ML21126A270

Attachment 3 - HI-STORM FW Amendment 7 Certificate of Compliance, Appendix a

ML21126A270
Person / Time
Site:	07201032
Issue date:	05/06/2021
From:	Holtec
To:	Office of Nuclear Material Safety and Safeguards
Shared Package
ML21126A266	List: ML21126A267 ML21126A268 ML21126A269 ML21126A270 ML21126A271 ML21126A273 ML21126A290 ML21126A291 ML21126A292 ML21126A293 ML21126A294 ML21126A295 ML21126A296 ML21126A297
References
5018083, CoC No. 1032
Download: ML21126A270 (44)

Text

CERTIFICATE OF COMPLIANCE NO. 1032 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM FW MPC STORAGE SYSTEM to Holtec Letter 5018083 Page 1 of 44

Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-i TABLE OF CONTENTS 1.0 USE AND APPLICATION............................................................................... 1.1-1 1.1 Definitions............................................................................................ 1.1-1 1.2 Logical Connectors.............................................................................. 1.2-1 1.3 Completion Times................................................................................ 1.3-1 1.4 Frequency............................................................................................ 1.4-1 2.0 NOT USED..................................................................................................... 2.0-1 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY............ 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY............................. 3.0-2 3.1 SFSC INTEGRITY............................................................................ 3.1.1-1 3.1.1 Multi-Purpose Canister (MPC)............................................... 3.1.1-1 3.1.2 SFSC Heat Removal System................................................. 3.1.2-1 3.1.3 MPC Cavity Reflooding.......................................................... 3.1.3-1 3.1.4 TRANSFER CASK Heat Removal System.. 3.1.4-1 3.2 SFSC RADIATION PROTECTION................................................... 3.2.1-1 3.2.1 TRANSFER CASK Surface Contamination............................ 3.2.1-1 3.3 SFSC CRITICALITY CONTROL....................................................... 3.3.1-1 3.3.1 Boron Concentration.............................................................. 3.3.1-1 Table 3-1 MPC Cavity Drying Limits.................................................................... 3.4-1 Table 3-2 MPC Helium Backfill Limits................................................................ 3.4-42 4.0 NOT USED..................................................................................................... 4.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS...................................... 5.0-1 5.1 Radioactive Effluent Control Program.................................................. 5.0-1 5.2 Transport Evaluation Program............................................................. 5.0-2 5.3 Radiation Protection Program.............................................................. 5.0-3 to Holtec Letter 5018083 Page 2 of 44

Definitions 1.1 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-1 1.0 USE AND APPLICATION

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

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

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

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

DAMAGED FUEL CONTAINER (DFC)

DFCs are specially designed enclosures for DAMAGED FUEL ASSEMBLIES or FUEL DEBRIS which permit gaseous and liquid media to escape while minimizing dispersal of gross particulates. DFCs authorized for use in the HI-STORM FW System are as follows:

1. Holtec Generic BWR design

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

DFIs are specially designed barriers installed at the top and bottom of the storage cell space which permit flow of gaseous and liquid media while preventing the potential migration of fissile material from fuel assemblies with cladding damage. DFIs are used ONLY with damaged fuel assemblies which can be handled by normal means and whose structural to Holtec Letter 5018083 Page 3 of 44

Definitions 1.1 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-2 1.1 Definitions Term Definition BLEU FUEL FUEL DEBRIS integrity is such that geometric rearrangement of fuel is not expected. Damaged fuel stored in DFIs may contain missing or partial fuel rods and/or fuel rods with known or suspected cladding defects greater than hairline cracks or pinhole leaks.

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

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

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

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

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities on an OVERPACK or TRANSFER CASK while it is being loaded with fuel assemblies. LOADING OPERATIONS begin when the first fuel assembly is placed in the MPC and end when the OVERPACK or TRANSFER CASK is suspended from or secured on the transporter. LOADING OPERATIONS does not include MPC TRANSFER. to Holtec Letter 5018083 Page 4 of 44

Definitions 1.1 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-3 1.1 Definitions Term Definition MULTI-PURPOSE CANISTER (MPC)

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

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

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

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

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

OVERPACK OVERPACKs are the casks which receive and contain the sealed MPCs for interim storage on the ISFSI.

They provide gamma and neutron shielding, and in some versions may provide for ventilated air flow to promote heat transfer from the MPC to the environs.

The term OVERPACK does not include the TRANSFER CASK.

