Text

Magnastor Final Analysis Report Amendment RAI Responses Supplement
	ML21251A531
Person / Time
Site:	07201031
Issue date:	09/02/2021
From:	; NAC International
To:	; Office of Nuclear Material Safety and Safeguards
Shared Package
ML21251A529	List: ML21251A530; ML21251A531;
References
	ED20210109
	Download: ML21251A531 (269)
	v • d • e

September 2021 Revision 21A, Supp 2 ,

MAGNASTOR

(,Modular Advanced .§eneration

,Muclear All-purpose S'TORage)

FINA:L SAFETY ANALYSIS REPORT MSO Amendment RAI Responses Suppleme:nt NON-PROPRIETARY VERSl*ON Docket No. 72-1031 ANAC ffif I INT ERN AT IO NA L Atlanta Corporate Headquarters: 3930 East Jones Bridge Road, Norcross, Georgia 30092 USA Phone 770-447-1144, Fax 770-447-1797, www.nacintl.com

Enclosure I to ED202 l OI 09 Page I of I Enclosure 1 NACINTERNATIONAL RESPONSES TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION REQUEST FOR ADDITIONAL INFORMATION

for MAGNASTOR FSAR nd 2 Round RAI Responses for Amendment 10 (Docket No 72-1031)

NAC International September 2021

Enclosure 1 to ED202 l O109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 Enclosure 1 NACINTERNATIONAL RESPONSE TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION NON-PROPRIETARY REQUEST FOR ADDITIONAL INFORMATION

July 2021 FOR REVIEW OF THE CERTIFICATE OF COMPLIANCE NO. 1031, AMENDMENT NO. 10 (EPID No. L-2019-LLA-0273 DOCKET NO. 72-1031)

September 2021

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Enclosure I to ED20210109 MAGNASTOR Docket No.: 72- I 03 I EPID No. L-2019-LLA-0273 TABLE OF CONTENTS STRUCTURAL EVALUATION ........................................................................................................................................ 3 THERMAL EVALUATION ............................................................................................................................................. 5 SHIELDING EVALUATION ........................................................................................................................................... 7

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Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-20 l 9-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION STRUCTURAL EVALUATION 2-1 Provide an evaluation of the building structure mentioned in the Proposed Technical Specifications (TS) submitted as Enclosure 4 ofNAC International's Responses to the NRC's RAI and the response to thermal RAis in Enclosure 1 of the submission dated February 25, 2021. The evaluation of the building should include the following information:

a) an assessment of the building's safety significance including a justification of the safety significance; b) the design bases of the building including the design codes and standards and the methods used for load determination, particularly lateral loads from natural phenomena hazards; c) the design criteria of the building including the design codes and standards and the methods used to determine the structural capacity of the building members and the design safety margin; and d) an analysis or a description of an analysis demonstrating that the building will not affect the performance of the MSO cask under normal, off-normal, and accident conditions, including natural phenomena. The analysis should include the input parameters and methods of evaluation (e.g., the use of structural analysis software or finite element analysis software).

In proposed TS 4.3.lG), the applicant included the requirement that the MSO cask must be stored in a building structure. The applicant described in the response to thermal RAI 4-1 that this storage building is necessary to assure protection from low speed wind. However, the applicant has not provided any description or evaluation related to the proposed storage building in the SAR or any referenced structural documents.

The applicant's statements about the building in the thermal RAI responses and the TS imply the building provides a safety related thermal function (i.e., eliminating the low speed wind effects on the cask). Furthermore, the staff notes that a collapse of the building onto the cask could lead to a loss of containment, a loss of shielding, or a criticality. Thus, the building could be a system, structure, or component (SSC) whose failure could indirectly result in conditions adversely affecting public health and safety. Following guidance in NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety," this could qualify the building as important to safety (ITS).

The regulations in Title 10 of Code of Federal Regulations (10 CFR) 72.236(6) requires that applicants for a certificate of compliance (CoC) provide the design bases and design criteria for SSCs that are ITS. Also, 10 CFR 72.236(1) requires that applicants for a CoC evaluate ITS SSCs to demonstrate that they will maintain confinement of radioactive material under normal, off-normal, and accident conditions. If the storage building is an ITS SSC, the applicant is required to provide the design bases and design criteria of the building by 10 Page 3 of 7

Enclosure I to ED202 l OI 09 MAGNASTOR Docket No.: 72-1031 EPID No. L-20 l 9-LLA-0273 CFR 72.236(6) as well as a structural evaluation of the building by 10 CFR 72.236(1).

The applicant stated in the response to RAI 4-2 that the building's design will depend on site-specific conditions, and the applicant described how the requirements of 10 CFR 72.212 and 10 CFR 72.48 would require a general licensee using the MSO cask to perform an evaluation of the building's influence on the cask. As the applicant noted in the RAI response, 10 CFR 72.212 and 10 CFR 72.48 evaluations consider the design bases, methods of evaluation, and other aspects of the evaluations from the CoC holder's final safety analysis rep011 (FSAR) for the storage system's design. However, the applicant has not provided any design bases or performed any evaluation for the proposed storage building in the SAR or any referenced document associated with this amendment. The design bases and evaluations are required to be provided by the applicant for a CoC in the FSAR per 10 CFR 72.236 and are needed to conduct the evaluations described in§§ 72.48 and 72.212.

The staff recognizes there are site-specific aspects to the design and evaluation of the proposed storage building. However, §72.236 does not allow for any exemptions for site-specific ITS SSCs and requires the CoC holder to provide the design bases, the design criteria, and an evaluation of the ITS SSCs. The evaluation and design information required of the CoC holder and documented in the FSAR may then serve to establish the methods of evaluation and the bounding parameters of the SSCs.

The staff requests an evaluation of the storage building including the building's safety significance, design bases, and design criteria. The staff also requests a structural analysis or

a description of a structural analysis assessing the structural performance of the building and any effect it may have on the MSO cask under normal, off-normal, and accident conditions, including natural phenomena. This information should include the codes and standards, the input parameters, and the specific methods of evaluation that will be used to design and analyze the building. Finally, the staff requests that the SAR be updated to include the information requested.

This infonnation is needed to determine compliance with the regulatory requirements in 10 CFR 72.236(6) and 10 CFR 72.236(1).

NAC International Response to Thermal Evaluation RAI 2-1:

See NAC response to RAI 4-1 .

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Enclosure I to ED202 l O109 MAGNASTOR Docket No.: 72-1031 EPID No. L-20 I 9-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION THERMAL EVALUATION 4-1 Provide adequate technical basis or thermal analysis that justify safe storage of the MSO inside a building.

In its responses to questions 4-1 and 4-2 in the NRC RAI dated February 25, 2021 (ADAMS accession number ML21067A043), NAC stated that the use of the MSO is limited to storage inside a building assuring protection from low speed wind in its proposed technical specifications. However, the applicant did not provide a thermal analysis that demonstrates that the predicted temperatures would be below allowable limits for a configuration inside a building or technical justification that demonstrates an outside configuration would be bounding. Justify why the outside configuration (that has not considered the effect of low speed wind) would be applicable to or bound a configuration inside a building to ensure that an appropriate method is used for future site-specific evaluations or provide an analysis of an array of casks stored inside a building which considers the proposed conditions on the building environment (i.e., building air temperatures, effects of vents near walls, etc.).

Additionally, the available margin for a cask located outside (quiescent conditions) is small.

Therefore, it is necessary for the applicant to evaluate phenomena and boundary conditions

for the inside configuration that are not captured in the cask analyzed located outside. The staff identified the following deficiencies for an MSO analyzed outside that could prevent the application of the thermal analysis results from bounding an inside configuration:

The free stream temperature of 76°F for convective heat transfer (for all external surfaces and inlet vents) and the external radiation temperature of 76°F could be different due to the building structure, unless ambient temperature refers to the temperature inside the building and the user established adequate control such that the ambient temperature is not exceeded during the entire licensed period. These controls can't rely on any active cooling system. Either provide a definition of ambient temperature stating it is both the indoor and outdoor air temperature for casks stored indoors or outside on a pad or provide additional temperature controls for casks stored inside a building.

A realistic or conservative approach to specify the boundary conditions on all external surfaces of the building that could affect the heat transfer. Building structural walls could add additional resistance to heat transfer because the walls would be blocking radiation heat transfer to the environment and radiating heat back to the casks. Also, a bounding or realistic configuration needs to be considered if the external walls of the building would be exposed to the ambient or will share walls with other buildings.

The MSO analyzed outside is based on a two-dimensional (2-D) axisymmetric model that cannot capture the three-dimensional effects of a cask array situated inside a building. It is not clear that evaluating the enclosure walls of a building and any building ventilation that provide passive cooling would be adequately captured using 2-D analysis .

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Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 RAI Response 4-2 (ADAMS accession number ML21067A043) states:

"10 CFR 72.212 (6) requires an evaluation of site parameters to see if they are bounded. In this case the buildings influence on cask performance must be evaluated. Per 10 CFR 72.212 (7) a 72.48(c) based evaluation for any changes must be performed which limits the evaluation to FSAR MOE or equivalent methods." However, because of the deficiencies identified above for an MSO evaluated outside, the staff does not believe the current FSAR method of evaluation (MOE) can be used to perform the thermal evaluation of a cask array situated inside a building. The staff needs the thermal evaluation of a cask array inside a building to determine the adequacy of the thermal design in meeting any applicable material temperature limits.

This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.236(b) and 10 CFR 72.236(t).

NAC International Response to Thermal Evaluation RAJ 4-1:

As indicated in this RAJ, NAC elected in our responses dated February 25, 2021 to require the MSO to be stored on an JSFSJ that was enclosed, albeit ventilated, from the outside environment to preclude the potential effects of low-wind speeds on the MSO overpack.

However due to regulatory challenges with implementing this approach, NAC has elected to address the original RAI on low-wind speed directly and remove the proposed requirement that the MSO must be used in an ISFSJ enclosure.

NAC has now performed a low-wind speed analysis on the MSO overpack. See NAC Calculation 30082-3603, Rev. 00, which is enclosed with this submittal package. The analysis demonstrates that the MSO will perform satisfactorily during low-wind conditions.

The current overpack thermal analysis presented in this amendment remains as is. The proposed Technical Specifications have been revised to remove any requirement that the MSO be used in an ISFSI enclosure .

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Enclosure I to ED202 IO I 09 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SHIELDING EVALUATION 5-1 Justify the NS-3 shielding material loss {proprietary information removed} due to exposure to radiation and show that the loss of material due to radiation dose is consistent with the dose the NS-3 is expected to receive during storage.

In its supplemental response dated April 20, 2021, to the NRC RAI dated October 8, 2020 (ADAMS Accession No. ML20258A160), see item 5-1 in the proprietary enclosure on the same issue, the applicant states that NS-3 material loss {proprietary information removed}

due to radiation. However, the staff could not determine how the value was determined.

The staff needs this information to determine if the request meets the regulatory requirements of 10 CFR 72.236(d).

NAC International Response to Thermal Evaluation RAI 5-1:

See NAC proprietary response to RAI 5-1.

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Enclosure I to ED202 l OI 09 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 Enclosure 1 NAC INTERNATIONAL RESPONSE TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION PROPRIETARY REQUEST FOR ADDITIONAL INFORMATION July 2021 FOR REVIEW OF THE CERTIFICATE OF COMPLIANCE NO. 1031, AMENDMENT NO. 10 (EPID No. L-2019-LLA-0273 DOCKET NO. 72-1031)

September 2021

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Enclosure I to ED20210 I 09 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 TABLE OF CONTENTS SHIELDING EVALUATION ............................................................................................................................... 3

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NAC PROPRIETARY INFORMATION REMOVED Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SHIELDING EVALUATION 5-1

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NAC PROPRIETARY INFORMATION REMOVED Enclosure I to ED20210109 MAGNASTOR Docket No.: 72-103 I EPID No. L-2019-LLA-0273

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NAC PROPRIETARY INFORMATION REMOVED Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273

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Enclosure 2 to ED202 IO I 09 Page I of I Enclosure 2 Proposed Changes for MAGNASTOR Technical Specifications nd 2 Round RAI Responses to Amendment 10 (Docket No 72-1031)

NAC International September 2021

APPENDIX A PROPOSED TECHNICAL SPECIFICATIONS AND DESIGN FEATURES FOR THE MAGNASTOR SYSTEM

AMENDMENT 10

Certificate of Compliance No. 1031 A-1 Amendment No. 10

Appendix A Table of Contents 1.0 USE AND APPLICATION ........................................................................................... A1-1 1.1 Definitions ............................................................................................................... A 1-1 1.2 Logical Connectors ................................................................................................. A 1-7 1.3 Completion Times ................................................................................................... A 1-9 1.4 Frequency ............................................................................................................. A1-13 2.0 [Reserved] .................................................................................................................. A2-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY .......................... A3-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ......................................... A3-2 3.1 MAGNASTOR SYSTEM Integrity .......................................................................... A3-3 3.1.1 Transportable Storage Canister (TSC) ........................................................... A3-3 3.1.2 CONCRETE CASK or MSO Heat Removal System ...................................... A3-9 3.2 MAGNASTOR SYSTEM Criticality Control for PWR Fuel ................................... A3-10 3.2.1 Dissolved Boron Concentration .................................................................... A3-10 3.3 MAGNASTOR SYSTEM Radiation Protection .................................................... A3-12 3.3.1 CONCRETE CASK or MSO Maximum Surface Dose Rate ......................... A3-12 3.3.2 TSC Surface Contamination .......................................................................... A3-16 4.0 DESIGN FEATURES ................................................................................................. A4-1 4.1 Design Features Significant to Safety .................................................................... A4-1 4.1.1 Criticality Control ............................................................................................ A4-1 4.1.2 Fuel Cladding Integrity ................................................................................... A4-1 4.1.3 Transfer Cask Shielding ................................................................................. A4-1 4.1.4 TSC Confinement Integrity ............................................................................. A4-2 4.2 Codes and Standards ............................................................................................ A4-2 4.2.1 Alternatives to Codes, Standards, and Criteria .............................................. A4-2 4.2.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria ...... A4-2 4.3 Site-Specific Parameters and Analyses ................................................................. A4-3 4.3.1 Design Basis Specific Parameters and Analyses ........................................... A4-3 4.4 TSC Handling and Transfer Facility ....................................................................... A4-4 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS .................................................. A5-1 5.1 Radioactive Effluent Control Program ................................................................... A5-1 5.2 TSC Loading, Unloading, and Preparation Program ............................................. A5-1 5.3 Transport Evaluation Program ............................................................................... A5-2 5.4 ISFSI Operations Program .................................................................................... A5-2 5.5 Radiation Protection Program ................................................................................ A5-3 5.6 Deleted ................................................................................................................... A5-3 5.7 Training Program .................................................................................................... A5-4 5.8 Pre-operational Testing and Training Exercises ..................................................... A5-4

Certificate of Compliance No. 1031 A-2 Amendment No. 10

List of Figures Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement ................................. A3-14 Figure A3-2 MSO Surface Dose Rate Measurement.. ...................................................... A3-15 List of Tables Table A3-1 Helium Mass per Unit Volume for MAGNASTOR TSCs ..................................... A3-8 Table A4-1 Load Combinations and Service Condition Definitions for the TSC Handling and Transfer Facility Structure ............................................................................ A4-6

Certificate of Compliance No. 1031 A-3 Amendment No. 10

Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions NOTE The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

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

ASS EMBLY AVERAGE Value calculated by averaging the 235 U wt % enrichment over FUEL ENRICHMENT the entire fuel region (UO2) of an individual fuel assembly, including axial blankets, if present.

