Gas s-and and -4 · A member of the STARS (Strategic Teaming and Resource Sharing) Alliance...

Pac~df s-and -4...Electric Company' James R. Becker Diablo Canyon Power Plant

Site Vice President Mail Code 104/5/601P. Box 56

September 1, 2009 Avila Beach, CA 93424

805.545.3462Internal: 691.3462PG&E Letter DIL-09-006 Fax: 805.545.6445

U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, DC 20555-0001

Materials License No. SNM-251 1, Docket No. 72-26Diablo Canyon Independent Spent Fuel Storage InstallationProprietary and Nonproprietary Response to NRC Request for InformationPertaininq to Diablo Canyon Independent Spent Fuel Storaqe Installation (ISFSI)License Amendment Request 08-001

References: 1. PG&E Letter DIL-08-002, "License Amendment Request 08-001,Revision to Technical Specification 3.1.1, 3.1.4, 3.2.1, 4.1, 4.3,and 5.1.3," dated April 7, 2008

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted LicenseAmendment Request (LAR) 08-001 to the Nuclear Regulatory Commission (NRC),which proposed to revise Technical. Specification (TS) 3.1.1, "Multi-purpose Canister(MPC)," TS 3.1.4, "Spent Fuel Storage Cask (SFSV) Time Limitation in CaskTransfer Facility (CTF)," TS 3.2.1, "Dissolved Boron Concentration," TS 4.1, "DesignFeatures Significant to Safety," TS 4.3, "Cask Handling/Cask Transfer Facility," andTS 5.1.3, "MPC and SFSC Loading, Unloading, and Preparation Program."

On February 13, 2009, the NRC staff requested additional information required tocomplete its review of LAR 08-001.

PG&E's proprietary and nonproprietary responses to the request for additionalinformation (RAI) is provided in Enclosures 1 and 2, respectively. Enclosures 3 and4 are nonproprietary and contain a marked-up and a clean version of revisedportions of the Diablo Canyon ISFSI TS pages, respectively. The TS includechanges proposed in LAR 08-01, as revised by changes proposed in the RAIresponses. Enclosure 5 contains a proprietary CD-ROM, which contains theinformation requested in Thermal Question 1. Enclosure 6 contains a proprietaryversion of Holtec Report HI-2053376, Revision 6.

Enclosures 1, 5, and 6 were prepared for use by the NRC staff in their review of thethe RAI responses. Enclosure 7 contains an affidavit signed by Holtec, the owner ofthe proprietary information. The affidavit sets forth the basis on which the Holtec

A member of the STARS (Strategic Teaming and Resource Sharing) Alliance

Callaway ° Comanche Peak * DiabLo Canyon * Palo Verde * San Onofre * South Texas Project '. Wolf Creek

Enclosures 1, 5, and 6 to this letter contain proprietary information.Withhold from public disclosure under 10 CFR 2.390. k 5 . .

Upon removal of Enclosures 1, 5, and 6, this letter is uncontrolled.

Pacific Gas and Electric Company®

- ~~_.I ____ .,

September 1, 2009

PG&E Letter DIL-09-006

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001

Materials License No. SNM-2511, Docket No. 72-26

James R. Becker Site Vice President

Diablo Canyon Independent Spent Fuel Storage Installation

Diablo Canyon Power Plant Mail Code 104/5/601 p. 0. Box 56 Avila Beach, CA 93424

805.545.3462 Internal: 691.3462 Fax: 805.545.6445

Proprietary and Nonproprietary Response to NRC Request for Information Pertaining to Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI) License Amendment Request 08-001

References: 1. PG&E Letter DIL-08-002, "~icense Amendment Request 08-001, Revision to Technical Specification 3.1.1, 3.1.4, 3.2.1,4.1,4.3, and 5.1.3," dated April 7, 2008

Dear Commissioners and Staff:

In Reference 1, Pacific Gas and Electric Company (PG&E) submitted License Amendment Request (LAR) 08-001 to the Nuclear Regulatory Commission (NRC), which proposed to revise Technical, Specification (TS) 3.1.1, "Multi-purpose Canister (MPC)," TS 3.1.4, "Spent Fuel Storage Cask (SFSV) Time Limitation in Cask Transfer Facility (CTF)," TS 3.2.1, "Dissolved Boron Concentration," TS 4.1, "Design Features Significant to Safety," TS 4.3, "Cask Handling/Cask Transfer Facility," and TS 5.1.3, "MPC and SFSC Loading, Unloading, and Preparation Program."

On February 13, 2009, the NRC staff requested additional information required to complete its review of LAR 08-001.

PG&E's proprietary and nonproprietary responses to the request for additional information (RAI) is provided in Enclosures 1 and 2, respectively. Enclosures 3 and 4 are nonproprietary and contain a marked-up and a clean version of revised portions of the Diablo Canyon ISFSI TS pages, respectively. The TS include changes proposed in LAR 08-01, as revised by changes proposed in the RAI responses. Enclosure 5 contains a proprietary CD-ROM, which contains the information requested in Thermal Question 1. Enclosure 6 contains a proprietary version of Holtec Report HI-2053376, Revision 6.

Enclosures 1, 5, and 6 were prepared for use by the NRC staff in their review of the the RAI responses. Enclosure 7 contains an affidavit signed by Holtec, the owner of the proprietary information. The affidavit sets forth the basis on which the Holtec


Callaway. Comanche Peak. Diablo Canyon • Palo Verde. San Onofre. South Texas Proj~ct '. Wolf Creek

Enclosures 1, 5, and 6 to this letter contain proprietary information. Withhold from public disclosure under 10 CFR 2.390.


Document Control Desk PG&E Letter DIL-09-006September 1, 2009

information contained in Holtec Report HI-2053376, Revision 6 and theaccompanying CD-ROM with computer data files may be withheld from publicdisclosure by the Commission, and it addresses with specificity the considerationslisted in the Freedom of Information Action ("FOIA"), 5 USC Sec. 552(b)(4) and theTrade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4),2.390(a)(4), and 2.390(b)(1). PG&E requests that the Holtec proprietary informationbe withheld from public disclosure in accordance with the cited regulations.

Correspondence with respect to the proprietary aspects of the application forwithholding related to the Holtec proprietary information or the Holtec affidavitprovided in Enclosure 6 should be addressed to Mr. Evan Rosenbaum, HoltecInternational, Holtec Center, 555 Lincoln Drive West, Marlton, New Jersey 08053.

A nonproprietary version of Enclosure 6 will be provided in a separate transmittal.

This information does not affect the results of the technical evaluation or the nosignificant hazards consideration determination previously transmitted inReference 1.

If you have any questions regarding this response, please contactMr. L. Jearl Strickland at (805) 545-6080.

I state under penalty of perjury that the foregoing is true and correct.

Executed on September 1, 2009.

Sinc rely,

Jame teckerSite Vice President

gwhEnclosurescc: Diablo Distribution

Evan Rosenbaum, Holtec Internationalcc/enc: Shana R. Helton, NRC Project Manager, Division of Spent Fuel

Storage and TransportationKelly Kozink, Holtec International Project ManagerMichael S. Peck, NRC Senior Resident Inspector


Callaway - Comanche Peak * Diablo Canyon * Palo Verde * San Onofre * South Texas Project * Wolf Creek

Enclosures 1, 5, and 6 to this letter contain proprietary information.Withhold from public disclosure under 10 CFR 2.390.


m Document Control Desk September 1, 2009

, ~ Page 2

PG&E Letter DIL-09-006

information contained in Holtec Report HI-2053376, Revision 6 and the accompanying CD-ROM with computer data files may be withheld from public disclosure by the Commission, and it addresses with specificity the considerations listed in the Freedom of Information Action ("FOIA"), 5 USC Sec. 552(b)(4) and the Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), 2.390(a)(4), and 2.390(b )(1). PG&E requests that the Holtec proprietary information be withheld from public disclosure in accordance with the cited regulations.

Correspondence with respect to the proprietary aspects of the application for withholding related to the Holtec proprietary information or the Holtec affidavit provided in Enclosure 6 should be addressed to Mr. Evan Rosenbaum, Holtec International, Holtec Center, 555 Lincoln Drive West, Marlton, New Jersey 08053.

A nonproprietary version of Enclosure 6 will be provided in a separate transmittal.

This information does not affect the results of the technical evaluation or the no significant hazards consideration determination previously transmitted in Reference 1.

If you have any questions regarding this response, please contact Mr. L. Jearl Strickland at (805) 545-6080.

I state under penalty of perjury that the foregoing is true and correct.

Executed on September 1,2009.

Site Vice President

gwh Enclosures cc: Diablo Distribution

Evan Rosenbaum, Holtec International cc/enc: Shana R. Helton, NRC Project Manager, Division of Spent Fuel

Storage and Transportation Kelly Kozink, Holtec International Project Manager Michael S. Peck, NRC Senior Resident Inspector


Callaway • Comanche Peak • Diablo Canyon • Palo Verde • San Onofre • South Texas Project • Wolf Creek

Enclosures 1, 5, and 6 to this letter contain proprietary information. Withhold from public disclosure under 10 CFR 2.390.


Enclosure 2PG&E Letter DIL-09-006

Page 1 of 14

NonProprietary PG&E Response to Request for Additional Information ForDiablo Canyon Independent Spent Fuel Storage Installation (ISFSI)

License Amendment Request 08-001

Thermal Question I

Provide the thermal models of the proposed HI-STORM system and the computer filesrelated to the design change, including the analysis for the HI-STORM in the CTF.

Holtec International Report HI-2053376, "Thermal-Hydraulic Analyses for DiabloCanyon Site-Specific HI-STORM System Design," lists thermal model related computerfiles generated during the evaluation of design change. The staff needs these files toreview the accuracy of these calculations and perform confirmatory calculation ifnecessary.

This information is necessary for determining compliance with 10 CFR 72.24(d) and

72.122(h)(1).

PG&E Response to Thermal Question 1

All of the computer data files listed in Holtec Report HI-2053376, Revision 6, includingall FLUENT, Excel and Mathcad files, are provided on the enclosed proprietaryCD-ROM.

Thermal Question 2

Clarify the purpose of the hypothetical reflecting cylinder and evaluate the impact ofdiameter reduction on the thermal performance.

In Section 5.1 of Holtec International Report HI-2053376, for the evaluation of theloaded HI-STORM in CTF, the applicant reduced the diameter of the hypotheticalreflecting cylinder that surrounds the cask to match the CTF cylinder inner diameter.The purpose of this hypothetical reflecting cylinder was not clearly stated in theapplication. The applicant needs to clarify the purpose of diameter reduction and theimpact to thermal performance.

This information is necessary for determining compliance with 10 CFR 72.24(d) and72. 122(h)(1).


This RAI is being separated into two questions as follows:

(1) What is the purpose and function of the hypothetical reflecting cylinder in atypical cask (i.e., not for a cask in an underground cask transfer facility(CTF)) thermal model?

Enclosure 2 . PG&E Letter DIL-09-006

Page 1 of 14

NonProprietary PG&E Response to Request for Additional Information For Diablo Canyon Independent Spent Fuel Storage Installation (ISFSI)

License Amendment Request 08-001

Thermal Question 1

Provide the thermal models of the proposed HI-STORM system and the computer files related to the design change, including the analysis for the HI-STORM in the CTF.

Holtec International Report HI-2053376, "Thermal-Hydraulic Analyses for Diablo Canyon Site-Specific HI-STORM System Design, " lists thermal model related computer files generated during the evaluation of design change. The staff needs these files to review the accuracy of these calculations and perform confirmatory calculation if necessary.

This information is necessary for determining compliance with 10 CFR 72.24(d) and 72. 122(h)(1).


All of the computer data files listed in Holtec Report HI-2053376, Revision 6, including all FLUENT, Excel and Mathcad files, are provided on the enclosed proprietary CD-ROM.

Thermal Question 2

Clarify the purpose of the hypothetical reflecting cylinder and evaluate the impact of diameter reduction on the thermal performance.

In Section 5.1 of Holtec International Report HI-2053376, for the evaluation of the loaded HI-STORM in CTF, the applicant reduced the diameter of the hypothetical reflecting cylinder that surrounds the cask to match the CTF cylinder inner diameter. The purpose of this hypothetical reflecting cylinder was not clearly stated in the application. The applicant needs to clarify the purpose of diameter reduction and the impact to thermal performance.