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

REDUNDANT PORT COVER DESIGN REDUNDANT PORT COVER DESIGN refers to two independent port cover plates per port opening, where each port cover plate contains multiple pass closure welds. to Holtec Letter 5018083 Page 5 of 44

Definitions 1.1 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-4 1.1 Definitions Term Definition REPAIRED/RECONSITUTED FUEL ASSEMBLY Spent nuclear fuel assembly which contains dummy fuel rods that displaces an amount of water greater than or equal to the original fuel rods and/or which contains structural repairs so it can be handled by normal means. If irradiated dummy stainless steel rods are present in the fuel assembly, the dummy/replacement rods will be considered in the site specific dose calculations.

SPENT FUEL STORAGE CASKS (SFSCs)

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

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

TRANSFER CASK TRANSFER CASKs are containers designed to contain the MPC during and after loading of spent fuel assemblies, and prior to and during unloading and to transfer the MPC to or from the OVERPACK.

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

TRANSPORT OPERATIONS includes MPC TRANSFER.

UNDAMAGED FUEL ASSEMBLY UNDAMAGED FUEL ASSEMBLIES are: a) fuel assemblies without known or suspected cladding defects greater than pinhole leaks or hairline cracks and which can be handled by normal means; or b) a BWR fuel assembly with an intact channel, a maximum planar average initial of 3.3 wt% U-235, without known or suspected GROSSLY BREACHED SPENT FUEL RODS, and which can be handled by to Holtec Letter 5018083 Page 6 of 44

Definitions 1.1 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 1.1-5 1.1 Definitions Term Definition normal means. An UNDAMAGED FUEL ASSEMBLY may be a REPAIRED/RECONSTITUTED FUEL ASSEMBLY.

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

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

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

ZR ZR means any zirconium-based fuel cladding or fuel channel material authorized for use in a commercial nuclear power plant reactor. to Holtec Letter 5018083 Page 7 of 44

Logical Connectors 1.2 Certificate of Compliance No. 1032 Amendment No.57 Appendix A 1.2-1 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors.

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

BACKGROUND Several levels of logic may be used to state Required Actions.

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

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

(continued) to Holtec Letter 5018083 Page 8 of 44

Logical Connectors 1.2 Certificate of Compliance No. 1032 Amendment No.57 Appendix A 1.2-2 1.2 Logical Connectors EXAMPLES The following examples illustrate the use of logical connectors.

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

A.1 VERIFY...

AND A.2 Restore...

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

(continued) to Holtec Letter 5018083 Page 9 of 44

Logical Connectors 1.2 Certificate of Compliance No. 1032 Amendment No.57 Appendix A 1.2-3 1.2 Logical Connectors EXAMPLES (continued)

EXAMPLE 1.2-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.1 Stop...

OR A.2.1 Verify...

AND A.2.2.1 Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove...

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

to Holtec Letter 5018083 Page 10 of 44

Completion Times 1.3 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 1.3-1 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

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

DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the HI-STORM FW System is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time.

An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the HI-STORM FW System is not within the LCO Applicability.

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

(continued) to Holtec Letter 5018083 Page 11 of 44

Completion Times 1.3 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 1.3-2 1.3 Completion Times (continued)

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

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

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

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

(continued) to Holtec Letter 5018083 Page 12 of 44

Completion Times 1.3 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 1.3-3 1.3 Completion Times (continued)

EXAMPLES (continued)

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

A.1 Restore system to within limit.

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

B.1 Complete action B.1.

AND B.2 Complete action B.2.

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

(continued) to Holtec Letter 5018083 Page 13 of 44

Completion Times 1.3 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 1.3-4 1.3 Completion Times (continued)

EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS

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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 <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time not met.

B.1 Complete action B.1.

AND B.2 Complete action B.2.

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

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

(continued) to Holtec Letter 5018083 Page 14 of 44

Completion Times 1.3 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 1.3-5 1.3 Completion Times (continued)

IMMEDIATE COMPLETION TIME When "Immediately" is used as a Completion Time, the Required Action should be pursued without delay and in a controlled manner. to Holtec Letter 5018083 Page 15 of 44

Frequency 1.4 Certificate of Compliance No. 1032 Amendment No.57 Appendix A 1.4-1 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements.

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

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

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

(continued) to Holtec Letter 5018083 Page 16 of 44

Frequency 1.4 Certificate of Compliance No. 1032 Amendment No.57 Appendix A 1.4-2 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or variables are outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

If the interval as specified by SR 3.0.2 is exceeded while the facility is not in a condition specified in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the specified condition. Failure to do so would result in a violation of SR 3.0.4 (continued) to Holtec Letter 5018083 Page 17 of 44

Frequency 1.4 Certificate of Compliance No. 1032 Amendment No.57 Appendix A 1.4-3 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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting activity AND 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> prior to starting the activity.