BREACHED SPENT FUEL Spent fuel with cladding defects that permit the release of gas ROD from the interior of the fuel rod. A fuel rod breach may be a minor defect (i.e., hairline crack or pinhole), allowing the rod to be classified as undamaged, or be a gross breach requiring a damaged fuel classification .

BURNUP a) Assembly Average Burnup:

Value calculated by averaging the burn up over the entire fuel region (UO2) of an individual fuel assembly, including axial blankets, if present. Assembly average burnup represents the reactor record, nominal, value. The assembly average burnup is equal to the reactor record, nominal, energy production (MWd) over the life of the fuel assembly divided by the fuel assembly pre-irradiation heavy metal (U) mass in metric tons.

b) Nonfuel Hardware Burnup:

Equivalent accumulated irradiation exposure for activation evaluation.

COMPOSITE CLOSURE A closure lid assembly, consisting of a stainless steel LID TRANSPORTABLE STORAGE CANISTER closure lid and a separate shield plate bolted together, that provides closure of a TRANSPORTABLE STORAGE CANISTER.

CONCRETE CASK The CONCRETE CASK is the vertical storage module that receives, holds and protects the sealed TSC for storage at the ISFSI. The CONCRETE CASK passively provides the radiation shielding, structural protection, and heat dissipation capabilities for the safe storage of spent fuel in a TSC .

(continued)

Certificate of Compliance No. 1031 A1-1 Amendment No. 10

Definitions 1.1

DAMAGED FUEL SPENT NUCLEAR FUEL (SNF) assembly that cannot fulfill its fuel-specific or system-related function. SNF is classified as damaged under the following conditions.

1. There is visible deformation of the rods in the SNF assembly.

Note: This is not referring to the uniform bowing that occurs in the reactor; this refers to bowing that significantly opens up the lattice spacing.

2. Individual fuel rods are missing from the SNF assembly and the missing rods are not replaced by a solid stainless steel or zirconium dummy rod that displaces a volume equal to, or greater than, the original fuel rod.

3. The SNF assembly has missing, displaced or damaged structural components such that:

3.1. Radiological and/or criticality safety is adversely affected (e.g., significantly changed rod pitch); or 3.2. The SNF assembly cannot be handled by normal means (i.e., crane and grapple); or

3.3. The SNF assembly contains fuel rods with damaged or Note:

missing grids, grid straps, and/or grid springs producing an unsupported length greater than 60 inches.

SNF assemblies with the following structural defects meet MAGNASTOR system-related functional requirements and are, therefore, classified as undamaged: Assemblies with missing or damaged grids, grid straps and/or grid springs resulting in an unsupported fuel rod length not to exceed 60 inches.

4. Any SNF assembly that contains fuel rods for which reactor operating records (or other records or tests) cannot support the conclusion that they do not contain gross breaches.

Note: BREACHED SPENT FUEL RODs with minor cladding defects (i.e., pinhole leaks or hairline cracks that will not permit significant release of particulate matter from the spent fuel rod) meet MAGNASTOR system-related functional requirements and are, therefore, classified as undamaged.

5. FUEL DEBRIS such as ruptured fuel rods, severed rods, loose fuel pellets, containers or structures that are supporting loose PWR fuel assembly parts.

Certificate of Compliance No. 1031 A1-2 (continued)

Amendment No. 10

Definitions 1.1 DAMAGED FUEL CAN A specially designed stainless steel screened can sized to hold (DFC) UNDAMAGED PWR FUEL, DAMAGED PWR FUEL, and/or FUEL DEBRIS. The screens preclude the release of gross particulate from the DFC into the canister cavity. DFCs are only authorized for loading in specified locations of a OF Basket Assembly.

FUEL DEBRIS FUEL DEBRIS is ruptured fuel rods, severed rods, loose fuel pellets, containers or structures that are supporting loose PWR fuel assembly parts.

GROSSLY BREACHED A breach in the spent fuel cladding that is larger than a pinhole SPENT FUEL ROD or hairline crack. A gross cladding breach may be established by visual examination with the capability to determine if the fuel pellet can be seen through the cladding, or through a review of reactor operating records indicating the presence of heavy metal isotopes.

INDEPENDENT SPENT The facility within the perimeter fence licensed for storage of FUEL STORAGE spent fuel within MAGNASTOR SYSTEMS (see also 10 CFR INSTALLATION (ISFSI) 72.3).

INITIAL PEAK PLANAR- The INITIAL PEAK PLANAR-AVERAGE ENRICHMENT is the AVERAGE ENRICHMENT maximum planar-average enrichment at any height along the axis of the fuel assembly. The INITIAL PEAK PLANAR-AVERAGE ENRICHMENT may be higher than the bundle (assembly) average enrichment.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities while a MAGNASTOR SYSTEM is being loaded with fuel assemblies.

LOADING OPERATIONS begin when the first assembly is placed in the TSC and end when the TSC is lowered into a CONCRETE CASKorMSO.

MAGNASTOR SYSTEM The MAGNASTOR (Modular Advanced Generation Nuclear All-(MAGNASTOR) purpose STORage) SYSTEM includes the components certified for the storage of spent fuel assemblies at an ISFSI. The MAGNASTOR SYSTEM consists of a CONCRETE CASK or MSO and a TSC. A MAGNASTOR TRANSFER CASK (MTC) or Passive MAGNASTOR TRANSFER CASK (PMTC) is provided and utilized to load and place a TSC in a CONCRETE CASK or MSO, or to remove a TSC from a CONCRETE CASK or MSO.

Certificate of Compliance No. 1031 A1-3 (continued)

Amendment No. 10

Definitions 1.1 MSO (Metal Storage The MSO is the vertical storage module that receives, holds and Overpack) protects the sealed TSC for storage at the ISFSI. The MSO passively provides the radiation shielding, structural protection, and heat dissipation capabilities for the safe storage of spent fuel in a TSC.

NONFUEL HARDWARE NONFUEL HARDWARE is defined as reactor control components (RCCs), burnable poison absorber assemblies (BPAAs), guide tube plug devices (GTPDs), neutron sources/

neutron source assemblies (NSAs), hafnium absorber assemblies (HFRAs), instrument tube tie components, guide tube anchors or other similar devices, in-core instrument thimbles, steel rod inserts (used to displace water from lower section of guide tube), and components of these devices such as individual rods.

All nonfuel hardware, with the exception of instrument tube tie components, guide tube anchors or other similar devices, and steel rod inserts, may be activated during in-core operations.

RCCs are commonly referred to as rod cluster control assemblies (RCCAs), control rod assemblies (CRAs), or control element assemblies (CEAs). RCCs are primarily designed to provide reactor shutdown reactivity control, are inserted into the guide tubes of the assembly, and are typically employed for a significant number of operating cycles. Burnup poison absorber assemblies (BPAAs) are commonly referred to as burnup poison rod assemblies (BPRAs), but may have vendor specific nomenclature such as BPRA, Pyrex BPRA or WABA (wet annular burnable absorber). BPAAs are used to control reactivity of fresh fuel or high reactivity fuels and are commonly used for a single cycle, but may be used for multiple cycles.

GTPDs are designed to block guide tube openings when no BPAA is employed and are commonly referred to as thimble plugs (TPs), thimble plug devices (TPDs), flow mixers (FMs),

water displacement guide tube plugs, or vibration suppressor inserts. GTPDs may be employed for multiple cycles. NSAs are primary and secondary neutron sources used during reactor startup and may be used for multiple cycles.

Integral fuel burnable absorbers, either integral to a fuel rod or as a substitution for a fuel rod, and fuel replacement rods (fueled, stainless steel, or zirconium alloy) are considered components of spent nuclear fuel (SNF) assemblies and are not considered to be nonfuel hardware.

(continued)

Certificate of Compliance No. 1031 A1-4 Amendment No. 10

Definitions 1.1 OPERABLE A system, component, or device is OPERABLE when it is capable of performing its specified safety functions.

SPENT NUCLEAR FUEL Irradiated fuel assemblies consisting of end-fittings, grids, fuel (SNF) rods and integral hardware. Integral hardware for PWR assemblies primarily consists of guide/instrument tubes, but may contain integral fuel burnable absorbers, either integral to a fuel rod or as a fuel rod substitution, and fuel replacement rods (another fuel rod, stainless steel rod, or zirconium alloy rod).

For BWR fuel, integral hardware may consist of water rods in various shapes, inert rods, fuel rod cluster dividers, and/or fuel assembly channels (optional). PWR SNF may contain NONFUEL HARDWARE.

STORAGE CASK A STORAGE CASK is either a CONCRETE CASK or an MSO.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI following placement of a CONCRETE CASK or MSO containing a loaded TSC at its designated storage location on the storage pad.

TRANSFER CASK TRANSFER CASK is a shielded lifting device designed to hold

TRANSFER OPERATIONS the TSC during LOADING OPERATIONS, TRANSFER OPERATIONS, and UNLOADING OPERATIONS. Either a MAGNASTOR TRANSFER CASK (MTC) or Passive MAGNASTOR TRANSFER CASK (PMTC) may be used.

TRANSFER OPERATIONS include all licensed activities involved in using a MAGNASTOR TRANSFER CASK (MTC) or Passive MAGNASTOR TRANSFER CASK (PMTC) to move a loaded and sealed TSC from a; CONCRETE CASK to another CONCRETE CASK or from an MSO to another MSO.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on a loaded MAGNASTOR CONCRETE CASK or MSO when it is being moved to and from its designated location on the ISFSI. TRANSPORT OPERATIONS begin when the loaded CONCRETE CASK or MSO is placed on or lifted by a transporter and end when the CONCRETE CASK or MSO is set down in its storage position on the ISFSI pad.

(continued)

Certificate of Compliance No. 1031 A1-5 Amendment No. 10

Definitions 1.1 TRANSPORTABLE The TRANSPORTABLE STORAGE CANISTER (TSC) is the STORAGE CANISTER welded container consisting of a basket in a weldment composed (TSC) of a cylindrical shell welded to a baseplate. The TSC includes a closure lid, a shield plate (optional), a closure ring, and redundant port covers at the vent and the drain ports. The closure lid is welded to the TSC shell and the closure ring is welded to the closure lid and the TSC shell. The port covers are welded to the closure lid. The TSC provides the confinement boundary for the radioactive material contained in the TSC cavity.

TSC TRANSFER FACILITY The TSC TRANSFER FACILITY includes: 1) a transfer location for the lifting and transfer of a TRANSFER CASK and placement of a TSC into or out of a CONCRETE CASK or MSO; and 2) either a stationary lift device or a mobile lifting device used to lift the TRANSFER CASK and TSC, but not licensed as part of the 10 CFR 50 facility.

UNDAMAGED FUEL SNF that can meet all fuel specific and system-related functions.

UNDAMAGED FUEL is SNF that is not DAMAGED FUEL, as defined herein, and does not contain assembly structural defects that adversely affect radiological and/or criticality safety.

As such, UNDAMAGED FUEL may contain:

a) BREACHED SPENT FUEL RODS (i.e, rods with minor defects up to hairline cracks or pinholes) but cannot contain grossly breached fuel rods; b) Grid, grid strap, and/or grid spring damage provided that the unsupported length of the fuel rod does not exceed 60 inches.

UNLOADING OPERATIONS UNLOADING OPERATIONS include the activities required to remove the fuel assemblies from a sealed TSC. UNLOADING OPERATIONS begin with the movement of the TSC from a CONCRETE CASK or MSO into a TRANSFER CASK in an unloading facility and end when the last fuel assembly has been removed from the TSC .

Certificate of Compliance No. 1031 A1-6 Amendment No. 10

Logical Connectors 1.2 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 Technical Specifications 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 indentations of the logical connectors.

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

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO 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)

Certificate of Compliance No. 1031 A1-7 Amendment No. 10

Logical Connectors 1.2

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 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 .

Certificate of Compliance No. 1031 A1-8 Amendment No. 10

Completion Times 1.3

1.0 1.3 PURPOSE USE AND APPLICATION Completion Times 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 Time(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, provided that MAGNASTOR 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 MAGNASTOR 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)

Certificate of Compliance No. 1031 A1-9 Amendment No. 10

Completion Times 1.3

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 B.1 Perform Action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion Time AND not met B.2 Perform Action B.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

(continued)

Certificate of Compliance No. 1031 A1-10 Amendment No. 10

Completion Times 1.3 EXAMPLES EXAMPLE 1.3-2 (continued) ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not A.1 Restore system to 7 days within limit. within limit.

B. Required Action B.1 Complete action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion Time AND not met. B.2 Complete action B.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months 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)

Certificate of Compliance No. 1031 A1-11 Amendment No. 10

Completion Times 1.3 EXAMPLES EXAMPLE 1.3-3 (continued) ACTIONS NOTE Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met A.1 Restore compliance 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with LCO.

B. Required Action B.1 Complete action B.1 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time AND not met. B.2 Complete action B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 to be 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 are tracked for each component.

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

Certificate of Compliance No. 1031 A1-12 Amendment No. 1O

Frequency 1.4

1.0 1.4 PURPOSE USE AND APPLICATION Frequency 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.

Each "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 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.

The use of "met" or "performed" in these instances conveys specific meanings. Surveillance is "met" only after the acceptance criteria are satisfied. Known failure of the requirements of Surveillance, even without Surveillance specifically being "performed", constitutes a Surveillance not "met".

(continued)

Certificate of Compliance No. 1031 A1-13 Amendment No. 10

Frequency 1.4 EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or variables are outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

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

(continued)

Certificate of Compliance No. 1031 A1-14 Amendment No. 10

Frequency 1.4

EXAMPLES (continued) EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limit Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting activity AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter Example 1.4-2 has two Frequencies. The first is a one-time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting the activity.

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

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

Certificate of Compliance No. 1031 A1-15 Amendment No. 10

2.0

2.0 [Reserved]

Certificate of Compliance No. 1031 A2-1 Amendment No. 10

LCO Applicability 3.0 3.0 LIMITING CONDITION 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 failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5.

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

LCO 3.0.3 Not applicable to MAGNASTOR.

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 MAGNASTOR.

Exceptions to this Condition are stated in the individual Specifications .

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

LCO 3.0.5 This exception to LCO 3.0.2 is not applicable for the MAGNASTOR SYSTEM to return to service under administrative control to perform the testing .

Certificate of Compliance No. 1031 A3-1 Amendment No. 10

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be a failure to meet the LCO. Failure to perform Surveillance within the specified Frequency shall be a 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 Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed from the time of discovery up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less.

This delay period is permitted to allow performance of the Surveillance.

