ML21349B420

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Attachment 1: Proposed HI-STORM 100 CoC Amendment 18 (non-proprietary)
ML21349B420
Person / Time
Site: Holtec
Issue date: 12/15/2021
From:
Holtec
To:
Office of Nuclear Material Safety and Safeguards
Shared Package
ML21349B418 List:
References
5014937
Download: ML21349B420 (28)
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Text

ATTACHMENT 1 TO HOLTEC LETTER 5014937 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (10-2004) 10 CFR 72 CERTIFICATE OF COMPLIANCE FOR SPENT FUEL STORAGE CASKS Page 1 of 5 The U.S. Nuclear Regulatory Commission is issuing this Certificate of Compliance pursuant to Title 10 of the Code of Federal Regulations, Part 72, "Licensing Requirements for Independent Storage of Spent Nuclear Fuel and High-Level Radioactive Waste" (10 CFR Part 72). This certificate is issued in accordance with 10 CFR 72.238, certifying that the storage design and contents described below meet the applicable safety standards set forth in 10 CFR Part 72, Subpart L, and on the basis of the Final Safety Analysis Report (FSAR) of the cask design. This certificate is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, and the conditions specified below.

Certificate No. Effective Expiration Docket No. Amendment No. Amendment Effective Date Package Identification No.

Date Date 1014 05/31/00 05/31/20 72-1014 178 TBD USA/72-1014 Issued To: (Name/Address)

Holtec International Holtec Technology Campus One Holtec Blvd.

Camden, NJ 08104 Safety Analysis Report Title Holtec International Inc.,

Final Safety Analysis Report for the HI-STORM 100 Cask System CONDITIONS This certificate is conditional upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Technical Specifications) and Appendix B (Approved Contents and Design Features) for aboveground systems except Version E, HI-TRAC MS, MPC-32M, and Version 1 of MPC-32 and MPC-68; the attached Appendix C (Technical Specifications) and Appendix D (Approved Contents and Design Features) for the HI-STORM 100S Version E, HI-TRAC MS, MPC-32M, and Version 1 of MPC-32 and MPC-68M; or the attached Appendix A-100U (Technical Specifications) and Appendix B-100U (Approved Contents and Design Features) for underground systems, and the conditions specified below:

1. CASK
a. Model No.: HI-STORM 100 Cask System The HI-STORM 100 Cask System (the cask) consists of the following components: (1) interchangeable multi-purpose canisters (MPCs), which contain the fuel; (2) a storage overpack (HI-STORM), which contains the MPC during storage; and (3) a transfer cask (HI-TRAC), which contains the MPC during loading, unloading and transfer operations. The cask stores up to 32 pressurized water reactor fuel assemblies or 68 boiling water reactor fuel assemblies.
b. Description The HI-STORM 100 Cask System is certified as described in the Final Safety Analysis Report (FSAR) and in the U.S. Nuclear Regulatory Commissions (NRC) Safety Evaluation Report (SER) accompanying the Certificate of Compliance (CoC). The cask comprises three discrete components: the MPC, the HI-TRAC transfer cask, and the HI-STORM storage overpack.

The MPC is the confinement system for the stored fuel. It is a welded, cylindrical canister with a honeycombed fuel basket, a baseplate, a lid, a closure ring, and the canister shell. All portions of MPC components that may come into contact with spent fuel pool water or the ambient environment are made of stainless steel or passivated aluminum/aluminum alloys such as the neutron absorbers. The canister shell, baseplate, lid, vent and drain port cover plates, and closure ring are the main confinement boundary components. All confinement boundary components are made entirely of stainless steel. The honeycombed basket, which contains neutron absorbing material, provides criticality control.

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ATTACHMENT 1 TO HOLTEC LETTER 5014937 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 187 Supplemental Sheet Page 2 of 5

1. b. Description (continued)

There are twelve types of MPCs: the MPC-24, MPC-24E, MPC-24EF, MPC-32, MPC-32F, MPC-32 Version 1, MPC-32M, MPC-68, MPC-68 Version 1, MPC-68F, MPC-68FF, and MPC-68M. The number suffix indicates the maximum number of fuel assemblies permitted to be loaded in the MPC. All twelve MPC models have the same external diameter.

The HI-TRAC transfer cask provides shielding and structural protection of the MPC during loading, unloading, and movement of the MPC from the spent fuel pool to the storage overpack. The transfer cask is a multi-walled (carbon steel/lead/carbon steel) cylindrical vessel with a neutron shield jacket attached to the exterior.

All transfer cask sizes have identical cavity diameters. The higher weight HI-TRAC transfer casks have thicker shielding and larger outer dimensions than the lighter HI-TRAC transfer casks.

