Type 2205 and UNS S31803 duplex stainless steels are tested by Charpy V-notch only per NB-2300. Drop weight tests are not required. Impact testing is not required for the vent port plug.

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

NB-2531 and NB-2541 Vent port plug UT and liquid penetrant testing (PT)

This plug may be made from plate or bar. Due to its small area, it has no structural function. It is leak tested along with the inner top cover plate after welding. Therefore, neither UT nor PT are required.

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-6 4.0 Design Features (continued)

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

REFERENCE ASME CODE SECTION/ARTICLE CODE REQUIREMENT JUSTIFICATION AND COMPENSATORY MEASURES NB-4243 and NB-5230 Category C weld joints in vessels and similar weld joints in other components shall be full penetration joints.

These welds shall be examined by UT or radiographic testing (RT) and either PT or magnetic particle testing (MT).

The shell to the outer top cover plate (OTCP) weld, the shell to the inner top cover weld, and the drain port cover and vent port plug welds are all partial penetration welds. The cover-to-shell welds are designed to meet the guidance provided in NUREG-1536, Revision 1 for the stress reduction factor.

Nondestructive examination (NDE) is done by qualified personnel, in accordance with Section V and the acceptance standards of Section III, Subsection NB-5000, except as noted for OTCP weld option 2 ultrasonic examination.

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

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

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

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

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

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

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

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

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-7 4.0 Design Features (continued)

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

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

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

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

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

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

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

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

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-8 4.0 Design Features (continued)

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

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-9 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Confinement Boundary REFERENCE ASME CODE SECTION/

ARTICLE CODE REQUIREMENT ALTERNATIVES, JUSTIFICATION & COMPENSATORY MEASURES NCA All Not compliant with NCA. Quality Assurance is provided according to 10 CFR Part 72 Subpart G in lieu of NCA-4000.

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

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

NB-1100 Requirements for Code Stamping of Components, Code reports and certificates, etc.

Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp, or to be ASME Certified.

NB-1132 Attachments with a pressure retaining function, including stiffeners, shall be considered part of the component.

Bottom shield plug and outer bottom cover plate are outside code jurisdiction; these components together are much larger than required to provide stiffening for the inner bottom cover plate; the weld that retains the outer bottom cover plate and with it the bottom shield plug is subject to root and final PT examination.

NB-2130 Material must be supplied by ASME approved material suppliers.

Material is certified to meet all ASME Code criteria but is not eligible for certification or Code Stamping if a non-ASME fabricator is used.

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

NB-4121 Material Certification by Certificate Holder NB-4243 and NB-5230 Category C weld joints in vessels and similar weld joints in other components shall be full penetration joints. These welds shall be examined by UT or RT and either PT or MT.

The shell to the outer top cover weld, the shell to the inner top cover weld, the siphon and vent cover plate welds, and the vent and siphon block welds to the shell are all partial penetration welds.

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-10 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Confinement Boundary REFERENCE ASME CODE SECTION/

ARTICLE CODE REQUIREMENT ALTERNATIVES, JUSTIFICATION & COMPENSATORY MEASURES NB-6100 and 6200 All completed pressure retaining systems shall be pressure tested.

The 61BTH Type 2 DSC is not a complete or installed pressure vessel until the top closure is welded following placement of Fuel Assemblies with the DSC. Due to the inaccessibility of the shell and lower end closure welds following fuel loading and top closure welding, as an alternative, the pressure testing of the DSC is performed in two parts. The DSC shell and shell bottom (including all longitudinal and circumferential welds) is pressure tested and examined at the fabrication facility.

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

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

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

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

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

NB-8000 Requirements for nameplates, stamping &

reports per NCA-8000.

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

NB-5520 NDE personnel must be qualified to a specific edition of SNT-TC-1A.

Permit use of the Recommended Practice SNT-TC-1A to include up to the most recent 2011 edition.

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-11 4.0 Design Features (continued) 61BTH Type 2 DSC ASME Code Alternatives for the Basket REFERENCE ASME CODE SECTION/

ARTICLE CODE REQUIREMENT ALTERNATIVES, JUSTIFICATION & COMPENSATORY MEASURES NCA All Not compliant with NCA. Quality Assurance is provided according to 10 CFR Part 72 Subpart G in lieu of NCA-4000.

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

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

NG/NF-1100 Requirements for Code Stamping of Components, Code reports and certificates, etc.

Code Stamping is not required. As Code Stamping is not required, the fabricator is not required to hold an ASME N or NPT stamp, or to be ASME Certified.

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

NG/NF-2130 Material must be supplied by ASME approved material suppliers.

Material is certified to meet all ASME Code criteria but is not eligible for certification or Code Stamping if a non-ASME fabricator is used.

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

NG/NF-4121 Material Certification by Certificate Holder NG-3352 Table NG-3352-1 lists the permissible welded joints and quality factors.

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

NG/NF-8000 Requirements for nameplates, stamping &

reports per NCA-8000.

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

NG/NF-5520 NDE personnel must be qualified to a specific edition of SNT-TC-1A.

Permit use of the Recommended Practice SNT-TC-1A to include up to the most recent 2011 edition.

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-12 4.0 Design Features (continued)

Code alternatives for the HSM concrete specifications are listed below:

REFERENCE ACI349-06/-13, AS APPLICABLE SECTION/ARTICLE CODE REQUIREMENT ALTERNATIVES, JUSTIFICATION AND COMPENSATORY MEASURES Appendix E, Section E.4-Concrete Temperatures, Paragraph E.4.3 Paragraph E.4.3 requires testing of concrete for temperatures higher than those given in Paragraph E.4.1.

The concrete temperature limit criteria in NUREG-1536, Revision 1, Section 8.4.14.2 is used for normal and off-normal conditions.

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

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

Appendix E, Section E.4-Concrete Temperatures, Paragraph E.4.1 Paragraph E.4.1 specifies that the concrete temperatures for normal operations shall not exceed 150 °F except for local areas such as around penetrations, which are allowed to have increased temperatures not to exceed 200 °F.

The concrete temperature limit criteria in NUREG-1536, Section 8.4.14.2 are used for normal and off-normal conditions.

Blended Cement per ASTM C595 may be used in lieu of Portland Cement Type II.

The cement supplier, as of January 2023, will no longer provide cement in accordance with ASTM C150 because the industry is transitioning to a cement with a smaller carbon footprint that includes 10% limestone.

ACI 349-06 identifies several ASTM specifications for cement that are acceptable per the code requirements. ASTM C150 and ASTM C595 are two of the acceptable cement specifications identified in Section 3.2 of ACI 349-06.

Thermal compatibility tests conducted on concrete mixes using the two cement types show comparable strength results with no signs of degradation due to exposure to elevated temperatures.

(continued)

All Indicated Changes are in response to Clarification S-4

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-13 4.0 Design Features (continued)

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

REFERENCE ANSI/AISC N690 CODE REQUIREMENT JUSTIFICATION AND COMPENSATORY MEASURES NB2 Required load combinations for normal, severe environmental, and extreme environmental and abnormal conditions.

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

N9.1.1.(a)

For exterior SC walls, the minimum value of the section thickness, tsc, shall be 18 inches (450 mm). For interior SC walls, the minimum tsc shall be 12 inches (300 mm).

As presented in Commentary for Section N9.1.1(a) of N690, the minimum section thickness for exterior SC walls is based on Table 1 of NUREG-0800, Revision 3, Section 3.5.3, Revision 3. It requires minimum 16.9-inch thick (430mm) 4-ksi (28 MPa) reinforced concrete (RC) walls to resist a tornado missile.

Conservatively, the SC wall is treated as a RC wall for missile loading. The thinner sections of the door are supported by the front wall of the EOS-HSM-SC during missile impact. Therefore, the door meets the specified minimum thickness value of 18 inches for exterior walls. The minimum thickness for interior walls is based on the maximum reinforcement ratio and minimum faceplate thickness. The specified minimum thickness value of 12 inches is conservatively rounded up from the actual minimum of 10 inches as presented in Commentary for Section N9.1.1(a) of N690. Therefore, the sections of the door and OVC that do not meet the specified thickness value of 12 inches, still meet the 10 inch minimum thickness requirement.

N9.1.1(c)

The reinforcement ratio of SC sections shall have a minimum value of 0.015 and a maximum value of 0.050.

According to AISC Steel Design Guide 32, high reinforcement ratios can potentially result in higher concrete stresses and change the governing in-plane shear limit state from steel faceplate yielding to concrete compression strut failure, which can potentially reduce the strength and ductility of SC walls. The reinforcement ratio for the thin walls of the EOS-HSM-SC minimally (less than 5%) exceeds the ratio of 0.050 and this exceedance facilitates compliance with the faceplate slenderness requirement in Section N9.1.3 of N690-18.

The reinforcement ratio for the top segment of the front wall is marginally less than the minimum reinforcement ratio of 0.015 when the effective thickness of the front wall faceplate is considered. Per Commentary Section N9.1.1(c) of N690, use of a very low reinforcement ratio poses concerns regarding handling strength and stiffness in addition to residual stresses due to fabrication operations and concrete casting.

These concerns are not applicable because the actual thickness is twice as large as the effective thickness.

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-14 4.0 Design Features (continued)

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

REFERENCE ANSI/AISC N690 CODE REQUIREMENT JUSTIFICATION AND COMPENSATORY MEASURES N9.1.1.(d)

The specified minimum yield stress of faceplates, Fy, shall not be less than 50 ksi (350 MPa) nor more than 65 ksi (450 MPa).

The door and OVC steel plates are constructed from ASTM A36. As presented in the Commentary for Section N9.1.1(d) of N690, the minimum yield strength of faceplates is intended to prevent premature yielding due to residual stresses from concrete casting and thermally induced stresses. The door and OVC are free to grow when subjected to thermal loads and require a concrete volume of relatively low height resulting in insignificant pressure on the faceplates during casting as compared to a large EOS-HSM-SC wall. Therefore, stresses due to thermal growth and residual stress from concrete casting will not contribute to premature yielding of the faceplates in these components.