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

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

Certificate of Compliance No. 1031 A3-2 Amendment No. 1O

Transportable Storage Canister (TSC) 3.1.1

3.1 3.1.1 MAGNASTOR SYSTEM Integrity Transportable Storage Canister (TSC)

The TSC shall be dry and helium filled. The following vacuum drying LCO 3.1.1 times, helium backfill and TSC transfer times shall be met as appropriate to the fuel content type and heat load:

1. The time durations covering the beginning of canister draining through completion of vacuum drying and helium backfill, minimum helium backfill times, and TSC transfer times shall meet the following:

A. PWR TSC Transfer Using MTC Reduced Helium Backfill Time Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 20 No limit 0 600

5 25 50 0 70.5

5 30 19 7 8

:5 35.5 Heat Load 15 Maximum Vacuum Time 7

8. PWR Using MTC with Maximum TSC Transfer Minimum Helium 8

Maximum TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 25 No limit 24 48

5 30 32 24 22

5 35.5 24 24 22 C. BWR Using MTC with 8 Hours TSC Transfer Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 25 No limit 0 8

5 29 34 6 8

5 30 31 6 8

5 33 26 6 8

Certificate of Compliance No. 1031 A3-3 (continued)

Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1

D. BWR Using MTC with Maximum TSC Transfer Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 25 No limit 24 65

5 29 No limit 24 32

5 30 44 24 32

5 33 33 24 32 E. PWR TSC Transfer Using PMTC1 Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 20 No limit 0 600

525 54 0 600

5 30 32 0 600

2. The time duration from the end of TSC annulus cooling, either by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the pool or by the annulus circulating water system, through completion of vacuum drying and helium backfill using a MTC shall not exceed the following:

Heat Load Time Limit (hours)

PWR 35.5 11 BWR 33 16 Note: The helium backfill times and TSC transfer times provided in Tables 1.B and 1.D shall be used for operations following the second or subsequent vacuum drying cycles using the MTC.

(continued) 1

CE 16 x 16 fuel only, with a maximum storage cell location heat load of 811 watts.

Certificate of Compliance No. 1031 A3-4 Amendment No. 1O

Transportable Storage Canister (TSC) 3.1.1

3. The time duration from the end of TSC annulus cooling, either by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the pool or by the annulus circulating water system, through completion of vacuum drying and helium backfill using a PMTC shall not exceed the following:

Heat Load Time Limit (hours)

PWR 34 PWR 17 Note: The helium backfill times and TSC transfer times provided in Table 1.E shall be used for operations following the second or subsequent vacuum drying cycles using the PMTC.

APPLICABILITY: Prior to TRANSPORT OPERATIONS (continued)

Certificate of Compliance No. 1031 A3-5 Amendment No. 1 O

Transportable Storage Canister (TSC) 3.1.1

ACTIONS NOTE Separate Condition entry is allowed for each TSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. TSC cavity vacuum A.1 Perform an engineering evaluation to 7 days drying pressure limit determine the quantity of moisture not met. remaining in the TSC.

AND A.2 Develop and initiate corrective actions 30 days necessary to return the TSC to an analyzed condition.

B. TSC helium backfill B.1 Perform an engineering evaluation to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months density limit not met. determine the effect of helium density differential.

AND B.2 Develop and initiate corrective actions 14 days necessary to return the TSC to an analyzed condition.

C. Required Actions C. 1 Remove all fuel assemblies from the 30 days and associated TSC.

Completion Times not met.

(continued)

Certificate of Compliance No. 1031 A3-6 Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.1.1.1 Verify TSC cavity vacuum drying pressure FREQUENCY Once, prior to TRANSPORT is less than or equal to 10 torr for greater OPERATIONS.

than or equal to 10 minutes with the vacuum pump turned off and isolated.

SR 3.1.1.2 Following vacuum drying and evacuation to Once, prior to TRANSPORT

< 3 torr, backfill the cavity with high purity OPERATIONS.

helium until a mass Mhelium corresponding to the free volume of the TSC measured during draining (Vrsc), multiplied by the helium density (Lhelium) required for the design basis heat load and specified in Table A3-1, is reached .

Certificate of Compliance No. 1031 A3-7 Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1

Table A3-1 Helium Mass per Unit Volume for MAGNASTOR TSCs Fuel Type Helium Density

/liter PWR 0.694 - 0.802 BWR 0.704- 0.814

Certificate of Compliance No. 1031 A3-8 Amendment No. 1O

CONCRETE CASK or MSO Heat Removal System 3.1.2

3.1 3.1.2 LCO 3.1.2 MAGNASTOR SYSTEM Integrity CONCRETE CASK or MSO Heat Removal System The CONCRETE CASK or MSO Heat Removal System shall be OPERABLE.

APPLICABILITY: During STORAGE OPERATIONS ACTIONS NOTE Separate Condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CONCRETE CASK or A.1 Ensure adequate heat Immediately MSO Heat Removal removal to prevent System inoperable. exceeding short-term temperature limits.

A.2 Restore CONCRETE 30 days

SURVEILLANCE REQUIREMENTS CASK or MSO Heat Removal System to OPERABLE status.

SURVEILLANCE FREQUENCY SR 3.1.2.1 Verify that the difference between the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average CONCRETE CASK or MSO air outlet temperature and ISFSI ambient temperature indicates that the CONCRETE CASK or MSO Heat Removal System is operable in accordance with the FSAR thermal evaluation.

OR Visually verify all CONCRETE CASK or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months MSO air inlet and outlet screens are free of blockage .

Certificate of Compliance No. 1031 A3-9 Amendment No. 10

Dissolved Boron Concentration 3.2.1

3.2 3.2.1 LCO 3.2.1 MAGNASTOR SYSTEM Criticality Control for PWR Fuel Dissolved Boron Concentration The dissolved boron concentration in the water in the TSC cavity shall be greater than, or equal to, the concentration specified in Appendix B, Table B2-4. A minimum concentration of 1,500 ppm is required for all PWR fuel types. Higher concentrations are required, depending on the fuel type and enrichment.

APPLICABILITY: During LOADING OPERATIONS and UNLOADING OPERATIONS with water and at least one fuel assembly in the TSC.

ACTIONS NOTE Separate Condition entry is allowed for each TSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. Dissolved boron A. 1 Suspend LOADING Immediately concentration not OPERATIONS or

met.

AND A.2 UNLOADING OPERATIONS Suspend positive reactivity Immediately additions.

A.3 Initiate action to restore Immediately boron concentration to within limits.

(continued)

Certificate of Compliance No. 1031 A3-10 Amendment No. 10

Dissolved Boron Concentration 3.2.1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify the dissolved boron concentration is Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to met using two independent measure- commencing LOADING ments. OPERATIONS or UNLOADING OPERATIONS.

AND Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter while the TSC is in the spent fuel pool or while water is in the TSC .

Certificate of Compliance No. 1031 A3-11 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

3.3 3.3.1 MAGNASTOR SYSTEM Radiation Protection CONCRETE CASK or MSO Maximum Surface Dose Rate LCO 3.3.1 The maximum surface dose rates for the CONCRETE CASK (Reference Figure A3-1) or MSO (Reference Figure A3-2), shall not exceed the following limits:

a. PWR and BWR - 120 mrem/hour gamma and 5 mrem/hour neutron on the vertical surfaces (at locations specified on Figures A3-1 and A3-2); and

b. PWR and BWR - 450 mrem/hour (neutron + gamma) on the top.

APPLICABILITY: Prior to start of STORAGE OPERATIONS ACTIONS

NO TE------- -----------------

Separate Condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CONCRETE CASK A.1 Administratively verify correct 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or MSO maximum fuel loading surface dose rate limits not met AND A.2 Perform analysis to verify 7 days compliance with the ISFSI radiation protection requirements of 10 CFR 20 and 10 CFR 72 B. Required Action B.1 Perform (and document) an 60 days and associated engineering assessment and Completion Time take appropriate corrective not met action to ensure the dose limits of 10 CFR 20 and 10 CFR 72 are not exceeded (continued)

Certificate of Compliance No. 1031 A3-12 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify maximum surface dose rates of Prior to start of STORAGE CONCRETE CASK or MSO loaded with a OPERATIONS of each loaded TSC containing fuel assemblies are within CONCRETECASKorMSO limits. Dose rates shall be measured at the before or after placement on locations shown in Figure A3-1 or A3-2. the ISFSI pad .

Certificate of Compliance No. 1031 A3-13 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement Measure dose rates at so*

approximate 70-inch diameter at four points approximately on 90-degree axes.

270"

TSC mid-plane - approximately 92 inches from bottom. Measure dose rates at four target points (approximately 0, 90, 180 & 270 degrees) on the mid-plane .

Certificate of Compliance No. 1031 A3-14 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

Figure A3-2 MSO Surface Dose Rate Measurement Measure dose rates at approximately 70 inch goo diameter at four points approximately on 90 degree axes.

180° 270°

I I

I I

TSC mid-plane approximately\_

I I

92 inches from bottom. Measure I

1------

dose rates at four target points (approximately 0, 90, 180 & 270 degrees) on the mid-plane.

1 I

I I

Certificate of Compliance No. 1031 A3-15 Amendment No. 10

TSC Surface Contamination 3.3.2 3.3 MAGNASTOR SYSTEM Radiation Protection 3.3.2 TSC Surface Contamination LCO 3.3.2 Removable contamination on the exterior surfaces of the TSC shall not exceed:

a. 10,000 dpm/100 cm 2 from beta and gamma sources; and

b. 100 dpm/100 cm 2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

NO TE---------------------------------*---

Se pa rate Condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A TSC removable surface A.1 Restore TSC removable Prior to TRANSPORT contamination limits not surface contamination OPERATIONS met to within limits (continued)

Certificate of Compliance No. 1031 A3-16 Amendment No. 10

TSC Surface Contamination 3.3.2

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2 Verify by either direct or indirect methods Once, prior to TRANSPORT that the removable contamination on the OPERATIONS exterior surfaces of the TSC is within limits

Certificate of Compliance No. 1031 A3-17 Amendment No. 10

DESIGN FEATURES 4.0 4.0 DESIG N FEATURES 4.1 Design Features Significant to Safety 4.1.1 Criticality Control 10 a) Mini mum B loading in the neutron absorber material:

Re quired Minimum Effective Required Minimum Actual Neutron Areal Density % Credit Used in Areal Density Absorber 109 /cm2 Criticality 109 /cm2 Type pWR Fuel 8WR Fuel Anal ses PWR Fuel 8WR Fuel Borated 0.036 0.027 0.04 0.03 Aluminum Alloy 0.030 0.0225 90 0.0334 0.025 0.027 0.020 0.03 0.0223 Borated MMC 0.036 0.027 0.04 0.03 0.030 0.0225 90 0.0334 0.025 0.027 0.020 0.03 0.0223 Baral 0.036 0.027 0.048 0.036 0.030 0.0225 75 0.04 0.030 0.027 0.020 0.036 0.0267 Enri chmenUsoluble boron limits for PWR systems and enrichment limits for BWR systems are incorporated in Appendix B Section 2.0 .

b) Ace eptance and qualification testing of borated aluminum alloy and borated MM C neutron absorber material shall be in accordance with Sections 10.1 .6.4.5, 10.1.6.4.6 and 10.1.6.4.7. Acceptance testing of Baral shall be in ace ordance with Section 10.1.6.4.8. These sections of the FSAR are hereby inco rporated into the MAGNASTOR CoC.

c) Solu ble boron concentration in the PWR fuel pool and water in the TSC shall be in accordance with LCO 3.2.1, with a minimum water temperature 5-10°F high er than the minimum needed to ensure solubility.

d) Mini mum fuel tube outer diagonal dimension PW R basket - 13.08 inches BWR basket - 8.72 inches Note: Not applicable to DFC locations of the OF Basket Assembly.

4.1.2 Fuel Cl adding Integrity The lice nsee shall ensure that fuel oxidation and the resultant consequences are preclud ed during canister loading and unloading operations.

4.1.3 Transfe r Cask Shielding The no minal configuration transfer cask radial bulk shielding (i.e., shielding integral to the transfer cask; excludes supplemental shielding) must provide a (continued)

Certificate of Compli ance No. 1031 A4-1 Amendment No. 10

DESIGN FEATURES 4.0

minimum radiation shield equivalent to 2 inches of carbon steel or stainless steel and 3.2 inches of lead gamma shielding and 2.25 inches of NS-4-FR (with 0.6 wt

% B4C and 6.0 wt % H) neutron shielding. Material and dimensions of the individual shield layers may vary provided maximum calculated radial dose rates of 1100 mrem/hr (PWR system) and 1600 mrem/hr (BWR system) are maintained on the vertical surface (not including doors or vent shielding).

4.1.4 TSC Confinement Integrity The TSC shell, bottom plate, all confinement welds, and the COMPOSITE CLOSURE LID shall be fabrication helium leak-tested in accordance with ANSI N14.5 to leaktight criterion.

The closure lid shall be helium leak-tested during fabrication (in accordance with ANSI N 14.5 to leaktight criterion) if it is constructed with a lid thickness less than 9 inches (nominal).

4.2 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition with Addenda through 2003, Section Ill, Subsection NB, is the governing Code for the design, material procurement, fabrication, and testing of the TSC .

The ASME Code, 2001 Edition with Addenda through 2003, Section Ill, Subsection NG, is the governing Code for the design, material procurement, fabrication and testing of the spent fuel baskets.

The American Concrete Institute Specifications ACl-349 and ACl-318 govern the design and construction of the vertically reinforced concrete structure of the CONCRETE CASK, respectively and not the CONCRETE CASK lid or upper segment, if equipped.

The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition with Addenda through 2003, Section Ill, Subsection NF, is the governing Code for the design of the MSO. The applicable standards of the American Society for Testing and Materials (ASTM) govern material procurement and the American Welding Society (AWS) D1 .1 or ASME Code Section VIII govern fabrication of the MSO.

The American National Standards Institute ANSI N14.6 (1993) and NUREG-0612 govern the TRANSFER CASK design, operation, fabrication, testing, inspection, and maintenance.

4.2.1 Alternatives to Codes, Standards, and Criteria Table 2.1-2 of the FSAR lists approved alternatives to the ASME Code for the design, procurement, fabrication, inspection and testing of MAGNASTOR SYSTEM TSCs and spent fuel baskets .

(continued)

Certificate of Compliance No. 1031 A4-2 Amendment No. 10

DESIGN FEATURES 4.0

4.2.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to ASME Code, Section Ill, 2001 Edition with Addenda through 2003, other than the alternatives listed in Table 2.1-2 of the FSAR, may be used when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternatives should demonstrate that:

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

2. Compliance with the specified requirements of ASME Code, Section Ill, Subsections NB and NG, 2001 Edition with Addenda through 2003, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

4.3 Site-Specific Parameters and Analyses This section presents site-specific parameters and analytical bases that must be verified by the MAGNASTOR SYSTEM user. The parameters and bases presented in Section 4.3.1 are those applied in the design bases analysis.

4.3.1 Design Basis Specific Parameters and Analyses The design basis site-specific parameters and analyses that require verification by the MAGNASTOR SYSTEM user are:

a. A temperature of 76°F is the maximum average yearly temperature. The three-day average ambient temperature shall be s106°F.

b. The allowed temperature extremes, averaged over a three-day period, shall be ~-40°F and :5133°F.

c. The analyzed flood condition of 15 fps water velocity and a depth of 50 ft of water (full submergence of the loaded cask) are not exceeded.

d. The potential for fire and explosion shall be addressed, based on site-specific considerations. This includes the condition that the fuel tank(s) of the cask handling equipment used to move the loaded CONCRETE CASK or MSO onto or from the ISFSI site contains a total of no more than 50 gallons of fuel.

(continued)

Certificate of Compliance No. 1031 A4-3 Amendment No. 10

DESIGN FEATURES 4.0

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

f. The TRANSFER CASK shall not be operated and used when surrounding air temperature is < 0°F. This limit is NOT applicable to the stainless steel MTC or PMTC.

g. The CONCRETE CASK or MSO shall not be lifted by the lifting lugs with surrounding air temperatures < 0°F.

h. Loaded CONCRETE CASK or MSO lifting height limit :524 inches.

i. The maximum design basis earthquake acceleration of 0.37g in the horizontal direction (without cask sliding) and 0.25g in the vertical direction at the ISFSI pad top surface do not result in cask tip-over.

