ML19099A299

Enclosure 4: CoC 1014, A13, App A-100U (Letter to K. Manzione Issuance of Certificate of Compliance No. 1014, Amendment No. 13 for the HI-STORM 100 Multipurpose Canister Cask System (Dkt. 72-1014, CAC: 001028, EPID: L-2018-LLA-0202)

ML19099A299
Person / Time
Site:	Holtec
Issue date:	04/15/2019
From:	John Mckirgan Spent Fuel Licensing Branch
To:	Manzione K Holtec
Jacobs C
Shared Package
ML19099A294	List: ML19099A295 ML19099A296 ML19099A297 ML19099A298 ML19099A299 ML19099A300 ML19099A301
References
CAC 001028, EPID L-2018-LLA-0202
Download: ML19099A299 (31)

Text

PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX A-100U TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100 CASK SYSTEM (MODEL NO. 100U ADDITION)

TABLE OF CONTENTS 1.0 USE AND APPLICATION ............................................................................... 1.1-1 1.1 Definitions ............................................................................................ 1.1-1 1.2 Logical Connectors .............................................................................. 1.1-1 1.3 Completion Times ................................................................................ 1.1-1 1.4 Frequency ............................................................................................ 1.1-1 2.0 NOT USED ..................................................................................................... 2.0-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY............... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ............................. 3.0-2 3.1 SFSC INTEGRITY ............................................................................ 3.1.1-1 3.1.1 Multi-Purpose Canister (MPC) ............................................... 3.1.1-1 3.1.2 SFSC Heat Removal System ................................................. 3.1.2-1 3.1.3 MPC Cavity Reflooding .......................................................... 3.1.3-1 3.1.4 Deleted ................................................................................... 3.1.4-1 3.1.5 Impressed Current Cathodic Protection System (ICCPS) ...... 3.1.5-1 3.2 SFSC RADIATION PROTECTION ................................................... 3.2.1-1 3.2.1 Not Used ................................................................................ 3.2.1-1 3.2.2 TRANSFER CASK Surface Contamination ............................ 3.2.2-1 3.2.3 Not Used ................................................................................ 3.2.3-1 3.3 SFSC CRITICALITY CONTROL ....................................................... 3.3.1-1 3.3.1 Boron Concentration .............................................................. 3.3.1-1 Table 3-1 MPC Cavity Drying Limits .................................................................... 3.4-1 Table 3-2 MPC Helium Backfill Limits .................................................................. 3.4-2 4.0 NOT USED ..................................................................................................... 4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS ...................................... 5.0-1 5.1 Not Used .............................................................................................. 5.0-1 5.2 Not Used .............................................................................................. 5.0-1 5.3 Not Used .............................................................................................. 5.0-1 5.4 Radioactive Effluent Control Program .................................................. 5.0-1 5.5 Cask Transport Evaluation Program .................................................... 5.0-2 5.6 Not Used .............................................................................................. 5.0-4 5.7 Radiation Protection Program .............................................................. 5.0-5 Table 5-1 TRANSFER CASK Lifting Requirements ............................................. 5.0-3 Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U i

Frequency 1.4 1.0 USE AND APPLICATION 1.1 Definitions Refer to Definitions in Appendix A.

1.2 Logical Connectors Refer to Logical Connectors in Appendix A 1.3 Completion Times Refer to Logical Connectors in Appendix A 1.4 Frequency Refer to Frequency in Appendix A Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 1.1-1

2.0 2.0 This section is intentionally left blank Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 2.0-1

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

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

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

LCO 3.0.3 Not applicable.

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

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.0-1

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

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

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

Exceptions to this Specification are stated in the individual Specifications.

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.0-2

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

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.0-3

Multi-Purpose Canister (MPC) 3.1.1 3.1 SFSC INTEGRITY 3.1.1 Multi-Purpose Canister (MPC)

LCO 3.1.1 The MPC shall be dry and helium filled.

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

MPC Total Decay Heat (Q) Vacuum Drying Time Limit Q < 26 kW None 26 kW < Q <30 kW 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> Q > 30 kW Not Permitted (see Table 3-1)

APPLICABILITY: During TRANSPORT OPERATIONS and STORAGE OPERATIONS.

ACTIONS

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

Separate Condition entry is allowed for each MPC.

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

met.

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

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

allowable time.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.1-1

Multi-Purpose Canister (MPC) 3.1.1 COMPLETION CONDITION REQUIRED ACTION TIME C. MPC helium backfill limit C.1 Perform an engineering 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> not met. evaluation to determine the impact of helium differential.

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

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

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

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.1-2

Multi-Purpose Canister (MPC) 3.1.1 COMPLETION CONDITION REQUIRED ACTION TIME E. Required Actions and E.1 Remove all fuel assemblies 30 days associated Completion from the SFSC.

Times not met.