This RAI is being separated into two questions as follows:

(1) . What is the purpose and function of the hypothetical reflecting cylinder in a typical cask (Le., not for a cask in an underground cask transfer facility (CTF)) thermal model?


Page 2 of 14

(2) How does the reduction in the hypothetical reflecting cylinder representthe effects of the cask being located in an underground CTF?

With respect to its use in a typical cask thermal model, the purpose of the hypotheticalreflecting cylinder is to bound the effects of neighboring casks in an ISFSI array. Inorder for ground-level ambient air to reach the inlet ducts of an interior cask in an arrayof casks, the air would need to flow around the neighboring casks. The neighboringcasks would also block a portion of the thermal radiation emitted from the sides of theinterior cask from reaching the ambient. The hypothetical reflecting cylinder construct inthe overpack thermal model conservatively bounds these effects by surrounding theoverpack in a hypothetical "tank" that only allows ambient air from above the cask toflow toward the inlet ducts (i.e., allows no flow past surrounding casks) and blocks mostof the thermal radiation from the sides of the overpack from reaching the ambient.

Holtec's NRC-approved HI-STORM 100 Final Safety Analysis Report (FSAR) contains adescription of the hypothetical reflecting cylinder in Subsection 4.4.1.1.9 and presents aschematic depiction in Figure 4.4.13. The description and figure have been essentiallythe same from Revision 1 (issued September 2002) through Revision 6 (issuedFebruary 2008) of the HI-STORM 100 FSAR. ADAMS accession numbers for a numberof these HI-STORM 100 FSAR revisions are:

* Revision 1 is ML022730080* Revision 3 is ML052700251* Revision 3A is ML052160271• Revision 4 is.ML063240599• Revision 5 is ML072550534

With respect to its use in a thermal model for a cask in an underground CTF, it wasrecognized that the CTF acts much like the hypothetical reflecting cylinder in that it onlyallows ambient air from above the cask to flow toward the inlet ducts and blocks most ofthe thermal radiation from the sides of the overpack from reaching the ambient. Assuch, the diameter of the hypothetical reflecting cylinder in the thermal model of theDiablo Canyon HI-STORM was reduced to match the inner diameter of the CTF tocreate the thermal model of the cask in the CTF. The impact of diameter reduction onthe thermal performance is presented in Holtec Report HI-2053376, Revision 6.

Thermal Question 3

Explain and/or revise, as necessary, the pressure evaluation in Section 5.1.7 of HoltecInternational Report HI-2053376 for the 100% Blockage of Air Inlets Accident for thefollowing phenomena and/or physical characteristics.

a. Clarify the inconsistency of P1 and Ti and re-evaluate the temperature ifnecessary.

Enclosure 2 PG&E Lette'r DIL-09-006

Page 2 of 14

(2) How does the reduction in the hypothetical reflecting cylinder represent the effects of the cask being located in an underground CTF?

With respect to its use in a typical cask thermal model, the purpose of the hypothetical reflecting cylinder is to bound the effects of neighboring casks in an ISFSI array. In order for ground-level ambient air to reach the inlet ducts of an interior cask in an array of casks, the air would need to flow around the neighboring casks. The neighboring casks would also block a portion of the thermal radiation emitted from the sides of the interior cask from reaching the ambient. The hypothetical reflecting cylinder construct in the overpack thermal model conservatively bounds these effects by surrounding the overpack in a hypothetical "tank" that only allows ambient air from above the cask to flow toward the inlet ducts (i.e., allows no flow past surrounding casks) and blocks most of the thermal radiation from the sides of the overpack from reaching the ambient.

Holtec's NRC-approved HI-STORM 100 Final Safety Analysis Report (FSAR) contains a description of the hypothetical reflecting cylinder in Subsection 4.4.1.1.9 and presents a schematic depiction in Figure 4.4.13.' The description and figure have been essentially the same from Revision 1 (issued September 2002) through Revision 6 (issued February 2008) of the HI-STORM 100 FSAR. ADAMS accession numbers for a number of these HI-STORM 100 FSAR revisions are:

• Revision 1 is ML022730080 • Revision 3 is ML052700251 • Revision 3A is ML052160271 • Revision 4 is.ML063240599 • Revision 5 is ML072550534

With respect to its use in a thermal model for a cask in an underground CTF, it was recognized that the CTF acts much like the hypothetical reflecting cylinder in that it only allows ambient air from above the cask to flow toward the inlet ducts and blocks most of the thermal radiation from the sides of the overpack from reaching the ambient. As such, the diameter of the hypothetical reflecting cylinder in the thermal model of the Diablo Canyon HI-STORM was reduced to match the inner diameter of the OTF to create the thermal model of the cask in the CTF. The impact of diameter reduction on the thermal performance is presented in Holtec Report HI-2053376, Revision 6.

Thermal Question 3

Explain and/or revise, as necessary, the pressure evaluation in Section 5. 1. 7 of Holtec International Report HI-2053376 for the 100% Blockage of Air Inlets Accident for the following phenomena and/or physical characteristics.

a. Clarify the inconsistency of P1 and T1 and re-evaluate the temperature if necessary.


Page 3 of 14

In Section 5.1.7, the applicant evaluates the final pressure based on thetemperature change in the event. The initial pressure (P1) andtemperature (TI) used in this analysis are from Table 9 and Table 10. Theinitial pressure (P1) of 189.9 psia is based on a storage scenario with100% rods ruptured. The initial cavity temperature (TI) of 509 1K, whichshould correlate to P1= 189.9 psia, instead correlates to an internalpressure of 73.48 psia.

Re-evaluate the temperature in section 5.1.7, using a TI that correspondsto P1=189.9 psia. Alternatively, justify why using an initial cavitytemperature of 509 "K is appropriate for an initial pressure of 189.9 psia.

b. Refer to Proprietary Enclosure 1.

c. Refer to Proprietary Enclosure 1.

d. Clarify the cavity average temperature calculation to address how thecalculation accounts for the void space within the cell.

Table 10 of Holtec Report HI-2053376 lists the MPC cavity averagetemperature from the Fluent model. Since the fuel basket cell is modeledwith the porous media Keff approach, the cavity volume within the cell isaveraged out in the porous media. It is not clear how the cavity averagetemperature calculation accounts for the void space within the cell.

e. Refer to Proprietary Enclosure 1.

This information is necessary for determining compliance with 10 CFR 72.24(d) and72.122(h)(1).


a. The perceived inconsistency of P1 and T1 is explained below.

The 100 percent rods rupture condition pressure of 189.8 psia wasdetermined assuming that the fill gas and gaseous fission productsreleased from the ruptured rods enter the MPC cavity without affecting theMPC cavity bulk temperature. This is conservative, as any increase in gasdensity would increase the helium gas circulation rate. This can beunderstood by considering the Rayleigh Number, often used as ameasurement of the effect of buoyancy-driven flows, which is proportionalto the square of the fluid density. This is the approach that was used inthe NRC-approved HI-STORM application (HI-STORM LAR 1014-1,ADAMS Accession Number for NRC SER is ML003711779).

Enclosure 2 PG&E Letter DIL-09-006

Page 3 of 14

In Section 5.1.7, the applicant evaluates the final pressure based on the temperature change in the event. The initial pressure (P1) and temperature (T1) used in this analysis are from Table 9 and Table 10. The initial pressure (P1) of 189.9 psia is based on a storage scenario with 100% rods ruptured. The initial cavity temperature (T1) 0,.509 OK, which should correlate to P1=189.9 psia, instead correlates to an internal pressure of 73.48 psia.

Re-evaluate the temperature in section 5.1.7, using a T1 that corresponds to P1 = 189. 9 psia. Alternatively, justify why using an initial cavity temperature of 509 OK is appropriate for an initial pressure of 189.9 psia.



d. Clarify the cavity average temperature calculation to address how the calculation accounts for the void space within the cell.

Table 10 of Holtec Report HI-2053376 lists the MPC cavity average temperature from the Fluent model. Since the fuel basket cell is modeled with the porous media Keff approach, the cavity volume within the cell is averaged out in the porous media. It is not clear how the cavity average temperature calculation accounts for the void space within the cell.




a. The perceived inconsistency of P1 and T1 is explained below.

The 100 percent rods rupture condition pressure of 189.8 psia was determined assuming that the fill gas and gaseous fission products released from the ruptured rods enter the MPC cavity without affecting the MPC cavity bulk temperature. This is conservative, as any increase in gas density would increase the helium gas circulation rate. This can be understood by considering the Rayleigh Number, often used as a measurement of the effect of buoyancy-driven flows, which is proportional to the square of the fluid density. This is the approach that was used in the NRC-approved HI-STORM application (HI-STORM LAR 1014-1, ADAMS Accession Number for NRC SER is ML003711779).

Enclosure 2PG&E Letter DIL-09-006Page 4 of 14

The effect of the temperature-pressure coupling on the MPC internalpressure is included in HI-2053376, Revision 6, Section 5.1.7 through theuse of the term ATpress, which is computed in Section 5.1.6. It is noted thatthis approach was used in the NRC-approved HI-STORM application (HI-STORM LAR 1014-1, ADAMS Accession Number for NRC SER isML003711779).

To confirm the adequacy of the method of calculating pressure in HI-2053376, Section 5.1.7, an alternate calculation has been performed in arevision to Holtec International Report HI-2053376., This alternatemethodology computes the MPC internal pressure as it changes withtemperature during the duration of the transient evaluation. The followingtable shows how the alternate method pressure in Appendix C comparesto that computed in Section 5.1.7.

Holtec International Report HI-2053376Pressure from Section 5.1.7 Pressure from Appendix C

213.4 psia 213.1 psia

This comparison shows agreement between the two values, whichconfirms the approach used in Section 5.1.7.



d. The cavity average temperature is computed on a volume average basiswith no consideration of the volume occupied by the fuel basket structure.This conservatively maximizes the volume of the hottest regions inside theMPC cavity, thereby maximizing all computed bulk temperatures andresulting internal pressures. It is noted that this approach was used in theNRC-approved HI-STORM application (HI-STORM LAR 1014-1, ADAMSAccession Number for NRC SER is ML003711779).


Thermal Question 4

Provide the inlet flow condition, geometry configuration, assumptions, initial andboundary conditions, and temperature history in the evaluation of the HI-STORM in CTFdescribed in Section 5.1.10 of Holtec Report HI-2053376.

a. Describe the inlet flow boundary condition in details.

In Section 5.1.10 of Holtec Report HI-2053376, the applicant states "theflow of air to the bottom inlet vents would be restricted." The flow reduction


Page 4 of 14

The effect of the temperature-pressure coupling on the MPC internal pressure is included in HI-2053376, Revision 6, Section 5.1.7 through the use of the term f:::,. T press, which is computed in Section 5.1.6. It is noted that this approach was used in the NRC-approved HI-STORM application (HISTORM LAR 1014-1, ADAMS Accession Number for NRC SER is ML003711779).

To confirm the adequacy of the method of calculating pressure in HI-2053376, Section 5.1.7, an alternate calculation has been performed in a revision to Holtec International Report HI-2053376. This alternate methodology computes the MPC internal pressure as it changes with temperature during the duration of the transient evaluation. The following table shows how the alternate method pressure in Appendix C compares to that computed in Section 5.1.7.

Holtec International Report HI-2053376 Pressure from Section 5.1.7 I Pressure from Appendix C

213.4 psia I 213.1. psia

This comparison shows agreement between the two values, which confirms the approach used in Section 5.1.7.


, '


d. The cavity average temperature is computed on a volume average basis with no consideration of the volume occupied by the fuel basket structure. This conservatively maximizes the volume of the hottest regions inside the MPC cavity, thereby maximizing all computed bulk temperatures and resulting internal pressures. It is noted that this approach was used ,in the NRC-approved HI-STORM application (HI-STORM LAR 1014-1, ADAMS Accession Number for NRC SER is ML0037117i9).


Thermal Question 4

Provide the inlet flow condition, geometry configuration, assumptions, initial and boundary conditions, and temperature history in the evaluation of the HI-STORM in CTF ,described in Section 5.1.10 of Holtec Report HI-2053376.

a. Describe the inlet flow boundary condition in details.