The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND"). This type of Frequency does not qualify for the 25% extension allowed by SR 3.0.2.

"Thereafter" indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performance in this example). If the specified activity is canceled or not performed, the measurement of both intervals stops. New intervals start upon preparing to restart the specified activity. to Holtec Letter 5018083 Page 18 of 44

2.0 Certificate of Compliance No. 1032 Appendix A 2.0-1 Revision No. 75 2.0 This section is intentionally left blank to Holtec Letter 5018083 Page 19 of 44

LCO Applicability 3.0 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.0-1 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2.

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

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

LCO 3.0.3 Not applicable.

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

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

to Holtec Letter 5018083 Page 20 of 44

LCO Applicability 3.0 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.0-2 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) to Holtec Letter 5018083 Page 21 of 44

LCO Applicability 3.0 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.0-3 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.3 (continued)

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

SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with Actions or that are related to the unloading of an SFSC. to Holtec Letter 5018083 Page 22 of 44

Multi-Purpose Canister (MPC) 3.1.1 Certificate of Compliance No. 1032 Amendment No. 765 Appendix A 3.1.1-1 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.

APPLICABILITY: Prior to TRANSPORT OPERATIONS ACTIONS

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

Separate Condition entry is allowed for each MPC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

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

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

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

30 days to Holtec Letter 5018083 Page 23 of 44

Multi-Purpose Canister (MPC) 3.1.1 Certificate of Compliance No. 1032 Amendment No. 765 Appendix A 3.1.1-2 ACTIONS (continued)

B.

MPC helium backfill limit not met.

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

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

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

C.

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

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

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

7 days (continued) to Holtec Letter 5018083 Page 24 of 44

Multi-Purpose Canister (MPC) 3.1.1 Certificate of Compliance No. 1032 Amendment No. 765 Appendix A 3.1.1-3 ACTIONS (continued)

D.

Required Actions and associated Completion Times not met.

D.1 Remove all fuel assemblies from the SFSC.

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

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

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

Once, prior to TRANSPORT OPERATIONS to Holtec Letter 5018083 Page 25 of 44

SFSC Heat Removal System 3.1.2 Certificate of Compliance No. 1032 Amendment No. 65 Appendix A 3.1.2-1 3.1 SFSC INTEGRITY 3.1.2 SFSC Heat Removal System LCO 3.1.2 The SFSC Heat Removal System shall be operable

---

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

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

APPLICABILITY: During STORAGE OPERATIONS.

ACTIONS

---

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

Separate Condition entry is allowed for each SFSC.

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

A.1 Remove blockage.

N/A B. SFSC Heat Removal System inoperable.

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

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (continued) to Holtec Letter 5018083 Page 26 of 44

SFSC Heat Removal System 3.1.2 Certificate of Compliance No. 1032 Amendment No. 65 Appendix A 3.1.2-2 ACTIONS (continued)

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

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

Immediately and once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND C.2.1 Restore SFSC Heat Removal System to operable status.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OR C.2.2 Transfer the MPC into a TRANSFER CASK.

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

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to Holtec Letter 5018083 Page 27 of 44

SFSC Heat Removal System 3.1.2 Certificate of Compliance No. 1032 Amendment No. 65 Appendix A 3.1.2-3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlets are free of blockage from solid debris or floodwater.

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

• 137oF for OVERPACKS containing MPC-37s,

• 152oF for OVERPACKS containing BWR

MPCs,

• 130 oF for OVERPACKS containing MPC-32MLs

• 116 oF for OVERPACKS containing MPC-37Ps

• 144 oF for OVERPACKS containing MPC-44s 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to Holtec Letter 5018083 Page 28 of 44

Fuel Cool-Down 3.1.3 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.1.3-1 3.1 SFSC INTEGRITY 3.1.3 MPC Cavity Reflooding LCO 3.1.3 The MPC cavity pressure shall be < 100 psig

---

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

The LCO is only applicable to wet UNLOADING OPERATIONS.

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

ACTIONS

---

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

Separate Condition entry is allowed for each MPC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

MPC cavity pressure not within limit.

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

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

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

Once, prior to MPC re-flooding operations.