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

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

SR 3.1.1.3 Verify that the helium leak rate through the MPC Once, prior to vent and drain port confinement welds meets the TRANSPORT leaktight criteria of ANSI N14.5-1997. OPERATIONS Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.1-3

SFSC Heat Removal System 3.1.2 3.1 SFSC INTEGRITY 3.1.2 SFSC Heat Removal System LCO 3.1.2 The SFSC Heat Removal System shall be operable

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

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

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

---

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

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

B. SFSC Heat Removal B.1 Restore SFSC Heat 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> System inoperable. Removal System to operable status.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.2-1

SFSC Heat Removal System 3.1.2 SURVEILLANCE REQUIREMENTS COMPLETION CONDITION REQUIRED ACTION TIME C. Required Action B.1 and C.1 Measure SFSC dose rates Immediately and associated Completion in accordance with the once per 12 Time not met. Radiation Protection hours thereafter Program.

AND C.2.1 Restore SFSC Heat 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> Removal System to operable status.

OR C.2.2 Transfer the MPC into a 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> TRANSFER CASK.

SURVEILLANCE FREQUENCY SR 3.1.2 Verify all VVM inlets and outlets are free of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> blockage from solid debris or floodwater.

OR For VVMs with installed temperature monitoring 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> equipment, verify that the difference between the average VVM air outlet temperature and ISFSI ambient temperature is 85oF for VVMs containing PWR MPCs and 93oF for VVMs containing BWR MPCs.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.2-2

Fuel Cool-Down 3.1.3 3.1 SFSC INTEGRITY 3.1.3 MPC Cavity Reflooding LCO 3.1.3 The MPC cavity pressure shall be < 100 psig

---

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

The LCO is only applicable to wet UNLOADING OPERATIONS.

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

ACTIONS

---

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

Separate Condition entry is allowed for each MPC.

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

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

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

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.3-1

Impressed Current Cathodic Protection System (ICCPS) 3.1.5 3.1 SFSC INTEGRITY 3.1.4 Deleted LCO 3.1.4 Deleted Certificate of Compliance No. 1014 Amendment No. 13 Appendix A 3.1.4-1

3.1 SFSC INTEGRITY 3.1.5 Impressed Current Cathodic Protection System (ICCPS)

LCO 3.1.5 The ICCPS shall be maintained operative APPLICABILITY: During STORAGE OPERATIONS for any ISFSI that uses an ICCPS for corrosion mitigation.

---

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

Separate condition entry is allowed for each ICCPS at a particular ISFSI site.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME C. ICCPS inoperable after A.1 Restore ICCPS to 6 months initial startup period. operable status OR A.2 Perform engineering 1 year evaluation to determine that the affected VVMs will maintain adequate integrity for at least 4 more years.

B. ICCPS 70% operable B.1 Perform engineering 1 year status not met. evaluation to determine that the affected VVMs will maintain adequate integrity for at least 3 more years.

OR B.2 Perform repairs necessary 3 years to re-establish integrity of the affected VVMs C. Required Actions and C.1 Transfer MPCs from 3 years associated Completion affected VVMs to Times not met. unaffected VVMs or other approved overpacks.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.5-1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.5.1 Verify the ICCPS is operable 1 year after installation Once within 1 of the first VVM and remains operable after initial year startup. The ICCPS may be shutdown temporarily as necessary for power outages, repair or preventive AND maintenance and testing, or system modifications after which the system should be returned to operable status as soon as practicable. This Every 1 month surveillance requirement is suspended for one year thereafter after action A.2 has been met SR 3.1.5.2 Verify the ICCPS has been operable for at least Once within 10 70% of the time after initial startup. The verification years shall not be performed prior to 8 years from the time of initial startup. If the integrity of the VVM has AND previously been re-established per ACTION B.2, then the initial startup period may be reset. This surveillance is no longer applicable upon initiation of Every 5 years ACTION C.1. thereafter Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.1.5-2

Not Used 3.2.1 3.2 SFSC RADIATION PROTECTION.

3.2.1 Not Used.

LCO 3.2.1 Not Used.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.2.1-1

TRANSFER CASK Surface Contamination 3.2.2 3.2 SFSC RADIATION PROTECTION.

3.2.2 TRANSFER CASK Surface Contamination.

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

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

b. 20 dpm/100 cm2 from alpha sources.

APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS

---

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

Separate Condition entry is allowed for each TRANSFER CASK.

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

met.

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.2.2-1

Not Used 3.2.3 3.2 SFSC RADIATION PROTECTION.

3.2.3 Not Used.

LCO 3.2.3 Not Used.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.2.3-1

Boron Concentration 3.3.1 3.3 SFSC CRITICALITY CONTROL 3.3.1 Boron Concentration LCO 3.3.1 As required by CoC Appendix B-100U, Table 2.1-2, the concentration of boron in the water in the MPC shall meet the following limits for the applicable MPC model and the most limiting fuel assembly array/class and classification to be stored in the MPC:

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

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

c. Not Used.

d. Not Used.

e. Not Used.

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

All INTACT FUEL ASSEMBLIES Maximum Initial Maximum Initial Array/Class Enrichment Enrichment 5.0

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.3.1-1

Boron Concentration

3.3.1 APPLICABILITY

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

ACTIONS

---

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

Separate Condition entry is allowed for each MPC.

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

AND A.2 Suspend positive reactivity Immediately additions.