In Section 5.1.10 of Holtec Report HI-2053376, the applicant states "the flow of air to the bottom inlet vents would be restricted." The flow reduction '


Page 5 of 14

was not clearly stated in the model. A quantitative description is

necessary.


c. Present the initial conditions and temperature history of key parameters inthe evaluation of the HI-STORM in the CTF.

This scenario is a transient problem. The initial conditions were notdescribed in the application and no temperature history was presented forthe key parameters in Table 6. Detailed initial conditions and time historyplots are needed to ensure the temperature converges to steady statevalues which comply with the temperature limits.

This information is necessary for determining compliance with 10 CFR 72.24(d),72.122(h)(1), and 72.128(a)(4).


a. The thermal model includes the interface with the ambient as an annularpressure boundary at the top of the cask, between the outer diameter ofthe cask and the inner diameter of the surrounding hypothetical reflectingcylinder. The ambient air is assumed quiescent and no fixed velocity isimposed on the model. The air flow rate is a computed result from thethermal model, determined as necessary to balance buoyancy forces andflow resistance.

The restriction in the flow of air referred to in Subsection 5.1.10 ofHI-2053376 is not a change in the model boundary conditions (i.e., no flowrate is imposed), but, rather is the result of the reduction in the diameter ofthe hypothetical reflecting cylinder. For more discussion on this diameterreduction, please see the response to Thermal Question 2 above.


c. This scenario is not a transient evaluation. To bound any possibleduration where a loaded HI-STORM cask cannot be removed from theCTF, a steady-state evaluation was performed in Holtec InternationalReport HI-2053376. All temperature limits were satisfied at steady-state.As a steady-state evaluation was performed, time history plots are notneeded to confirm convergence.

Thermal Question 5

Explain the allowable temperature limits for fuel cladding at different fuel ages forstorage under normal conditions.


Page 50f14

was not clearly stated in the model. A quantitative description is necessary.


c. Present the initial conditions and temperature history of key parameters in the evaluation of the HI-STORM in the CTF.

This scenario is a transient problem. The initial conditions were not described in the application and no temperature history was presented for the key parameters in Table 6. Detailed initial conditions and time history plots are needed to ensure the temperature converges to steady state values which comply with the temperature limits.

This information is necessary for determining compliance with 10 CFR 72.24(d), 72. 122(h)(1), and 72. 128(a)(4).


a. The thermal model includes the interface with the ambient as an annular pressure boundary at the top of the cask, between the outer diameter of the cask and the inner diameter of the surrounding hypothetical reflecting cylinder. The ambient air is assumed quiescent and no fixed velocity is imposed on the model. The air flow rate is a computed result from the thermal model, determined as necessary to balance buoyancy forces and flow resistance.

The restriction in the flow of air referred to in Subsection 5.1.10 of HI-2053376 is not a change in the model boundary conditions (i.e., no flow rate is imposed), but. rather is the result of the reduction in the diameter of the hypothetical reflecting cylinder. For more discussion on this diameter reduction, please see the response to Thermal Question 2 above.


c. This scenario is not a transient evaluation. To bound any possible duration where a loaded HI-STORM cask cannot be removed from the CTF, a steady-state evaluation was performed in Holtec International Report HI-2053376. All temperature limits were satisfied at steady-state. As a steady-state evaluation was performed, time history plots are not needed to confirm convergence.

Thermal Question 5

Explain the allowable temperature limits for fuel cladding at different fuel ages for storage under normal conditions.


Page 6 of 14

Table 2 of Holtec Report HI-2053376 lists the computed and allowable fuel claddingtemperatures at various fuel ages during storage under normal conditions. Clarify howthe allowable temperatures are derived for different fuel ages. Due to the small margins(4-7 IF) between the computed and allowable fuel cladding temperatures, thisinformation is necessary for the staff to make a determination of safety and regulatorycompliance.

This information is necessary for determining compliance with 10 CFR 72.24(d), and72.128(a)(4).


The limits on fuel cladding vs. age for normal storage were established in theHI-STORM FSAR, Revision 1. The development of these values is discussed indetail in the HI-STORM FSAR, Revision 1, Section 4.3. Refer to HI-STORM FSAR,Revision 1, Table 4.3.7, for the cladding temperature limits and permissibletemperatures. HI-STORM FSAR, Revision 1, Section 4.3 is referenced as part ofthe DC ISFSI licensing basis.

Although subsequent Holtec licensing actions have changed the fuel claddingtemperature limit for normal storage to 752°F (400'C) (Reference Holtec CoC,Amendment 3, Appendix B, Section 3.7.2.5), the DC ISFSI licensing basis is the moreconservative limit of the HI-STORM FSAR, Revision 1, Table 4.3-7.

Criticality Question 6

Justify that there is no chemical or other mechanism that could change the boronconcentration in the MPC if the MPC is filled with borated water, as required byTS 3.2. 1, for longer than 48 hours.

The note in both SR 3.2. 1.1 and SR 3.2.1.2 specifies that a surveillance of the dissolvedboron concentration must be performed "if the MPC is submerged in water or if water isto be added to or recirculated through the MPC." This note reduces the surveillancerequirement from what it previously required. While the staff recognizes that this note isconsistent with the surveillance requirements in the TS for the Holtec design, thisamendment request must be evaluated on its own merits so that the staff may make itsregulatory determination regarding the safety of the use of the system at the DiabloCanyon facility.

Justify that the dissolved boron concentration will not change if the MPC is filled withborated water, as required by TS 3.2.1, for longer than 48 hours. Specifically, statewhether there are any chemical or other mechanisms that could potentially result in anunsafe concentration of dissolved boron. For example, explain if there are anymechanisms, such as boron precipitation, for the boron concentration to decrease if theMPC is filled with borated water, as required by TS 3.2.1, for greater than 48 hours.


Page 6 of 14

Table 2 of Holtec Report HI-2053376 lists the computed and allowable fuel cladding temperatures at various fuel ages during storage under normal conditions. Clarify how the allowable temperatures are derived for different fuel ages. Due to the small margins (4-7 OF) between the computed and allowable fuel cladding temperatures, this information is necessary for the staff to make a determination of safety and regulatory compliance.

This information is necessary for determining compliance with 10 CFR 72.24(d), and 72. 128(a)(4).


The limits on fuel cladding vs. age for normal storage were established in the HI-STORM FSAR, Revision 1. The development of these values is discussed in detail in the HI-STORM FSAR, Revision 1, Section 4.3. Refer to HI-STORM FSAR, Revision 1, Table 4.3.7, for the cladding temperature limits and permissible temperatures. HI-STORM FSAR, Revision 1, Section 4.3 is referenced as part of the DC ISFSI licensing basis.

Although subsequent Holtec licensing actions have changed the fuel cladding temperature limit for normal storage to 752°F (400°C) (Reference Holtec CoC, Amendment 3, Appendix B, Section 3.7.2.5), the DC ISFSI licensing basis is the more conservative limit of the HI-STORM FSAR, Revision 1, Table 4.3-7.

Criticalitv Question 6

Justify that there is no chemical or other mechanism that could change the boron concentration in the MPC if the MPC is filled with borated water, as required by TS 3.2. 1, for longer than 48 hours.

The note in both SR 3.2.1.1 and SR 3.2.1.2 specifies that a surveillance ofthe dissolved boron concentration must be performed "if the MPC is submerged in water or if water is to be added to or recirculated through the MPC." This note reduces the surveillance requirement from what it previously required. While the staff recognizes that this note is consistent with the surveillance requirements in the TS for the Holtec design, this amendment request must be evaluated on its own merits so that the staff may make its regulatory determination regarding the safety of the use of the system at the Diablo Canyon facility.

Justify that the dissolved boron concentration will not change if the MPC is filled with borated water, as required by TS 3.2.1, for longer than 48 hours. Specifically, state whether there are any chemical or other mechanisms that could potentially result in an unsafe concentration of dissolved boron. For example, explain if there are any mechanisms, such as boron precipitation, for the boron concentration to decrease if the MPC is filled with borated water, as required by TS 3.2.1, for greater than 48 hours.


Page 7 of 14

This information is necessary for determining compliance with 10 CFR 72.124.

PG&E Response to Criticality Question 6

The only potential mechanisms that could result in a reduction in the boronconcentration in the MPC are boron precipitation and the addition of unborated water.Precipitation would not occur since boron is maintained at least 2600 ppm (2600 ppm isless than the solubility at 32°F (approximately 4000 ppm)). Any postulated plate out ofboron on stainless steel from an unknown phenomena could change the waterconcentration, but would result in an even boron distribution of plate out and no effecton criticality control. As such, the only mechanism to change boron concentration isaddition of water to the MPC, which requires sampling in accordance with the proposedchanges to Diablo Canyon ISFSI Technical Specification (TS) Surveillances 3.2.1.1 and3.2.1.2.

The MPC, in the HI-TRAC, is processed in the Cask Washdown Area, where the cask isin an open area. Therefore, inadvertent flooding, which could introduce water in anuncontrolled manner, is precluded.

Even though the MPC boron concentration is not required to be sampled unless water isintroduced or recirculated, the time-to-boil requirements will require recirculation on aspecified frequency, and the boron concentration will be measured during recirculation.For the DC ISFSI's initial spent fuel load campaign, the time-to-boil is estimated to bebetween 50 and 60 hours. For a maximum heat load canister, recirculation of andboron measurement would occur approximately every 35 hours. In the unlikely casethat a canister is loaded with as little as a 10 kW heat load, recirculation would occur atapproximately 100 hours. Diablo Canyon ISFSI TS 5.1.3.c requires that the watertemperature of a water-filled or partially loaded MPC shall be shown by analysis to beless than boiling at all times.

Confinement Question 7

Revise TS 3.1.1 to require three weld passes for the structural-lid-to-shell weld.

The application states that, with respect to TS 3.1.1, "Multi-Purpose Canister (MPC),"the structural-lid-to-shell weld can be exempted from the helium leak test if theassociated welds are performed with at least two weld passes and with liquid penetrantexaminations of the root and final weld passes.

To ensure the integrity of the independent field weld important to safety, and to providean acceptable method for meeting applicable requirements of 10 CFR 72.122(h) and72.104, Interim Staff Guidance (ISG) - 18 (Rev. 1), "The Design and Testing of LidWelds on Austenitic Stainless Steel Canisters as the Confinement Boundary for SpentFuel Storage," may be applied. However, to exempt the structural-lid-to-shell weld fromthe helium leak test, the associated welds must be performed with at least three weld


Page 7 of 14 L.II:.


PG&E Response to Criticality Question 6

The only potential mechanisms that could result in a reduction in the boron concentration in the MPC are boron precipitation and the addition of unborated water. Precipitation would not occur since boron is maintained at least 2600 ppm (2600 ppm is less than the solubility at 32°F (approximately 4000 ppm». Any postulated plate out of boron on stainless steel from an unknown phenomena could change the water concentration, butwould result in an even boron distribution of plate out and no effect on criticality control. As such, the only mechanism to change boron concentration is addition of water to the MPC, which requires sampling in accordance with the proposed changes to Diablo Canyon ISFSI Technical Specification (TS) Surveillances 3.2.1.1 and 3.2.1.2.

The MPC, in the HI-TRAC, is processed in the Cask Washdown Area, where the cask is in an open area. Therefore, inadvertent flooding, which could introduce water in an uncontrolled manner, is precluded.

Even though the MPC boron concentration is not required to be sampled unless water is introduced or recirculated, the time-to-boil requirements will require recirculation on a specified frequency, and the boron concentration will be measured during recirculation. For the DC ISFSI's initial spent fuel load campaign, the time-to-boil is estimated to be between 50 and 60 hours. For a maximum heat load canister, recirculation of and boron measurement would occur approximately every 35 hours. In the unlikely case that a canister is loaded with as little as a 10 kW heat load, recirculation would occur at approximately 100 hours. Diablo Canyon ISFSI TS 5.1.3.c requires that the water temperature of a water-filled or partially loaded MPC shall be shown by analysis to be less than boiling at all times.


Revise TS 3. 1. 1 to require three weld passes for the structural-lid-to-shell weld.

The application states that, with respect to TS 3. 1. 1, "Multi-Purpose Canister (MPC)," the structural-lid-to-shell weld can be exempted from the helium leak test if the associated welds are performed with at least two weld passes and with liquid penetrant examinations of the root and final weld passes.