Additionally, the margins for the door thickness to withstand local damage due to missile attack, ductile capacity for missile impact, and structural adequacy for punching shear are sufficiently large. The OVC has no structural safety function. Therefore, a material meeting the properties of ASTM A36 will have sufficient strength for this application.

N9.1.4b(a)

Steel anchors shall be spaced not to exceed the minimum spacing required to develop the yield strength of the faceplates over the development length.

This requirement ensures that sufficient composite action exists between the steel faceplate and concrete. However, the requirement does not consider the contribution of ties to available shear strength of the SC component, leading to inefficient designs for those components such as thin walls, for which the density of ties tends to be high. Studies based on finite element analysis demonstrate the contribution of ties to the composite action and show that composite action is adequate for the thin walls of the EOS-HSM-SC.

N9.1.4b(b)

Steel anchors shall be spaced not to exceed the minimum spacing required to prevent interfacial shear failure before out-of-plane shear failure of the SC section.

This requirement does not consider the required strength of the SC component but the available out-of-plane strength, leading to inefficient designs in those cases where the demand-to-capacity ratio for out-of-plane shear interaction is low. For the design of the EOS-HSM-SC, this criterion is modified such that the spacing of steel anchors required to prevent interfacial shear failure is deemed adequate if the demand-to-capacity ratio for out-of-plane shear interaction (presented in Section N9.3.6a of N690-18) is below 1.0 when required strength at least 1/3 greater than that determined by structural analysis is used. This approach is validated by laboratory test results.

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-15 4.0 Design Features (continued)

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

N9.1.7a(b)

The flange fitted at the end of the sleeve for a fully developed edge at the opening perimeter shall extend a distance of at least the section thickness beyond the opening perimeter.

The front wall opening in the top segment of the EOS-HSM-SC only is considered as an opening because the majority of the front wall opening area is in the top segment and the bottom segment has only a slightly concave edge. The design of the front wall opening in the top segment of the EOS-HSM-SC follows the requirements on design and detailing around openings to the maximum practical extent possible to achieve a fully developed edge at the opening perimeter: a sufficiently fine finite element mesh is employed for the front wall and around its opening; a sleeve spanning across the opening from the front faceplate to the back faceplate is provided; and an equivalent flange is provided by thickening the front wall faceplate to provide additional strength in the stress concentration region. For the EOS-HSM-SC front wall, it is impractical to extend a distance of at least the section thickness beyond the opening perimeter because of the proximity of the front wall opening to the side walls.

N9.3.6a The interaction of out-of-plane shear forces shall be limited by Equation A-N9-24 of N690-

18.

The interaction of out-of-plane shear forces for thin walls of the EOS-HSM-SC is considered based on a modified approach described in the discussion on Section N9.1.4b(b) of N690-18.

NM2.4 User Note: Parameters documented and retrievable for each weld include, but are not limited to, the welder, weld wire lot/filler metal used, equipment used, date the weld was performed, date the weld was inspected, identification of weld inspector, and weld WPS used. The fabricator or constructor, as applicable for the work scope, should develop a method whereby each weld and its associated data can be identified.

Welding shall be documented as per the requirements of AISC 360-16. The EOS-HSM-SC is made up of Category B, C, and NITS items and not Safety Related as outlined in N690-18. The requirements of AISC 360-16 are consistent with Category B items as described in Chapter 14 of the UFSAR.

NM2.7.(d).(1)

At tie locations, the perpendicular distance between the opposite faceplates are within plus or minus tsc/200, rounded upward to the nearest 1/16 in. (2 mm), where tsc is the SC section thickness. This tolerance check shall be performed for the row of tie-bars located closest to the free edges of SC panels.

For walls less than 24, the wall thickness tolerance at tie locations shall be plus or minus 1/8, measured at the row of tie-bars located closest to the free edges of the SC panels. The EOS-HSM-SC does not have segmented walls to apply a tighter tolerance at the free edges.

The EOS-HSM-SC design is its own free standing support structure that will not be affected by discontinuities at the wall connections. Any variance will be smoothly transitioned by nature of its construction. The formulas were developed for walls that are a minimum of 24. The formula when applied to much thinner walls leads to impractical designs.

Therefore, the tolerances of this Section should be applied as stated above.

(continued)

All Indicated Changes are in response to Clarification S-4

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-16 4.0 Design Features (continued)

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

NM2.7.(d).(3)

In between the tie locations, the perpendicular distance between the opposite faceplates are within plus or minus tsc/100, rounded upward to the nearest 1/16 in. (2 mm). This tolerance check shall be performed along the free edges of the SC wall panels.

For less than 24, the wall thickness tolerance in between tie locations shall be plus or minus 1/4, measured at the free edge of the SC panels.

The EOS-HSM-SC does not have segmented walls to apply a tighter tolerance at the free edges. The EOS-HSM-SC design is its own free standing support structure that will not be affected by discontinuities at the wall connections. Any variance will be smoothly transitioned by nature of its construction. The formulas were developed for walls that are a minimum of 24. The formula when applied to much thinner walls leads to impractical designs.

Therefore, the tolerances of this Section should be applied as stated above.

NM2.7.(2)

Additionally, after concrete curing, the faceplate waviness, fw, shall be limited to the following:

(

)

2 1 2

p t min w

t s

f NM s

where, s = spacing of the steel anchors, in. (mm) st,min = minimum tie spacing, in. (mm) tp = thickness of faceplate, in. (mm)

The inspection for the faceplate waviness will not be required for the EOS-HSM-SC. Units of HSMs are typically poured in groups, and therefore, the verification of this requirement cannot be performed at all locations. Due to the construction process of the EOS-HSM-SC, many walls are inaccessible after pouring. This exception is for the inspection and verification of these tolerances after curing, not the tolerance values themselves.

NM2.14 If not available from a qualified source, the material shall be dedicated for use as specified in Subpart 2.14 of ASME NQA-1.

Commercial grade dedication is not required for ITS Category B, C and NITS items per the TN QA program. HSMs are not considered basic components; therefore, per 10 CFR Part 21, they are not subject to commercial grade dedication.

NM2.15 The fabricator shall be able to demonstrate, by written procedure and by actual practice, a method of material identification meeting the requirements of the contract documents.

Material traceability is not required for ITS Category B or C items as outlined in Section 14.2 of the UFSAR and therefore, the EOS-HSM-SC components do not require material traceability as described in the code.

However, all other aspects of NM2.15, including material identification, are required.

NM3.4 Except for stainless steels, machine-finished surfaces shall be protected against corrosion by a rust-inhibitive coating that is removable prior to erection or that has characteristics that make removal prior to erection unnecessary.

Rust inhibitor shall not be required for threads or cut edges of rolled shapes and plates. Dywidag rods and similar threaded items used in concrete construction are not normally provided with rust inhibitor.

NN This chapter addresses minimum requirements for quality control, quality assurance and nondestructive evaluation for safety-related structural steel systems and steel elements of composite members for nuclear facilities.

Chapter NN quality control and quality assurance requirements do not apply to the EOS-HSM-SC. The EOS-HSM-SC is an ITS Category B item; therefore, AISC 360-16 shall be applied. The nondestructive examination of welded joints described in Section NN5.5 shall still apply.

(continued)

All Indicated Changes are in response to Clarification S-4

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-17 4.0 Design Features (continued)

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

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

2. Compliance with the specified requirements of above-specified ASME and ACI codes would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

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

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

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-18 4.0 Design Features (continued) 4.5 Storage Location Design Features The following storage location design features and parameters shall be verified by the system user to assure technical agreement with the UFSAR.

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

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

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

1.

Flood levels up to 50 ft and water velocity of 15 fps.

2.

One-hundred year roof snow load of 110 psf.

3.

Normal ambient temperature is based on the heat load of the DSC as follows:

For the EOS-HSM:

a.

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

b.

For the EOS-37PTH DSCs with a heat load greater than 41.8 kW or for the EOS-89BTH DSCs with a heat load greater than 41.6 kW, the minimum temperature is -20 °F. The maximum calculated average yearly temperature is 70 °F.

For the HSM-MX:

c.

The minimum temperature is -20 °F. The maximum calculated normal average ambient temperature corresponding to a 24-hour period is 90 °F.

4.

Off-normal ambient temperature range of -40 °F without solar insolation to 117 °F with full solar insolation. The 117 °F off-normal ambient temperature corresponds to a 24-hour calculated average temperature of 103 °F.

(continued)

Design Features 4.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 4-19 4.0 Design Features (continued)

5.

The response spectra at the base of the HSMs shall be compared against the response spectra defined in UFSAR Section 2.3.4 for the EOS-HSM, and Section A.2.3.4 for the HSM-MX and shown to be enveloped by the UFSAR response spectra. If it is not enveloped, stability can be demonstrated by either static or dynamic analysis.

6.

The potential for fires and explosions shall be addressed, based on site-specific considerations.

7.

Supplemental Shielding: In cases where engineered features (i.e., berms, shield walls) are used to ensure that the requirements of 10 CFR 72.104(a) are met, such features are to be considered important to safety and must be evaluated to determine the applicable Quality Assurance Category.

8.

If an INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) site is located in a coastal salt water marine atmosphere, then any load-bearing carbon steel DSC support structure rail components for the EOS-HSM, or front and rear DSC supports for the HSM-MX shall be procured with a minimum 0.20% copper content or stainless steel shall be used for corrosion resistance. For weld filler material used with carbon steel, 1% or more nickel bearing weld material would also be acceptable in lieu of 0.20% copper content.

9.

If an ISFSI site is required to evaluate blockage of air vents for durations longer than evaluated in the UFSAR, a new duration can be determined based on site-specific parameters. The evaluation should be performed using the same methodology documented in the UFSAR.