Above Ground Systems The HI-STORM 100 or 100S storage overpack provides shielding and structural protection of the MPC during storage. The HI-STORM 100S is a variation of the HI-STORM 100 overpack design. The overpack is a heavy-walled steel and concrete, cylindrical vessel. Its side wall consists of plain (un-reinforced) concrete that is enclosed between inner and outer carbon steel shells. The overpack has air vents at the bottom and at the top to allow air to circulate naturally through the cavity to cool the MPC inside. A loaded MPC is stored within the HI-STORM 100 or 100S storage overpack in a vertical orientation. The HI-STORM 100A and 100SA are variants of the HI-STORM 100 family and are outfitted with an extended baseplate and gussets to enable the overpack to be anchored to the concrete storage pad in high seismic applications. The version E can be arrayed in a free standing or anchored configuration.

Underground Systems The HI-STORM 100U System is an underground storage system identified with the HI-STORM 100 Cask System. The HI-STORM 100U storage Vertical Ventilated Module (VVM) utilizes a storage design identified as an air-cooled vault or caisson. The HI-STORM 100U storage VVM relies on vertical ventilation instead of conduction through the soil, as it is essentially a below-grade storage cavity. Air inlets and outlets allow air to circulate naturally through the cavity to cool the MPC inside. The subterranean steel structure is seal welded to prevent ingress of any groundwater from the surrounding subgrade, and it is mounted on a stiff foundation.

The surrounding subgrade and a top surface pad provide significant radiation shielding. A loaded MPC is stored within the HI-STORM 100U storage VVM in the vertical orientation.

2. OPERATING PROCEDURES Written operating procedures shall be prepared for cask handling, loading, movement, surveillance, and maintenance. The users site-specific written operating procedures shall be consistent with the technical basis described in Chapter 8 of the FSAR.
3. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM Written cask acceptance tests and maintenance program shall be prepared consistent with the technical basis described in Chapter 9 of the FSAR.

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ATTACHMENT 1 TO HOLTEC LETTER 5014937 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 178 Supplemental Sheet Page 3 of 5

4. QUALITY ASSURANCE Activities in the areas of design, purchase, fabrication, assembly, inspection, testing, operation, maintenance, repair, modification of structures, systems and components, and decommissioning that are important to safety shall be conducted in accordance with a Commission-approved quality assurance program which satisfies the applicable requirements of 10 CFR Part 72, Subpart G, and which is established, maintained, and executed with regard to the cask system.
5. HEAVY LOADS REQUIREMENTS Each lift of an MPC, a HI-TRAC transfer cask, or any HI-STORM overpack must be made in accordance to the existing heavy loads requirements and procedures of the licensed facility at which the lift is made. A plant-specific review (under 10 CFR 50.59 or 10 CFR 72.48, if applicable) is required to show operational compliance with existing plant specific heavy loads requirements. Lifting operations outside of structures governed by 10 CFR Part 50 must be in accordance with Section 5.5 of Appendix A or Section 5.2 of Appendix C and Sections 3.4.6 and 3.5 (if applicable) of Appendix B or D, for above ground systems, section 5.5 of Appendix A-100U for the underground systems.
6. APPROVED CONTENTS Contents of the HI-STORM 100 Cask System must meet the fuel specifications given in Appendices B or D, as applicable, for aboveground systems or B-100U for underground systems to this certificate.
7. DESIGN FEATURES Features or characteristics for the site, cask or ancillary equipment must be in accordance with Appendices B or D, as applicable, for aboveground systems or B-100U for underground systems to this certificate.
8. CHANGES TO THE CERTIFICATE OF COMPLIANCE The holder of this certificate who desires to make changes to the certificate, which includes Appendices A, C, and A-100U (Technical Specifications) and Appendices B, D, and B-100U (Approved Contents and Design Features), shall submit an application for amendment of the certificate.
9. SPECIAL REQUIREMENTS FOR FIRST SYSTEMS IN PLACE
a. For the storage configuration, each user of a HI-STORM 100 Cask and HI-STORM 100U Cask with a heat load equal to or greater than 20 kW shall perform a thermal validation test in which the user measures the total air mass flow rate through the cask system using direct measurements of air velocity in the inlet vents. The user shall then perform an analysis of the cask system with the taken measurements to demonstrate that the measurements validate the analytic methods described in Chapter 4 of the FSAR. The thermal validation test and analysis results shall be submitted in a letter report to the NRC pursuant to 10 CFR 72.4 within 180 days of the users loading of the first cask with a heat load equal to or greater than 20 kW. To satisfy condition 9(a) for casks of the same system type (i.e., HI-STORM 100 casks, HI-STORM 100U casks), in lieu of additional submittals pursuant to 10 CFR 72.4, users may document in their 72.212 report a previously performed test and analysis submitted by letter report to the NRC that demonstrates validation of the analytic methods described in Chapter 4 of the FSAR.
b. For the transfer configuration, each user of the HI-STORM 100 Cask and HI-STORM 100U Cask shall procure, if necessary, a Supplemental Cooling System (SCS) capable of providing the thermal-hydraulic characteristics (coolant temperature at the annulus inlet, coolant temperature located at the annulus outlet, and coolant flow rate) that will ensure that thermal limits (described in Appendix 2.C of the FSAR) are not exceeded during transfer operations. The thermal-hydraulic characteristics of the SCS shall be determined using the analytical methods described in Chapter 4 for the transfer configuration. For the transfer configuration, each first time user shall measure the SCS thermal-hydraulic characteristics to validate the performance of the SCS. The SCS analysis and validation shall be documented in an update to the 72.212 report within 180 days of the users first transfer operation with the SCS. Condition 9(b) does not apply to the MPC-68M or the MPC-32M.