To ensure the integrity of the independent field weld important to safety, and to provide an acceptable method for meeting applicable requirements of 10 CFR 72. 122(h) and 72.104, Interim Staff Guidance (ISG) - 18 (Rev. 1), "The Design and Testing of Lid Welds on Austenitic Stainless Steel Canisters as the Confinement Boundary for Spent Fuel Storage, " may be applied. However, to exempt the structural-lid-to-shell weld from the helium leak test, the associated welds must be performed with at least three weld


Page 8 of 14

passes, and at least three different weld layers must be dye penetrant test (PT)examined.

The two-weld pass, described in LAR 08-001, is not consistent with the acceptableguidance of ISG- 18 to meet the applicable regulatory requirements and to qualify forexemption from the helium leakage test. Provide a proposed revision to TS 3.1.1requiring three weld passes for the structural-lid-to-shell welds.

The information is necessary for determining compliance with 10 CFR 72.122(h) and72.104.

PG&E Response to Confinement Question 7

Diablo Canyon ISFSI TS 4.2.1 refers to the Diablo Canyon ISFSI FSAR, Table 3.4-6,which states that dye penetrant (PT) performed will include the root and final layers andeach approximately 3/8 inch of weld depth. Since the TS references the DC ISFSIFSAR Table 3.4-6, PG&E will revise DC ISFSI FSAR Table 3.4-6, to state: "If PT aloneis used, at a minimum, it will include the root and final weld layers and eachapproximately 3/8-inch of weld depth (minimum of 3 weld layers)" for the MPC Lid-to-Shell Weld and the MPC Enclosure Vessel and Lid.

PG&E's response to Confinement Question 7 supersedes the Technical Analysisdiscussion related to TS 3.1.1, "Multi-Purpose Canister (MPG)" in PG&E's LicenseAmendment Request 08-001 (Reference PG&E Letter DIL-08-002, Section 4.0.


Specify whether the reduced height of the MPC impacts the leaktight criteria of the MPCvent and drain port welds and/or the confinement integrity of the canister.

With the reduction of the MPC height, and the resulting changes of MPC cavitypressure, the applicant needs to confirm that no over-pressurization may exist in theMPC cavity. This information is required to ensure that the leak rate through thesewelds will not exceed the leaktight criteria of ANSI N14.5, specified in S.R. 3.1.1.3, forany size MPC.



The configuration of the vent and drain ports is not changed by the shortening of theMPC; the design pressure of the MPC is not changed for the reduced height of theMPC; and the leak testing of the vent and drain port covers is performed usingatmospheric pressure Helium on the back side of the welds. Since leaktight is definedby ANSI N 14.5-1997 as a leak test with 1 atm of Helium on one side and a MassSpectrum Leak Detector vacuum of 0.01 atm or less and a measured leakage of


Page 8 of 14

passes, and at least three different weld layers must be dye penetrant test (PT) examined.

The two-weld pass, described in LAR 08-001, is not consistent with the acceptable guidance of ISG-18 to meet the applicable regulatory requirements and to qualify for exemption from the helium leakage test. Provide a proposed revision to TS 3. 1. 1 requiring three weld passes for the structural-lid-to-shell welds.

The information is necessary for determining compliance with 10 CFR 72. 122(h) and 72.104.


Diablo Canyon ISFSI TS 4.2.1 refers to the Diablo Canyon ISFSI FSAR, Table 3.4-6, which states that dye penetrant (PT) performed will include the root and final layers and each approximately 3/8 inch of weld depth. Since the TS references the DC ISFSI FSAR Table 3.4-6, PG&E will revise DC ISFSI FSAR Table 3.4-6, to state: "If PT alone is used, at a minimum, it will include the root and final weld layers and each approximately 3/8-inch of weld depth (minimum of 3 weld layers)" for the MPC Lid-toShell Weld and the MPC Enclosure Vessel and Lid.

PG&E's response to Confinement Question 7 supersedes the Technical Analysis discussion related to TS 3.1.1, "Multi-Purpose Canister (MPG)" in PG&E's License Amendment Request 08-001 (Reference PG&E Letter DIL-08-00i, Section 4.0.


Specify whether the reduced height of the MPC impacts the leaktight criteria of the MPC vent and drain port welds and/or the confinement integrity of the canister.

With the reduction of the MPC height, and the resulting changes of MPC cavity pressure, the applicant needs to confirm thatno over-pressurization may exist in the MPC cavity. This information is required to ensure that the leak rate through these welds will not exceed the leaktight criteria of ANSI N14.5, specified in S.R. 3.1.1.3, for any size MPC.



The configuration of the vent and drain ports is not changed by the shortening of the MPC; the design pressure of the MPC is not changed for the .reduced height of the. MPC; and the leak testing of the vent and drain port covers is performed using atmospheric pressure Helium on the back side of the welds. Since leaktight is defined by ANSI N14.5-1997 as a leak test with 1 atm of Helium on one side and a Mass' . Spectrum Leak Detector vacuum of 0.01 atm or less and a measured leakage of


Page 9 of 14

lx10-7 ref-cm 3/sec., leaktightness is unaffected by the postulated accident pressure. Iffor some reason the pressure was higher on the backside of the weld during the testing,the measured leakage rate would be higher, which would result in conservative decisionmaking.

Holtec Report HI-2053376, Revision 6, demonstrates that there is no overpressurizationwith the reduction of the MPC height and the resulting changes of MPC cavity pressure.


Clarify how the allowable MPC internal pressure limits were derived under normal, off-normal, and accident conditions, for the shortened MPC.

The applicant lists the calculated pressures for all conditions (0%, 1%, 10% and 100%rods ruptured) and allowable internal pressure limits (normal, off-normal, and accidentconditions), in Table 9 of Holtec Report HI-2053376. The applicant should clarify howthe allowable MPC internal pressure limits are defined, or derived under differentconditions, for the shortened MPC. Provide the analyses and/or calculations fordetermining the MPC pressures for all conditions. This information is needed to assurethat the defined pressure limits are adequate and that confinement integrity ispreserved.



The allowable MPC internal pressure limits for the shortened MPC are the same as thelimits applied to the standard height MPC in HI-STORM CoC Amendment 1. Refer toHI-STORM FSAR, Revision 1, Table 2.2.1. The calculations performed for theshortened MPC are documented in Holtec Report HI-2053376, Revision 6 and verifiednormal, off-normal, and accident conditions to be within the original design limits.

The thermal models and computer files for HI-2053376 are being provided in responseto Thermal Question 1.


Provide a calculation showing that the reduced height of the MPC will not result in aninternal pressure resulting in a change to the design basis limit for the MPC internalpressure.

For normal storage conditions, the MPC uses multiple confinement barriers provided bythe fuel cladding and the MPC enclosure vessel to assure that there is no release ofradioactive material to the environment. The applicant informed the staff, in PG&ELetter DIL-08-004, that the height of HI-TRAC 125D transfer cask, containing the


Page 9 of 14

1 x1 0-7 ref-cm3/sec., leaktightness is unaffected by the postulated accident pressure. If for some reason the pressure was higher on the backside of the weld during the testing, the measured leakage rate would be higher, which would result in conservative decision making.

Holtec Report HI-2053376, Revision 6, demonstrates that there is no overpressurization with the reduction of the MPC height and the resulting changes of MPC cavity pressure.


Clarify how the allowable MPC internal pressure limits were derived under normal, offnormal, and accident conditions, for the shortened MPC.

The applicant lists the calculated pressures for all conditions (0%, 1 %, 10% and 100% rods ruptured) and allowable internal pressure limits (normal, off-normal, arid accident conditions), in Table 9 of Holtec Report HI-2053376. The applicant should clarify how the allowable MPC internal pressure limits are defined, or derived under different conditions, for the shortened MPC. Provide the analyses and/or calculations for determining the MPC pressures for all conditions. This information is needed to assure that the defined pressure limits are adequate and that confinement integrity is preserved.

This information is necessary for determining compliance with 10 CFR 72. 104.


The allowable MPC internal pressure limits for the shortened MPC are the same as the limits applied to the standard height MPC in HI-STORM CoC Amendment 1. Refer to HI-STORM FSAR, Revision 1, Table 2.2.1. The calculations performed for the shortened MPC are documented in Holtec Report HI-2053376, Revision 6 and verified normal, off-normal, and accident conditions to be within the original design limits.

The thermal models and computer files for HI-2053376 are being provided in response to Thermal Question 1.


Provide a calculation showing that the reduced height of the MPC will not result in an internal pressure resulting in a change to the design basis limit for the MPC internal pressure.

For normal storage conditions, the MPC uses multiple confinement barriers provided by the fuel cladding and the MPC enclosure vessel to assure that there is no release of radioactive material to the environment. The applicant informed the staff, in PG&E Letter 0IL-08-004, that the height of HI-TRAC 1250 transfer cask, containing the


Page 10 of 14

MPC-32, was reduced by approximately 9 inches, permitting the transfer cask to behandled in the vertical orientation during all operations.

For this reduced height of MPC, the applicant needs to provide additional analyses toclarify the pressure calculations in Holtec Report HI-2053376 and to ensure the reducedheight of MPC will not pose an internal pressure change to the design basis limitsignificant to safety for the MPC, as the MPC is a fission product barrier. With theheight of MPC reduced by 9 inches, the staff needs to review the model or thecalculation package of the HI-STORM with reduced height of MPC to evaluate thepredicted MPC internal pressures, (particularly under fire, 100% fuel rod rupture, and100% blockage of air inlets), to ensure the overpressurization in the MPC will not occurand that confinement integrity is preserved.



Holtec Report HI-2053376, Revision 6, provides the evaluation that demonstrates thatthe shortened MPC meets the original design criteria limits for storage in normal, off-normal and accident conditions, which include fire (Sections 5.1.5 and 5.2.3),100 percent fuel rod rupture (Section 5.1.6 and Table 9), and 100 percent blockage ofair inlets (Section 5.1.7 and Appendix C). Please note that PG&E requested that Holtecadd additional conservatism to the values for initial MPC fill pressure (maximum versesnominal), and internal fuel rod gas pressure (to account for integral fuel burnableabsorber (IFBA) loading) above the values used in the pressure calculations that wereperformed to support the licensing of the MPC-32 in Holtec CoC Amendment 1. Theuse of these increased pressures was limited to the calculations for overpressure, andwas not used in the thermal evaluations (where additional gas would be beneficial).This is stated in HI-2053376, Revision 6, Section 4.0, 2nd paragraph.

The thermal models of the proposed HI-STORM system and the computer files related

to the design change are provided in response to Thermal Question 1.


Revise Holtec Report HI-2053376 or otherwise clarify that the equation PIT2 = P2TI isvalid between the 100% rod rupture condition and the 100% blockage of air inletaccident.

Page 11 of Holtec Report HI-2053376 uses the equation P1 T2 = P2TI, which is onlyvalid if the amount of gas remains unchanged between condition 1 (100% rod rupture)and condition 2 (100% blockage of air inlet accident). Revise the calculation to clarifythat the amount of gas does not change during the 100% blockage of air inlet accident.



Page 10 of 14

MPC-32, was reduced by approximately 9 inches, permitting the transfer cask to be handled in the vertical orientation during all operations.

For this reduced height of MPC, the applicant needs to provide additional analyses to clarify the pressure calculations in Holtec Report HI-2053376 and to ensure the reduced height of MPC will not pose an internal pressure change to the design basis limit significant to safety for the MPC, as the MPC is a fission product barrier. With the height of MPC reduced by 9 inches, the staff needs to review the model or the calculation package of the HI-STORM with reduced height of MPC to evaluate the predicted MPC internal pressures, (particularly under fire, 100% fuel rod rupture, and 100% blockage of air inlets), to ensure the over pressurization in the MPC will not occur and that confinement integrity is preserved. .

This information is necessary for determining compliance with" 10 CFR 72.104.


Holtec Report HI-2053376, Revision 6, provides the evaluation that demonstrates that the shortened MPC meets the original design criteria limits for storage in normal, offnormal and accident conditions, which include fire (Sections 5.1.5 and 5.2.3), 100 percent fuel rod rupture (Section 5.1.6 and Table 9), and 100 percent blockage of air inlets (Section 5.1.7 and Appendix C). Please note that PG&E requested that Holtec add additional conservatism to the values for initial MPC fill pressure (maximum verses nominal), and internal fuel rod gas pressure (to account for integral fuel burnable absorber (IFBA) loading) above the values used in the pressure calculations that were performed to support the licensing of the MPC-32 in Holtec CoC Amendment 1. The use of these increased pressures was limited to the calculations for overpressure, and was not used in the thermal evaluations (where additional gas would be beneficial) .. This is stated in HI-2053376, Revision 6, Section 4.0, 2nd paragraph.