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-1 5.0 ADMINISTRATIVE CONTROLS 5.1 Programs Each user of the NUHOMS EOS System will implement the following programs to ensure the safe operation and maintenance of the ISFSI:

Radiological Environmental Monitoring Program (see 5.1.1 below)

Radiation Protection Program (see 5.1.2 below)

HSM Thermal Monitoring Program (see 5.1.3 below) 5.1.1 Radiological Environmental Monitoring Program

a.

A radiological environmental monitoring program will be implemented to ensure that the annual dose equivalent to an individual located outside the ISFSI controlled area does not exceed the annual dose limits specified in 10 CFR 72.104(a).

b.

Operation of the ISFSI will not create any radioactive materials or result in any credible liquid or gaseous effluent release.

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

a.

As part of its evaluation pursuant to 10 CFR 72.212, the licensee shall perform an analysis to confirm that the limits of 10 CFR Part 20 and 10 CFR 72.104 will be satisfied under the actual site conditions and configurations considering the planned number of DSCs to be used and the planned fuel loading conditions. This analysis is also used to qualify fuel considered for loading, as outlined below:

1.

For the DSCs considered for loading, select HLZC(s) appropriate to store the spent fuel.

2.

Compute the decay heat of the fuel assemblies considered for loading.

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

3.

Compute the source term for the fuel assemblies considered for loading. The design basis source terms provided in the UFSAR may be used for site-specific shielding analysis if they are shown to bound the site-specific source terms.

4.

Demonstrate computationally that the EOS-HSM or HSM-MX to be loaded meets the dose rate requirements of TS 5.1.2(c). This evaluation may be used as the basis for the dose rate limits established in TS 5.1.2(b).

5.

Demonstrate computationally that direct radiation from the ISFSI meets the requirements of 72.104.

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-2 5.0 ADMINISTRATIVE CONTROLS (continued)

b.

On the basis of the analysis in TS 5.1.2(a), the licensee shall establish a set of HSM dose rate limits which are to be applied to DSCs used at the site. Limits shall establish dose rates for:

i.

HSM front face, ii.

HSM door centerline, and iii.

End shield wall exterior for the EOS-HSM or exterior side wall of the HSM-MX monolith.

c.

Notwithstanding the limits established in TS 5.1.2(b), the dose rate limits may not exceed the following values as calculated for a content of design basis fuel as follows:

For EOS-HSM:

i.

65 mrem/hr average over the front face, ii.

15 mrem/hr at the door centerline, and iii.

5 mrem/hr average at the end shield wall exterior.

For HSM-MX:

i.

165 mrem/hr average over the front face, ii.

15 mrem/hr at the door centerline, and iii.

5 mrem/hr average at the exterior side wall of the HSM-MX monolith.

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

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

Notify the U.S. Nuclear Regulatory Commission (Director of the Office of Nuclear Material Safety and Safeguards) within 30 days, Administratively verify that the correct fuel was loaded, Ensure proper installation of the HSM door, Ensure that the DSC is properly positioned on the DSC supports, and Perform an analysis to determine that placement of the as-loaded DSC at the ISFSI will not cause the ISFSI to exceed the radiation exposure limits of 10 CFR Part 20 and 10 CFR Part 72 and/or provide additional shielding to assure exposure limits are not exceeded.

d.

A monitoring program to ensure the annual dose equivalent to any real individual located outside the ISFSI controlled area does not exceed regulatory limits is incorporated as part of the environmental monitoring program in the Radiological Environmental Monitoring Program of TS 5.1.1.

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-3 5.0 ADMINISTRATIVE CONTROLS (continued)

e.

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

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

f.

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

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

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

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-4 5.0 ADMINISTRATIVE CONTROLS (continued) 5.1.3.1 EOS-HSM Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each EOS-HSM. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria.

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

a.

Daily Visual Inspection of EOS-HSM Inlets and Outlets (Front Wall and Roof Birdscreens) and Wind Deflectors

i.

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

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

ii.

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

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

b.

Daily EOS-HSM Temperature Measurement Program

i.

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

1.

direct measurement of the EOS-HSM concrete temperature

2.

direct measurement of inlet and outlet air temperatures (continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-5 5.0 ADMINISTRATIVE CONTROLS (continued)

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

ii.

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

iii.

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

iv.

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

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

v.

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

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

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-6 5.0 ADMINISTRATIVE CONTROLS (continued) 5.1.3.2 HSM-MX Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each HSM-MX. There are no credible scenarios that could block both the inlet and outlet vents. Therefore, only blockage of inlet vent is considered in the UFSAR. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria. Each user must implement either TS 5.1.3.2(a) OR 5.1.3.2(b).

a.

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

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

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

b.

Daily HSM-MX Temperature Measurement Program

i.

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

ii.

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

iii.

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

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-7 5.0 ADMINISTRATIVE CONTROLS (continued) iv.

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

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

v.

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

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

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

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

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

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

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

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

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-8 5.0 ADMINISTRATIVE CONTROLS (continued)

Background

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

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

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

1.

The DSC will continue to provide confinement.

2.

The TC can continue to perform its design function regarding DSC transfer and shielding.

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

HSM concrete temperature testing shall be performed whenever:

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

(continued)

Administrative Controls 5.0 EOS System Amendment 4 Proposed Technical Specifications - Revision 5 5-9 5.0 ADMINISTRATIVE CONTROLS (continued) 5.4 Hydrogen Gas Monitoring For DSCs, while welding the inner top cover during LOADING OPERATIONS, and while cutting the inner top cover to DSC shell weld when the DSC cavity is wet during UNLOADING OPERATIONS, hydrogen monitoring of the space under the top shield plug in the DSC cavity is required, to ensure that the combustible mixture concentration remains below the flammability limit of 4%. If this limit is exceeded, all welding operations shall be stopped and the DSC cavity purged with helium to reduce hydrogen concentration safely below the limit before welding or cutting operations can be resumed.

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

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

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-1 Table 1 Fuel Assembly Design Characteristics for the EOS-37PTH DSC PWR FUEL CLASS B&W 15X15 WE 17X17 CE 15X15 WE 15X15 CE 14X14 WE 14X14 CE 16X16 Fissile Material UO2 UO2 UO2 UO2 UO2 UO2 UO2 Maximum Number of Fuel Rods 208 264 216 204 176 179 236 Maximum Number of Guide/ Instrument Tubes 17 25 9

21 5

17 5

Table 2 Maximum Uranium Loading per FFC for Failed PWR Fuel Fuel Assembly Class Maximum Uranium Loading (MTU)

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

Transfer in the EOS-TC108 AND (storage in the EOS-HSM OR HSM-MX)

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

1. Not Used.

2. NSAs and Neutron Sources shall only be stored in the inner zone of the basket. Figure 3 defines the compartments categorized as the Inner and Peripheral Zones.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-2 Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH (2 Pages)

PWR Fuel Class Maximum Planar Average Initial Enrichment (wt. % U-235) as a Function of Soluble Boron Concentration and Basket Type (Fixed Poison Loading) With and Without CCs Minimum Soluble Boron (ppm)

Basket Type A1/A2/A3/A4H/A4L/A5 B1/B2/B3/B4H/B4L/B5 w/o CCs w/ CCs w/o CCs w/ CCs INTACT FUEL DAMAGED/

FAILED FUEL(2)

INTACT FUEL DAMAGED/

FAILED FUEL(2)

INTACT FUEL DAMAGED/

FAILED FUEL(3)

INTACT FUEL DAMAGED/

FAILED FUEL(3)

WE 17x17 Class 2000 4.35 4.20 4.35 4.15 4.50 4.15 4.45 4.25 2100 4.50 4.20 4.45 4.20 4.65 4.25 4.60 4.40 2200 4.60 4.40 4.55 4.35 4.75 4.45 4.70 4.55 2300 4.70 4.45 4.65 4.50 4.85 4.65 4.85 4.60 2400 4.85 4.45 4.80 4.60 5.00 4.65 4.95 4.75 2500 4.95 4.65 4.90 4.70 5.00 5.00 5.00 4.95 CE 16x16 Class 2000 5.00 4.75 5.00 4.70 5.00 5.00 5.00 5.00 2100 5.00 5.00 5.00 5.00 2200 2300 2400 2500 BW 15x15 Class 2000 4.25 4.05 4.20 4.00 4.40 4.10 4.35 4.15 2100 4.40 4.10 4.30 4.15 4.55 4.20 4.45 4.25 2200 4.50 4.25 4.45 4.15 4.65 4.35 4.60 4.30 2300 4.60 4.35 4.55 4.30 4.80 4.40 4.70 4.50 2400 4.75 4.40 4.65 4.45 4.90 4.55 4.85 4.50 2500 4.85 4.55 4.75 4.65 5.00 4.75 4.90 4.75 2600 (1)

(1)

(1) 5.00 5.00 (1)

(1)

WE 15x15 2000 4.45 4.10 4.40 4.10 4.55 4.30 4.55 4.25 2100 4.60 4.15 4.55 4.15 4.65 4.50 4.65 4.35 2200 4.70 4.25 4.65 4.35 4.80 4.55 4.80 4.45 2300 4.85 4.35 4.75 4.45 5.00 4.50 4.95 4.50 2400 4.95 4.50 4.90 4.50 5.00 4.90 5.00 4.80 2500 5.00 4.75 5.00 4.65 5.00 5.00 5.00 5.00 CE 15x15 Assembly Class 2000 4.60 4.25 4.55 4.20 4.75 4.35 4.70 4.30 2100 4.70 4.45 4.65 4.40 4.85 4.50 4.85 4.35 2200 4.85 4.50 4.80 4.45 5.00 4.60 4.95 4.60 2300 5.00 4.55 4.90 4.65 5.00 5.00 5.00 4.80 2400 5.00 5.00 5.00 4.85 5.00 5.00 5.00 5.00 2500 5.00 5.00 CE 14x14 Assembly Class 2000 5.00 5.00 5.00 4.50 5.00 5.00 5.00 4.95 2100 5.00 4.95 5.00 5.00 2200 5.00 5.00 2300 2400 2500

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-3 Table 4 Maximum Planar Average Initial Enrichment for EOS-37PTH (2 Pages)