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ATTACHMENT 1 TO HOLTEC LETTER 5014937 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 178 Supplemental Sheet Page 4 of 5

10. PRE-OPERATIONAL TESTING AND TRAINING EXERCISE A dry run training exercise of the loading, closure, handling, unloading, and transfer of the HI-STORM 100 Cask System shall be conducted by the licensee prior to the first use of the system to load spent fuel assemblies. The training exercise shall not be conducted with spent fuel in the MPC. The dry run may be performed in an alternate step sequence from the actual procedures, but all steps must be performed. The dry run shall include, but is not limited to the following:
a. Moving the MPC and the transfer cask into the spent fuel pool or cask loading pool.
b. Preparation of the HI-STORM 100 Cask System for fuel loading.
c. Selection and verification of specific fuel assemblies to ensure type conformance.
d. Loading specific assemblies and placing assemblies into the MPC (using a dummy fuel assembly),

including appropriate independent verification.

e. Remote installation of the MPC lid and removal of the MPC and transfer cask from the spent fuel pool or cask loading pool.
f. MPC welding, NDE inspections, pressure testing, draining, moisture removal (by vacuum drying or forced helium dehydration, as applicable), and helium backfilling. (A mockup may be used for this dry-run exercise.)
g. Operation of the HI-STORM 100 SCS or equivalent system, if applicable.
h. Transfer cask upending/downending on the horizontal transfer trailer or other transfer device, as applicable to the sites cask handling arrangement.
i. Transfer of the MPC from the transfer cask to the overpack/VVM.
j. Placement of the HI-STORM 100 Cask System at the ISFSI, for aboveground systems only.
k. HI-STORM 100 Cask System unloading, including flooding MPC cavity, removing MPC lid welds. (A mockup may be used for this dry-run exercise.)
11. The NRC has approved an exemption request by the CoC applicant from the requirements of 10 CFR 72.236(f), to allow a Supplemental Cooling System to provide for decay heat removal in accordance with Section 3.1.4 of Appendices A, C, and A-100U.

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ATTACHMENT 1 TO HOLTEC LETTER 5014937 NRC FORM 651 U.S. NUCLEAR REGULATORY COMMISSION (3-1999) 10 CFR 72 CERTIFICATE OF COMPLIANCE Certificate No. 1014 FOR SPENT FUEL STORAGE CASKS Amendment No. 187 Supplemental Sheet Page 5 of 5

12. AUTHORIZATION The HI-STORM 100 Cask System, which is authorized by this certificate, is hereby approved for general use by holders of 10 CFR Part 50 licenses for nuclear reactors at reactor sites under the general license issued pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR 72.212, this certificate, and the attached Appendices A, B, A-100U, B-100U, C, and D as applicable. The HI-STORM 100 Cask System may be fabricated and used in accordance with any approved amendment to CoC No. 1014 listed in 10 CFR 72.214. Each of the licensed HI-STORM 100 System components (i.e., the MPC, overpack, and transfer cask), if fabricated in accordance with any of the approved CoC Amendments, may be used with one another provided an assessment is performed by the CoC holder that demonstrates design compatibility.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION TBD, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555 Dated TBD Attachments:

1. Appendix A
2. Appendix B
3. Appendix A-100U
4. Appendix B-100U
5. Appendix C
6. Appendix D 5 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX A TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100 CASK SYSTEM 6 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 SFSC Heat Removal System 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlets are free Table 3-5 of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature Table 3-5 monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is

< 155oF for OVERPACKS containing PWR MPCs, < 137oF for OVERPACKS containing BWR MPCs (except MPC-68M) and 164°F for OVERPACKS containing MPC-68M. For sites that have loaded in accordance with the Topical Report HI-2200343-A, Revision 2, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is less than or equal to the value computed using the topical report methodology.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix A 3.1.2-2 7 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Helium Backfill Limits Table 3-2 Table 3-1a MPC Cavity Drying Limits for all MPC Types for VENTILATED OVERPACK Note 9 Method of Moisture Fuel Burnup MPC Heat Load (kW) Removal (MWD/MTU)

(Notes 1 and 2) 26 (MPC-24/24E/24EF, MPC-32/32F, VDSNote 5 or FHDNote 6 MPC-68/68F/68FF)

All Assemblies < 45,000 36.9 (MPC-68M)Note 6 VDS or FHD 42.8 (MPC-68M)Note 7 VDS or FHD 36.9 (MPC-24/24E/24EF, All Assemblies < 45,000 MPC-32/32F, VDSNote 8 or FHD MPC-68/68F/68FF)Note 6 One or more assemblies 29 (MPC-68M) VDSNote 4

> 45,000 36.9 (MPC-24/24E/24EF/MPC-32/32F/MPC-68/68F/68FF)Note6 VDSNote8 or FHD One or more assemblies

> 45,000 36.9 (MPC-68M)Note6 VDSNote8 or FHD 42.8 (MPC-68M)Note 7 VDSNote8 or FHD Notes:

9. 1. VDS means a vacuum drying system. The acceptance criterion when using a VDS is MPC cavity pressure shall be < 3 torr for > 30 minutes.
9. 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.