For design basis earthquake accelerations up to and greater than 0.37g in the horizontal direction and 0.25g in the vertical direction at the ISFSI pad top surface, site-specific cask sliding is permitted with validation by the cask user that the cask does not slide off the pad and that the g-load resulting from the collision of two sliding casks remains bounded by the cask tip-over accident condition analysis presented in Chapter 3 of the FSAR.

An alternative to crediting site-specific cask sliding for design basis earthquake accelerations up to and greater than 0.37g in the horizontal direction and 0.25g in the vertical direction at the ISFSI pad top surface, the use of the MAGNASTOR system is permitted provided the ISFSI pad has bollards and the cask user validates that the cask does not overturn, g-loads resulting from the cask contacting the bollard is bounded by the cask tip-over accident condition presented in Chapter 3 of the FSAR, and the ISFSI pad and bollards are designed, fabricated and installed such that they are capable of handling the combined loading of the design basis earthquake and any contact between the bollard and cask during the design basis earthquake.

4.4 TSC Handling and Transfer Facility The TSC provides a leaktight confinement boundary and is evaluated for normal and off-normal handling loads. A handling and transfer facility is not required for TSC and TRANSFER CASK handling and transfer operations within a 10 CFR 50 licensed facility or for utilizing an external crane structure integral to a 10 CFR 50 licensed facility.

(continued)

Certificate of Compliance No. 1031 A4-4 Amendment No. 10

DESIGN FEATURES 4.0

Movements of the TRANSFER CASK and TSC outside of a 10 CFR 50 licensed facility are not permitted unless a TSC TRANSFER FACILITY is designed, operated, fabricated, tested, inspected, and maintained in accordance with the following requirements. These requirements do not apply to handling heavy loads under a 10 CFR 50 license.

The permanent or stationary weldment structure of the TSC TRANSFER FACILITY shall be designed to comply with the stress limits of ASME Code, Section Ill, Subsection NF, Class 3 for linear structures. All compression loaded members shall satisfy the buckling criteria of ASME Code, Section Ill, Subsection NF.

The reinforced concrete structure of the facility shall be designed in accordance with ACl-349 and the factored load combinations set forth in ACl-318 for the loads defined in Table A4-1 shall apply. TRANSFER CASK and TSC lifting devices installed in the handling facility shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with NUREG-0612, Section 5.1.

If mobile load lifting and handling equipment is used at the facility, that equipment shall meet the guidelines of NUREG-0612, Section 5.1, with the following conditions:

a. The mobile lifting device shall have a minimum safety factor of two over the allowable load table for the lifting device in accordance with the guidance of NUREG-0612, Section 5.1.6 (1)(a), and shall be capable of stopping and holding the load during a design earthquake event;

b. The mobile lifting device shall contain ::::;50 gallons of fuel during operation inside the ISFSI;

c. Mobile cranes are not required to meet the guidance of NUREG-0612, Section 5.1.6(2) for new cranes;

d. The mobile lifting device shall conform to the requirements of ASME 830.5, "Mobile and Locomotive Cranes";

e. Movement of the TSC, CONCRETE CASK, or MSO in a horizontal orientation is not permitted .

Certificate of Compliance No. 1031 A4-5 Amendment No. 10

DESIGN FEATURES 4.0

Table A4-1 Load Combinations and Service Condition Definitions for the TSC Handling and Transfer Facility Structure ASME Section Ill Service Load Combination Condition for Definition of Note Allowable Stress All primary load bearing D*

Level A members must satisfy Level A D+S stress limits D+ M +W' 1 Factor of safety against D+F Level D overturning shall be ?: 1.1, if D+E applicable.

D+Y D = Crane hook dead load D* = Apparent crane hook dead load s = Snow and ice load for the facility site M = Tornado missile load of the facility site 1

W' F

E y

=

Tornado wind load for the facility site 1 Flood load for the facility site Seismic load for the facility site Tsunami load for the facility site

1. Tornado missile load may be reduced or eliminated based on a Probabilistic Risk Assessment for the facility site .

Certificate of Compliance No. 1031 A4-6 Amendment No. 10

DESIGN FEATURES 4.0

5.0 5.1 ADMINISTRATIVE CONTROLS AND PROGRAMS Radioactive Effluent Control Program 5.1.1 A program shall be established and maintained to implement the requirements of 10 CFR 72.44 (d) or 10 CFR 72.126, as appropriate.

5.1.2 The MAGNASTOR SYSTEM does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents are not required. LCO 3.3.2, TSC Surface Contamination, provides assurance that excessive surface contamination is not available for release as a radioactive effluent.

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

5.2 TSC Loading, Unloading, and Preparation Program A program shall be established to implement the FSAR, Chapter 9 general procedural guidance for loading fuel and components into the TSC, unloading fuel and components from the TSC, and preparing the TSC and CONCRETE CASK or MSO for storage. The requirements of the program for loading and preparing the TSC shall be completed prior to removing the TSC from the 10 CFR 50 structure. The program requirements for UNLOADING OPERATIONS shall be maintained until all spent fuel is removed from the spent fuel pool and TRANSPORT OPERATIONS have been completed on the last CONCRETE CASK or MSO. The program shall provide for evaluation and control of the following requirements during the applicable operation:

a. Verify that no TRANSFER CASK, CONCRETE CASK or MSO handling using the lifting lugs occurs when the ambient temperature is

< 0°F. This limit is NOT applicable to the stainless steel MTC or PMTC.

b. The water temperature of a water-filled, or partially filled, loaded TSC shall be shown by analysis and/or measurement to be less than boiling at all times.

c. Verify that the drying time, cavity vacuum pressure, and component and gas temperatures ensure that the fuel cladding temperature limit of 400°C is not exceeded during TSC preparation activities, including TRANSFER OPERATIONS, and that the TSC is adequately dry. For fuel with burnup

> 45 GWd/MTU, limit cooling cycles to :5 10 for temperature changes greater than 65°C.

d. Verify that the helium backfill purity and mass assure adequate heat transfer and preclude fuel cladding corrosion.

e. The integrity of the inner port cover welds to the closure lid at the vent port and at the drain port shall be verified in accordance with the procedures in Section 9.1.1.

(continued)

Certificate of Compliance No. 1031 A5-1 Amendment No. 10

DESIGN FEATURES 4.0

f. Verify that the time to complete the transfer of the TSC from the TRANSFER CASK to the CONCRETE CASK or MSO and from a CONCRETE CASK to another CONCRETE CASK, and from an MSO to another MSO assures that the fuel cladding temperature limit of 400°C is not exceeded.

g. The surface dose rates of the CONCRETE CASK or MSO are adequate to allow proper storage and to assure consistency with the offsite dose analysis.

h. The equipment used to move the loaded CONCRETE CASK or MSO onto or from the ISFSI site contains no more than 50 gallons of fuel.

This program will control limits, surveillances, compensatory measures and appropriate completion times to assure the integrity of the fuel cladding at all times in preparation for and during LOADING OPERATIONS, UNLOADING OPERATIONS, TRANSPORT OPERATIONS, TRANSFER OPERATIONS and STORAGE OPERATIONS, as applicable.

5.3 Transport Evaluation Program A program that provides a means for evaluating transport route conditions shall be developed to ensure that the design basis impact g-load drop limits are met.

For lifting of the loaded TRANSFER CASK, CONCRETE CASK, or MSO using

devices that are integral to a structure governed by 10 CFR 50 regulations, 10 CFR 50 requirements apply. This program evaluates the site-specific transport route conditions and controls, including the transport route road surface conditions; road and route hazards; security during transport; ambient temperature; and equipment operability and lift heights. The program shall also consider drop event impact g-loading and route subsurface conditions, as necessary.

5.4 ISFSI Operations Program A program shall be established to implement FSAR requirements for ISFSI operations.

At a minimum, the program shall include the following criteria to be verified and controlled:

a. Minimum CONCRETE CASK or MSO center-to-center spacing.

b. ISFSI pad parameters (i.e., thickness, concrete strength, soil modulus, reinforcement, etc.) are consistent with the FSAR analyses.

c. Maximum CONCRETE CASK or MSO lift heights ensure that the g-load limits analyzed in the FSAR are not exceeded .

Certificate of Compliance No. 1031 A5-2 Amendment No. 10

APPENDIX B PROPOSED APPROVED CONTENTS FOR THE MAGNASTOR SYSTEM AMENDMENT 10

Certificate of Compliance No. 1031 Amendment No. 10

Appendix B Table of Contents 1.0 FUEL SPECIFICATIONS AND LOADING CONDITIONS ......................................................... 81-1 2.0 FUEL TO BE STORED IN THE MAGNASTOR SYSTEM ......................................................... B2-1 List of Figures Figure B2-1 Schematic of 37 - Fuel Storage Location Map ................................................... B2-11 Figure B2-2 [DELETED] .................................................................................................................. B2-12 Figure B2-3 [DELETED] .............................................................................................. B2-12 Figure B2-4 Schematic of 87-Assembly BWR Basket. ........................................................... B2-18 Figure B2-5 Schematic of 82-Assembly BWR Basket ................................................................... 82-19 Figure B2-6 BWR Partial Length Fuel Rod Location Sketches ...................................................... B2-20 List of Tables Table B2-1 TSC with PWR Fuel Limits ............................................................................................ B2-2 Table B2-2 PWR Fuel Loading Patterns ......................................................................................... 82-5 Table B2-3 Bounding PWR Fuel Assembly Physical Characteristics ............................................. 82-6 Table B2-4 Bounding PWR Fuel Assembly Loading Criteria - EnrichmenUSoluble Boron Limits ...................................................................................................................B2-7 Table B2-5 Additional SNF Assembly Cool Time Required to Load NONFUEL HARDWARE ................................................................................................................. 82-8 Table B2-6 Allowed BPAA/NSA Burn up and Cool Time Combinations .......................................... 82-9 Table B2-7 Allowed GTPD/NSA Burnup and Cool Time Combinations .......................................... 82-9

Table Table Table Table Table B2-8 B2-9 B2-10 B2-11 B2-12 Table B2-13 Minimum Cool Time Summary Table .......................................................................... B2-10 TSC with BWR Fuel Limits .......................................................................................... B2-13 BWR SNF Assembly Characteristics .......................................................................... 82-15 BWR SNF Assembly Loading Criteria ........................................................................ 82-16 BWR SNF Assembly Loading Criteria - Enrichment Limits for 87-Assembly and 82-Assembly Configurations .......................................................... 82-17 PWR Loading Table - Low SNF Assembly Average Burn up Enrichment Limits ........................................................................................................................... 82-21 Table B2-14 BWR Loading Table - Low SNF Assembly Average Burn up Enrichment Limits ........................................................................................................................... B2-21 Table B2-15 Loading Table for PWR Fuel - 959 W/Assembly ....................................................... 82-22 Table B2-16 Loading Table for PWR Fuel - 911 W/Assembly ....................................................... 82-27 Table B2-17 Loading Table for PWR Fuel - 1,200 W/Assembly .................................................... B2-35 Table B2-18 Loading Table for PWR Fuel - 1,140 W/Assembly .................................................... 82-40 Table B2-19 Loading Table for PWR Fuel - 922 W/Assembly ....................................................... 82-48 Table B2-20 Loading Table for PWR Fuel - 876 W/Assembly ....................................................... 82-53 Table B2-21 Loading Table for PWR Fuel - 800 W/Assembly ....................................................... 82-61 Table B2-22 Loading Table for PWR Fuel - 760 W/Assembly ....................................................... B2-66 Table B2-23 Loading Table for BWR Fuel - 379 W/Assembly ....................................................... B2-74 Table B2-24 Loading Table for BWR Fuel - 360 W/Assembly ............................................................. B2-79 Table B2-25 Loading Table for PWR Fuel - 959 W/Assembly-WE 14x14 Fuel. ............................. B2-87 Table B2-26 Loading Table for PWR Fuel - 513 W/Assembly - WE 14x14 Fuel. ............................. 82-90 Table B2-27 Loading Table for PWR Fuel -1300 W/Assembly-WE 14x14 Fuel ........................... 82-93 Table B2-28 Loading Table for PWR Fuel -1800 W/Assembly-WE 14x14 Fuel ........................... B2-96 Table B2-29 Loading Table for PWR Fuel - 830 W/Assembly-WE 14x14 Fuel. ............................. B2-99 Table B2-30 Loading Table for PWR Fuel - 487 W/Assembly- WE 14x14 Fuel. ........................... B2-102 Table B2-31 Loading Table for PWR Fuel -1235 W/Assembly- WE 14x14 Fuel ......................... B2-105 Table B2-32 Loading Table for PWR Fuel-1710 W/Assembly-WE 14x14 Fuel .........................82-108 Table B2-33 Loading Table for PWR Fuel - 788 W/Assembly-WE 14x14 Fuel. ........................... B2-111 Certificate of Compliance No. 1031 B-1 Amendment No. 10

Table B2-34 Loading Table for PWR Fuel - 513 W/Assembly - CE 16x16 Fuel ............................ B2-114

Table Table Table Table Table Table Table B2-35 B2-36 B2-37 B2-38 B2-39 B2-40 B2-41 Loading Table for PWR Fuel - 1300 W/Assembly - CE 16x16 Fuel .......................... B2-117 Loading Table for PWR Fuel -1800 W/Assembly - CE 16x16 Fuel ..........................82-120 Loading Table for PWR Fuel - 830 W/Assembly - CE 16x16 Fuel ............................82-123 Loading Table for PWR Fuel - 487 W/Assembly - CE 16x16 Fuel ............................82-126 Loading Table for PWR Fuel -1235 W/Assembly- CE 16x16 Fuel .......................... B2-129 Loading Table for PWR Fuel - 1710 W/Assembly - CE 16x16 Fuel .......................... B2-132 Loading Table for PWR Fuel - 788 W/Assembly - CE 16x16 Fuel ............................82-135 Table B2-42 Low SNF Assembly Average 8urnup Enrichment Limits for CE 16x16 Fuel Loaded via the PMTC ..............................................................................................82-138 Table B2-43 Loading Table for CE 16x16 Fuel Loaded via the PMTC ........................................82-138

Certificate of Compliance No. 1031 B-2 Amendment No. 10

Appendix B Approved Contents

1.0 FUEL SPECIFICATIONS AND LOADING CONDITIONS The MAGNASTOR SYSTEM is designed to safely store up to 37 undamaged PWR fuel assemblies in the 37 PWR Basket Assembly or up to 87 undamaged BWR fuel assemblies in the 87 BWR Basket Assembly. The system is also designed to store up to 4 damaged fuel cans (DFCs) in the OF Basket Assembly.

The OF Basket Assembly has a capacity of up to 37 undamaged PWR fuel assemblies including 4 DFC locations. DFCs may be placed in up to 4 of the DFC locations. Each DFC may contain an undamaged PWR fuel assembly, a damaged PWR fuel assembly, or PWR FUEL DEBRIS equivalent to one PWR fuel assembly. FUEL DEBRIS is included in the definition of DAMAGED FUEL (Appendix A, Section 1.1 ). PWR UNDAMAGED FUEL assemblies may be placed directly in the DFC locations of a OF Basket Assembly without the use of a DFC.