PWR Fuel Class Maximum Planar Average Initial Enrichment (wt. % U-235) as a Function of Soluble Boron Concentration and Basket Type (Fixed Poison Loading) With and Without CCs Minimum Soluble Boron (ppm)

Basket Type A1/A2/A3/A4H/A4L/A5 B1/B2/B3/B4H/B4L/B5 w/o CCs w/ CCs w/o CCs w/ CCs INTACT FUEL DAMAGED/

FAILED FUEL(2)

INTACT FUEL DAMAGED/

FAILED FUEL(2)

INTACT FUEL DAMAGED/

FAILED FUEL(3)

INTACT FUEL DAMAGED/

FAILED FUEL(3)

WE 14x14 Class 2000 5.00 5.00 5.00 5.00 5.00 5.00 5.00 5.00 2100 2200 2300 2400 2500 Notes:

1. Not analyzed.

2. May only be stored in basket types A4H and A4L

3. May only be stored in basket types B4H and B4L

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-4 Table 5 Minimum B-10 Content in the Neutron Poison Plates of the EOS-37PTH DSC Basket Type Minimum B-10 Content (areal density) for MMC (mg/cm2)

A1/A2/A3/A4H/A4L/A5 28.0 B1/B2/B3/B4H/B4L/B5 35.0

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

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

2. Example BWR fuel designs are listed herein and are not all-inclusive.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-6 Table 7A PWR Minimum Enrichments as a Function of Burnup Burnup Range (GWd/MTU)

Minimum Enrichment (wt. % U-235) 1-6 0.7 7-16 1.3 17-30 1.8 31-62 Burnup/16(1)

Notes:

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

round down to 3.8%.

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-7 Table 7B EOS-37PTH DSC Fuel Qualification Table for Storage in the HSM-MX, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup (GWd/FA)

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

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

(1) The minimum cooling time is 2.0 years.

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

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

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-8 Table 7C EOS-37PTH DSC Fuel Qualification Table for Storage in the EOS-HSM, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup (GWd/FA)

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

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

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

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

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

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-9 Table 8 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the EOS-89BTH DSC Basket Type Loading Configuration

- Number of Fuel Assemblies (1)

Maximum Lattice Average Initial Enrichment (wt. % U-235)

Minimum B-10 Areal Density (mg/cm2)

All fuel Except ABB-10-C and ATRIUM 11 ABB-10-C Fuel ATRIUM 11 Fuel MMC BORAL A1/A2/A3 (2) 89 4.20 4.05 4.05 32.7 39.2 88 4.45 4.25 4.25 87 4.60 4.40 4.35 84 5.00 4.90 4.80 B1/B2/B3 (2) 89 4.55 4.35 4.30 41.3 49.6 88 4.80 4.60 4.50 87 4.95 4.70 4.65 84 5.00 5.00 5.00 C1/C2/C3 (2) 89 4.85 4.60 (3)

Not Allowed 60.0 Note:

1. See Figure 10 for 88-FA, 87-FA and 84-FA loading configurations.

2. Mixing fuel types in the same DSC is permissible based on the calculated enrichments for each fuel type for a given basket type and loading configuration. For example, when mixing GNF2 and ATRIUM 11 fuels in basket type A1/A2/A3 and 88-fuel-assembly loading configuration, the maximum enrichment for GNF2 fuels is 4.45wt% and the maximum enrichment for ATRIUM 11 fuels is 4.25wt%.

3. ATRIUM 11 fuel is not an allowed content for basket type C1/C2/C3.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-10 Table 9 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Intact Fuel)

Basket Type Maximum Lattice Average Initial Enrichment (wt. % U-235)(1)

Minimum B-10 Areal Density, (mg/cm2)

Borated Aluminum/MMC Boral A

3.7 22 27 B

4.1 32 38 C

4.4 42 50 D

4.6 48 58 E

4.8 55 66 F

5.0(1) 62 75 Note:

1)

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-11 Table 10 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Damaged Fuel)

Basket Type Maximum Lattice Average Initial Enrichment (wt. % U-235)

Minimum B-10 Areal Density, (mg/cm2)

Up to 4 Damaged Assemblies(1)

Five or More Damaged Assemblies(1)

(16 Maximum)

Borated Aluminum/MMC Boral A

3.7 2.80 22 27 B

4.1 3.10 32 38 C

4.4 3.20 42 50 D

4.6 3.40 48 58 E

4.8 3.50 55 66 F

5.0(2, 3) 3.60 62 75 Notes:

1)

See Figure 5 for the location of damaged fuel assemblies within the 61BTH Type 2 DSC.

2)

ATRIUM 11 fuel assemblies are authorized for storage only in the Type F basket only with a maximum of 4 damaged fuel assemblies.

3)

For ATRIUM 11 fuel assemblies, the U-235 wt. % enrichment is reduced by 0.55%.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-12 Table 11 Maximum Lattice Average Initial Enrichment and Minimum B-10 Areal Density for the 61BTH Type 2 DSC (Failed and Damaged Fuel)

Basket Type Maximum Lattice Average Initial Enrichment (wt. % U-235)

Minimum B-10 Areal Density (mg/cm2)

Up to 4 Failed Assemblies (Corner Locations)(1, 2)

Up to 4 Failed Assemblies (Corner Locations) and up to 12 Damaged Assemblies (Interior Locations)(1, 2)

Borated Aluminum/MMC Boral A

3.7 2.8 22 27 B

4.0 3.1 32 38 C

4.4 3.2 42 50 D

4.6 3.4 48 58 E

4.8 3.4 55 66 F

5.0 3.5 62 75 Notes:

1) See Figure 5 for the locations of the failed and damaged assemblies within the 61BTH Type 2 DSC.

2) Failed ATRIUM 11 fuel assemblies are not authorized for storage in the 61BTH Type 2 DSC.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-13 Table 12 Maximum Lattice Average Initial Enrichments and Minimum B-10 Areal Density for the 61BTH Type 2 DSC for > 16 Damaged Fuel Assemblies Basket Type Up to 57 Damaged Fuel at 3.30 wt. % U-235 Minimum B-10 Areal Density (mg/cm2)

Remaining Four Intact Assemblies (1)

Remaining Four Damaged Assemblies (1)

Borated Aluminum/MMC Boral A

B C

D 5.00 4.20 48 58 E

5.00 4.20 55 66 F

5.00 4.20 62 75 Note:

1) See Figure 5 for the locations of the damaged assemblies within the 61BTH Type 2 DSC

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-14 Table 13 BWR Fuel Assembly Design Characteristics for the 61BTH Type 2 DSC BWR FUEL CLASS Initial Design or Reload Fuel Designation(1) (3) 7x7-49/0 GE1 GE2 GE3 8x8-63/1 GE4 8x8-62/2 GE-5 GE-Pres GE-Barrier GE8 Type I 8x8-60/4 GE8 Type II 8x8-60/1 GE9 GE10 9x9-74/2 GE11 GE13 10x10-92/2 GE12 GE14 GNF2 7x7-49/0 ENC-IIIA 7x7-48/1Z ENC-III(2) 8x8-60/4Z ENC Va ENC Vb 8x8-62/2 FANP 8x8-2 9x9-79/2 FANP9 9x9-2 Siemens QFA 9x9 10x10-91/1 ATRIUM-10 ATRIUM-10XM 11x11 ATRIUM-11 Notes:

(1)

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

(2)

Includes ENC-IIIE and ENC-IIIF.

(3)

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-15 Table 14 Maximum Uranium Loading per FFC for Failed 61BTH Type 2 Fuel Fuel Assembly Class Maximum MTU/Assembly 7x7 0.198 8x8 0.188 9x9 0.180 10x10 0.187

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-16 Table 15 Deleted

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-17 Table 16 Deleted

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-18 Table 17 System Configurations for 61BTH Type 2 HLZCs HLZC Storage Module Transfer Cask 1

HSM-MX OS197/OS197H/

OS197FC-B/OS197HFC-B 2

HSM-MX OS197/OS197H/

OS197FC-B/OS197HFC-B 3

HSM-MX OS197/OS197H/

OS197FC-B/OS197HFC-B 4

HSM-MX OS197/OS197H/

OS197FC-B/OS197HFC-B 5

HSM-MX OS197FC-B/OS197HFC-B 6

HSM-MX OS197FC-B/OS197HFC-B 7

HSM-MX OS197FC-B/OS197HFC-B 8

HSM-MX OS197FC-B/OS197HFC-B 9

HSM-MX OS197/OS197H/

OS197FC-B/OS197HFC-B 10 HSM-MX OS197FC-B/OS197HFC-B

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-19 Table 18 BWR Minimum Enrichments as a Function of Burnup (EOS-89BTH DSC and 61BTH Type 2 DSC)

Burnup Range (GWd/MTU)

Minimum Enrichment (wt. %)

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

Notes:

1) Round down to the nearest 0.1%. Example: for 62 GWd/MTU, 62/16 = 3.875%, round down to 3.8%.

2) Fuel below the minimum enrichment defined in this table is classified as LOW-ENRICHED OUTLIER FUEL. Number and location are specified in Section 2.2 for the EOS-89BTH DSC and in Section 2.3 for the 61BTH Type 2 DSC.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-20 Table 19 61BTH Type 2 DSC Fuel Qualification Table, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup (GWd/FA)

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

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

1) The minimum cooling time is 2.0 years.

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

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

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

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-21 Table 20 61BTH Type 2 DSC Fuel Qualification Table, HLZC 2, 4, 5, 6, 7, and 8, Peripheral Locations (Minimum required years of cooling time after reactor core discharge)

Burnup (GWd/FA)

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

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

1) The minimum cooling time is 2.0 years.

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

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

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

5) The peripheral locations are defined in Figure 6.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-22 Table 21 EOS-89BTH DSC Fuel Qualification Table, All Fuel (Minimum required years of cooling time after reactor core discharge)

Burnup (GWd/FA)

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

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

1) The minimum cooling time is 1.0 year.