9. 3. Vacuum drying of the system must be performed with the annular gap between the MPC and the TRANSFER CASK filled with water.
9. 4. The maximum allowable decay heat per fuel storage location is 0.426 kW.
5. Maximum allowable storage cell heat load is 1.083 kW (MPC-24/24E/24EF), 0.812 kW (MPC-32/32F) and 0.382 kW (MPC-68/68F/68FF).
6. Maximum per assembly allowable heat loads under uniform or regionalized storage defined in Appendix B, Section 2.4.1 or 2.4.2.
7. Maximum per assembly allowable heat loads defined in Appendix B Figures 2.4-1 through 2.4-4.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-32 8 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Helium Backfill Limits Table 3-2

8. 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. Applies when any one assembly heat load is greater than 0.426 kW.
9. Alternative heat load limits may be developed following the methodology in Topical Report HI-2200343-A, Revision 2. These patterns must have a total MPC heat load less than or equal to 50 kW. Dryness criteria are still as specified in Notes 1 or 2 as applicable to the selected drying process, and Note 3 still applies to vacuum drying.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-42 9 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Helium Backfill Limits Table 3-2 Table 3-2a MPC Helium Backfill Limits for VENTILATED OVERPACKNote 1,21 MPC MODEL LIMIT MPC-24/24E/24EF

i. Cask Heat Load 27.77 kW (MPC-24) 0.1212 +/-10% g-moles/l or 28.17 kW (MPC-24E/EF) - OR uniformly distributed per Table 3-4 or 29.3 psig and 48.5 psig regionalized loading per Table 3-3 ii. Cask Heat Load >27.77 kW (MPC-24) or > 28.17 kW (MPC-24E/EF) -

uniformly distributed 45.5 psig and 48.5 psig or greater than regionalized heat load limits per Table 3-3 MPC-68/68F/68FF

i. Cask Heat Load 28.19 kW - 0.1218 +/-10% g-moles/l uniformly distributed per Table 3-4 OR or regionalized loading per Table 3-3 29.3 psig and 48.5 psig ii. Cask Heat Load > 28.19 kW -

uniformly distributed or 45.5 psig and 48.5 psig greater than regionalized heat load limits per Table 3-3 MPC-32/32F

i. Cask Heat Load 28.74 kW -

uniformly distributed per Table 3-4 29.3 psig and 48.5 psig or regionalized loading per Table 3-3 ii. Cask Heat Load >28.74 kW -

uniformly distributed or 45.5 psig and 48.5 psig greater than regionalized heat load limits per Table 3-3 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. 186 Appendix A 3.3.1-62 10 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Helium Backfill Limits Table 3-2 MPC-68M

i. Cask Heat Load 28.19 kW -

uniformly distributed per Table 3-4 0.1218 +/-10% g-moles/l or OR regionalized loading per Table 3-3 29.3 psig and 48.5 psig ii. Cask Heat Load > 28.19 kW -

uniformly distributed 45.5 psig and 48.5 psig or greater than regionalized heat load limits per Table 3-3 iii. Cask Heat Load 42.8 kW QSHL Loading Pattern shown in 43.5 psig and 46.5 psig Appendix B, Figure 2.4-1 QSHL patterns shown in Appendix B, 45.5 psig and 48.5 psig Figures 2.4-2 through2.4-4 Notes

1. Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF
2. For heat load patterns developed in accordance with Table 3-1, Note 9, helium backfill limits shall be calculated in accordance with Topical Report HI-2200343-A Revision 2 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-72 11 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Heat Load Limits Table 3-3 Table 3-3: Regionalized StorageNote 2 Cell Heat Load Limits MPC Type Number of Storage Cell Number of Storage Cell Cells in Inner Heat Load Cells in Outer Heat Load RegionNote 1 (Inner Region) RegionNote 1 (Outer (kW) Region)

(kW)

MPC-24 4 1.470 20 0.900 MPC-24E/EF 4 1.540 20 0.900 MPC-32/32F 12 1.131 20 0.600 MPC- 32 0.500 36 0.275 68/68F/68FF/68M Note 1: The location of MPC-32 and MPC-68 inner and outer region cells are defined in Appendix B Figures 2.1-3 and 2.1-4 respectively.

The MPC-24 and MPC-24E/EF cell locations are defined below:

Inner Region Cell numbers 9, 10, 15, 16 in Appendix B Figures 2.1-1 and 2.1-2 respectively.