The system requires few operating controls. The principal controls and limits for MAGNASTOR are satisfied by the selection of fuel for storage that meets the Approved Contents presented in this section and in the tables for MAGNASTOR design basis spent fuels.

If any Fuel Specification or Loading Condition of this section is violated, the following actions shall be completed:

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

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

Within 60 days, submit a special report that describes the cause of the violation and actions taken to restore or demonstrate compliance and prevent reoccurrence .

Certificate of Compliance No. 1031 81-1 Amendment No. 10

Appendix B Approved Contents

2.0 FUEL TO BE STORED IN THE MAGNASTOR SYSTEM UNDAMAGED PWR FUEL ASSEMBLIES, DAMAGED PWR FUEL ASSEMBLIES, PWR FUEL DEBRIS (DAMAGED FUEL), UNDAMAGED BWR FUEL ASSEMBLIES and NONFUEL HARDWARE meeting the limits specified in this section may be stored in the MAGNASTOR SYSTEM .

Certificate of Compliance No. 1031 82-1 Amendment No. 10

ftNAC fiffl INTERNATIONAL

September 2, 2021 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852-2738 Attn: Document Control Desk

Subject:

Supplemental Responses to the NRCs Request for Additional Information for the NAC International MAGNASTOR Cask System Amendment No. 10 Docket No. 72-103 I

References:

1. U.S. Nuclear Regulatory Commission (NRC) Certificate of Compliance (CoC) No.

1031 for the NAC International MAGNASTOR Cask System, Amendment No. 7, March 24, 2019

2. MAGNASTOR Cask System Final Safety Analysis Report (FSAR),

Revision 10, NAC International, February 2019

3. ED20190099, Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, October 9, 2019

4. ED20190125, Submission of a Request to Amend the U.S. Nuclear Regulatory Commission Certificate of Compliance No. 1031 for the NAC International MAGNASTOR Cask System, December 9, 2019

5. U.S. Nuclear Regulatory Commission (NRC), Application for Amendment No. 10 to the Model No. MAGNASTOR Storage Cask- Request for Supplemental Information, March 11, 2020

6. ED2020006 l, Submission of a Responses to the NRCs Request for Supplemental Information for the NAC International MAGNASTORCask System Amendment No. 10, May 13, 2020

7. U.S. Nuclear Regulatory Commission (NRC), Application for Amendment No. 10 to the Model No. MAGNASTOR Storage Cask- First Request for Additional Information, October 8, 2020

8. ED20210025, Submission ofa Responses to the NRCs Request for Additional Information for the NAC International MAGNASTORCask System Amendment No. 10, February 25, 2021

9. ED20210069, Supplemental Responses to the NRCs Request for Additional Information for the NAC International MAGNASTOR Cask System Amendment No. 10, April 20, 2021

10. U.S. Nuclear Regulatory Commission (NRC), Application for Amendment No. 10 to the Model No. MAGNASTOR Storage Cask- Second Request for Additional Information, July 12, 2021

ED20210109

ANAC fifrl INTERNATIONAL

U.S. Nuclear Regulatory Commission September 2, 2021 Page 2 of2 NAC International (NAC) hereby submits responses to Reference 10. In response to RAI 2-1 and 4-1, NAC has elected to remove the requirement that the MSO be stored at an ISFSI which is enclosed by a building from the environment. NAC has elected to remove the building requirement and directly address the original RSI and RAJ pertaining to the effects of low-wind speeds presented in References 5 and 7. In addressing the effects of low-wind speed, no changes to the FSAR change pages submitted via 19C and 21A are affected. However, the proposed Technical Specifications have been revised to remove the requirement that the MSO is to be used in at an ISFSI enclosed by a building.

In accordance with NAC's administrative practices and upon final acceptance of this application, the 19C and 21A changed pages will be reformatted and incorporated into the next revision of the MAGNASTOR FSAR. Attached to this letter is a signed affidavit requesting all proprietary information be withheld from public disclosure via 10 CFR 2.390.

If you have any comments or questions, please contact me on my direct line at 678-328-1236.

Sincerely,

Wren Fowler Director, Licensing Engineering Attachment Attachment 1 - NAC International Affidavit Pursuant to 10 CFR 2.390

Enclosures:

Enclosure 1 - 2 nd Round RAI Responses for Amendment 10 Enclosure 2 - Proposed Changes for MAGNASTOR Technical Specifications Enclosure 3 - Supporting Calculations and References

ED20210!09

ftNAC riffl INTERNATIONAL

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 George Carver (Affiant), Vice President, Engineering and Support Services, of NAC International, hereinafter referred to as NAC, at 3930 East Jones Bridge Road, Peachtree Corners, Georgia 30092, being duly sworn, deposes and says that:

I. Affiant has reviewed the information described in Item 2 and is personally familiar with the trade secrets and privileged information contained therein, and is authorized to request its withholding.

2. The information to be withheld includes the following NAC Proprietary Information that is being provided to support the technical review of NA C's Request for a Certificate of Compliance (CoC)

(No. 1031) for the NAC International MA GNAS TOR Cask System.

Enclosure 1 - Proprietary Request for Additional Information, Pages 3 thru 5

Enclosure 3 - Supporting Calculations and References o NAC Calculation 30082-3603, Revision Oand Data Disk I of I o BISCO Products, Inc. Technical Report No. NS-3-009, "Off-Gassing ofBISCO NS-3 Due to Accelerated Radiation Aging", September 9, 1983 NAC is the owner of the information contained in the above documents. Thus, all of the above identified information is considered NAC Proprietary Information.

3. NAC makes this application for withholding of proprietary information based upon the exemption from disclosure set forth in: the Freedom of Information Act ("FOIA"); 5 USC Sec. 552(b )( 4) and the Trade Secrets Act; 18 USC Sec. 1905; and NRC Regulations 10 CFR Part 9.17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial financial information obtained from a person, and privileged or confidential" (Exemption 4). The information for which exemption from disclosure is herein sought is all "confidential commercial information," and some portions may also qualify under the narrower definition of "trade secret," within the meanings assigned to those terms for purposes of FOIA Exemption 4.

4. Examples of categories of information that fit into the definition of proprietary information are:

a. Information that discloses a process, method, or apparatus, including supporting data and analyses, where prevention of its use by competitors of NAC, without license from NAC, constitutes a competitive economic advantage over other companies.

b. Information that, if used by a competitor, would reduce their expenditure of resources or improve their competitive position in the design, manufacture, shipment, installation, assurance of quality or licensing of a similar product.

c. Information that reveals cost or price information, production capacities, budget levels or commercial strategies ofNAC, its customers, or its suppliers.

d. Information that reveals aspects of past, present or future NAC customer-funded development plans and programs of potential commercial value to NAC.

e. Information that discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information that is sought to be withheld is considered to be proprietary for the reasons set forth in Items 4.a, 4.b, and 4.d.

ED20210109 Page I of3

ftNAC rftfl INTERNATIONAL

NAC INTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390

5. The information to be withheld is being transmitted to the NRC in confidence.

6. The information sought to be withheld, including that compiled from many sources, is of a sort customarily held in confidence by NAC, and is, in fact, so held. This information has, to the best of my knowledge and belief, consistently been held in confidence by NAC. No public disclosure has been made, and it is not available in public sources. All disclosures to third parties, including any required transmittals to the NRC, have been made, or must be made, pursuant to regulatory provisions or proprietary agreements, which provide for maintenance of the information in confidence. Its initial designation as proprietary information and the subsequent steps taken to prevent its unauthorized disclosure are as set forth in Items 7 and 8 following.

7. Initial approval of proprietary treatment of a document/information is made by the Vice President, Engineering, the Project Manager, the Licensing Specialist, or the Director, Licensing - the persons most likely to know the value and sensitivity of the information in relation to industry knowledge.

Access to proprietary documents within NAC is limited via "controlled distribution" to individuals on a "need to know" basis. The procedure for external release ofNAC proprietary documents typically requires the approval of the Project Manager based on a review of the documents for technical content, competitive effect and accuracy of the proprietary designation. Disclosures of proprietary documents outside of NAC are limited to regulatory agencies, customers and potential customers and their agents, suppliers, licensees and contractors with a legitimate need for the information, and then only in accordance with appropriate regulatory provisions or proprietary agreements .

8. NAC has invested a significant amount of time and money in the research, development, engineering and analytical costs to develop the information that is sought to be withheld as proprietary. This information is considered to be proprietary because it contains detailed descriptions of analytical approaches, methodologies, technical data and/or evaluation results not available elsewhere. The precise value of the expertise required to develop the proprietary information is difficult to quantify, but it is clearly substantial.

9. Public disclosure of the information to be withheld is likely to cause substantial harm to the competitive position ofNAC, as the owner of the information, and reduce or eliminate the availability of profit-making opportunities. The proprietary information is part of NA C's comprehensive spent fuel storage and transport technology base, and its commercial value extends beyond the original development cost to include the development of the expertise to determine and apply the appropriate evaluation process. The value of this proprietary information and the competitive advantage that it provides to NAC would be lost if the information were disclosed to the public. Making such information available to other parties, including competitors, without their having to make similar investments of time, labor and money would provide competitors with an unfair advantage and deprive NAC of the opportunity to seek an adequate return on its large investment .

ED20210109 Page 2 of3

ftNAC WFI INTERNATIONAL

NACINTERNATIONAL AFFIDAVIT PURSUANT TO 10 CFR 2.390 STA TE OF GEORGIA, COUNTY OF GWINNETT Mr. George Carver, being duly sworn, deposes and says:

That he has read the foregoing affidavit and the matters stated herein are true and correct to the best of his knowledge, information and belief.

Executed at Peachtree Corners, Georgia, this _ _ _ day of _ _ _ _ _ _ _, 2021.

George Carver Vice President, Engineering and Support Services, NAC International Subscribed and sworn before me this _ _ _day of _ _ _ _ _ _ _, 2021.

Notary Public

ED20210109 Page 3 of3

Enclosure 1 to ED202 l O109 Page 1 of 1 Enclosure 1 NACINTERNATIONAL RESPONSES TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION REQUEST FOR ADDITIONAL INFORMATION

for MAGNASTOR FSAR 2nd Round RAI Responses for Amendment 10 (Docket No 72-1031)

NAC International September 2021

Enclosure I to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 Enclosure 1 NACINTERNATIONAL RESPONSE TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION NON-PROPRIETARY REQUEST FOR ADDITIONAL INFORMATION

July 2021 FOR REVIEW OF THE CERTIFICATE OF COMPLIANCE NO. 1031, AMENDMENT NO. 10 (EPID No. L-2019-LLA-0273 DOCKET NO. 72-1031)

September 2021

Page 1 of 7

Enclosure 1 to £D20210109 MAGNASTOR Docket No.: 72-1031

TABLE OF CONTENTS EPID No. L-2019-LLA-0273 STRUCTURAL EVALUATION .................................................................................................. ...................................... 3 THERMAL EVALUATION .................................................................................................. ........................................... 5 SHIELDING EVALUATION .................................................................................................. ......................................... 7

Page 2 of 7

Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-20 I 9-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION STRUCTURAL EVALUATION 2-1 Provide an evaluation of the building structure mentioned in the Proposed Technical Specifications (TS) submitted as Enclosure 4 ofNAC Jnternational's Responses to the NRC's RAJ and the response to thermal RAis in Enclosure 1 of the submission dated February 25, 2021. The evaluation of the building should include the following information:

a) an assessment of the building's safety significance including a justification of the safety significance; b) the design bases of the building including the design codes and standards and the methods used for load determination, particularly lateral loads from natural phenomena hazards; c) the design criteria of the building including the design codes and standards and the methods used to determine the structural capacity of the building members and the design safety margin; and d) an analysis or a description of an analysis demonstrating that the building will not affect the performance of the MSO cask under normal, off-normal, and accident

conditions, including natural phenomena. The analysis should include the input parameters and methods of evaluation (e.g., the use of structural analysis software or finite element analysis software).

In proposed TS 4.3.lG), the applicant included the requirement that the MSO cask must be stored in a building structure. The applicant described in the response to thermal RAJ 4-1 that this storage building is necessary to assure protection from low speed wind. However, the applicant has not provided any description or evaluation related to the proposed storage building in the SAR or any referenced structural documents.

The applicant's statements about the building in the thermal RAJ responses and the TS imply the building provides a safety related thermal function (i.e., eliminating the low speed wind effects on the cask). Furthermore, the staff notes that a collapse of the building onto the cask could lead to a loss of containment, a loss of shielding, or a criticality. Thus, the building could be a system, structure, or component (SSC) whose failure could indirectly result in conditions adversely affecting public health and safety. Following guidance in NUREG/CR-6407, "Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety," this could qualify the building as important to safety (ITS).

The regulations in Title 10 of Code of Federal Regulations (10 CFR) 72.236(6) requires that applicants for a certificate of compliance (CoC) provide the design bases and design criteria for SSCs that are ITS. Also, 10 CFR 72.236(1) requires that applicants for a CoC evaluate ITS SSCs to demonstrate that they will maintain confinement of radioactive material under normal, off-normal, and accident conditions. If the storage building is an ITS SSC, the applicant is required to provide the design bases and design criteria of the building by 10 Page 3 of7

Enclosure I to ED20210 I 09 MAGNASTOR Docket No.: 72-1031

EPID No. L-20 I 9-LLA-0273 CFR 72.236(6) as well as a structural evaluation of the building by IO CFR 72.236(1).

The applicant stated in the response to RAI 4-2 that the building's design will depend on site-specific conditions, and the applicant described how the requirements of IO CFR 72.212 and IO CFR 72.48 would require a general licensee using the MSO cask to perform an evaluation of the building's influence on the cask. As the applicant noted in the RAI response, IO CFR 72.212 and 10 CFR 72.48 evaluations consider the design bases, methods of evaluation, and other aspects of the evaluations from the CoC holder's final safety analysis report (FSAR) for the storage system's design. However, the applicant has not provided any design bases or performed any evaluation for the proposed storage building in the SAR or any referenced document associated with this amendment. The design bases and evaluations are required to be provided by the applicant for a CoC in the FSAR per IO CFR 72.236 and are needed to conduct the evaluations described in §§ 72.48 and 72.212.

The staff recognizes there are site-specific aspects to the design and evaluation of the proposed storage building. However, §72.236 does not allow for any exemptions for site-specific ITS SSCs and requires the CoC holder to provide the design bases, the design criteria, and an evaluation of the ITS SSCs. The evaluation and design information required of the CoC holder and documented in the FSAR may then serve to establish the methods of evaluation and the bounding parameters of the SSCs.

The staff requests an evaluation of the storage building including the building's safety significance, design bases, and design criteria. The staff also requests a structural analysis or

a description of a structural analysis assessing the structural performance of the building and any effect it may have on the MSO cask under normal, off-normal, and accident conditions, including natural phenomena. This information should include the codes and standards, the input parameters, and the specific methods of evaluation that will be used to design and analyze the building. Finally, the staff requests that the SAR be updated to include the information requested.

This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.236(6) and 10 CFR 72.236(1).

NAC International Response to Thermal Evaluation RAJ 2-1:

See NAC response to RAI 4-1 .

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Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPlD No. L-2019-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION THERMAL EVALUATION 4-1 Provide adequate technical basis or thermal analysis that justify safe storage of the MSO inside a building.