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

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

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

5) For fuel transferred in the EOS-TC108, additional cooling time restrictions are specified in Figure 2.

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-23 Table 22 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125 Parameter Limit Number of RECONSTITUTED FUEL ASSEMBLIES per DSC 89 Maximum number of irradiated stainless steel rods per RECONSTITUTED FUEL ASSEMBLY Per table below Minimum cooling time Per table below Number of Irradiated Stainless Steel Rods per Fuel Assembly Minimum Cooling Time (years) 7x7 Class 8x8 Class 9x9 Class 10x10 Class 11x11 Class Min.

Max.

Min.

Max.

Min.

Max.

Min.

Max.

Min.

Max.

0 5

0 6

0 7

0 9

0 11 Per Table 21 6

15 7

18 8

22 10 26 12 34 2.00 16 20 19 24 23 29 27 34 35 46 2.25 21 25 25 30 30 37 35 43 47 57 2.50 26 30 31 36 38 44 44 51 58 69 2.75 31 35 37 42 45 51 52 60 70 80 3.00 36 49 43 64 52 81 61 100 81 112 3.25

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-24 Table 23 EOS-89BTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108 Parameter Limit Number of RECONSTITUTED FUEL ASSEMBLIES per DSC 89 (all types) 49 containing irradiated stainless steel rods Maximum number of irradiated stainless steel rods per DSC 100 for 7x7 Class 120 for 8x8 Class 140 for 9x9 Class 180 for 10x10 Class 220 for 11x11 Class Maximum number of irradiated stainless steel rods per RECONSTITUTED FUEL ASSEMBLY 5 for 7x7 Class 6 for 8x8 Class 7 for 9x9 Class 9 for 10x10 Class 11 for 11x11 Class Loading restrictions for locations within the basket Per Figure 9 Minimum cooling time Per Table 21

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-25 Table 24 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC125/135 AND Storage in the EOS-HSM Parameter Limit Number of RECONSTITUTED FUEL ASSEMBLIES per DSC 37 Maximum number of irradiated stainless steel rods per RECONSTITUTED FUEL ASSEMBLY Per table below Minimum cooling time Per table below Number of Irradiated Stainless Steel Rods per Fuel Assembly Minimum Cooling Time (years) 14x14 Class 15x15 Class 16x16 Class 17x17 Class Min.

Max.

Min.

Max.

Min.

Max.

Min.

Max.

0 8

0 10 0

11 0

13 Per Table 7C 9

17 11 20 12 23 14 25 3.00 18 34 21 40 24 45 26 51 4.00 35 51 41 60 46 68 52 76 4.50 52 68 61 80 69 91 77 102 5.00 69 85 81 100 92 113 103 127 5.25 86 102 101 120 114 136 128 152 5.50 103 118 121 140 137 159 153 178 5.75 119 135 141 160 160 182 179 203 6.00 136 179 161 216 183 236 204 264 6.25

Tables EOS System Amendment 4 Proposed Technical Specifications - Revision 5 T-26 Table 25 EOS-37PTH DSC Reconstituted Fuel Limits for Transfer in the EOS-TC108 Number of RECONSTITUTED FUEL ASSEMBLIES per DSC 37 (all types) 21 containing irradiated stainless steel rods Maximum number of irradiated stainless steel rods per DSC 32 for 14x14 Class 40 for 15x15 Class 48 for 16x16 and 17x17 Classes Maximum number of irradiated stainless steel rods per RECONSTITUTED FUEL ASSEMBLY 4 for 14x14 Class 5 for 15x15 Class 6 for 16x16 and 17x17 Classes Loading restrictions for locations within the basket Per Figure 14 Minimum cooling time 2 years

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-1 Figure 1A Deleted

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-2 Zone Number 1

2 3

Maximum Decay Heat, (H), (kW/FA plus CCs, if included) 1.0 1.5 1.05 Maximum Number of Fuel Assemblies 13 8

16 Maximum Decay Heat per DSC (kW) 41.8 Figure 1B Heat Load Zone Configuration 2 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-3 Zone Number 1

2 3

Maximum Decay Heat (kW/FA plus CCs, if included) 0.95 1.0 1.0 Maximum Number of Fuel Assemblies 13 8

16 Maximum Decay Heat per DSC (kW) 36.35 Figure 1C Heat Load Zone Configuration 3 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-4 Zone Number 1

2 3

Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.625 1.6 Maximum Number of Fuel Assemblies 13 8

16 Maximum Decay Heat per DSC (kW) 50.0(1)

Notes:

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

Figure 1D Heat Load Zone Configuration 4 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-5 Zone Number 1

2 3

4 Maximum Decay Heat (kW/FA plus CCs, if included) 0.7 0.5 2.4 0.85 Maximum Number of Fuel Assemblies 5

6 8

18 Maximum Decay Heat per DSC (kW) 41.0 Notes:

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

Figure 1E Heat Load Zone Configuration 5 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-6 Z3 Z3**

Z3 Z3 Z2*

Z1 Z2*

Z3 Z3 Z2*

Z1 Z1 Z1 Z2*

Z3 Z3**

Z1 Z1 Z1 Z1 Z1 Z3**

Z3 Z2*

Z1 Z1 Z1 Z2*

Z3 Z3 Z2*

Z1 Z2*

Z3 Z3 Z3**

Z3

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

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

Zone Number 1

2(1) 3(1)

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

Maximum Number of Fuel Assemblies 13 8

16 Maximum Decay Heat per DSC (kW) 46.00

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

2. The maximum allowable heat load per FAILED FUEL compartment is 0.8 kW.

Figure 1F Heat Load Zone Configuration 6 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-7 Zone Number 1

2 3

Maximum Number of Fuel Assemblies 13 8

16 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 1.0 1.60 1.3125 Maximum Decay Heat per DSC (kW) 41.8(1)

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

Notes:

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

Figure 1G Heat Load Zone Configuration 7 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-8 Z3 Z3**

Z3 Z3 Z2*

Z1 Z2*

Z3 Z3 Z2*

Z1 Z1 Z1 Z2*

Z3 Z3**

Z1 Z1 Z1 Z1 Z1 Z3**

Z3 Z2*

Z1 Z1 Z1 Z2*

Z3 Z3 Z2*

Z1 Z2*

Z3 Z3 Z3**

Z3

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

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

Zone Number 1

2(2) 3(2)(3)

Maximum Number of Fuel Assemblies 13 8

16 Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.8 1.50 1.50 Maximum Decay Heat per DSC (kW) 41.8(1)(4)

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

Notes:

1. The maximum decay heat per DSC is limited to 41.8 kW when DAMAGED or FAILED FUEL is loaded.

2. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

3. The maximum allowable heat load per FAILED FUEL is 0.8 kW.

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

Figure 1H Heat Load Zone Configuration 8 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-9 Z5 Z4 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z3 Z2 Z1 Z2 Z3 Z4 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z4 Z3 Z2 Z1 Z2 Z3 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z4 Z5 Zone Number 1

2 3

4 5

Maximum Decay Heat (kW/FA plus CCs, if included) 0.50 0.70 2.0 0.75 2.4 Maximum Number of Fuel Assemblies 5

6 4

18 4

Maximum Decay Heat per DSC (kW) 37.80 Figure 1I Heat Load Zone Configuration 9 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-10 Figure 1J Deleted

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-11 Z4*

Z1 Z4*

Z3 Z3 Z3 Z3 Z3 Z4*/**

Z3 Z1 Z1 Z1 Z3 Z4*/**

Z1 Z3 Z1 Z1 Z1 Z3 Z1 Z2*

Z3 Z1 Z1 Z1 Z3 Z2*

Z3 Z3 Z3 Z3 Z3 Z2 Z1 Z2

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

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

Zone Number 1

2(1) 3 4(1)

Maximum Number of Fuel Assemblies 13 4

16 4

Upper Compartment Maximum Decay Heat (kW/FA plus CCs, if included) 0.5 3.0 0.7 3.0(2)

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

Maximum Decay Heat per DSC (kW) 44.5 Notes:

1. DAMAGED FUEL and FAILED FUEL shall not be loaded in the same DSC.

2. The maximum allowable heat load per FAILED FUEL is 0.8 kW.

Figure 1K Heat Load Zone Configuration 11 for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-12 Heat Load Zone Configuration 2 Zone Number 1

2 3(1)

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

2 3(2)

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

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

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

Figure 2 EOS-89BTH DSC Heat Load Zone Configurations for transfer in the EOS-TC108

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-13 P

P P

P I

I I

P P

I I

I P

P I

I I

P P

I I

I P

P I

I I

P P

Figure 3 Peripheral (P) and Inner (I) Fuel Locations for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-14 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Z3 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA)

NA NA 0.393 NA NA NA Maximum Decay Heat per Zone (kW)

NA NA 22.0 NA NA NA Maximum Decay Heat per DSC (kW) 22.0 Figure 4A Heat Load Zone Configuration 1 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-15 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA)

NA 0.35 NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW)

NA 8.75 NA 11.52 6.48 NA Maximum Decay Heat per DSC (kW) 22.0(1)

(1) Adjust payload to maintain total DSC heat load within the specified limit Figure 4B Heat Load Zone Configuration 2 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-16 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Z2 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA)

NA 0.35 NA NA NA NA Maximum Decay Heat per Zone (kW)

NA 19.4 NA NA NA NA Maximum Decay Heat per DSC (kW) 19.4 Figure 4C Heat Load Zone Configuration 3 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-17 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z5 Z4 Z2 Z1 Z1 Z1 Z2 Z4 Z5 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) 0.22 0.35 NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW) 1.98 5.60 NA 11.52 6.48 NA Maximum Decay Heat per DSC (kW) 19.4(1)

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

Figure 4D Heat Load Zone Configuration 4 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-18 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z2 Z2 Z2 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA)

NA 0.35 NA NA 0.54 NA Maximum Decay Heat per Zone (kW)

NA 3.15 NA NA 28.08 NA Maximum Decay Heat per DSC (kW) 31.2(1)