Outer Region Cell numbers 1-8, 11-14, 17-24 in Appendix B Figures 2.1-1 and 2.1-2 respectively.

Note 2: The storage cell regionalization is defined in Note 1 in accordance with safety analyses under the heat load limits of this Table. For heat load patterns developed in accordance with Table 3-1, Note 9, these limits do not apply.

Table 3-4: Uniform Storage Cell Heat Load Limits MPC Type Heat Load (kW)

MPC-24 1.157 MPC-24E/EF 1.173 MPC-68/68F/68FF/68M 0.414 MPC-32 0.898 Note: For heat load patterns developed in accordance with Table 3-1, Note 9, these limits do not apply.

Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-92 12 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 LCO Completion Time Table 3-5 Table 3-5: Completion Time for Actions to Restore SFSC Heat Removal System OperableNote 2 Decay Heat Limits per Condition B Condition C Surveillance MPC Material MPC Type Storage Location Completion Time Completion Time Frequency MPC-24/24E/24EF MPC-32/32F Appendix B, Section 2.4 Alloy X Except 8 hrs 24 hrs 24 hrs Duplex1 MPC-68/68F/68FF/68M MPC-68M Appendix B, Figures 2.4-1 through 2.4-4 MPC-24/24E/24EF Alloy X MPC-32/32F Appendix B, Section 2.4 8 hrs 16 hrs 16 hrs MPC-68/68F/68FF/68M Alloy X MPC-68M Appendix B, Figures 4 hrs 12 hrs 12 hrs 2.4-1 through 2.4-4 MPC-24 Appendix A, Table 3-3 (Regionalized)

MPC-24E/EF Alloy X Except 1 OR 8 hrs 64 hrs 24 hrs Duplex MPC-32/32F Appendix A, Table 3-4 MPC-68/68F/68FF/68M (Uniform)

MPC-24 Appendix A, Table 3-3 (Regionalized)

MPC-24E/EF Alloy X OR 8 hrs 24 hrs 24 hrs MPC-32/32F Appendix A, Table 3-4 MPC-68/68F/68FF/68M (Uniform)

MPC-24/24E/24EF 0.75 kW Alloy X MPC-32/32F 0.5 kW 24 hrs 64 hrs 30 days MPC-68/68F/68FF/68M 0.264 kW Note

2) 1) If any component of the MPC is made of duplex, these completion times are not applicable.
2) For patterns developed in accordance with Table 3-1, Note 9, alternative completion times shall be calculated in accordance with Topical Report HI-2200343-A Revision 2 Certificate of Compliance No. 1014 Amendment No. 186 Appendix A 3.3.1-102 13 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX B APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM 100 CASK SYSTEM 14 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 2.4.2 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for VENTILATED OVERPACK The maximum allowable decay heat per fuel storage location for intact or undamaged fuel assemblies in regionalized loading is determined using the following equations:

Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:

Q0 = Maximum uniform storage MPC decay heat (34 kW)

X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.4-2.

n2 = Number of storage locations in outer region from Table 2.4-2.

Allowable heat loads for Damaged Fuel and Fuel Debris in regionalized loading are shown in Table 2.4-5.

Optional loading patterns for MPC-68M are shown in Figures 2.4-1 through 2.4-4.

Alternatively to the heat load patterns in Sections 2.4.1 and 2.4.2, per cell allowable heat loads may be determined per Topical Report HI-2200343-A Revision 2.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-51 15 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 2.4.3 Burnup Limits as a Function of Cooling Time for ZR-Clad Fuel for VENTILATED OVERPACK The maximum allowable ZR-clad fuel assembly average burnup varies with the minimum required fuel assembly cooling time. Tables 2.4-3 and 2.4-4 provide for each MPC the allowable maximum burnup based on the assemblys particular cooling time.These same limits apply for heat load patterns developed in accordance with the topical report, HI-2200343-A, Revision 2.

2.4.3.2 2.4.3.1 Linear interpolation of burnups between cooling times is permitted. For example, the allowable burnup for a cooling time of 4.5 years may be interpolated between those burnups calculated for 4 year and 5 years.

2.4.3.22.4.3.3 Calculated burnup limits shall be rounded down to the nearest integer.

2.4.3.4 2.4.3.3 Calculated burnup limits greater than 68,200 MWD/MTU for PWR fuel and 65,000 MWD/MTU for BWR must be reduced to be equal to these values.

2.4.4 When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.

2.4.5 Fuel Loading Decay Heat Limits for UNVENTILATED OVERPACK Tables 2.4-6a and 2.4-6b provide the maximum allowable decay heat per fuel storage location for MPC-68M in an UNVENTILATED OVERPACK.