The thermal models of the proposed HI-STORM system and the computer files related to the design change are provided in response to Thermal Question 1.


Revise Holtec Report HI-2053376 or otherwise clarify that the equation P{T2 = P2T1 is valid between the 100% rod rupture condition and the 100% blockage of air inlet accident. .

Page 11 of Holtec Report HI-2053376 uses the equation P1 T2 = P2T1, which is only valid if the amount of gas remains unchanged between condition 1 (100% rod rupture) and condition 2 (100% blockage of air inlet accident). Revise the calculation to clarify that the amount of gas does not change during the 100% blockage of air inlet accident.



Page 11 of 14


P1T2=P2T1 is valid for the 100 percent blockage with 100 percent fuel failure, since nis at maximum due to the 100 percent fuel failure initial condition, and V is constant dueto the fixed volume of the MPC and fuel.

To further demonstrate the validity of the 100 percent blockage calculation, Holtec hasprovided an alternate calculation in Appendix C of HI-2053376 Revision 6, whichdemonstrates the agreement with the original calculation, as discussed in the responseto Question 3.

Material Question 12

Revise SAR Chapter 5 and propose a revision to the TS to address protection of thecladding from'degradation, due to excessive oxidation of exposed fuel pellets, duringloading and, unloading operations.

Page 5.1-7 of SAR chapter 5.1.1.2 mentions maintaining an inert gas in the spaceabove the water level in the loaded fuel cask during welding operations to avoidproblems with any combustible gas generation. Protection of the cladding from theeffects of fuel pellet oxidation is also important but not addressed. Oxidation of the fuelpellets due to excessive oxidation during loading and unloading operations can lead tofuel cladding degradation. Protection of the cladding from degradation that leads togross ruptures is required by 10 CFR 72.122(h).

Fuel oxidation may be avoided by maintaining an inert gas cover during draining andflooding operations, or other means, as detailed in the SFST-ISG No. 22, "Potential RodSplitting Due to Exposure to an Oxidizing Atmosphere During Short-Term Cask LoadingOperations in LWR or Other Uranium Oxide Based Fuel."

Provide a discussion in SAR chapter 5.1.1.2 to address that an inert gas cover must bemaintained during draining and flooding operations to ensure that no excessiveoxidation of fuel pellets will occur during loading and unloading operations.

Additionally, propose a revision to TS 5.1.3, or add a new TS, to require backfilling with

an inert gas, such as helium, during loading and unloading operations.

This is necessary for determining compliance with 10 CFR 72.122(h).

PG&E Response to Material Question 12

DC ISFSI FSAR, Section 5.1.1.2, maintains the fuel in water or an inert environment byusing helium during MPC blowdown orcooldown prior to reflood.



Page 11 of 14

P1 T2=P2T1 is valid for the 100 percent blockage with 100 percent fuel failure, since n is at maximum due to the 100 percent fuel failure initial condition, and V is constant due to the fixed volume of the MPC and fuel.

To further demonstrate the validity of the 100 percent blockage calculation, Holtec has provided an alternate calculation in Appendix C of HI-2053376 Revision 6, which demonstrates the agreement with the original calculation, as discussed in the response to Question ~.


Revise SAR Chapter 5 and propose a revision to the TS to address protection of the cladding from degradation, due to excessive oxidation of exposed fuel pellets, during loading and, unloading operations. '

Page 5. 1-7 of SAR chapter 5. 1. 1.2 mentions maintaining an inert gas in the space above the water level in the loaded fuel cask during welding operations to avoid problems with any combustible gas generation. Protection of the cladding from the effects of fuel pellet oxidation is also important but not addressed. Oxidation of the fuel pellets due to excessive oxidation during loading and unloading operations can lead to fuel cladding degradation. Protection of the cladding from degradation that leads to gross ruptures is required by 10 CFR 72. 122(h).

Fuel oxidation may be avoided by maintaining an inert gas cover during draining and flooding operations, or other means, as detailed in the SFST-ISG No. 22, "Potential Rod Splitting Due to Exposure to an Oxidizing Atmosphere During Short-Term Cask Loading Operations in LWR or Other Uranium Oxide Based Fuel."

Provide a discussion in SAR chapter 5.1.1.2 to address that an inert gas cover must be maintained during draining and flooding operations to ensure that no excessive oxidation of fuel pellets will occur during loading and unloading operations.

Additionally, propose a revision to TS 5.1.3, or add a new TS, to require backfilling with an inert gas, such as helium, during loading and unloading operations.

This is necessary for determining compliance with 10 CFR 72. 122(h).


DC ISFSI FSAR, Section 5.1.1.2, maintains the fuel in water or an inert environment by using helium during MPC blowdown or,cooldown prior to reflood.

, J


Page 12 of 14

PG&E proposes to add TS 5.1.3.k to address protection of the cladding fromdegradation, due to excessive oxidation, during loading and unloading operations.Refer to PG&E Letter DIL-09-006, Enclosure 3, for the proposed TS 5.1.3.k addition.

In addition, PG&E will revise the DC ISFSI FSAR, Section 5.1.1.2, MPC Loading andSealing Operations, to state: "The use of helium during MPC water displacement andmoisture removal ensures that there will be no excessive oxidation of the fuel claddingduring loading operations." PG&E will also revise DC ISFSI FSAR, Section 5.1.1.3, Off-normal Event Recovery Operations, to state: "Using helium for cooling prior to refloodensures that the fuel is not exposed to an oxidizing environment during the unloadingoperation."


Revise SAR operating procedure section 5.1.1.2 and propose a revision to the TS torequire flammable (hydrogen) gas monitoring and mitigation during all canister lidwelding or cutting operations during spent fuel loading or unloading.

The SAR language and TS as presently written do not address unloading operationsand do not require hydrogen mitigation measures during these operations. Failure toprovide adequate hydrogen monitoring/mitigation measures have resulted inunanticipated hydrogen ignition events while welding canister lids.

In addition to revising SAR section 5.1.1.2, provide a proposed revision to TS 5.1.3, oradd a new TS, to require flammable (hydrogen) gas monitoring and mitigation during allcanister lid welding or cutting operations during spent fuel loading or unloading.

This information is necessary for determining compliance with 10 CFR 72.122(c).


DC ISFSI FSAR, Section 5.1.1.2, which addresses loading operations, requires that"appropriate monitoring for combustible gas concentrations shall be performed prior to,and during, MPC lid welding operations." As a mitigation measure during loadingoperations, DC ISFSI FSAR, Section 5.1.1.2 states: "In addition, the space below theMPC lid shall be exhausted or purged with inert gas prior to, and during, MPC lidwelding operations to provide additional assurance that explosive gas mixtures will notdevelop in this space."

DC ISFSI FSAR, Section 5.1.1.4, which addresses unloading operations, requires thatappropriate monitoring for combustible gas concentrations shall be performed prior to,and during, MPC lid cutting operations. As a mitigation measure during unloadingoperations, DC ISFSI FSAR, Section 5.1.1.4, states: "In addition, the space below theMPC lid shall be exhausted prior to, and during, MPC lid cutting operations to provideadditional assurance that explosive gas mixtures will not develop in this space."


Page 12 of 14

PG&E proposes to add TS 5.1.3.k to address protection of the cladding from degradation, due to excessive oxidation, during loading and unloading operations. Refer to PG&E Letter DIL-09-006, Enclosure 3, for the proposed TS 5.1.3.k addition.

In addition, PG&E will revise the DC ISFSI FSAR, Section 5.1.1.2, MPC Loading and Sealing Operations, to state: "The use of helium during MPC water displacement and moisture removal ensures that there will be 'no excessive oxidation of the fuel cladding during loading operations." PG&E will also revise DC ISFSI FSAR, Section 5.1.1.3, Offnormal Event Recovery Operations, to state: "Using helium for cooling prior to reflood ensures that the fuel is not exposed to an oxidizing environment during the unloading operation."


Revise SAR operating procedure section 5.1.1.2 and propose a revision to the TS to require flammable (hydrogen) gas monitoring and mitigation during all canister lid welding or cutting operations during spent fuel loading or unloading.

The SAR language and TS as presently written do not address unloading operations and do not require hydrogen mitigation measures during these operations. Failure to provide adequate hydrogen monitoring/mitigation measures have resulted in unanticipated hydrogen ignition events while welding canister lids.

In addition to revising SAR section 5.1.1.2, provide a proposed revision to TS 5.1.3, or add a new TS, to require flammable (hydrogen) gas monitoring and mitigation during all canister lid welding or cutting operations during spent fuel loading or unloading.

This information is necessary for determining compliance with 10 CFR 72. 122(c).


DC ISFSI FSAR, Section 5.1.1.2, which addresses loading operations, requires that "appropriate monitoring for combustible gas concentrations shall be performed prior to, and during, MPC lid welding operations." As a mitigation measure during loading operations, DC ISFSI FSAR, Section 5.1.1.2 states: "In addition, the space below the MPC lid shall be exhausted or purged with inert gas prior to, and during, MPC lid welding operations to provide additional assurance that explosive gas mixtures will not develop in this space."

DC ISFSI FSAR, Section 5.1.1.4,which addresses unloading operations, requires that appropriate monitoring for combustible gas concentrations shall be performed prior to, and during, MPC lid cutting operations. As a mitigation measure during unloading operations, DC ISFSI FSAR, Section 5.1.1.4, states: "In addition, the space below the MPC lid shall be exhausted prior to, and during, MPC lid cutting operations to provide additional assurance that explosive gas mixtures will not develop in this space."


Page 13 of 14

To ensure that adequate hydrogen monitoring/mitigation measures are taken during allcanister lid welding or cutting operations during spent fuel loading or unloading, and tobe consistent with Holtec CoC, Amendment 2, PG&E proposes to add TS 5.1.3.j.TS 5.1.3.j will require verification that combustible gasses in the MPC are monitoredand controlled to avoid combustion during MPC lid-to-shell welding or MPC cuttingactivities. Refer to PG&E Letter DIL-09-006, Enclosure 3, for the proposed TS 5.1.3.jaddition.


Revise SAR Section 4.2.3.3.6 to address how 10 CFR 72.126(d) will be met for twodifferent situations:

For spent fuel canisters which have been fabricated and delivered but not yet loaded,and, for canisters yet to be fabricated or delivered.

The staff is aware that the canister vendor may not perform helium leakage rate testingof the canister shell welds (shop welds) at the fabrication shop. Without this heliumleakage rate testing, and in the absence of a dose calculation, the staff does not haveassurance that the dose limits of 10 CFR 72.104 will be met, that adequate inspection ofthe canister was performed, or that the canister will reasonably maintain confinement.

A dose limit calculation is required by 10 CFR 72.126(d), which states, in part:"Analyses must be made to show that releases to the general environment duringnormal operations and anticipated occurrences will be within the exposure limit given in10 CFR 72.104. Analyses of design basis accidents must be made to show thatreleases to the general environment will be within the exposure limits given in10 CFR 72.106."

To meet these requirements, the staff has accepted the performance of a heliumleakage rate test of all canister shell welds (shop welds), per ANSI N 14.5, to show thatthe "leak-tight" (leakage rate less than or equal to lx 10-7 ref.cm3/sec) criteria has beensatisfied. This satisfies performing the dose limit calculations required by10 CFR 72.126(d).

Otherwise, in accordance with SFST-ISG-5, Rev. 1, "Confinement Evaluation, " a dosecalculation based on a higher leakage rate must be performed to demonstratecompliance with Part 72 dose limits and the requirement to maintain sufficient helium forcooling and inerting purposes over the operational lifetime of the canister.

This requirement is necessary for determining compliance with 10 CFR 72.126(d),72.104, and 72.106.