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

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

---

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

---

this LCO.

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

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.3.1-2

MPC Helium Backfill Limits Table 3-2 Table 3-1 MPC Cavity Drying Limits for All MPC Types Method of Moisture Fuel Burnup MPC Heat Load Q (kW) Removal (MWD/MTU)

(Notes 1 and 2)

All Assemblies < 45,000 < 30 VDS or FHD All Assemblies < 45,000 > 30 FHD One or more assemblies >

< 36.9 FHD 45,000 Notes:

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

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

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

3. Vacuum drying of the MPC must be performed with the annular gap between the MPC and the HI-TRAC filled with water.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.4-1

MPC Helium Backfill Limits Table 3-2 Table 3-2 MPC Helium Backfill Limits1 MPC MODEL LIMIT MPC-24/24E

i. Cask Heat Load < 27.77 kW (MPC-24) 0.1212 +/-10% g-moles/l or < 28.17 kW (MPC-24E) OR

> 29.3 psig and < 48.5 psig ii. Cask Heat Load >27.77 kW (MPC-24) > 45.5 psig and < 48.5 psig or > 28.17 kW (MPC-24E)

MPC-32

> 29.3 psig and < 48.5 psig

i. Cask Heat Load < 28.74 kW ii. Cask Heat Load >28.74 kW > 45.5 psig and < 48.5 psig MPC-68 0.1218 +/-10% g-moles/l

i. Cask Heat Load < 28.19 kW OR

> 29.3 psig and < 48.5 psig ii. Cask Heat Load > 28.19 kW > 45.5 psig and < 48.5 psig 1

Helium used for backfill of MPC shall have a purity of > 99.995%. Pressure range is at a reference temperature of 70oF Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 3.4-2

4.0 4.0 This section is intentionally left blank Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 4.0-1

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

5.1 Not Used.

5.2 Not Used.

5.3 Not Used.

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

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

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

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-1

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

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

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

a. For the TRANSFER CASK, the following requirements apply:

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

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

(continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-2

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.5 Cask Transport Evaluation Program (continued)

3. The TRANSFER CASK, when loaded with spent fuel, may be lifted to any height necessary during TRANSPORT OPERATIONS provided the lifting device is designed in accordance with ANSI N14.6 and has redundant drop protection features.

4. The TRANSFER CASK and MPC, when loaded with spent fuel, may be lifted to those heights necessary to perform cask handling operations, including MPC TRANSFER, provided the lifts are made with structures and components operated, fabricated, tested, inspected, and maintained in accordance with the guidelines of NUREG-0612, Control of Heavy Loads at Nuclear Power Plants,as applicable, and has devices that prevent uncontrolled lowering of the load.

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

TRANSFER CASK Horizontal 42 (Notes 1 and 2)

TRANSFER CASK Vertical None Established (Note 2)

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

2. See Technical Specification 5.5.a.3 and 4 (continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-3

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.6 Not Used.

(continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-4

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

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

5.7.3 Based on the analysis performed pursuant to Section 5.7.2, the licensee shall establish individual cask surface dose rate limits for the HI-TRAC TRANSFER CASK and the HI-STORM VVM to be used at the site. Total (neutron plus gamma) dose rate limits shall be established at the following locations:

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

b. The side of the TRANSFER CASK

c. The outlet vent on the VVM 5.7.4 Notwithstanding the limits established in Section 5.7.3, the measured dose rates on a loaded VVM shall not exceed 30 mrem/hr (gamma+neutron) on the top of the VVM.

5.7.5 The licensee shall measure the TRANSFER CASK and VVM surface neutron and gamma dose rates as described in Section 5.7.8 for comparison against the limits established in Section 5.7.3 or Section 5.7.4, whichever are lower.

(continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-5

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.7 Radiation Protection Program (contd) 5.7.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.7.3 or Section 5.7.4, the licensee shall:

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

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

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

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

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

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

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

c. A minimum of four (4) dose rate measurements shall be taken on the top of the VVM. These measurements shall be taken approximately 90 degrees apart around the circumference of the lid, approximately 18 inches radially inward from the edge of the lid.

(continued)

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-6

Programs 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS 5.7 Radiation Protection Program (contd)

d. A minimum of four (4) dose rate measurements shall be taken adjacent to the outlet vent screen of the VVM, approximately 90 degrees apart.

5.7.9 The Radiation Protection Space (RPS) is a prismatic subgrade buffer zone surrounding a loaded VVM. The RPS boundary is located at a minimum of fourteen (14) feet from the centerline of a loaded VVM located on the periphery of an operating ISFSI, and at a minimum of twenty-one (21) feet from the centerline of a loaded VVM not located on the periphery. The RPS boundary shall not be encroached upon during any site construction activity.

The jurisdictional boundary of the RPS extends from the top surface of the foundation pad to the top of the VVM interface pad and the top surface pad.

The ISFSI design shall ensure that there is no significant loss of shielding in the RPS due to a credible accident or an extreme environment event during construction involving excavation adjacent to the RPS boundary.

Certificate of Compliance No. 1014 Amendment No. 13 Appendix A-100U 5.0-7