In its responses to questions 4-1 and 4-2 in the NRC RAI dated February 25, 2021 (ADAMS accession number ML21067A043), NAC stated that the use of the MSO is limited to storage inside a building assuring protection from low speed wind in its proposed technical specifications. However, the applicant did not provide a thermal analysis that demonstrates that the predicted temperatures would be below allowable limits for a configuration inside a building or technical justification that demonstrates an outside configuration would be bounding. Justify why the outside configuration (that has not considered the effect of low speed wind) would be applicable to or bound a configuration inside a building to ensure that an appropriate method is used for future site-specific evaluations or provide an analysis of an array of casks stored inside a building which considers the proposed conditions on the building environment (i.e., building air temperatures, effects of vents near walls, etc.).

Additionally, the available margin for a cask located outside (quiescent conditions) is small.

Therefore, it is necessary for the applicant to evaluate phenomena and boundary conditions

for the inside configuration that are not captured in the cask analyzed located outside. The staff identified the following deficiencies for an MSO analyzed outside that could prevent the application of the thermal analysis results from bounding an inside configuration:

The free stream temperature of 76°F for convective heat transfer (for all external surfaces and inlet vents) and the external radiation temperature of 76°F could be different due to the building structure, unless ambient temperature refers to the temperature inside the building and the user established adequate control such that the ambient temperature is not exceeded during the entire licensed period. These controls can't rely on any active cooling system. Either provide a definition of ambient temperature stating it is both the indoor and outdoor air temperature for casks stored indoors or outside on a pad or provide additional temperature controls for casks stored inside a building.

A realistic or conservative approach to specify the boundary conditions on all external surfaces of the building that could affect the heat transfer. Building structural walls could add additional resistance to heat transfer because the walls would be blocking radiation heat transfer to the environment and radiating heat back to the casks. Also, a bounding or realistic configuration needs to be considered if the external walls of the building would be exposed to the ambient or will share walls with other buildings.

The MSO analyzed outside is based on a two-dimensional (2-D) axisymmetric model that cannot capture the three-dimensional effects of a cask array situated inside a building. It is not clear that evaluating the enclosure walls of a building and any building ventilation that provide passive cooling would be adequately captured using 2-D analysis .

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Enclosure I to ED20210 I 09 MAGNASTOR Docket No.: 72-1031

RAJ Response 4-2 (ADAMS accession number ML21067A043) states:

EPID No. L-2019-LLA-0273 "10 CFR 72.212 (6) requires an evaluation of site parameters to see if they are bounded. In this case the buildings influence on cask performance must be evaluated. Per 10 CFR 72.212 (7) a 72.48(c) based evaluation for any changes must be performed which limits the evaluation to FSAR MOE or equivalent methods." However, because of the deficiencies identified above for an MSO evaluated outside, the staff does not believe the current FSAR method of evaluation (MOE) can be used to perform the thermal evaluation of a cask array situated inside a building. The staff needs the thermal evaluation of a cask array inside a building to determine the adequacy of the thermal design in meeting any applicable material temperature limits.

This information is needed to determine compliance with the regulatory requirements in 10 CFR 72.236(6) and 10 CFR 72.236(f).

NAC International Response to Thermal Evaluation RAI 4-1:

As indicated in this RAI, NAC elected in our responses dated February 25, 2021 to require the MSO to be stored on an ISFSI that was enclosed, albeit ventilated, from the outside environment to preclude the potential effects of low-wind speeds on the MSO overpack.

However due to regulatory challenges with implementing this approach, NAC has elected to address the original RAI on low-wind speed directly and remove the proposed requirement

that the MSO must be used in an ISFSI enclosure .

NAC has now performed a low-wind speed analysis on the MSO overpack. See NAC Calculation 30082-3603, Rev. 00, which is enclosed with this submittal package. The analysis demonstrates that the MSO will perform satisfactorily during low-wind conditions.

The current overpack thermal analysis presented in this amendment remains as is. The proposed Technical Specifications have been revised to remove any requirement that the MSO be used in an ISFSI enclosure .

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Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-20 I 9-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SHIELDING EVALUATION 5-1 Justify the NS-3 shielding material loss {proprietary information removed} due to exposure to radiation and show that the loss of material due to radiation dose is consistent with the dose the NS-3 is expected to receive during storage.

In its supplemental response dated April 20, 2021, to the NRC RAI dated October 8, 2020 (ADAMS Accession No. ML20258Al60), see item 5-1 in the proprietary enclosure on the same issue, the applicant states that NS-3 material loss {proprietary information removed}

due to radiation. However, the staff could not determine how the value was determined.

The staff needs this information to determine if the request meets the regulatory requirements of 10 CFR 72.236(d).

NAC International Response to Thermal Evaluation RAJ 5-1:

See NAC proprietary response to RAI 5-1.

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Enclosure I to ED202 l OI 09 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 Enclosure 1 NACINTERNATIONAL RESPONSE TO THE UNITED STATES NUCLEAR REGULATORY COMMISSION PROPRIETARY REQUEST FOR ADDITIONAL INFORMATION July 2021 FOR REVIEW OF THE CERTIFICATE OF COMPLIANCE NO. 1031, AMENDMENT NO. 10 (EPID No. L-2019-LLA-0273 DOCKET NO. 72-1031)

September 2021

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Enclosure I to ED202 IO I 09 MAGNASTOR Docket No.: 72-1031

TABLE OF CONTENTS EPID No. L-2019-LLA-0273 SHIELDING EVALUATION .................................................................................................. ............................. 3

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NAG PROPRIETARY INFORMATION REMOVED Enclosure 1 to ED202 l O109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273 NAC INTERNATIONAL RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION SHIELDING EVALUATION 5-1

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NAG PROPRIETARY INFORMATION REMOVED Enclosure I to ED202 l OI 09 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273

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NAC PROPRIETARY INFORMATION REMOVED Enclosure 1 to ED20210109 MAGNASTOR Docket No.: 72-1031 EPID No. L-2019-LLA-0273

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Enclosure 2 to ED20210109 Page 1 of 1 Enclosure 2 Proposed Changes for MAGNASTOR Technical Specifications nd 2 Round RAI Responses to Amendment 10 (Docket No 72-1031)

NAC International September 2021

APPENDIX A PROPOSED TECHNICAL SPECIFICATIONS AND DESIGN FEATURES FOR THE MAGNASTOR SYSTEM

AMENDMENT 10

Certificate of Compliance No. 1031 A-1 Amendment No. 1O

Appendix A Table of Contents

1.0 1.1 1.2 1.3 USE AND APPLICATION ........................................................................................... A1-1 Definitions ............................................................................................................... A 1-1 Logical Connectors ................................................................................................. A 1-7 Completion Times ................................................................................................... A 1-9 1.4 Frequency ............................................................................................................. A1-13 2.0 [Reserved] .................................................................................................................. A2-1 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY .......................... A3-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY ......................................... A3-2 3.1 MAGNASTOR SYSTEM Integrity .......................................................................... A3-3 3.1.1 Transportable Storage Canister (TSC) ........................................................... A3-3 3.1.2 CONCRETE CASK ~r MSO Heat Removal System ...................................... A3-9 3.2 MAGNASTOR SYSTEM Criticality Control for PWR Fuel ................................... A3-10 3.2.1 Dissolved Boron Concentration .................................................................... A3-10 3.3 MAGNASTOR SYSTEM Radiation Protection .................................................... A3-12 3.3.1 CONCRETE CASK or MSO Maximum Surface Dose Rate ......................... A3-12 3.3.2 TSC Surface Contamination .......................................................................... A3-16 4.0 DESIGN FEATURES ................................................................................................. A4-1 4.1 Design Features Significant to Safety .................................................................... A4-1 4.1.1 Criticality Control ............................................................................................ A4-1 4.1.2 Fuel Cladding Integrity ................................................................................... A4-1 4.1.3 Transfer Cask Shielding ................................................................................. A4-1 4.1.4 TSC Confinement Integrity ............................................................................. A4-2 4.2 Codes and Standards ............................................................................................ A4-2 4.2.1 Alternatives to Codes, Standards, and Criteria .............................................. A4-2 4.2.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria ...... A4-2 4.3 Site-Specific Parameters and Analyses ................................................................. A4-3 4.3.1 Design Basis Specific Parameters and Analyses ........................................... A4-3 4.4 TSC Handling and Transfer Facility ....................................................................... A4-4 5.0 ADMINISTRATIVE CONTROLS AND PROGRAMS .................................................. A5-1 5.1 Radioactive Effluent Control Program ................................................................... A5-1 5.2 TSC Loading, Unloading, and Preparation Program ............................................. A5-1 5.3 Transport Evaluation Program ............................................................................... A5-2 5.4 ISFSI Operations Program .................................................................................... A5-2 5.5 Radiation Protection Program ................................................................................ A5-3 5.6 Deleted ................................................................................................................... A5-3

5. 7 Training Program .................................................................................................... A5-4 5.8 Pre-operational Testing and Training Exercises ..................................................... A5-4

Certificate of Compliance No. 1031 A-2 Amendment No. 10

List of Figures

Figure A3-1 Figure A3-2 CONCRETE CASK Surface Dose Rate Measurement ................................. A3-14 MSO Surface Dose Rate Measurement.. ...................................................... A3-15 List of Tables Table A3-1 Helium Mass per Unit Volume for MAGNASTOR TSCs ..................................... A3-8 Table A4-1 Load Combinations and Service Condition Definitions for the TSC Handling and Transfer Facility Structure ............................................................................ A4-6

Certificate of Compliance No. 1031 A-3 Amendment No. 10

Definitions 1.1

1.0 1.1 USE AND APPLICATION Definitions NOTE The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

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

ASSEMBLY AVERAGE Value calculated by averaging the 235 U wt % enrichment over FUEL ENRICHMENT the entire fuel region (UO2) of an individual fuel assembly, including axial blankets, if present.

BREACHED SPENT FUEL Spent fuel with cladding defects that permit the release of gas ROD from the interior of the fuel rod. A fuel rod breach may be a minor defect (i.e., hairline crack or pinhole), allowing the rod to be classified as undamaged, or be a gross breach requiring a damaged fuel classification .

BURNUP a) Assembly Average Burnup:

Value calculated by averaging the burn up over the entire fuel region (UO2) of an individual fuel assembly, including axial blankets, if present. Assembly average burnup represents the reactor record, nominal, value. The assembly average burnup is equal to the reactor record, nominal, energy production (MWd) over the life of the fuel assembly divided by the fuel assembly pre-irradiation heavy metal (U) mass in metric tons.

b) Nonfuel Hardware Burnup:

Equivalent accumulated irradiation exposure for activation evaluation.

COMPOSITE CLOSURE A closure lid assembly, consisting of a stainless steel LID TRANSPORTABLE STORAGE CANISTER closure lid and a separate shield plate bolted together, that provides closure of a TRANSPORTABLE STORAGE CANISTER.

CONCRETE CASK The CONCRETE CASK is the vertical storage module that receives, holds and protects the sealed TSC for storage at the ISFSI. The CONCRETE CASK passively provides the radiation shielding, structural protection, and heat dissipation capabilities for the safe storage of spent fuel in a TSC .

(continued)

Certificate of Compliance No. 1031 A1-1 Amendment No. 10

Definitions 1.1

DAMAGED FUEL SPENT NUCLEAR FUEL (SNF) assembly that cannot fulfill its fuel-specific or system-related function. SNF is classified as damaged under the following conditions.

1. There is visible deformation of the rods in the SNF assembly.

Note: This is not referring to the uniform bowing that occurs in the reactor; this refers to bowing that significantly opens up the lattice spacing.

2. Individual fuel rods are missing from the SNF assembly and the missing rods are not replaced by a solid stainless steel or zirconium dummy rod that displaces a volume equal to, or greater than, the original fuel rod.

3. The SNF assembly has missing, displaced or damaged structural components such that:

3.1. Radiological and/or criticality safety is adversely affected (e.g., significantly changed rod pitch); or 3.2. The SNF assembly cannot be handled by normal means (i.e., crane and grapple); or

3.3. The SNF assembly contains fuel rods with damaged or Note:

missing grids, grid straps, and/or grid springs producing an unsupported length greater than 60 inches.

SNF assemblies with the following structural defects meet MAGNASTOR system-related functional requirements and are, therefore, classified as undamaged: Assemblies with missing or damaged grids, grid straps and/or grid springs resulting in an unsupported fuel rod length not to exceed 60 inches.

4. Any SNF assembly that contains fuel rods for which reactor operating records (or other records or tests) cannot support the conclusion that they do not contain gross breaches.

Note: BREACHED SPENT FUEL RODs with minor cladding defects (i.e., pinhole leaks or hairline cracks that will not permit significant release of particulate matter from the spent fuel rod) meet MAGNASTOR system-related functional requirements and are, therefore, classified as undamaged.

5. FUEL DEBRIS such as ruptured fuel rods, severed rods, loose fuel pellets, containers or structures that are supporting loose PWR fuel assembly parts.

Certificate of Compliance No. 1031 A1-2 (continued)

Amendment No.10

Definitions 1.1

DAMAGED FUEL CAN (DFC)

A specially designed stainless steel screened can sized to hold UNDAMAGED PWR FUEL, DAMAGED PWR FUEL, and/or FUEL DEBRIS. The screens preclude the release of gross particulate from the DFC into the canister cavity. DFCs are only authorized for loading in specified locations of a OF Basket Assembly.

FUEL DEBRIS FUEL DEBRIS is ruptured fuel rods, severed rods, loose fuel pellets, containers or structures that are supporting loose PWR fuel assembly parts.

GROSSLY BREACHED A breach in the spent fuel cladding that is larger than a pinhole SPENT FUEL ROD or hairline crack. A gross cladding breach may be established by visual examination with the capability to determine if the fuel pellet can be seen through the cladding, or through a review of reactor operating records indicating the presence of heavy metal isotopes.

INDEPENDENT SPENT The facility within the perimeter fence licensed for storage of FUEL STORAGE spent fuel within MAGNASTOR SYSTEMS (see also 10 CFR INSTALLATION (ISFSI) 72.3).

INITIAL PEAK PLANAR-AVERAGE ENRICHMENT The INITIAL PEAK PLANAR-AVERAGE ENRICHMENT is the maximum planar-average enrichment at any height along the axis of the fuel assembly. The INITIAL PEAK PLANAR-AVERAGE ENRICHMENT may be higher than the bundle (assembly) average enrichment.

LOADING OPERATIONS LOADING OPERATIONS include all licensed activities while a MAGNASTOR SYSTEM is being loaded with fuel assemblies.

LOADING OPERATIONS begin when the first assembly is placed in the TSC and end when the TSC is lowered into a CONCRETE CASK or MSO.

MAGNASTOR SYSTEM The MAGNASTOR (Modular Advanced Generation Nuclear All-(MAGNASTOR) purpose STORage) SYSTEM includes the components certified for the storage of spent fuel assemblies at an ISFSI. The MAGNASTOR SYSTEM consists of a CONCRETE CASK or MSO and a TSC. A MAGNASTOR TRANSFER CASK (MTC) or Passive MAGNASTOR TRANSFER CASK (PMTC) is provided and utilized to load and place a TSC in a CONCRETE CASK or MSO, or to remove a TSC from a CONCRETE CASK or MSO.

Certificate of Compliance No. 1031 A1-3 (continued)

Amendment No. 10

Definitions 1.1

MSO (Metal Storage Overpack)

The MSO is the vertical storage module that receives, holds and protects the sealed TSC for storage at the ISFSI. The MSO passively provides the radiation shielding, structural protection, and heat dissipation capabilities for the safe storage of spent fuel in a TSC.