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

Figure 4E Heat Load Zone Configuration 5 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-19 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z6 Z6 Z6 Z6 Z6 Z4 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z5 Z4 Z6 Z1 Z1 Z1 Z6 Z4 Z5 Z4 Z6 Z6 Z6 Z6 Z6 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA) 0.22 NA NA 0.48 0.54 0.70 Maximum Decay Heat per Zone (kW) 1.98 NA NA 11.52 6.48 11.20 Maximum Decay Heat per DSC (kW) 31.2 Figure 4F Heat Load Zone Configuration 6 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-20 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA)

NA NA NA 0.48 0.54 NA Maximum Decay Heat per Zone (kW)

NA NA NA 12.00 19.44 NA Maximum Decay Heat per DSC (kW) 31.2(1)

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

Figure 4G Heat Load Zone Configuration 7 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-21 Z5 Z5 Z5 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z5 Z4 Z3 Z2 Z2 Z2 Z3 Z4 Z5 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z4 Z5 Z5 Z5 Zone 1 Zone 2 Zone 3 Zone 4 Zone 5 Zone 6 Maximum Decay Heat (kW/FA)

NA 0.35 0.393 0.48 0.54 NA Maximum Decay Heat per Zone (kW)

NA 3.15 6.288 11.52 6.48 NA Maximum Decay Heat per DSC (kW) 27.4(1)

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

Figure 4H Heat Load Zone Configuration 8 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-22 Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Zone 1 Zone 2 Zone 3 Zone 4 Maximum Decay Heat (kW/FA) 0.393 0.48 0.35 0.35 Maximum Decay Heat per Zone (kW) 3.54 7.68 4.2 8.4 Maximum Decay Heat per DSC (kW) 22.0(1)

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

Figure 4I Heat Load Zone Configuration 9 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-23 Z4 Z4 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z3 Z2 Z1 Z1 Z1 Z2 Z3 Z4 Z4 Z2 Z2 Z2 Z2 Z2 Z4 Z4 Z4 Z3 Z3 Z3 Z4 Z4 Z4 Z4 Z4 Zone 1 Zone 2 Zone 3 Zone 4 Maximum Decay Heat (kW/FA) 0.393 0.48(2) 1.20(2) 0.48(2)

Maximum Decay Heat per Zone (kW) 3.54 7.68 14.4 11.52 Maximum Decay Heat per DSC (kW) 31.2(1)

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

Note 2: If the maximum decay heat per FA in Zone 3 is greater than 0.9 kW, the maximum decay heat per FA in Zone 2 and Zone 4 shall be less than or equal to 0.393 kW.

Figure 4J Heat Load Zone Configuration 10 for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-24 C

C C

A B

C C

C B

A B

B C

C C

B B

C C

C B

B C

C C

B B

A B

C C

C B

A C

C C

A Corner Locations See Note 1 B

Interior Locations See Note 2 C

Interior/Edge Locations See Note 3 Note 1: When loading up to 4 damaged or 4 failed assemblies, these must be placed in corner A locations, and the remaining locations B and C shall be loaded with intact fuel. If fewer than 4 damaged or 4 failed assemblies are to be stored, the remaining A locations may be loaded with intact fuel provided they meet the respective damaged or failed enrichment limits of Table 10 or Table 11. Damaged and failed fuel shall not be mixed, i.e., up to four damaged assemblies may be stored, or up to four failed assemblies may be stored in A locations.

Note 2: If loading more than four damaged assemblies, place first four damaged assemblies in the corner A locations per Note 1, and up to 12 additional damaged assemblies in these interior B locations, with the remaining intact in a 61BTH Type 2 Basket. The maximum lattice average initial enrichment of assemblies (damaged or intact stored in the 2x2 cells) is limited to the Five or More Damaged Assemblies column of Table 10. For the 61BTH Type 2 DSC containing both damaged and failed fuel assemblies, this enrichment is limited to the and up to 12 Damaged Assemblies column of Table 11.

Note 3: If loading more than 16 damaged assemblies, place the first 57 damaged assemblies in the interior/edge "C" and the interior B locations. Place the remaining four intact or damaged assemblies in the corner "A" locations. The maximum lattice average initial enrichments of assemblies is limited to the Remaining Four Intact Assemblies or Remaining Four Damaged Assemblies column of Table 12.

Figure 5 Location of Damaged and Failed Fuel Assemblies inside the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-25 P

P P

I I

I P

P P

I I

I P

P I

I I

P P

I I

I P

P I

I I

P P

I I

I P

P P

I I

I P

P P

Figure 6 Peripheral (P) and Inner (I) Fuel Locations for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-26 RECONSTITUTED FUEL ASSEMBLIES with 5 irradiated stainless steel rods may be loaded into all peripheral locations (i.e., not restricted). See Figure 6 for peripheral locations.

A RECONSTITUTED FUEL ASSEMBLY with > 5 and 10 irradiated stainless steel rods may be loaded in any peripheral location, with additional restrictions in accordance with Section 2.3. Examples:

If Location B contains a RECONSTITUTED FUEL ASSEMBLY with > 5 irradiated stainless steel rods, peripherally adjacent Locations A and C shall contain fuel assemblies that do not contain irradiated stainless steel rods.

If Locations E and G contain RECONSTITUTED FUEL ASSEMBLIES with > 5 irradiated stainless steel rods, peripherally adjacent Locations D, F, and H shall contain fuel assemblies that do not contain irradiated stainless steel rods.

Figure 7 Peripheral Location Restrictions for Reconstituted Fuel with Irradiated Stainless Steel Rods for the 61BTH Type 2 DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-27 P

P P

I I

I P

P P

I I

I P

P I

I I

P P

I I

I P

P I

I I

P P

I I

I P

P I

I I

P P

I I

I P

P P

I I

I P

P P

Figure 8 Peripheral (P) and Inner (I) Fuel Locations for the EOS-89BTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-28 X

X X

X R

X X

X R

R R

X X

X R

R R

X X

X R

R R

X X

X R

R R

X X

X R

R R

X X

X R

R R

X X

X R

R R

X X

X R

X X

R = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods allowed at these locations.

X = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods not allowed at these locations.

Note: No restrictions on location for RECONSTITUTED FUEL ASSEMBLIES that do not contain irradiated stainless steel rods.

Figure 9 EOS-89BTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-29 C

C B

A/C B

C C

Note:

1. Location identified as A is for empty placement in 88-FA Loading

2. Locations identified as B are for empty placements in 87-FA Loading

3. Locations identified as C are for empty placements in 84-FA Loading Figure 10 Empty Locations in Short-Loading Configurations for the EOS-89BTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-30 Z6 Z5 Z6 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z4 Z2 Z2 Z2 Z1 Z2 Z2 Z2 Z4 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z6 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z6 Z5 Z3 Z1 Z1 Z1 Z1 Z1 Z1 Z1 Z3 Z5 Z6 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z6 Z3 Z2 Z1 Z1 Z1 Z1 Z1 Z2 Z3 Z4 Z2 Z2 Z2 Z1 Z2 Z2 Z2 Z4 Z4 Z3 Z3 Z3 Z3 Z3 Z4 Z6 Z5 Z6 Zone No.

Z1 Z2 Z3 Z4 Z5 Z6 Max. Decay Heat per SFA (kW) 0.40 0.60 1.30 1.70 1.30 1.70 No. of Fuel Assemblies 29 20 20 8

4 8

Heat Load Per Zone 11.6 12.0 26.0 13.6 5.2 13.6 Max. Decay Heat per DSC (kW)

See Note 1 for EOS-HSM and Note 2 for HSM-MX Notes:

1.

Maximum heat load for EOS-89BTH DSC during Storage is 48.2 kW in EOS-HSM.

2.

Maximum heat load for EOS-89BTH DSC during Storage is 48.2 kW in lower compartment of HSM-MX and 41.8 kW in upper compartment of HSM-MX.

Figure 11 Maximum Heat Load Configuration 1 for EOS-89BTH DSC (MHLC-89-1) Transferred in the EOS-TC125

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-31 Z4 Z3 Z4 Z4 Z3 Z2 Z3 Z4 Z5 Z3 Z2 Z1 Z2 Z3 Z5 Z6 Z2 Z1 Z2 Z1 Z2 Z6 Z5 Z3 Z2 Z1 Z2 Z3 Z5 Z4 Z3 Z2 Z3 Z4 Z4 Z3 Z4 Zone No.

Z1 Z2 Z3 Z4 Z5 Z6 Max. Decay Heat per SFA (kW) 1.5 1.0 2.4 3.5 4.3 1.6 No. of Fuel Assemblies 4

9 10 8

4 2

Heat Load Per Zone 6.0 9.0 24.0 28.0 17.2 3.2 Max. Decay Heat per DSC (kW)

See Note 1 Notes:

1.

Maximum heat load for EOS-37PTH DSC during Storage is 50.0 kW in the EOS-HSM.

2.

See Figure 13 for Damaged/failed fuel locations.

3.

MHLC-37-1 is only applicable for transfer operations in an EOS-TC125 or EOS-TC135 transfer cask and storage in an EOS-HSM storage module. It is not applicable to the following configurations:

A. transfer in an EOS-TC108 transfer cask and storage in either an EOS-HSM or HSM-MX storage module or B. transfer in an EOS-TC125 or EOS-TC135 transfer cask and storage in an HSM-MX storage module.

Figure 12 Maximum Heat Load Configuration 1 for EOS-37PTH DSC (MHLC-37-1) Transferred in the EOS-TC125/135 AND Stored in the EOS-HSM

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-32 D2 F1 D2 D1 D1 D2/F2 D1 D1 D2/F2 F1 F1 D2 D1 D1 D2 D1 D1 F1 Notes:

1.

The damaged fuel locations are marked with a D1 for configuration 1, and D2 for configuration 2. Only one configuration may be loaded in each DSC.

2.