Page 13 of 14

To ensure that adequate hydrogen monitoring/mitigation measures are taken during all canister lid welding or cutting operations during spent fuel loading or unloading, and to be consistent with Holtec CoC, Amendment 2, PG&E proposes to add TS 5.1.3.j. TS 5.1.3.j will require verification that combustible gasses in the MPC are monitored and controlled to avoid combustion during MPC lid-to-shell welding or MPC cutting activities. Refer to PG&E Letter DIL'-09-006, Enclosure 3, for the proposed TS 5.1.3.j addition.


Revise SAR Section 4.2.3.3.6 to address how1.D CFR 72. 126(d) will be met for two different situations:

For spent fuel canisters which have been fabricated and delivered but not yet loaded, and, for canisters yet to be fabricated or delivered.

The staff is aware that the canister vendor may not perform helium leakage rate testing of the canister shell welds (shop welds) at the fabrication shop. Without this helium leakage rate testing, and in the absence of a dose calculation, the staff does not have assurance that the dose limits of 10 CFR 72.104 will be met, that adequate inspection of the canister was performed, or that the canister will reasonably maintain confinement.

A dose limit calculation is required by 10 CFR 72. 126(d), which states, in part: "Analyses must be made to show that releases to the general environment during normal operations and anticipated occurrences will be within the exposure limit given in 10 CFR 72.104. Analyses of design basis accidents must be made to show that releases to the general environment will be within the exposure limits given in 10 CFR 72.106."

To meet these requirements, the staff has accepted the performance of a helium leakage rate test of all canister shell welds (shop welds), per ANSI N14.5, ,to show that the "leak-tight" (leakage rate less than or equal to 1x10-7 ref.cm3/sec) criteria has been satisfied. This satisfies performing the dose limit calculations required by 10 CFR 72. 126(d).

Otherwise, in accordance with SFST-ISG-5, Rev. 1, "Confinement Evaluation," a dose calculation based on a higher leakage rate must be performed to demonstrate compliance with Part 72 dose limits and the requirement to maintain sufficient helium for cooling and inerting purposes over the operational lifetime of the canister.

This requirement is necessary for determining compliance with 10 CFR 72. 126(d), 72. 104, and 72. 106.


Page 14 of 14


Since PG&E's Material License is based on the HI-STORM CoC, Amendment 1, PG&Ehas required Holtec to perform the factory leakage test of the MPC shell welds asoutlined in HI-STORM FSAR, Revision 1, Section 9.1.3 for MPCs fabricated for PG&E.The Shop weld leakage criteria used by Holtec for PG&E MPCs is < 5 x 10-6 std cc/sec.(helium). The PG&E site-specific confinement analysis (Holtec Report HI-200251.3,submitted by PG&E Letter DIL-01-007, dated December 21, 2001), also uses this valueas identified in the DC ISFSI FSAR Section 7.5.2.1.

PG&E will revise DC ISFSI FSAR, Section 4.2.3.3.6, to state: "All factory welds areexamined per ASME Section III and helium leak tested to ensure conformance to theoffsite dose analysis."



Page 14 of 14

Since PG&E's Material License is based on the HI-STORM CoC, Amendment 1, PG&E has required Holtec to perform the factory leakage test of the MPC shell welds as outlined in HI-STORM FSAR, Revision 1, Section 9.1.3 for MPCs fabricated for PG&E. The Shop weld leakage criteria used by Holtec for PG&E MPCs is ~ 5 x 10-6 std cc/sec. (helium). The PG&E site-specific confinement analysis (Holtec Report HI-200251.3, submitted by PG&E Letter DIL-01-007, dated December 21, 2001), also uses this value as identified in the DC ISFSI FSAR Section 7.5.2.1.

PG&E will revise DC ISFSI FSAR, Section 4.2.3.3.6, to state: "Ali factory welds are examined per ASME Section III and helium leak tested to ensure conformance to the offsite dose analysis."


Proposed Diablo Canyon ISFSI Technical Specification Changes (mark-up)Includes LAR 08-01 As Modified by RAI Responses


Proposed Diablo Canyon ISFSI Technical Specification Changes (mark-up) Includes LAR 08-01 As Modified by RAI Responses

APPENDIX

TECHNICAL SPECIFICATIONSFOR THE

DIABLO CANYON

INDEPENDENT SPENT FUEL STORAGEINSTALLATION

Docket No. 72-26

Materials License No. SNM-2511

ISFSI TS for RAIResponse

RO

APPENDIX

TECHNICAL SPECIFICATIONS FOR THE

DIABLO CANYON

INDEPENDENT SPENT FUEL STORAGE ·INST ALLATION

Docket No. 72-26


ISFSI TS for RAI RO Response

TABLE OF CONTENTS

1.0 USE AND APPLICATION ........................................... 1.1-11 .1 D e fi n itio n s .......................................................................................................... 1 .1 -11.2 Lo g ica l C o n ne cto rs ............................................................................................ 1.2-11.3 C o m pletio n T im e s .............................................................................................. 1.3-11 .4 F re q u e n c y .......................................................................................................... 1 .4 -1

2.0 A P P R O V E D C O N T E N T S ............................................................................................ 2.0-1

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ........................... 3.0-13.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .......................................... 3.0-23.1 Spent Fuel Storage Cask (SFSC) Integrity ................................................................. 3.1-13.1.1 Multi-Purpose Canister (MPC)

3.1.2 Spent Fuel Storage Cask (SFSC) Heat Removal System ................................. 3.1-33 .1.3 F ue l C o o l-D ow n .................................................................................................. 3 .1-43.1.4 Spet, Fuel S•toage Cask. (•,,-r-C Time. Limit--tion,, in

Cask Transfer Facility (CTF)lntentionally left blank .......................................... 3.1-53.2 Cask Criticality Control Program ............................... .... ........................ 3.2-13.2.1 Dissolved Boron Concentration ................................ 3.2-1

4.0 D ES IG N FEA TU R ES ................................................................................... . .... 4.0-14.1 Design Features Significant to Safety .............................. 4.0-14 .1.1 C ritica lity C o ntro l ........................................................................... .................. 4 .0-14.2 Codes and Standards ................................................. 4.0-14.3 Cask Handling/Cask Transfer Facility................................ 4.0-34 .3 .1 C ask T ransporte r .............................................................................................. 4 .0-34.3 .2 S to rage C apacity .............................................................................................. 4 .0-34.3.3 SFSC Load Handling Equipm ent ...................................................................... 4.0-34.3.4 C TF Structure Requirem ents ............................................................................. 4.0-3

5.0 ADMINISTRATIVE CONTROLS ...................................5.0-15.1 Administrative Program ..................................... 5.0-15.1.1 Technical Specifications (TS) Bases Control Program ...................................... 5.0-15.1.2 Radioactive Effluent Control Program ....................................................... .. 5.0-15.1.3 MPC and SFSC Loading, Unloading, and Preparation Program ....................... 5.0-25.1.4 IS FS O perations P rogram ................................................................................. 5.0-35.1.5 Cask Transportation Evaluation Program ......................................................... 5.0-3

DIABLO CANYON ISFS5ISFSI TS for RAIResponse

TABLE OF CONTENTS

1.0 USE AND APPLICATION ............................................................................................ 1.1-1 1.1 Definitions .......................................................................................................... 1.1-1 1.2 Logical Connectors ............................................................................................ 1.2-1 1.3 Completion Times .............................................................................................. 1.3-1 1.4 Frequency .......................................................................................................... 1.4-1

2.0 APPROVED CONTENTS ............................................................................................ 2.0-1

3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY ........................... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .......................................... 3.0-2 3.1 Spent Fuel Storage Cask (SFSC) Integrity .................................................. : .............. 3.1-1 3.1.1 Multi-Purpose Canister (MPC)

3.1.2 Spent Fuel Storage Cask (SFSC) Heat Removal System ................................. 3.1-3 3.1.3 Fuel Cool-Down .................................................................................................. 3.1-4 3.1.4 Spent Fuel Storage Cask (SFSC) Time Limitation in

Cask Transfer Facility (CTF)lntentionally left blank ....... ..................................... 3.1-5 3.2 Cask Criticality Control Program ........................................................................ 3.2-1 3.2.1 Dissolved Boron Concentration .......................................................................... 3.2-1

4.0 DESIGN FEATURES .................................................................................................. 4.0-1 4.1 Design Features Significant to Safety ...................................................... .' ........ .4.0-1 4.1.1 Criticality Control ............................................................................................... 4.0-1 4.2 Codes and Standards ....................................................................................... .4.0-1 4.3 Cask Handling/Cask Transfer Facility ................................................................ 4.0-3 4.3.1 Cask Transporter ............................................................................................... 4.0-3 4.3.2 Storage Capacity ................................................................................................ 4.0-3 4.3.3 SFSC Load Handling Equipment ...................................................................... .4.0-3 4.3.4 CTF Structure Requirements ............................................................................. 4.0-3

5.0 ADMINISTRATIVE CONTROLS ................................................................................. 5.0-1 5.1 Administrative Program ...................................................................................... 5.0-1 5.1.1 Technical Specifications (TS) Bases Control Program ...................................... 5.0-1 5.1.2 Radioactive Effluent Control Program ................................................................ 5.0-1 5.1.3 MPC and SFSC Loading, Unloading, and Preparation Program ....................... 5.0-2 5.1.4 ISFSI Operations Program ................................................................................. 5.0-3 5.1.5 Cask Transportation Evaluation Program .......................................................... 5.0-3

DIABLO CANYON ISFSI ISFSI TS for RAI Response

MPC3.1.1

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

C. MPC helium leak rate limit C.1 Perform an engineering 24 hoursfor vent and drain port evaluation to determinecover plate welds not met. the impact of increased

helium leak rate on heatremoval capability andoffsite dose.

AND

C.2 Develop and initiate 7 dayscorrective actionsnecessary to return theMPC to an analyzedcondition.

D. Required Actions and D.1 Remove all fuel 30 daysassociated Completion assemblies from theTimes not met. MPC.

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

SR 3.1.1.1 Verify MPC cavity vacuum drying pressure is • 3 torr Once, prior tofor > 30 min. TRANSPORT

OR OPERATIONS.

While recirculating helium through the MPC cavity,verify that the gas temperature exiting thedemoisturizer is < 21°F for _> 30 min.

SR 3.1.1.2 Verify MPC helium backfill pressure is Ž!29.3 psig and Once, prior to< 33.3 psig. TRANSPORT

OPERATIONS.

SR 3.1.1.3 Verify that the total helium leak rate through the MPC Once, prior tolid confinement we!dvent and the-drain aR4.vef4-port TRANSPORTconfinement welds meets the leaktight criteria of OPERATIONS.ANSI N14.5-1977.is • 5.OE 6 atm cc/sec (He).

DIABLO CANYON ISFSIISFSI TS for RAIResponse

3.1-2

ACTIONS (continued)

MPC 3.1.1


C. MPC helium leak rate limit C.1 Perform an engineering 24 hours for vent and drain pori evaluation to determine cover plate welds not met. the impact of increased

helium leak rate on heat removal capability and offsite dose.

AND

C.2 Develop and initiate 7 days corrective actions necessary to return the MPC to an analyzed condition.

D. Required Actions and D.1 Remove all fuel 30 days associated Completion assemblies from the Times not met. MPC.


SR 3.1.1.1

SURVEILLANCE

Verify MPC cavity vacuum drying pressure is ::; 3 torr for ~ 30 min.

OR

While recirculating helium through the MPC cavity, verify that the gas temperature exiting the demoisturizer is ::; 21°F for ~ 30 min.

. FREQUENCY

Once, prior to TRANSPORT OPERATIONS.

SR 3.1.1.2 Verify MPC helium backfill pressure is ~ 29.3 psig and Once, prior to ::; 33.3 psig. TRANSPORT

OPERATIONS.

SR 3.1.1.3 Verify that the total helium leak rate through the MPC lid confinement '.veld vent and tREHlrain and vent port confinement welds meets the leaktight criteria of ANSI N14.5-1977.is < 5.0E 6 atm cc/sec (He).


3.1-2


SFSC Time Limitation in CTF3.1.4

3.1 SPENT FUEL STORAGE CASK (SFSC) INTEGRITY

3.1.4 Intentionally left blank Spent Fuel Storage Cask (SF.SC) Time LimitatiOn i• CaskTransfer Facility (CTF-)

LCO 3.1.4 The SFSC shall not be in the CTF for greater than 22 Hours

APPIC'ABILITY: Dur.ing TRANSPORT PRE-RA-TIONS, while the SFSC is in the CTF

ACT4QNSNOTE

Separate ConRditionp enr isald forF each SF50G.