A minor deviation from the prescribed loading pattern in an MPCs permissible contents to allow one slightly thermally-discrepant fuel assembly per quadrant to be loaded as long as the peak cladding temperature for the MPC remains below the ISG-11 Rev 3 requirements is permitted for essential dry storage campaigns to support decommissioning.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-53 16 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 2.4.6 Burnup and Cooling Time Qualifications for the MPC-68M for UNVENTILATED OVERPACK The burnup and cooling time for every fuel loaded into the MPC-68M must satisfy the following equation:

= 3 + 2 + +

where, Ct = Minimum cooling time (years),

Bu = Assembly-average burnup (MWd/mtU),

A, B, C, D= Polynomial coefficients listed in Table 2.4-9 These same limits apply for heat load patterns developed in accordance with the topical report HI-2200343-A, Revision 2.

Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-54 17 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 TABLE 2.4-9 Burnup and Cooling Time Fuel Qualification Requirements for MPC-68M for UNVENTILATED OVERPACK Polynomial Coefficients, see Subsection 2.4.5 Cell Decay Heat Load Limit (kW) A B C D 0.382 9.44656e-14 -8.01992e-09 2.79524e-04 -4.10441e-01

>0.382 < decay heat 8.59250e-15 -1.40950e-09 9.57523e-05 -1.02585e+00 1.625 Certificate of Compliance No. 1014 Amendment No. 168 Appendix B 2-59 18 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX C TECHNICAL SPECIFICATIONS FOR THE HI-STORM 100S VERSION E CASK 19 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 SFSC Heat Removal System 3.1.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.2 Verify all OVERPACK inlets and outlet area are Table 3-3 free of blockage from solid debris or floodwater.

OR For OVERPACKS with installed temperature Table 3-3 monitoring equipment, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is

< 142oF (MPC-32M), or < 163oF (MPC-32 Version 1/MPC-68 Version 1), or < 155oF (MPC-24/24E/24EF/32/32F), or < 137oF (MPC-68/68F/68FF) or < 164oF (MPC-68M).

For sites that have loaded in accordance with the Topical Report HI-2200343-A, Revision 2, verify that the difference between the average OVERPACK air outlet temperature and ISFSI ambient temperature is less than or equal to the value computed using the topical report methodology.

Certificate of Compliance No. 1014 Amendment No. 158 Appendix C 3.1.2-2 20 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Cavity Drying Limits Table 3-1 Table 3-1a MPC Cavity Drying Limits for VENTILATED OVERPACKNote 7, 13 Method of Moisture Fuel Burnup MPC Heat Load (kW) Note 12 Removal (MWD/MTU)

(Notes 1, 2, and 3) 26 (MPC-32 Version 1, VDSNote 5 or FHDNote 6 MPC-68 Version 1) 36.9 (MPC-32 Version 1, All Assemblies < 45,000 VDSNote 8 or FHD MPC-68 Version 1)Note 6 41.2 (MPC-32M)Note 9 VDS or FHD 40 (MPC-32M)Note 10 27 (MPC-32M) VDSNote 4 36.9 (MPC-32 Version 1, One or more assemblies VDSNote 8 or FHD MPC-68 Version 1)Note 6

> 45,000 41.2 (MPC-32M)Note 9 VDSNote 8,11 or FHD 40 (MPC-32M)Note 10 Notes:

1. VDS means a vacuum drying system. The acceptance criterion when using a VDS is 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 system must be performed with the annular gap between the MPC and the TRANSFER CASK filled with water.
4. The maximum allowable decay heat per fuel storage location is 0.843 kW for MPC-32M.
5. Maximum allowable storage cell heat load is 0.812 kW (MPC-32 Version 1) and 0.382 kW (MPC-68 Version 1).
6. Maximum per assembly allowable heat loads under uniform or regionalized storage defined in Appendix B, Section 2.4.1 or 2.4.2.

Certificate of Compliance No. 1014 Amendment No. 158 Appendix C 3.4-1 21 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937

7. For limits applicable to MPC-24/24E/24EF/32/32F/68/68F/68FF/68M see Appendix A Table 3-1.
8. 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.
9. Maximum per assembly allowable heat loads defined in Appendix D, Section 2.4.1.
10. Maximum per assembly allowable heat loads defined in Appendix D Figures 2.4-1 and 2.4-2.
11. Applies when any one storage cell heat load is greater than 0.843kW.
12. For MPC-32M, these heat load limits may need to be modified based on fuel height, in accordance with Appendix D Section 2.4.4.

12.13. Alternative heat load limits may be developed following the methodology in Topical Report HI-2200343-A Revision 2. These heat load patterns must have a total MPC heat load less than 50 kW. Dryness criteria are still as specified in Notes 1 or 2 as applicable to the selected drying process , and Note 3 still applies to vacuum drying.