The Failed fuel locations are marked with an F1 for configuration 1, and F2 for configuration 2. Only one configuration may be loaded in each DSC. Failed fuel in all configurations is limited to 0.8 kW.

3.

Damaged and failed fuel shall not be loaded in the same DSC.

Figure 13 Damaged and Failed Fuel Configurations for the EOS-37PTH DSC

Figures EOS System Amendment 4 Proposed Technical Specifications - Revision 5 F-33 X

X X

X R

R R

X X

R R

R X

X R

R R

X X

R R

R X

X R

R R

X X

R = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods allowed at these locations.

X = RECONSTITUTED FUEL ASSEMBLIES with irradiated stainless steel rods not allowed at these locations.

Note: No restrictions on location for RECONSTITUTED FUEL ASSEMBLIES that do not contain irradiated stainless steel rods.

Figure 14 EOS-37PTH DSC Allowed Reconstituted Fuel Locations for Transfer in the EOS-TC108 to E-64088 CoC 1042 Amendment 4, Revision 5 UFSAR Changed Pages (Proprietary Version)

Withheld Pursuant to 10 CFR 2.390 to E-64088 CoC 1042 Amendment 4, Revision 5 UFSAR Changed Pages (Public Version)

Proprietary and Security Related Information for Drawing EOS01-3300-SAR, Rev. 0F Withheld Pursuant to 10 CFR 2.390

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 2-3 2.1.2 Horizontal Storage Module (EOS-HSM/EOS-HSMS)/EOS-HSM-HS The EOS horizontal storage module (HSM) and EOS-HSMS are essentially identical except the EOS-HSMS base is split into two parts. EOS-HSM is used herein for both the EOS-HSM, the EOS-HSMS and the high seismic EOS-HSM-HS. The EOS-HSMs are considered ITS since these provide physical protection and shielding for the DSC during storage. The reinforced concrete HSM (EOS-HSM-RC) is designed in accordance with American Concrete Institute (ACI) 349-06 [2-3] and constructed to ACI-318-08 [2-4]. The steel structure of the steel-plate composite HSM (EOS-HSM-SC) is designed and constructed in accordance with ANSI/AISC N690-18

[2-23]. Important to Safety welding including structural welding and stud welding shall conform to AWS D1.1. The concrete and supplemental reinforcement of the EOS-HSM-SC are designed in accordance with ACI 349-13 [2-24] and constructed in accordance with ACI 318-08 [2-4]. Code alternatives and exceptions are discussed in Section 4.4.4 of the Technical Specifications [2-18]. The level of testing, inspection, and documentation provided during construction and maintenance is in accordance with the quality assurance requirements as defined in 10 CFR Part 72, Subpart G and as described in Chapter 14. Thermal instrumentation for monitoring EOS-HSM concrete temperatures is considered not important-to-safety (NITS).

2.1.3 ISFSI Basemat and Approach Slabs The ISFSI basemat and approach slabs and buildings for indoor storage are considered NITS and are designed, constructed, maintained, and tested as commercial-grade items.

Licensees are required to perform an assessment to confirm that the license seismic criteria described in Section 2.3.4 are met.

2.1.4 Transfer Equipment 2.1.4.1 Transfer Cask and Yoke The transfer casks (EOS-TCs) are ITS since they protect the DSC during handling and are part of the primary load path used while handling the DSCs in the fuel/reactor building. An accidental drop of a loaded transfer cask (TC) (weighing up to 135 tons) has the potential for creating conditions in the plant that must be evaluated. These possible drop conditions are evaluated with respect to the impact on the DSC in Chapters 3 and 12. Therefore, the EOS-TCs are designed, constructed, and tested in accordance with a QA program incorporating a graded quality approach for ITS requirements as defined by 10 CFR Part 72, Subpart G, paragraph 72.140(b) and described in Chapter 14.

A lifting yoke is used for handling the TC within the fuel/reactor building and it is used by the licensee (utility) under their 10 CFR Part 50 [2-5] program requirements.

All Indicated Changes are in response to Clarification S-4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-5 8.2.1.3 EOS-HSM Horizontal Storage Module The applicable codes for EOS-HSM-RC are:

Concrete construction per ACI-318-08 [8-7].

Concrete Design per ACI-349-06 [8-8].

DSC support structure design per AISC Manual of Steel Construction [8-11].

The applicable codes for EOS-HSM-SC are:

Steel-plate composite design and construction per ANSI/AISC-N690-18 [8-55].

Concrete construction per ACI-318-08 [8-7].

Concrete design per ACI-349-13 [8-26].

DSC support structure design per AISC Manual of Steel Construction [8-11].

Cement, aggregate, reinforcing steel, faceplate, studs, tie bars, and DSC support structure steel conform to ASTM specifications.

The EOS-HSM concrete is designed and constructed using a specified compressive strength of 5,000 psi, normal weight concrete. The specified compressive strength may be determined at 28 days or at test age designated for determination of f'c. The cement is Type II or Type III Portland cement meeting the requirements of ASTM C150 [8-56] or blended Portland cement meeting the requirements of ASTM C595 [8-53]*, [8-54]*, and [8-57]. The concrete aggregate meets the specifications of ASTM C33. The reinforcing steel is ASTM A615 or A706 Gr 60 deformed bars placed vertically and horizontally at each face of the walls and roof.

Note that although CoC 1042 Amendment 4 includes approval of the use of blended Portland cement, per References [8-53] and [8-54] NRC has approved its use under Amendments 1, 2, and 3 as well.

For EOS-HSM-RC, the concrete surface temperature limits criteria are based on the provisions in Section 3.5.1.2 of NUREG-1536, as follows:

If concrete temperatures in general or local areas are at or below 200 °F for normal/off-normal conditions/occurrences, no tests to prove capability at elevated temperatures or reduction of concrete strength are required.

If concrete temperatures in general or local areas exceed 200 °F but do not exceed 300 °F, no tests to prove capability at elevated temperatures or reduction of concrete strength are required if the aggregates have a coefficient of thermal expansion (CTE) no greater than 6x10-6 in/in/°F, or are one of the following materials: limestone, dolomite, marble, basalt, granite, gabbro, or rhyolite.

72.48 &

Amd 4 All Indicated Changes are in response to Clarification S-4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-25 8-48 Outokumpu, Data Sheet Duplex Stainless Steel.

8-49 Euronorm EN485-2, Aluminium and aluminium alloys - Sheet, strip and plate - Part 2: Mechanical properties.

8-50 Euronorm EN573-3, Aluminium and aluminium alloys - Chemical composition and form of wrought products - Part 3: Chemical composition and form of products.

8-51 Ryerson Plastics, Edition 26.

8-52 The Steel Construction Institute, Design Manual for Structural Stainless Steel, 4th Edition, 2017.

8-53 Letter from Prakash Narayanan to US NRC, Proposed Additional Alternative to the ACI Code, Concrete Temperature Limits, Docket 72-1042, CoC 1042 Amendments 1, 2, and 3, dated August 23, 2023 ADAMS ML23235A066.

8-54 Letter from US NRC to Mr. Prakash Narayanan, Proposed Additional Alternative to the American Concrete Institute Code, Concrete Temperature Limits, for Certificate of Compliance No. 1042, Amendment Nos. 1, 2, and 3 (Docket No. 72-1042, CAC No.

001028, Enterprise Project Identifier: L-2023-LLR-0037), dated October 24, 2023 ADAMS ML23277A127.

8-55 American National Standard, Specification for Safety-Related Steel Structures for Nuclear Facilities, ANSI/AISC-N690-18, June 28, 2018.

8-56 ASTM International, C150/C150M, Standard Specification for Portland Cement.

8-57 ASTM International, C595/C595M, Standard Specification for Blended Hydraulic Cements.

8-58 ASTM International, Specification for High-Strength Low-Alloy Columbium-Vanadium Structural Steel, A572/A572M-21.

8-59 ASTM International, Standard Specification for General Requirements for Steel Bars, Carbon and Alloy, Hot-Wrought, A29/A29M-23.

8-60 ASTM International, Standard Specification for Deformed and Plain Low-Alloy Steel Bars for Concrete Reinforcement, A706/A706M-22a.

8-61 ASTM International, Standard Specification for Hex Cap Screws, Bolts and Studs, Steel, Heat Treated, 120/105/90 ksi Minimum Tensile Strength, General Use, A449-14.

8-62 Deleted.

8-63 ASME Boiler and Pressure Vessel Code,Section II, Part D, Properties (Customary), 2023.

8-64 American Welding Society, AWS D1.1, July 2015, Structural Welding Code-Steel.

72.48 All Indicated Changes are in response to Revised RAI 8-3 Revised RAI 8-3 Clarification S-4

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-54 Table 8-24 Material Properties, ASTM A615 Grade 60 and ASTM A706 Grade 60 EOS-HSM-RC Reinforcing Steel Temp

(°F)

Yield Strength (ksi) (1)

Modulus of Elasticity (103 ksi) (1)

Density (lb/ft3) (2) 100 60.0 29.0 490 200 57.0 28.4 300 54.0 27.8 400 51.0 27.3 500 51.0 27.0 Notes

1. Reference [8-12].

2. Reference [8-11].

All Indicated Changes are in response to Revised RAI 8-3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-67 Table 8-37 Material Properties, ASTM A-572 Gr. 60 Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.4 60.0 75.0 0.28 100 29.26(6) 60.0 75.0 200 28.8 53.0 75.0 300 28.3 48.6 75.0 400 27.9 45.1 75.0 500 27.3 42.4 75.0 Notes:

(1) Reference [8-58]

(2) Table TM-1 [8-63] for Carbon steel with C 0.3% Carbon content as per Table 2 of

[8-58].

(3) Table Y-1 [8-63]

(4) Table U [8-63]

(5) Table PRD [8-63]

(6) Value based on interpolation.