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

to Holtec Letter 5018083 Page 29 of 44

TRANSFER CASK Heat Removal System 3.1.4 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.2.4-1 3.1 SFSC INTEGRITY 3.1.4 TRANSFER CASK Heat Removal System LCO 3.1.4 The HI-TRAC VW Version V or V2 Heat Removal System shall be operable

---

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

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

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

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

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

C.1 Provide supplemental cooling OR C.2 Remove MPC from HI-TRAC Immediately to Holtec Letter 5018083 Page 30 of 44

TRANSFER CASK Heat Removal System 3.1.4 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.2.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.4 Verify all HI-TRAC VW Version V or V2 inlets and outlets are free of blockage from debris.

Immediately and once every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to Holtec Letter 5018083 Page 31 of 44

TRANSFER CASK Contamination 3.2.1 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.2.4-1 3.2 SFSC RADIATION PROTECTION.

3.2.1 TRANSFER CASK Surface Contamination.

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

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

b. 20 dpm/100 cm2 from alpha sources.

---

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

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

APPLICABILITY: During TRANSPORT OPERATIONS.

ACTIONS

---

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

Separate Condition entry is allowed for each TRANSFER CASK.

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

A.1 Restore removable surface contamination to within limits.

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

Once, prior to TRANSPORT OPERATIONS to Holtec Letter 5018083 Page 32 of 44

Boron Concentration 3.3.1 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 3.3.1-1 3.3 SFSC CRITICALITY CONTROL 3.3.1 Boron Concentration LCO 3.3.1 The concentration of boron in the water in the MPC shall meet the following limits for the applicable MPC model and the most limiting fuel assembly array/class to be stored in the MPC:

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

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

Maximum Initial Enrichment 5.0 wt% 235U (ppmb)

Maximum Initial Enrichment 4.0 wt% 235U (ppmb)

Maximum Initial Enrichment 5.0 wt% 235U (ppmb)

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

---

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

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

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

APPLICABILITY:

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

to Holtec Letter 5018083 Page 33 of 44

Boron Concentration 3.3.1 Certificate of Compliance No. 1032 Amendment No. 57 Appendix A 3.3.1-2 ACTIONS

---

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

Separate Condition entry is allowed for each MPC.

CONDITION REQUIRED ACTION COMPLETION TIME A.

Boron concentration not within limit.

A.1 Suspend LOADING OPERATIONS or UNLOADING OPERATIONS.

Immediately AND A.2 Suspend positive reactivity additions.

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

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

---

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

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

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

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

AND Once per 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> thereafter. to Holtec Letter 5018083 Page 34 of 44

3.4 Tables Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-1 Table 3-1 MPC Cavity Drying Limits Fuel Burnup (MWD/MTU)

MPC Type MPC Heat Load (kW)

Method of Moisture Removal (Notes 1 and 2)

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

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

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

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

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

MPC-89 29 (Table 2.3-10A of Appendix B or pattern developed in accordance with Table 2.3-10B of Appendix B) 46.36 (Table 2.3-2A of Appendix B) 46.2 (Figures 2.3-10 and 2.3-11 of Appendix B) 46.14 (Figures 2.3-12 and 2.3-13 of Appendix B) to Holtec Letter 5018083 Page 35 of 44

3.4 Tables Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-2 Fuel Burnup (MWD/MTU)

MPC Type MPC Heat Load (kW)

Method of Moisture Removal (Notes 1 and 2)

One or more assemblies

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

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

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

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

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

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

One or more assemblies

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

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

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

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

MPC-44 44 (Table 2.3-8A of Appendix B) to Holtec Letter 5018083 Page 36 of 44

3.4 Tables Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-3 Fuel Burnup (MWD/MTU)

MPC Type MPC Heat Load (kW)

Method of Moisture Removal (Notes 1 and 2)

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

Notes:

1.

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

2.

FHD means a forced helium dehydration system. The acceptance criterion when using an FHD system is the gas temperature exiting the demoisturizer shall be 21oF for 30 minutes or the gas dew point exiting the MPC shall be 22.9oF for 30 minutes.

3.

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

4.

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

5.