CONDITION, REQUIRED ACTION COMPLETION TIME

A IL O Ant mpt I.... ................. IRe o eSatelr


SI 1..1e~f ID\/= II O I the lP C-p-tFl me t;Ih im i itten, AV

DIABLO CANYON ISFSIISFS1 TS for RAIResponse

3.1-5


SFSC Time Limitation in CTF 3.1.4

3.1.4 Intentionally left blank Spent Fuel Storage Cask (SFSC) Time Limitation in Cask Transfer Facility (CTF)

LCO 3.1.4 The SFSC shall not be in the CTF for greater than 22 Hours

APPLICABILITY: During TRANSPORT OPERATIONS 'Nhile the SFSC is in the CTF.

ACTIONS NOTE

Separate Condition entry is allowed for each SFSC.

~~ION .At. LCO notmet.

SURVEI LLANCE REQUI REMEf!>JTS

SR 3.1.4.1 ~';~~ Verify a sFSC in~meets the time limitation.


3.1-5

g hours

Dissolved Boron Concentration3.2.1

3.2 Cask Criticality Control Program

3.2.1 Dissolved Boron Concentration

LCO 3.2.1 The dissolved boron concentration in the water of the MPC cavity shall beas follows:

a. For all MPCs with one or more fuel assemblies having initialenrichment of < 4.1 wt% 235 U: > 2000 ppmb.

b. For MPC24/24E/24EF with one or more fuel assemblies having initialenrichment of > 4.1 and < 5.0 wt% 235 U: _> 2000 ppmb.

c. For MPC 32 with one or more fuel assemblies having initialenrichment of > 4 1 aRd - 5.0 wt% 235 U: _> 2600 ppmb.

----------------- NOTE -------------------------------For MPC-32, with maximum initial enrichments between 4.1 wt% and 5.0 wt% 235 U, theminimum dissolved boron concentration may be determined by linear interpolation between2000 ppmb at 4.1 wt% and 2600 ppmb at 5.0 wt% 235 U, based on the assembly with the highestinitial enrichment to be loaded.

APPLICABILITY: During LOADING OPERATIONS and UNLOADING OPERATIONS withwater and at least one fuel assembly in the MPC.

ACTIONS- - - - - - - - - - -- -- - - - - - - - - - - - - - - - - - - - - - -I-- - - - - - I-"I----------------------------------------

Separate Condition entry is allowed for each MPC.


A. Dissolved boron A.1 Suspend LOADING Immediatelyconcentration not met. OPERATIONS or

UNLOADINGOPERATIONS

AND

A.2 Suspend positive Immediatelyreactivity additions

AND

A.3 Initiate action to restore Immediatelyboron concentration towithin limits


3.2-1

Dissolved Boron Concentration 3.2.1



LCO 3.2.1 The dissolved boron concentration in the water of the MPC cavity shall be as follows:

a. For all MPCs with one or more fuel assemblies having initial enrichment of:5 4.1 wt% 235 U: ~ 2000 ppmb.

b. For MPC24/24E/24EF with one or m·ore fuel assemblies having initial enrichment of > 4.1 and :5 5.0 wt% 235 U: ~ 2000 ppmb.

c. For MPC 32 with one or more fuel assemblies having initial enrichment of > 4.1 and ~ 5.0 wt% 235 U: ~ 2600 ppmb.

----------------~---------------------------------------NO TE-------------------------------------------------------------For MPC-32, with maximum initial enrichments between 4.1 wt% and 5.0 wt% 235 U, the minimum dissolved boron concentration may be determined by linear interpolation between 2000 ppmb at 4. 1 wt% and 2600 ppmb at 5.0 wt% 235 U, based on the assembly with the highest initial enrichment to be loaded.

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

ACTIONS ----------------~---------------------------------------NOT E -------------------------------------------------------------Separate Condition entry is allowed for each MPC.

CONDITION

A. Dissolved boron concentration not met.


A.1

AND

A.2

AND

A.3

REQUIRED ACTION

Suspend LOADING OPERATIONS or UNLOADING OPERATIONS

Suspend positive reactivity additions

Initiate action to restore boron concentration to within limits

3.2-1

COMPLETION TIME

Immediately

Immediately

Immediately



SURVEILLANCE FREQUENCY+

NOTE

This surveillance is only required to be performed if the MPC issubmerged in water or if water is to be added to or recirculated throughthe MPC.

SR 3.2.1.1 Verify the dissolved boron concentration is met usingtwo independent measurements.

Within 8 hoursprior tocommencingLOADINGOPERATIONS

AND

Every 48 hoursthereafter while theMPC is in thespent fuel pool orwhile water is inthe MPC.

NOTE



Within 8 hoursprior tocommencingUNLOADINGOPERATIONS

AND



3.2-2



SURVEILLANCE

NOTE

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

SR 3.2.1.1 Verify the dissolved boron concentration is met using two independent measurements.

NOTE




3.2-2

FREQUENCY

Within 8 hours prior to commencing LOADING OPERATIONS

AND

Every 48 hours thereafter while the MPC is in the spent fuel pool or while water is in the MPC.

Within 8 hours prior to commencing UNLOADING OPERATIONS

AND


Design Features4.0

4.0 DESIGN FEATURES

4.1 Design Features Significant to Safety

4.1.1 Criticality Control

a. MULTI-PURPOSE CANISTER (MPC) MPC-24

1. Flux trap size: Ž_ 1.09 in.

2. 10B loading in the Be-at-neutron absorbers: _ 0.0267 g/cm 2 (Boral) and Ž0.0223g/cm 2 (Metamic)

b MPC-24E and MPC-24EF

1. Flux trap size:

" Cells 3, 6, 19, and 22: _> 0.776 in.

" All Other Cells: _> 1.076 in.

2. 10B loading in the BeiaJ-neutron absorbers: _ 0.0372 g/cm 2 (Boral) and Ž0.0310g/cm 2 (Metamic)

c. MPC-32

1. Fuel cell pitch: Ž> 9.158 in.

2. 10B loading in the Be-al-neutron absorbers: _ 0.0372 g/cm 2 (Boral) and Ž0.0310g/cm 2 (Metamic)

4.1.2 Design Features Important to Criticality Control

a. Fuel spacers shall be sized to ensure that the active fuel region of intact fuelassemblies remain within the neutron poison region of the MPC basket with water inthe MPC.

b. The B4 C content in Metamic shall be < 33.0 wt%.

c. Neutron Absorber Test

The minimum '°B for the neutron absorber shall meet the minimum requirements foreach MPC model specified in Section 4.1.1 above.

4.2 Codes and Standards

The following provides information on the governing codes for the confinement boundary(important to Safety) design:

DIABLO CANYON ISFSIISFSI TS for RAIResponse - 4.0-1Markup

4.0 DESIGN FEATURES




1. Flux trap size: ~ 1.09 in.

Design Features 4.0

2. 1°B loading in the BefcH-neutron absorbers: ~ 0.0267 g/cm2 (Boral) and ~ 0.0223 glcm2 (Metamic)


1. Flux trap size:

• Cells 3,6, 19, and 22: ~ 0.776 in.

• All Other CellS: ~ 1.076 in.

2. 10B loading in the BefcH-neutron absorbers: ~ 0.0372 g/cm2 (Boral) and ~ 0.0310 glcm2 (Metamic)

c. MPC-32

1. Fuel cell pitch: ~ 9.158 in.

2. 10B loading in the BefcH-neutron absorbers: ~ 0.0372 g/cm2 (Boral) and ~ 0.0310 glcm2 (Metamic)


a. Fuel spacers shall be sized to ensure that the active fuel region of intact fuel assemblies remain within the neutron poison region of the MPC basket with water in the MPC.

b. The B4C content in Metamic shall be < 33.0 wt%.


The minimum 10B for the neutron absorber shall meet the minimum requirements for each MPC model specified in Section 4.1.1 above.

4.2 Codes and Standards

The following provides information on the governing codes for the confinement boundary (important to Safety) design:

DIABLO CANYON ISFSI ISFSI TS for RAI Response -Markup

4.0-1

Design Features4.0

4.0 DESIGN FEATURES (continued)

4.3 Cask Handling/Cask Transfer Facility

4.3.1 Cask Transporter

A site-specific cask transporter is used to transport the TRANSFER CASK between thepower plant and the CASK TRANSFER FACILITY (CTF) and the SPENT FUELSTORAGE CASK (SFSC) between the CTF and ISFSI pad. The requirements for thecask transporter are as follows:

a. TRANSPORT OPERATIONS shall be conducted using the cask transporter.

b. The cask transporter fuel tank shall not contain > 50 gallons of diesel fuel at anytime.

c. The cask transporter shall be designed, fabricated, inspected, maintained, operated,and tested in accordance with the applicable guidelines of NUREG-0612.

d. The cask transporter lifting towers shall have redundant drop protection features.

e. Lifting of a SFSC, loaded TRANSFER CASK, or loaded MPC outside of structuresgoverned by 10 CFR 50 shall be performed with lifting devices that are designed,fabricated, inspected, maintained, operated and tested in accordance with theapplicable guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear PowerPlants."

4.3.2 Storage Capacity

The Diablo Canyon ISFSI can accommodate up to 4,400 spent fuel assemblies andother NONFUEL HARDWARE. The ISFSI storage capacity will accommodate up to140 SFSCs (138 plus 2 spare locations).

4.3.3 SFSC Load Handling Equipment

Lifting of a SFSC outside of structures governed by 10 CFR 50 shall be performed withload handling equipment that is designed, fabricated, inspected, maintained, operatedand tested in accordance with the applicable guidelines of NUREG-0612, "Control ofHeavy Loads at Nuclear Power Plants" as clarified by Section 4.3.4 below. The CTFrequirements in Section 4.3.4 below do not apply to heavy loads governed by theregulations of 10 CFR 50.

4.3.4 CTF Structure Requirements

a. PeFrmanent Load Handling .quipme• t Weldment and Reinforced Concrete

1. The weldment structure of the CTF shall be designed to comply with the stresslimits of ASME Code, Section III, Subsection NF, Class 3 for linear structures. Allcompression-loaded members shall satisfy the buckling criteria of ASMESection III, Subsection NF. The applicable loads, load combinations, andassociated service condition definitions are provided in Diablo Canyon ISFS5SAR Section 4.4.5.

2. The reinforced concrete structure of the CTF shall be designed in accordancewith ACI-349-1997, as clarified in Diablo Canyon ISFSI SAR Section 4.2.1.2.

(continued)

DIABLO CANYON ISFSIISFSI TS for RAI 4.0-3Response




Design Features 4.0

A site-specific cask transporter is used to transport the TRANSFER CASK between the power plant and the CASK TRANSFER FACILITY (CTF) and the SPENT FUEL STORAGE CASK (SFSC) between the CTF and ISFSI pad. The requirements for the cask transporter are as follows:


b. The cask transporter fuel tank shall not contain> 50 gallons of diesel fuel at any time.

c. The cask transporter shall be designed, fabricated, inspected, maintained, operated, and tested in accordance with the applicable guidelines of NUREG-0612.


e. Lifting of a SFSC, loaded TRANSFER CASK, or loaded MPC outside of structures governed by 10 CFR 50 shall be performed with lifting devices that are designed, fabricated, inspected, maintained, operated and tested in accordance with the applicable guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."


The Diablo Canyon ISFSI can accommodate up to 4,400 spent fuel assemblies and other NONFUEL HARDWARE. The ISFSI storage capacity will accommodate up to 140 SFSCs (138 plus 2 spare locations).


Lifting of a SFSC outside of structures governed by 10 CFR 50 shall be performed with load handling equipment that is designed, fabricated, inspected, maintained, operated and tested in accordance with the applicable guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants" as clarified by Section 4.3.4 below. The CTF requirements in Section 4.3.4 below do not apply to heavy loads governed by the regulations of 10 CFR 50.


a. Permanent Load Handling EquipmentWeldment and Reinforced Concrete

1. The weldment structure of the CTF shall be designed to comply with the stress limits of ASME Code, Section III, Subsection NF, Class 3 for linew structures. All compression-loaded members shall satisfy the buckling criteria of ASME Section III, Subsection NF. The applicable loads, load combinations, and associated service condition definitions are provided in Diablo Canyon ISFSI SAR Section 4.4.5.