Table 8-38 Material Properties, ASTM A29 Gr. 1010 through 1020 Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.4 51.0(1) 65.0(1) 0.28 100 29.26(6) 49.5 65.0 200 28.8 46.9 65.0 300 28.3 44.9 65.0 400 27.9 43.4 65.0 500 27.3 42.3 65.0 600 26.5 41.8 62.4 Notes:

(1) Table 7.1 for Type B [8-64]

(2) Table TM-1 [8-63] for Carbon steel with C 0.3% Carbon content as per Table 2 of

[8-59].

(3) Based on the highest rate of reduction provided in Reference [8-12] Figure 7-3.

(4) Based on rate of reduction for high strength alloys provided in Reference [8-12]

Figure 7-4.

(5) Table PRD [8-63]

(6) Value based on interpolation.

All Indicated Changes are in response to Revised RAI 8-3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-68 Table 8-39 Material Properties, ASTM A706 Gr. 60 EOS-HSM-SC Ties Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.4 60.0(1) 80.0(1) 0.28 100 29.26(6) 58.2 80.0 200 28.8 55.2 80.0 300 28.3 52.8 80.0 400 27.9 51.0 80.0 500 27.3 49.8 80.0 600 26.5 49.2 76.8 Notes:

(1) Reference [8-60]

(2) Table TM-1 [8-63] for Carbon steel with C 0.3% Carbon content as per Table 2 of

[8-60].

(3) Based on the highest rate of reduction provided in Reference [8-12] Figure 7-3.

(4) Based on rate of reduction for high strength alloys provided in Reference [8-12]

Figure 7-4.

(5) Table PRD [8-63]

(6) Value based on interpolation.

Table 8-40 Material Properties, ASTM A449 Type 1, <1 in. dia.

Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.2 92.0 120.0 0.28 100 29.06(6) 92.0 120.0 200 28.6 81.3 120.0 300 28.1 74.5 118.4 400 27.7 69.1 117.3 500 27.1 65.1 117.2 600 26.4 62.0 117.2 Notes:

(1) Reference [8-61]

(2) Table TM-1 [8-63] for Carbon steel with C > 0.3% Carbon content as per Table 2 of

[8-61].

(3) Table Y-1 [8-63]

(4) Table U [8-63]

(5) Table PRD [8-63]

(6) Value based on interpolation.

All Indicated Changes are in response to Revised RAI 8-3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-69 Table 8-41 Material Properties, ASTM A449 Type 1, diameters > 1.0 in. to 1 1/2 in.

Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.2 81.0 105.0 0.28 100 29.06(6) 81.0 105.0 200 28.6 71.6 105.0 300 28.1 65.6 103.6 400 27.7 60.8 102.6 500 27.1 57.3 102.5 600 26.4 54.6 102.5 Notes:

(1) Reference [8-61]

(2) Table TM-1 [8-63] for Carbon steel with C > 0.3% Carbon content as per Table 2 of

[8-61].

(3) Table Y-1 [8-63]

(4) Table U [8-63]

(5) Table PRD [8-63]

(6) Value based on interpolation.

Table 8-42 Material Properties, ASTM A-572 Gr. 50 Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.4 50.0 65.0 0.28 100 29.26(6) 50.0 65.0 200 28.8 44.2 65.0 300 28.3 40.5 65.0 400 27.9 37.6 65.0 500 27.3 35.4 65.0 Notes:

(1) Reference [8-58]

(2) Table TM-1 [8-63]

(3) Table Y-1 [8-63]

(4) Table U [8-63]

(5) Table PRD [8-63]

(6) Value based on interpolation.

All Indicated Changes are in response to Revised RAI 8-3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 8-70 Table 8-43 Material Properties, SA-572 Gr. 65 - Applicable to EOS-HSM-SC Only Temp

(°F)

E(2)

(103 ksi)

Sy (3)

(ksi)

Su (4)

(ksi)

(5)

(lb/in3) 70(1) 29.4 65.0 80.0 0.28 100 29.26(6) 65.0 80.0 200 28.8 57.4 80.0 300 28.3 52.6 80.0 400 27.9 48.8 80.0 500 27.3 45.9 80.0 Notes:

(1) Reference [8-61]

(2) Table TM-1 [8-63] for Carbon steel with C 0.3% Carbon content as per Table 1 of

[8-61].

(3) Table Y-1 [8-63]

(4) Table U [8-63]

(5) Table PRD [8-63]

(6) Value based on interpolation.

All Indicated Changes are in response to Revised RAI 8-3

NUHOMS EOS System Updated Final Safety Analysis Report Rev. 5, 07/23 February 2025 Revision 5 72-1042 Amendment 4 Page 10-5 10.1.3.2 HSM Reinforcing steel placement in the EOS-HSM-RC is inspected in accordance with ACI 117 [10-9] and cured concrete is visually inspected in accordance with ACI 311.4R for all EOS-HSMs [10-10]. The EOS-HSM-SC is inspected in accordance with ANSI/AISC N690 [10-33] with alternatives discussed in Section 4.4.4 of the Technical Specifications [10-32].

Weld inspections and inspector qualifications conform to AWS D1.1.

10.1.3.3 Transfer Cask The load-bearing welds for the EOS-TC structural body are inspected by MT as specified on the drawings in Chapter 1, with acceptance criteria of ASME Subarticle NF-5340. Non-destructive examination personnel are qualified in accordance with SNT-TC-1A.

10.1.4 Shielding Tests 10.1.4.1 DSC The shielding performance of the top and bottom shield plugs and cover plates of the DSC is verified by their material certifications and dimensional inspections. No further testing is required.

10.1.4.2 HSM The HSM concrete is tested in accordance with ASTM C138 [10-11] to verify a minimum density of 140 lb/ft3 for the EOS-HSM-RC and 139 pcf for the EOS-HSM-SC.

The shielding capability of the faceplates of the EOS-HSM-SC is verified by its material certifications and dimensional inspections. No further testing is required.

10.1.4.3 Transfer Cask The TC lead shielding is installed as lead sheet or interlocking lead bricks, rather than being cast in place. The neutron shield material in the lid and bottom end is also installed as solid sheets of borated high density polyethylene. Shielding performance is verified by material certification and dimensional inspection.

The radial neutron shielding is provided by filling the neutron shield shell with water during operations. No testing is necessary.

All Indicated Changes are in response to Clarification S-4

to E-64088 Page 1 of 1 Changes Not Related to Specific RAIs Item 1:

NUHOMS EOS Certificate of Compliance (CoC) No. 1042 Technical Specifications (TS) has been modified as described below.

EOS-TC135 was inadvertently omitted from TS Section 3.1.3, Note 2, page 3-7 during the initial Amendment 4 submittal. As noted in Section 4.5, paragraph 2 of the UFSAR, the thermal evaluation for EOS-TC125 bounds those for EOS-TC135. Therefore, EOS-TC135 has been added to the third sentence of Note 2.

TS Impact: TS Section 3.1.3, Note 2 has been updated as described.

v t e Letter Sequence Supplement
CAC:001028, SR 3.5.1.2 Notation (Approved, Closed) EPID:L-2022-LLA-0017, Independent Spent Fuel Storage Installation - Request for a Temporary Exemption from 10 CFR 73, Appendix B, Section Le and 10 CFR 73.55(r) Annual Physical Requalification Requirement (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results\|Request]] Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, ... further results\|Supplement]] Administration Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance, Withholding Request Acceptance Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, ... further results\|Meeting]] Questions 22 January 2019 25 August 2021 17 January 2018 19 January 2018 23 February 2018 23 February 2018 23 February 2018 23 February 2018 27 February 2018 27 February 2018 23 February 2018 23 February 2018 27 February 2018 27 February 2018 28 February 2018 28 February 2018 28 February 2018 28 February 2018 28 February 2018 28 February 2018 28 February 2018 6 March 2018 6 March 2018 8 March 2018 8 March 2018 8 March 2018 8 March 2018 8 March 2018 8 March 2018 9 March 2018 9 March 2018 12 March 2018 22 March 2018 26 March 2018 28 March 2018 3 April 2018 3 April 2018 3 April 2018 3 April 2018 5 April 2018 5 April 2018 5 April 2018 5 April 2018 23 April 2018 23 April 2018 10 May 2018 17 May 2018 17 May 2018 29 June 2018 29 May 2018 13 September 2018 18 September 2018 ... further results Answers 21 September 2023 5 April 2018 29 March 2018 7 May 2018 10 April 2018 26 September 2018 22 April 2019 26 June 2019 22 April 2019 18 September 2019 1 November 2019 15 December 2019 31 March 2020 5 June 2020 10 July 2020 11 September 2020 11 November 2020 27 January 2021 9 February 2021 19 November 2021 30 November 2021 25 February 2022 7 June 2022 11 July 2022 13 July 2022 29 July 2022 31 August 2022 31 August 2022 9 September 2022 3 October 2022 3 October 2022 1 December 2022 21 December 2022 6 January 2023 27 January 2023 17 March 2023 8 May 2023 30 June 2023 22 April 2024 14 May 2024 4 November 2024 6 November 2024 Results Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, ... further results\|Approval]] Other: L-18-006, ISFSI - Site-Specific License Renewal Application, Revision 0, July 2018, L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML17311A450, ML18018A018, ML18022A077, ML18022A078, ML18022A079, ML18087A056, ML18087A057, ML18087A058, ML18087A059, ML18087A060, ML18087A061, ML18087A062, ML18100A185, ML18100A188, ML18100A190, ML18100A191, ML18100A193, ML18101A024, ML18108A052, ML18131A047, ML18131A048, ML18141A561, ML18141A562, ML18141A563, ML18141A564, ML18141A565, ML18141A567, ML18179A258, ML18179A260, ML18179A266, ML18201A455, ML18205A179, ML18222A351, ML18228A530, ML18228A531, ML18228A532, ML18228A533, ML18234A012, ML18248A121, ML18255A093, ML18255A094, ML18255A096, ML18255A097, ML18255A098, ML18255A101, ML18255A102, ML18324A577, ML18324A594... further results
MONTHYEAR2018-01-11 [Table View]

ML25043A122

Text

Subject:

References:

Enclosures:

Background

Navigation menu

Search