Certificate of Compliance No. 1014 Amendment No. 158 Appendix C 3.4-2 22 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 MPC Helium Backfill Limits Table 3-2 Table 3-2a MPC Helium Backfill Limits for VENTILATED OVERPACKNotes 1,3, 4 MPC MODEL LIMIT Note 4 MPC-32M

i. Cask Heat Load 41.2 kW 43.0 psig and 46.0 psig Regionalized Loading per Appendix D, Section 2.4.1 ii. Cask Heat Load 40.0 kW Note 2 and 46.8 psig Discrete Loading Patterns per Appendix D, Section 2.4.2 MPC-32 Version 1/ MPC-68 Version 1
i. All allowable heat loads per Appendix D 49.5 psig and 52.5 psig Section 2.4 Notes:
1. Helium used for backfill of MPC shall have a purity of 99.995%. Pressure range is at a reference temperature of 70oF.
2. Minimum permitted helium backfill is equal to:

43.8(Q/Q)

Where:

Q = aggregate heat load for MPC at time of fuel loading (kW)

Q = allowable maximum heat load for the canister in Appendix D, Table 2.4-3 For any scenario where Q/Q 0.9, 0.9 shall be used.

3. For limits applicable to MPC-24/24E/24EF/32/32F/68/68F/68FF/68M see Appendix A Table 3-2.
4. These heat load limits may need to be modified based on fuel height, in accordance with Appendix D Section 2.4.4 4.5. For heat load patterns developed in accordance with Table 3-1a, Note 13, helium backfill limits shall be calculated in accordance with Topical Report HI-2200343-A Revision 2.

Certificate of Compliance No. 1014 Amendment No. 158 Appendix C 3.4-4 23 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Heat Removal System Completion Times Table 3-3 Table 3-3 Completion Time for Actions to Restore HI-STORM 100S Version E SFSC Heat Removal System to Operable Note1 Condition A Condition B Decay Heat Limits per Surveillance MPC Material MPC Type Completion Completion Storage Location Frequency Time Time Alloy X Except MPC-32 Version 1/ Appendix D, Section 2.4 8 hrs 24 hrs 24 hrs Duplex Note3 MPC-68 Version 1 Alloy X MPC-32 Version 1/ Appendix D, Section 2.4 8 hrs 16 hrs 16 hrs MPC-68 Version 1 MPC-32 Version 1 0.5 kW Alloy X MPC-68 Version 1 0.264 kW 24 hrs 64 hrs 30 days MPC-32M 0.75 kWNote 2 Appendix D SectionNote 2 Alloy X 2.4.1 Except MPC-32M OR 8 hrs 24 hrs 24 hrs Duplex Note 3 Appendix D SectionNote 2 2.4.2 Appendix D SectionNote 2 2.4.1 Alloy X MPC-32M OR 8 hrs 24 hrs 24 hrs Appendix D SectionNote 2

2.4.2 Notes

1. For limits applicable to MPC-24/24E/24EF/32/32F/68/68F/68FF/68M see Appendix A Table 3-5.
2. For MPC-32M, heat load limits may need to be modified based on fuel height, in accordance with Appendix D Section 2.4.4.
3. If any component of the MPC is made of duplex, these completion times are not applicable.

3.4. For heat load patterns developed in accordance with Table 3-1a, Note 13, alternative completion times may be calculated in accordance with Topical Report HI-2200343-A Revision 2 Certificate of Compliance No. 1014 Amendment No. 158 Appendix C 3.4-6 24 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 PROPOSED CERTIFICATE OF COMPLIANCE NO. 1014 APPENDIX D APPROVED CONTENTS AND DESIGN FEATURES FOR THE HI-STORM 100S VERSION E CASK AND HI-TRAC MS 25 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 2.4 Decay Heat Limits For MPC-24/24E/24EF/32/32F/68/68F/68FF/68M decay heat, burnup, and cooling time limits from Appendix B Section 2.4 apply for ZR clad fuel. Decay heat limits from Appendix B Table 2.1-1 apply for SS clad fuel.

For MPC-32 Version 1 decay heat, burnup and cooling time limits for MPC-32 from Appendix B Section 2.4 apply for ZR clad fuel. Decay heat limits for MPC-32 from Appendix B Table 2.1-1 apply for SS clad fuel.

For MPC-68 Version 1 decay heat, burnup and cooling time limits for MPC-68 from Appendix B Section 2.4 apply for ZR clad fuel. Decay heat limits for MPC-68 from Appendix B Table 2.1-1 apply for SS clad fuel.

Decay heat limits for ZR clad for storage in MPC-32M in HI-STORM 100S Version E are provided in the following subsections. Burnup and cooling time limits for the MPC-32M are provided in Table 2.1-4. These burnup/cooling time limits also apply for heat load patterns developed in accordance with the topical report HI-2200343-A Revision 2.

2.4.1 Regionalized Fuel Loading Decay Heat Limits for ZR-Clad Fuel for MPC-32M for a VENTILATED OVERPACK The maximum allowable decay heat per fuel storage location for intact fuel assemblies in regionalized loading is determined using the following equations:

Q(X) = 2 x Q0 / (1 + Xy) y = 0.23 / X0.1 q2 = Q(X) / (n1 x X +n2) q1 = q2 x X Where:

Q0 = Maximum uniform storage MPC decay heat (38 kW)

X = Inner region to outer region assembly decay heat ratio (0.5 X 3) n1 = Number of storage locations in inner region from Table 2.4-3.

n2 = Number of storage locations in outer region from Table 2.4-3.