NONFUEL HARDWARE NONFUEL HARDWARE is defined as reactor control components (RCCs), burnable poison absorber assemblies (BPAAs), guide tube plug devices (GTPDs), neutron sources/

neutron source assemblies (NSAs), hafnium absorber assemblies (HFRAs), instrument tube tie components, guide tube anchors or other similar devices, in-core instrument thimbles, steel rod inserts (used to displace water from lower section of guide tube), and components of these devices such as individual rods.

All nonfuel hardware, with the exception of instrument tube tie components, guide tube anchors or other similar devices, and steel rod inserts, may be activated during in-core operations.

RCCs are commonly referred to as rod cluster control assemblies (RCCAs), control rod assemblies (CRAs), or control element assemblies (CEAs). RCCs are primarily designed to provide reactor shutdown reactivity control, are inserted into the guide tubes of the assembly, and are typically employed for a significant number of operating cycles. Burnup poison absorber assemblies (BPAAs) are commonly referred to as burnup poison rod assemblies (BPRAs), but may have vendor specific nomenclature such as BPRA, Pyrex BPRA or WABA (wet annular burnable absorber). BPAAs are used to control reactivity of fresh fuel or high reactivity fuels and are commonly used for a single cycle, but may be used for multiple cycles.

GTPDs are designed to block guide tube openings when no BPAA is employed and are commonly referred to as thimble plugs (TPs), thimble plug devices (TPDs), flow mixers (FMs),

water displacement guide tube plugs, or vibration suppressor inserts. GTPDs may be employed for multiple cycles. NSAs are primary and secondary neutron sources used during reactor startup and may be used for multiple cycles.

Integral fuel burnable absorbers, either integral to a fuel rod or as a substitution for a fuel rod, and fuel replacement rods (fueled, stainless steel, or zirconium alloy) are considered components of spent nuclear fuel (SNF) assemblies and are not considered to be nonfuel hardware.

(continued)

Certificate of Compliance No. 1031 A1-4 Amendment No. 10

Definitions 1.1

OPERABLE SPENT NUCLEAR FUEL (SNF)

A system, component, or device is OPERABLE when it is capable of performing its specified safety functions.

Irradiated fuel assemblies consisting of end-fittings, grids, fuel rods and integral hardware. Integral hardware for PWR assemblies primarily consists of guide/instrument tubes, but may contain integral fuel burnable absorbers, either integral to a fuel rod or as a fuel rod substitution, and fuel replacement rods (another fuel rod, stainless steel rod, or zirconium alloy rod).

For BWR fuel, integral hardware may consist of water rods in various shapes, inert rods, fuel rod cluster dividers, and/or fuel assembly channels (optional). PWR SNF may contain NONFUEL HARDWARE.

STORAGE CASK A STORAGE CASK is either a CONCRETE CASK or an MSO.

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the ISFSI following placement of a CONCRETE CASK or MSO containing a loaded TSC at its designated storage location on the storage pad.

TRANSFER CASK TRANSFER CASK is a shielded lifting device designed to hold

TRANSFER OPERATIONS the TSC during LOADING OPERATIONS, TRANSFER OPERATIONS, and UNLOADING OPERATIONS. Either a MAGNASTOR TRANSFER CASK (MTC)

MAGNASTOR TRANSFER CASK (PMTC) may be used.

or Passive TRANSFER OPERATIONS include all licensed activities involved in using a MAGNASTOR TRANSFER CASK (MTC) or Passive MAGNASTOR TRANSFER CASK (PMTC) to move a loaded and sealed TSC from a; CONCRETE CASK to another CONCRETE CASK or from an MSO to another MSO.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS include all licensed activities performed on a loaded MAGNASTOR CONCRETE CASK or MSO when it is being moved to and from its designated location on the ISFSI. TRANSPORT OPERATIONS begin when the loaded CONCRETE CASK or MSO is placed on or lifted by a transporter and end when the CONCRETE CASK or MSO is set down in its storage position on the ISFSI pad.

(continued)

Certificate of Compliance No. 1031 A1-5 Amendment No. 10

Definitions 1.1

TRANSPORTABLE STORAGE CANISTER (TSC)

The TRANSPORTABLE STORAGE CANISTER (TSC) is the welded container consisting of a basket in aweldment composed of a cylindrical shell welded to a baseplate. The TSC includes a closure lid, a shield plate (optional), a closure ring, and redundant port covers at the vent and the drain ports. The closure lid is welded to the TSC shell and the closure ring is welded to the closure lid and the TSC shell. The port covers are welded to the closure lid. The TSC provides the confinement boundary for the radioactive material contained in the TSC cavity.

TSC TRANSFER FACILITY The TSC TRANSFER FACILITY includes: 1) a transfer location for the lifting and transfer of a TRANSFER CASK and placement of a TSC into or out of a CONCRETE CASK or MSO; and 2) either a stationary lift device or a mobile lifting device used to lift the TRANSFER CASK and TSC, but not licensed as part of the 10 CFR 50 facility.

UNDAMAGED FUEL SNF that can meet all fuel specific and system-related functions.

UNDAMAGED FUEL is SNF that is not DAMAGED FUEL, as defined herein, and does not contain assembly structural defects that adversely affect radiological and/or criticality safety .

As such, UNDAMAGED FUEL may contain:

a) BREACHED SPENT FUEL RODS (i.e, rods with minor defects up to hairline cracks or pinholes) but cannot contain grossly breached fuel rods; b) Grid, grid strap, and/or grid spring damage provided that the unsupported length of the fuel rod does not exceed 60 inches.

UNLOADING OPERATIONS UNLOADING OPERATIONS include the activities required to remove the fuel assemblies from a sealed TSC. UNLOADING OPERATIONS begin with the movement of the TSC from a CONCRETE CASK or MSO into a TRANSFER CASK in an unloading facility and end when the last fuel assembly has been removed from the TSC .

Certificate of Compliance No. 1031 A1-6 Amendment No. 10

Logical Connectors 1.2

1.0 1.2 PURPOSE USE AND APPLICATION Logical Connectors 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 Technical Specifications 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 indentations of the logical connectors.

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

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO 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)

Certificate of Compliance No. 1031 A1-7 Amendment No. 10

Logical Connectors 1.2

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 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 .

Certificate of Compliance No. 1031 A1-8 Amendment No. 10

Completion Times 1.3

1.0 1.3 PURPOSE USE AND APPLICATION Completion Times 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 Time(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, provided that MAGNASTOR 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 MAGNASTOR 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)

Certificate of Compliance No.1031 A1-9 Amendment No. 10

Completion Times 1.3

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 B.1 Perform Action B.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion Time AND not met B.2 Perform Action B.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own Completion Time. Each Completion Time is referenced to the time that Condition B is entered.

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

(continued)

Certificate of Compliance No. 1031 A1-10 Amendment No. 10

Completion Times 1.3

EXAMPLES (continued)

EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not A.1 Restore system to 7 days within limit. within limit.

8. Required Action 8.1 Complete action 8.1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated Completion Time AND not met. 8.2 Complete action 8.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a system is determined not to meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition 8 is also entered, and the Completion Time clocks for Required Actions 8.1 and 8.2 start. If the system is restored after Condition 8 is entered, Conditions A and 8 are exited, and therefore, the Required Actions of Condition 8 may be terminated.

(continued)

Certificate of Compliance No. 1031 A1-11 Amendment No. 10

Completion Times 1.3

EXAMPLES (continued)

EXAMPLE 1.3-3 ACTIONS NOTE Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met A.1 Restore compliance 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with LCO.

8. Required Action 8.1 Complete action 8.1 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated Completion Time AND not met. 8.2 Complete action 8.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 to be 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 are tracked for each component.

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

Certificate of Compliance No. 1031 A1-12 Amendment No. 10

Frequency 1.4

1.0 1.4 PURPOSE USE AND APPLICATION Frequency 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.

Each "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 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.

The use of "met" or "performed" in these instances conveys specific meanings. Surveillance is "met only after the acceptance criteria are satisfied. Known failure of the requirements of Surveillance, even without Surveillance specifically being "performed", constitutes a Surveillance not "met".

(continued)

Certificate of Compliance No. 1031 A1-13 Amendment No. 10

Frequency 1.4

EXAMPLES The following examples illustrate the various ways that Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment or variables are outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is

exceeded while the facility is in a condition specified in the Applicability of the LCO, the LCO is not met in accordance with SR 3.0.1.

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

(continued)

Certificate of Compliance No. 1031 A1-14 Amendment No. 1O

Frequency 1.4

EXAMPLES (continued) EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limit Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting activity AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter Example 1.4-2 has two Frequencies. The first is a one-time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting the activity.

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

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

Certificate of Compliance No. 1031 A1-15 Amendment No. 10

2.0

2.0 [Reserved]

Certificate of Compliance No. 1031 A2-1 Amendment No. 10

LCO Applicability 3.0

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

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

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

LCO 3.0.3 Not applicable to MAGNASTOR.

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 MAGNASTOR.

Exceptions to this Condition are stated in the individual Specifications.

LCO 3.0.5 These exceptions allow entry into specified conditions in the Applicability where the associated ACTIONS to be entered allow operation in the specified conditions in the Applicability only for a limited period of time.

This exception to LCO 3.0.2 is not applicable for the MAGNASTOR SYSTEM to return to service under administrative control to perform the testing .

Certificate of Compliance No. 1031 A3-1 Amendment No. 10

SR Applicability 3.0

3.0 SR 3.0.1 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be a failure to meet the LCO. Failure to perform Surveillance within the specified Frequency shall be a 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 Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed from the time of discovery up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is less.

This delay period is permitted to allow performance of the Surveillance.

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

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

Certificate of Compliance No. 1031 A3-2 Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1 3.1 MAGNASTOR SYSTEM Integrity 3.1.1 Transportable Storage Canister (TSC)

LCO 3.1.1 The TSC shall be dry and helium filled. The following vacuum drying times, helium backfill and TSC transfer times shall be met as appropriate to the fuel content type and heat load:

1. The time durations covering the beginning of canister draining through completion of vacuum drying and helium backfill, minimum helium backfill times, and TSC transfer times shall meet the following:

A. PWR TSC Transfer Using MTC Reduced Helium Backfill Time Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours) s 20 No limit 0 600

525 50 0 70.5

5 30 19 7 8

:5 35.5 Heat Load 15 Maximum Vacuum Time 7

8. PWR Using MTC with Maximum TSC Transfer Minimum Helium 8

Maximum TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 25 No limit 24 48

5 30 32 24 22

5 35.5 24 24 22 C. BWR Using MTC with 8 Hours TSC Transfer Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

5 25 No limit 0 8

529 34 6 8

5 30 31 6 8

5 33 26 6 8

Certificate of Compliance No. 1031 A3-3 (continued)

Amendment No. 10

- -- - ------ ----- ~ - - - * -

Transportable Storage Canister (TSC) 3.1.1

D. BWR Using MTC with Maximum TSC Transfer Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

25 No limit 24 65

29 No limit 24 32

30 44 24 32

33 33 24 32 E. PWR TSC Transfer Using PMTC1 Maximum Minimum Maximum Heat Load Vacuum Time Helium TSC Transfer (kW) Limit (hours) Backfill Time Time (hours)

(hours)

20 No limit 0 600

25 54 0 600

2.

30 32 0 600 The time duration from the end of TSC annulus cooling, either by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the pool or by the annulus circulating water system, through completion of vacuum drying and helium backfill using a MTC shall not exceed the following

Heat Load Time Limit (hours)

PWR 35.5 11 BWR 33 16 Note: The helium backfill times and TSC transfer times provided in Tables 1.B and 1.D shall be used for operations following the second or subsequent vacuum drying cycles using the MTC.

(continued) 1

CE 16 x 16 fuel only, with a maximum storage cell location heat load of 811 watts.

Certificate of Compliance No. 1031 A3-4 Amendment No. 1O

Transportable Storage Canister (TSC) 3.1.1

3. The time duration from the end of TSC annulus cooling, either by 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in the pool or by the annulus circulating water system, through completion of vacuum drying and helium backfill using a PMTC shall not exceed the following:

Heat Load Time Limit (hours)

PWR S25 34 PWR s 30 17 Note: The helium backfill times and TSC transfer times provided in Table 1.E shall be used for operations following the second or subsequent vacuum drying cycles using the PMTC.

APPLICABILITY: Prior to TRANSPORT OPERATIONS (continued)

Certificate of Compliance No. 1031 A3-5 Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1

ACTIONS NOTE Separate Condition entry is allowed for each TSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. TSC cavity vacuum A.1 Perform an engineering evaluation to 7 days drying pressure limit determine the quantity of moisture not met. remaining in the TSC.

AND A.2 Develop and initiate corrective actions 30 days necessary to return the TSC to an analyzed condition.

B. TSC helium backfill B.1 Perform an engineering evaluation to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months density limit not met. determine the effect of helium density differential.

AND B.2 Develop and initiate corrective actions 14 days necessary to return the TSC to an analyzed condition.

C. Required Actions C.1 Remove all fuel assemblies from the 30 days and associated TSC.

Completion Times not met.

(continued)

Certificate of Compliance No. 1031 A3-6 Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR3.1.1.1 Verify TSC cavity vacuum drying pressure FREQUENCY Once, prior to TRANSPORT is less than or equal to 10 torr for greater OPERATIONS.

than or equal to 10 minutes with the vacuum pump turned off and isolated.

SR 3.1.1.2 Following vacuum drying and evacuation to Once, prior to TRANSPORT

< 3 torr, backfill the cavity with high purity OPERATIONS.

helium until a mass Mhelium corresponding to the free volume of the TSC measured during draining (VTSc), multiplied by the helium density (Lhelium) required for the design basis heat load and specified in Table A3-1, is reached .

Certificate of Compliance No. 1031 A3-7 Amendment No. 10

Transportable Storage Canister (TSC) 3.1.1

Table A3-1 Helium Mass per Unit Volume for MAGNASTOR TSCs Fuel Type Helium Density

/liter PWR 0.694 - 0.802 BWR 0.704- 0.814

Certificate of Compliance No. 1031 A3-8 Amendment No. 1O

CONCRETE CASK or MSO Heat Removal System 3.1.2

3.1 3.1.2 LCO 3.1.2 MAGNASTOR SYSTEM Integrity CONCRETE CASK or MSO Heat Removal System The CONCRETE CASK or MSO Heat Removal System shall be OPERABLE.

APPLICABILITY: During STORAGE OPERATIONS ACTIONS NOTE Separate Condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CONCRETE CASK or A.1 Ensure adequate heat Immediately MSO Heat Removal removal to prevent System inoperable. exceeding short-term temperature limits.

A.2 Restore CONCRETE 30 days CASK or MSO Heat Removal System to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR3.1.2.1 Verify that the difference between the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average CONCRETE CASK or MSO air outlet temperature and ISFSI ambient temperature indicates that the CONCRETE CASK or MSO Heat Removal System is operable in accordance with the FSAR thermal evaluation.

OR Visually verify all CONCRETE CASK or 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months MSO air inlet and outlet screens are free of blockage .

Certificate of Compliance No. 1031 A3-9 Amendment No. 10

Dissolved Boron Concentration 3.2.1

3.2 3.2.1 LCO 3.2.1 MAGNASTOR SYSTEM Criticality Control for PWR Fuel Dissolved Boron Concentration The dissolved boron concentration in the water in the TSC cavity shall be greater than, or equal to, the concentration specified in Appendix B, Table B2-4. A minimum concentration of 1,500 ppm is required for all PWR fuel types. Higher concentrations are required, depending on the fuel type and enrichment.