Vacuum drying of the MPC must be performed using cycles of the drying system, according to the guidance contained in ISG-11 Revision 3. The time limit for these cycles shall be determined based on site specific conditions. to Holtec Letter 5018083 Page 37 of 44

3.4 Tables Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 3.4-4 Table 3-2 MPC Helium Backfill Limits1 MPC Model Decay Heat Limits Applied (per Appendix B Section 2.3)

Pressure range (psig)

MPC-37 Table 2.3-1C Table 2.3-3 42.0 and 50.0 Table 2.3-1B 42.0 and 47.8 Table 2.3-1A, Pattern A 42.0 and 45.5 Table 2.3-1A, Pattern B 41.0 and 46.0 Figure 2.3-1 Figure 2.3-2 Figure 2.3-3 45.5 and 49.0 Figure 2.3-4 Figure 2.3-5 Figure 2.3-6 44.0 and 47.5 Figure 2.3-7 Figure 2.3-8 Figure 2.3-9 44.5 and 48.0 Table 2.3-9A Table 2.3-9B 41.0 and 44.0 MPC-89 Table 2.3-2B Table 2.3-4 42.0 and 50.0 Table 2.3-2A 42.5 and 47.5 Figure 2.3-10 Figure 2.3-11 Figure 2.3-12 Figure 2.3-13 42.0 and 47.0 Table 2.3-10A Table 2.3-10B 42.5 and 45.5 MPC-32ML Table 2.3-5, All Patterns 41.5 and 45.5 MPC-37P Table 2.3-1A, Pattern A 42.0 and 45.5 Table 2.3-1A, Pattern B 41.0 and 46.0 Table 2.3-7A Table 2.3-7B 44.0 and 47.0 MPC-44 Table 2.3-8A Table 2.3-8B Table 2.3-13 41.0 and 44.0 1 Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF to Holtec Letter 5018083 Page 38 of 44

4.0 Certificate of Compliance No. 1032 Amendment No. 75 Appendix A 4.0-1 4.0 This section is intentionally left blank to Holtec Letter 5018083 Page 39 of 44

Programs 5.0 Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-1 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS The following programs shall be established, implemented and maintained.

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

a.

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

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

b.

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

to Holtec Letter 5018083 Page 40 of 44

Programs 5.0 Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-2 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.2 Transport Evaluation Program

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

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

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

1.

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

2.

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

3.

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

4.

For existing handling equipment which does not meet the above criteria, a site-specific drop analysis shall be performed as part of the 10 CFR 72.212 report to demonstrate that the acceptance criteria set forth in the HI-STORM FW FSAR are met. The analysis shall be performed using methodologies consistent with those described in the HI-STORM FW FSAR. to Holtec Letter 5018083 Page 41 of 44

Programs 5.0 Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-3 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program 5.3.1 Each cask user shall ensure that the Part 50 radiation protection program appropriately addresses dry storage cask loading and unloading, as well as ISFSI operations, including transport of the loaded OVERPACK or TRANSFER CASK outside of facilities governed by 10 CFR Part 50. The radiation protection program shall include appropriate controls for direct radiation and contamination, ensuring compliance with applicable regulations, and implementing actions to maintain personnel occupational exposures As Low As Reasonably Achievable (ALARA). The actions and criteria to be included in the program are provided below.

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

5.3.3 Based on the analysis performed pursuant to Section 5.3.2, the licensee shall establish individual cask surface dose rate limits for the TRANSFER CASK and the OVERPACK to be used at the site. Total (neutron plus gamma) dose rate limits shall be established at the following locations:

a.

The top of the OVERPACK.

b.

The side OVERPACK

c.

The side of the TRANSFER CASK

d.

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

a.

15 mrem/hr (gamma + neutron) on the top of the OVERPACK

b.

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

c.

3500 mrem/hr (gamma + neutron) on the side of the TRANSFER CASK 5.3.5 The licensee shall measure the TRANSFER CASK and OVERPACK surface neutron and gamma dose rates as described in Section 5.3.8 for comparison against the limits established in Section 5.3.3 or Section 5.3.4, whichever are lower. to Holtec Letter 5018083 Page 42 of 44

Programs 5.0 Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-4 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued) 5.3.6 If the measured surface dose rates exceed the lower of the two limits established in Section 5.3.3 or Section 5.3.4, the licensee shall:

a.

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

b.

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

c.

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

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

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

a.

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

b.

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

One measurement set shall be taken approximately at the cask mid-height plane, 90 degrees apart around the circumference of the cask. The second and third measurement sets shall be taken approximately 60 inches above and below the mid-height plane, respectively, also 90 degrees apart around the circumference of the cask. to Holtec Letter 5018083 Page 43 of 44

Programs 5.0 Certificate of Compliance No. 1032 Amendment No. 675`

Appendix A 5.0-5 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS (continued) 5.3 Radiation Protection Program (continued)

c.

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

d.

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

to Holtec Letter 5018083 Page 44 of 44