Allowable heat loads for Damaged Fuel and Fuel Debris are shown in Table 2.4-1. Allowable storage locations for Damaged Fuel in DFIs and Damaged Fuel or Fuel Debris in DFCs are shown in Table 2.4-1. Cell heat load limits and total heat load limits may need to be adjusted in accordance with Section 2.4.4.

2.4.2 Discrete Loading Pattern Decay Heat Limits for ZR-Clad Fuel in MPC-32M for a VENTILATED OVERPACK Discrete decay heat loading patterns (Patterns A and B) for MPC-32M are shown in Figures 2.4-1 and 2.4-2. Figures 2.4-1 and 2.4-2 provide the maximum allowable decay heat loads per fuel storage location. Table 2.4-2 provides the maximum total allowable decay heat load and maximum Certificate of Compliance No. 1014 Amendment No.

Appendix D 2-13 26 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 allowable quadrant decay heat load for Figures 2.4-1 and 2.4-2. Cell heat load limits, quadrant heat load limits and total heat load limit may need to be adjusted in accordance with Section 2.4.4.

Alternatively to the patterns in Sections 2.4.1 and 2.4.2, decay heat limits may be determined per Topical Report HI-2200343-A Revision 2.

2.4.3 When complying with the maximum fuel storage location decay heat limits, users must account for the decay heat from both the fuel assembly and any NON-FUEL HARDWARE, as applicable for the particular fuel storage location, to ensure the decay heat emitted by all contents in a storage location does not exceed the limit.

2.4.4 Variable Fuel Height for MPC-32M 2.4.4.1 For fuel with a longer active fuel length than the reference fuel (144 in), the total heat load, quadrant heat load limits and specific heat load limits in each cell, may be increased by the ratio SQRT(L/144), where L is the active length of the fuel in inches.

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

2.4.5 Decay Heat Limits for MPC-32M for the UNVENTILATED OVERPACK Tables 2.4-5a and 2.4-5b provide the maximum allowable decay heat per fuel storage location for MPC-32M for UNVENTILATED OVERPACK.

A minor deviation from the prescribed loading pattern in an MPCs permissible contents to allow one slightly thermally-discrepant fuel assembly per quadrant to be loaded as long as the peak cladding temperature for the MPC remains below the ISG-11 Rev 3 requirements is permitted for essential dry storage campaigns to support decommissioning.

Certificate of Compliance No. 1014 Amendment No.

Appendix D 2-14 27 of 28

ATTACHMENT 1 TO HOLTEC LETTER 5014937 Approved Contents 2.0 Table 2.4-1 Allowable Heat Loads and Soluble Boron Requirements for MPC-32M Number Penalty on per Min. Soluble Locations/Storage DFC/DFI of storage cell Boron Row No.

DFC/DFI Cell Numbers (Note 1) heat load limit Content Locations (Note 2)

(Note 3) 2, 11, 22, 31 Appendix C 1 4 0%

(NOTE 4) Table 3-6 1, 4, 5, 10, 23, 28, Appendix C 2 8 5%

29, 32 Table 3-5 1, 2, 4, 5, 10, 16, Appendix C 3 12 17, 23, 28, 29, 31, 5%

32 Table 3-5 DFC 1, 2, 3, 4, 5, 10, 11, 16, 17, 22, 23, 28, Appendix C 4 16 0%

29, 30, 31, 32 Table 3-6 (NOTE 4) 1, 2, 3, 4, 5, 10, 11, Appendix C 5 16 16, 17, 22, 23, 28, 5%

29, 30, 31, 32 Table 3-6 Appendix C 6 4 2, 11, 22, 31 10%

Table 3-4 1, 2, 4, 5, 10, 16, Appendix C 7

DFI 12 17, 23, 28, 29, 31, 40%

32 Table 3-4 1, 2, 3, 4, 5, 10, 11, Appendix C 8 16 16, 17, 22, 23, 28, 40%

29, 30, 31, 32 Table 3-4 1, 2, 3, 4, 5, 10, 11, DFI or DFCs - 5% Appendix C 9

DFC 16 16, 17, 22, 23, 28, 29, 30, 31, 32 DFIs - 40% Table 3-6 Note 1: Damaged fuel assemblies or fuel debris can be loaded in DFCs while only damaged fuel assemblies that can be handles by normal means can be loaded in DFIs.

Note 2: DFCs/DFIs are allowed for storage in certain basket peripheral locations as defined herein. Basket storage cell numbers are identified in Figure 2.1-1.

Note 3: Heat load penalties are applicable to ONLY those cells where DFCs/DFIs are located and are applied to the allowable undamaged fuel assembly decay heat limit in that storage cell location. The penalties remain the same for all regionalized patterns and discrete loading patterns. Alternatively decay heat limits may be determined per Topical Report HI-2200343-A Revision 2.

Note 4: Storage cell locations 6, 9, 24, 27 all must remain empty.

Certificate of Compliance No. 1014 Amendment No.

Appendix D 2-15 28 of 28

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