APPLICABILITY: During LOADING OPERATIONS and UNLOADING OPERATIONS with water and at least one fuel assembly in the TSC.

ACTIONS NOTE Separate Condition entry is allowed for each TSC.

CONDITION REQUIRED ACTION COMPLETION TIME A. Dissolved boron A.1 Suspend LOADING Immediately concentration not OPERATIONS or

met.

A.2 UNLOADING OPERATIONS Suspend positive reactivity Immediately additions.

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

(continued)

Certificate of Compliance No. 1031 A3-10 Amendment No. 10

Dissolved Boron Concentration 3.2.1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR3.2.1.1 Verify the dissolved boron concentration is Once within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months prior to met using two independent measure- commencing LOADING ments. OPERATIONS or UNLOADING OPERATIONS.

AND Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter while the TSC is in the spent fuel pool or while water is in the TSC .

Certificate of Compliance No. 1031 A3-11 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

3.3 3.3.1 MAGNASTOR SYSTEM Radiation Protection CONCRETE CASK or MSO Maximum Surface Dose Rate LCO 3.3.1 The maximum surface dose rates for the CONCRETE CASK (Reference Figure A3-1) or MSO (Reference Figure A3-2), shall not exceed the following limits:

a. PWR and BWR - 120 mrem/hour gamma and 5 mrem/hour neutron on the vertical surfaces (at locations specified on Figures A3-1 and A3-2); and

b. PWR and BWR - 450 mrem/hour (neutron + gamma) on the top.

APPLICABILITY: Prior to start of STORAGE OPERATIONS ACTIONS

N OTE--------------------------*-----

Separate Condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CONCRETE CASK A.1 Administratively verify correct 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or MSO maximum fuel loading surface dose rate limits not met AND A.2 Perform analysis to verify 7 days compliance with the ISFSI radiation protection requirements of 10 CFR 20 and 10 CFR 72 B. Required Action B.1 Perform (and document) an 60 days and associated engineering assessment and Completion Time take appropriate corrective not met action to ensure the dose limits of 10 CFR 20 and 10 CFR 72 are not exceeded (continued)

Certificate of Compliance No. 1031 A3-12 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Verify maximum surface dose rates of Prior to start of STORAGE CONCRETE CASK or MSO loaded with a OPERATIONS of each loaded TSC containing fuel assemblies are within CONCRETE CASK or MSO limits. Dose rates shall be measured at the before or after placement on locations shown in Figure A3-1 or A3-2. the ISFSI pad .

Certificate of Compliance No. 1031 A3-13 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1

- Figure A3-1 CONCRETE CASK Surface Dose Rate Measurement so*

Measure dose rates at approximate 70-inch diameter at four points approximately on 90-degree axes.

270"

TSC mid-plane - approximately 92 inches from bottom. Measure dose rates at four target points (approximately 0, 90, 180 & 270 degrees) on the mid-plane .

Certificate of Compliance No. 1031 A3-14 Amendment No. 10

Concrete Cask or MSO Maximum Surface Dose Rate 3.3.1 Figure A3-2 MSO Surface Dose Rate Measurement Measure dose rates at approximately 70 inch goo diameter at four points approximately on 90 degree axes.

180° 270°

I I

I I

TSC mid-plane approximately\_ I 92 inches from bottom. Measure dose rates at four target points I (approximately 0, 90, 180 & 270 degrees) on the mid-plane. ----- i -----

1 I

I I

Certificate of Compliance No. 1031 A3-15 Amendment No. 10

TSC Surface Contamination 3.3.2 3.3 MAGNASTOR SYSTEM Radiation Protection 3.3.2 TSC Surface Contamination LCO 3.3.2 Removable contamination on the exterior surfaces of the TSC shall not exceed:

a. 10,000 dpm/100 cm 2 from beta and gamma sources; and

b. 100 dpm/100 cm 2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS ACTIONS

--------------NO TE------------------------- ----------------

Sepa rate Condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. TSC removable surface A.1 Restore TSC removable Prior to TRANSPORT contamination limits not surface contamination OPERATIONS met to within limits (continued)

Certificate of Compliance No. 1031 A3-16 Amendment No. 10

TSC Surface Contamination 3.3.2

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2 Verify by either direct or indirect methods Once, prior to TRANSPORT that the removable contamination on the OPERATIONS exterior surfaces of the TSC is within limits Certificate of Compliance No. 1031 A3-17 Amendment No. 10

DESIGN FEATURES 4.0

4.0 4.1 4.1.1 DESIGN FEATURES Design Features Significant to Safety Criticality Control a) Minimum 10 B loading in the neutron absorber material:

Required Minimum Effective Required Minimum Actual Neutron Areal Density % Credit Used in Areal Density Absorber (108 ! /cm2) Criticality (108 ! /cm2)

Type PWR Fuel BWR Fuel Analyses PWR Fuel BWR Fuel Borated 0.036 0.027 0.04 0.03 Aluminum Alloy 0.030 0.0225 90 0.0334 0.025 0.027 0.020 0.03 0.0223 Borated MMC 0.036 0.027 0.04 0.03 0.030 0.0225 90 0.0334 0.025 0.027 0.020 0.03 0.0223 Bora! 0.036 0.027 0.048 0.036 0.030 0.0225 75 0.04 0.030 0.027 0.020 0.036 0.0267 Enrichment/soluble boron limits for PWR systems and enrichment limits for

BWR systems are incorporated in Appendix B Section 2.0 .

b) Acceptance and qualification testing of borated aluminum alloy and borated MMC neutron absorber material shall be in accordance with Sections 10.1.6.4.5, 10.1.6.4.6 and 10.1.6.4. 7. Acceptance testing of Bora I shall be in accordance with Section 10.1.6.4.8. These sections of the FSAR are hereby incorporated into the MAGNASTOR Coe.

c) Soluble boron concentration in the PWR fuel pool and water in the TSC shall be in accordance with LCO 3.2.1, with a minimum water temperature 5-10°F higher than the minimum needed to ensure solubility.

d) Minimum fuel tube outer diagonal dimension PWR basket - 13.08 inches BWR basket - 8. 72 inches Note: Not applicable to DFC locations of the DF Basket Assembly.

4.1.2 Fuel Cladding Integrity The licensee shall ensure that fuel oxidation and the resultant consequences are precluded during canister loading and unloading operations.

4.1.3 Transfer Cask Shielding The nominal configuration transfer cask radial bulk shielding (i.e., shielding integral to the transfer cask; excludes supplemental shielding) must provide a (continued)

Certificate of Compliance No. 1031 A4-1 Amendment No. 10

DESIGN FEATURES 4.0

minimum radiation shield equivalent to 2 inches of carbon steel or stainless steel and 3.2 inches of lead gamma shielding and 2.25 inches of NS-4-FR (with 0.6 wt

% B4C and 6.0 wt % H) neutron shielding. Material and dimensions of the individual shield layers may vary provided maximum calculated radial dose rates of 1100 mrem/hr (PWR system) and 1600 mrem/hr (BWR system) are maintained on the vertical surface (not including doors or vent shielding).

4.1.4 TSC Confinement Integrity The TSC shell, bottom plate, all confinement welds, and the COMPOSITE CLOSURE LID shall be fabrication helium leak-tested in accordance with ANSI N14.5 to leaktight criterion.

The closure lid shall be helium leak-tested during fabrication (in accordance with ANSI N14.5 to leaktight criterion) if it is constructed with a lid thickness less than 9 inches (nominal).

4.2 Codes and Standards The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition with Addenda through 2003, Section 111, Subsection NB, is the governing Code for the design, material procurement, fabrication, and testing of the TSC .

The ASME Code, 2001 Edition with Addenda through 2003, Section 111, Subsection NG, is the governing Code for the design, material procurement, fabrication and testing of the spent fuel baskets.

The American Concrete Institute Specifications ACl-349 and ACl-318 govern the design and construction of the vertically reinforced concrete structure of the CONCRETE CASK, respectively and not the CONCRETE CASK lid or upper segment, if equipped.

The American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), 2001 Edition with Addenda through 2003, Section 111, Subsection NF, is the governing Code for the design of the MSO. The applicable standards of the American Society for Testing and Materials (ASTM) govern material procurement and the American Welding Society (AWS) D1 .1 or ASME Code Section VIII govern fabrication of the MSO.

The American National Standards Institute ANSI N14.6 (1993) and NUREG-0612 govern the TRANSFER CASK design, operation, fabrication, testing, inspection, and maintenance.

4.2.1 Alternatives to Codes, Standards, and Criteria Table 2.1-2 of the FSAR lists approved alternatives to the ASME Code for the design, procurement, fabrication, inspection and testing of MAGNASTOR SYSTEM TSCs and spent fuel baskets.

(continued)

Certificate of Compliance No. 1031 A4-2 Amendment No. 10

DESIGN FEATURES 4.0

4.2.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to ASME Code, Section Ill, 2001 Edition with Addenda through 2003, other than the alternatives listed in Table 2.1-2 of the FSAR, may be used when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternatives should demonstrate that:

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

2. Compliance with the specified requirements of ASME Code, Section Ill, Subsections NB and NG, 2001 Edition with Addenda through 2003, would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

4.3 Site-Specific Parameters and Analyses This section presents site-specific parameters and analytical bases that must be verified by the MAGNASTOR SYSTEM user. The parameters and bases presented in Section 4.3.1 are those applied in the design bases analysis.

4.3.1 Design Basis Specific Parameters and Analyses The design basis site-specific parameters and analyses that require verification by the MAGNASTOR SYSTEM user are:

a. A temperature of 76°F is the maximum average yearly temperature. The three-day average ambient temperature shall be :5106°F.

b. The allowed temperature extremes, averaged over a three-day period, shall be ;:;:-40°F and :5133°F.

c. The analyzed flood condition of 15 fps water velocity and a depth of 50 ft of water (full submergence of the loaded cask) are not exceeded.

d. The potential for fire and explosion shall be addressed, based on site-specific considerations. This includes the condition that the fuel tank(s) of the cask handling equipment used to move the loaded CONCRETE CASK or MSO onto or from the ISFSI site contains a total of no more than 50 gallons of fuel.

(continued)

Certificate of Compliance No. 1031 A4-3 Amendment No. 10

DESIGN FEATURES 4.0

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

f. The TRANSFER CASK shall not be operated and used when surrounding air temperature is < 0°F. This limit is NOT applicable to the stainless steel MTC or PMTC.

g. The CONCRETE CASK or MSO shall not be lifted by the lifting lugs with surrounding air temperatures < 0°F.

h. Loaded CONCRETE CASK or MSO lifting height limit ~24 inches.

i. The maximum design basis earthquake acceleration of 0.37g in the horizontal direction (without cask sliding) and 0.25g in the vertical direction at the ISFSI pad top surface do not result in cask tip-over.

For design basis earthquake accelerations up to and greater than 0.37g in the horizontal direction and 0.25g in the vertical direction at the ISFSI pad top surface, site-specific cask sliding is permitted with validation by the cask user that the cask does not slide off the pad and that the g-load resulting from the collision of two sliding casks remains bounded by the cask tip-over accident condition analysis presented in Chapter 3 of the FSAR.

An alternative to crediting site-specific cask sliding for design basis earthquake accelerations up to and greater than 0.37g in the horizontal direction and 0.25g in the vertical direction at the ISFSI pad top surface, the use of the MAGNASTOR system is permitted provided the ISFSI pad has bollards and the cask user validates that the cask does not overturn, g-loads resulting from the cask contacting the bollard is bounded by the cask tip-over accident condition presented in Chapter 3 of the FSAR, and the ISFSI pad and bollards are designed, fabricated and installed such that they are capable of handling the combined loading of the design basis earthquake and any contact between the bollard and cask during the design basis earthquake.

4.4 TSC Handling and Transfer Facility The TSC provides a leaktight confinement boundary and is evaluated for normal and off-normal handling loads. A handling and transfer facility is not required for TSC and TRANSFER CASK handling and transfer operations within a 10 CFR 50 licensed facility or for utilizing an external crane structure integral to a 10 CFR 50 licensed facility.

(continued)

Certificate of Compliance No. 1031 A4-4 Amendment No. 1O

DESIGN FEATURES 4.0

Movements of the TRANSFER CASK and TSC outside of a 10 CFR 50 licensed facility are not permitted unless a TSC TRANSFER FACILITY is designed, operated, fabricated, tested, inspected, and maintained in accordance with the following requirements. These requirements do not apply to handling heavy loads under a 10 CFR 50 license.

The permanent or stationary weldment structure of the TSC TRANSFER FACILITY shall be designed to comply with the stress limits of ASME Code, Section Ill, Subsection NF, Class 3 for linear structures. All compression loaded members shall satisfy the buckling criteria of ASME Code, Section Ill, Subsection NF.

The reinforced concrete structure of the facility shall be designed in accordance with ACl-349 and the factored load combinations set forth in ACl-318 for the loads defined in Table A4-1 shall apply. TRANSFER CASK and TSC lifting devices installed in the handling facility shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with NUREG-0612, Section 5.1.

If mobile load lifting and handling equipment is used at the facility, that equipment shall meet the guidelines of NUREG-0612, Section 5.1, with the following conditions:

a. The mobile lifting device shall have a minimum safety factor of two over the allowable load table for the lifting device in accordance with the guidance of NUREG-0612, Section 5.1.6 (1 )(a), and shall be capable of stopping and holding the load during a design earthquake event;

b. The mobile lifting device shall contain :550 gallons of fuel during operation inside the ISFSI; C. Mobile cranes are not required to meet the guidance of NUREG-0612, Section 5.1.6(2) for new cranes;

d. The mobile lifting device shall conform to the requirements of ASME B30.5, "Mobile and Locomotive Cranes";

e. Movement of the TSC, CONCRETE CASK, or MSO in a horizontal orientation is not permitted .

Certificate of Compliance No. 1031 A4-5 Amendment No. 1O

DESIGN FEATURES 4.0

Table A4-1 Load Combinations and Service Condition Definitions for the TSC Handling and Transfer Facility Structure ASME Section Ill Service Load Combination Condition for Definition of Note Allowable Stress All primary load bearing D*

Level A members must satisfy Level A D+S stress limits D+M+ W' 1 Factor of safety against D+F Level D overturning shall be ~ 1.1, if D+E applicable.

D+Y D = Crane hook dead load D* = Apparent crane hook dead load s = Snow and ice load for the facility site M = Tornado missile load of the facility site 1

W' F

E y

=

Tornado wind load for the facility site 1 Flood load for the facility site Seismic load for the facility site Tsunami load for the facility site

1. Tornado missile load may be reduced or eliminated based on a Probabilistic Risk Assessment for the facility site .

Certificate of Compliance No. 1031 A4-6 Amendment No. 1O

DESIGN FEATURES 4.0

5.0 5.1 ADMINISTRATIVE CONTROLS AND PROGRAMS Radioactive Effluent Control Program 5.1.1 A program shall be established and maintained to implement the requirements of 10 CFR 72.44 (d) or 10 CFR 72.126, as appropriate.

5.1.2 The MAGNASTOR SYSTEM does not create any radioactive materials or have any radioactive waste treatment systems. Therefore, specific operating procedures for the control of radioactive effluents ar~ not required. LCO 3.3.2, TSC Surface Contamination, provides assurance that excessive surface contamination is not available for release as a radioactive effluent.