2. The reinforced concrete structure of the CTF shall be designed in accordance with ACI-349-1997, as clarified in Diablo Canyon ISFSI SAR Section 4.2.1.2.


4.0-3

(continued)

Design Features4.0


b. Mobile Load Handling Equipment

Mobile load handling equipment used in lieu of permann• t load haRndingequipmentthe cask transporter, shall meet the guidelines of NUREG-0612, Section5.1, with the following clarifications:

1. Mobile lifting devices shall have a minimum safety factor of two over theallowable load table for the lifting device in accordance with the guidance ofNUREG-0612, Section 5.1.6(1)(a) and shall be capable of stopping and holdingthe load during a Design Basis Earthquake (DBE) event.

2. Mobile lifting devices shall conform to the requirements of ASME B30.5, "Mobileand Locomotive Cranes," in lieu of the requirements of ASME B30.2, "Overheadand Gantry Cranes."

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

4. Horizontal movements of the TRANSFER CASK and MPC using a mobile craneare prohibited.

DIABLO CANYON ISFSIISFSl TS for RAIResponse

4.0-4



Design Features 4.0

Mobile load handling equipment used in lieu of permanent load handling equipmentthe cask transporter,'shall meet the guidelines of NURE<3-0612, Section 5.1, with the following clarifications:

1. Mobile lifting devices 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 Basis Earthquake (DBE) event.

2. Mobile lifting devices shall conform to the requirements of ASME B30.5, "Mobile and Locomotive Cranes," in lieu of the requirements of ASME B30.2, "Overhead and Gantry Cranes."

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

4. Horizontal movements of the TRANSFER CASK and MPC using a mobile crane are prohibited.


4.0-4

Administrative Controls5.0

5.0 ADMINISTRATIVE CONTROLS (continued)

5.1.3 MPC and SFSC Loading, Unloading, and Preparation Program

This program shall be established and maintained to implement Diablo Canyon ISFSISAR Section 10.2 requirements for loading fuel and components into MPCs, unloadingfuel and components from MPCs, and preparing the MPCs for storage in the SFSCs.The requirements of the program for loading and preparing the MPC shall be completeprior to removing the MPC from the fuel handling building/auxiliary building. Theprogram provides for evaluation and control of the following requirements during theapplicable operation:

a. Verify that no transfer cask handling operations are allowed at environmentaltemperatures below -18 0C [0 'F].

b. Based on the drying process used and the heat load of the fuel involved, Vverify themaintenance of the required conditions water-in the annular gap between the loadedMPC and TRANSFER CASK during MPC moisture removal operations (loading) orMPC reflooding operations (unloading).

c. The water temperature of a water-filled or partially filled loaded MPC shall be shownby analysis to be less than boiling at all times.

d. Verify that the drying times and pressures assure that fuel cladding temperature limitis not violated and the MPC is adequately dry.

e. Verify that the inerting backfill pressure and purity assure adequate heat transfer andcorrosion control.

f. Verify that leak testing assures adequate MPC integrity and consistency with offsitedose analysis.

g. Verify surface dose rates on the TRANSFER CASK are adequate to assure properloading and consistency with the offsite dose analysis.

h. Verify surface dose rates on the SFSCs are adequate to assure proper storage andconsistency with the offsite dose analysis.

i. During MPC re-flooding, verify the helium exit temperature is such that waterquenching or flashing does not occur.

j. Verify that combustible gasses in the MPC are monitored and controlled to avoidcombustion during MPC lid-to-shell welding or MPC cutting activities.

k. Verify that fuel cladding is not exposed to an oxidizing environment by maintainingthe cladding in water or an inert atmosphere.

This program will control limits, surveillances, compensatory measures and appropriatecompletion times to assure the integrity of the fuel cladding at all times in preparation ofand during LOADING, UNLOADING or TRANSPORT OPERATIONS, as applicable.

(continued)

DIABLO CANYON ISFSIISFSl TS for RAI 5.0-2Response



Administrative Controls 5.0

This program shall be established and maintained to implement Diablo Canyon ISFSI SAR Section 10.2 requirements for loading fuel and components into MPCs, unloading fuel and components from MPCs, and preparing the MPCs for storage in the SFSCs. The requirements of the program for loading and preparing the MPC shall be complete prior to removing the MPC from the fuel handling building/auxiliary building. The program provides for evaluation and control of the following requirements during the applicable operation:

a. Verify that no transfer cask handling operations are allowed at environmental temperatures below -18°C [0 OF].

b. Based on the drying process used and the heat load of the fuel involved, ¥verify the maintenance of the required conditions wateF-in the annular gap between the loaded MPC and TRANSFER CASK during MPC moisture removal operations (loading) or MPC reflooding operations (unloading).

c. The water temperature of a water-filled or partially filled loaded MPC shall be shown by analysis to be less than boiling at all times.

d. Verify that the drying times and pressures assure that fuel cladding temperature limit is not violated and the MPC is adequately dry.

e. Verify that the inerting backfill pressure and purity assure adequate heat transfer and corrosion control.

f. Verify that leak testing assures adequate MPC integrity and consistency with offsite dose analysis.

g. Verify surface dose rates on the TRANSFER CASK are adequate to assure proper loading and consistency with the offsite dose analysis.

h. Verify surface dose rates on the SFSCs are adequate to assure proper storage and consistency with the offsite dose analysis.

i. During MPC re-flooding, verify the helium exit temperature is such that water quenching or flashing does not occur.

j. Verify that combustible gasses in the MPC are monitored and controlled to avoid combustion during MPC lid-to-shell welding or MPC cutting activities.

k. Verify that fuel cladding is not exposed to an oxidizing environment by maintaining the cladding in water or an inert atmosphere.

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 of and during LOADING, UNLOADING or TRANSPORT OPERATIONS, as applicable.


. ?

(continued)

5.0-2


Proposed Diablo Canyon ISFSI Technical Specification Changes (retyped),Includes LAR 08-01 As Modified by RAI Responses

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Proposed Diablo Canyon ISFSI Technical S.pecification Changes (retyped) Includes LAR 08-01 As Modified by RAI Responses

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APPENDIX

TECHNICAL SPECIFICATIONSFOR THE

DIABLO CANYON

INDEPENDENT SPENT FUEL STORAGEINSTALLATION

Docket No. 72-26


ISFSI TS for RAIResponse -

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RO

APPENDIX

TECHNICAL SPECIFICATIONS fOR THE

DIABLO CANYON

INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Docket No. 72-26


ISFSI TS for RAI RO Response -Markup

TABLE OF CONTENTS

1.0 U S E A N D A P P LIC A T IO N ............................................................................................ 1.1-11 .1 D e fi n itio n s .......................................................................................................... 1 .1 -11.2 Log ica l C o nne cto rs ............................................................................................ 1.2-11 .3 C o m p letio n T im e s .............................................................................................. 1 .3 -11 .4 F re q u e n c y .......................................................................................................... 1 .4 -1


3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY .......................... 3.0-13.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .......................................... 3.0-23.1 Spent Fuel Storage Cask (SFSC) Integrity ................................................................. 3.1-13.1.1 Multi-Purpose Canister (MPC)

3.1.2 Spent Fuel Storage Cask (SFSC) Heat Removal System ................................. 3.1-33 .1 .3 F ue l C o o l-D ow n .................................................................... I .............................. 3 .1-43 .1.4 Inte ntio na lly left bla n k ......................................................................................... 3 .1-53.2 Cask Criticality Control Program ........................................................................ 3.2-13.2.1 Dissolved Boron Concentration .......................................................................... 3.2-1

4 .0 D E S IG N F EA T U R E S .................................................................................................. 4 .0-14.1 Design Features Significant to Safety ................................................................ 4.0-14 .1 .1 C ritica lity C o ntro l ............................................................................................... 4 .0-14 .2 C odes and S tandards ........................................................................................ 4 .0-14.3 Cask Handling/Cask Transfer Facility ................................................................ 4.0-34 .3 .1 C ask T ra nsporte r ............................................................................................... 4 .0-34 .3 .2 S to rage C a pacity ................................................................................................ 4 .0-34.3.3 SFSC Load Handling Equipment. ......................... ...... 4.0-34.3.4 CTF Structure Requirements ............................................................................. 4.0-3

5.0 ADMINISTRATIVE CONTROLS ................................................................................. 5.0-15.1 Administrative Program ..................................... 5.0-15.1.1 Technical Specifications (TS) Bases Control Program ...................................... 5.0-15.1.2 Radioactive Effluent Control Program ................................................................ 5.0-15.1.3 MPC and SFSC Loading, Unloading, and Preparation Program ....................... 5.0-25.1.4 ISFS1 Operations Program ................................................................................. 5.0-35.1.5 Cask Transportation Evaluation Program .......................................................... 5.0-3

DIABLO CANYON ISFS1ISFSI TS for RAIResponse -

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TABLE OF CONTENTS

1.0 USE AND APPLICATION ............................................................................................ 1.1-1 1.1 Definitions .......................................................................................................... 1.1-1 1.2 Logical Connectors ............................................................................................ 1.2-1 1.3 Completion Times .............................................................................................. 1.3-1 1.4 Frequency .......................................................................................................... 1.4-1


3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILlTY' ........................... 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY .......................................... 3.0-2 3.1 Spent Fuel Storage Cask (SFSC) Integrity ................................................................. 3.1-1 3.1.1 Multi-Purpose Canister (MPC)

3.1.2 Spent Fuel Storage Cask (SFSC) Heat Removal System ................................. 3.1-3 3.1.3 Fuel Cool-Down ................................................................................................... 3.1-4 3.1.4 Intentionally left blank ......................................................................................... 3.1-5 3.2 Cask Criticality Control Program ........................................................................ 3.2-1 3.2.1 Dissolved Boron Concentration .......................................................................... 3.2-1

4.0 DESIGN FEATURES .................................................................................................. 4.0-1 4.1 Design Features Significant to Safety ............................................................... .4.0-1 4.1.1 Criticality Control .............................................................................................. .4.0-1 4.2 Codes and Standards ........................................................................................ 4.0-1 4.3 Cask Handling/Cask Transfer Facility ................................................................ 4.0-3 4.3.1 Cask Transporter ............................................................................................... 4.0-3 4.3.2 Storage Capacity ................................................................................................ 4.0-3 4.3.3 SFSC Load Handling Equipment ...................................................................... .4.0-3 4.3.4 CTF Structure Requirements ............................................................................. 4.0-3

5.0 ADMINISTRATIVE CONTROLS ................................................................................. 5.0-1 5.1 Administrative Program ............................................... : ....................................... 5.0-1 5.1.1 Technical Specifications (TS) Bases Control Program ...................................... 5.0-1 5.1.2 Radioactive Effluent Control Program ............................................................... ~5.0-1 5.1.3 MPC and SFSC Loading, Unloading, and Preparation Program ....................... 5.0-2 5.1.4 ISFSI Operations Program ................................................................................. 5.0-3 5.1.5 Cask Transportation Evaluation Program .......................................................... 5.0-3


MPC3.1.1

ACTIONS (continued)


C. MPC helium leak rate limit C.1 Perform an engineering 24 hoursfor vent and drain port evaluation to determinecover plate welds not met. the impact of increased

helium leak rate on heatremoval capability andoffsite dose.

AND

C.2 Develop and initiate 7 dayscorrective actionsnecessary to return theMPC to an analyzedcondition.

D. Required Actions and D.1 Remove all fuel 30 daysassociated Completion assemblies from theTimes not met. MPC.


SURVEILLANCE FREQUENCY

SR 3.1.1.1 Verify MPC cavity vacuum drying pressure is < 3 torr Once, prior tofor _> 30 min. TRANSPORT

OR OPERATIONS.

While recirculating helium through the MPC cavity,verify that the gas temperature exiting thedemoisturizer is < 21OF for > 30 min.

SR 3.1.1.2 Verify MPC helium backfill pressure is Ž 29.3 psig and Once, prior to•33.3 psig. TRANSPORT

OPERATIONS.

SR 3.1.1.3 Verify that the total helium leak rate through the MPC Once, prior tovent and drain port confinement welds meets the TRANSPORTleaktight criteria of ANSI N14.5-1977. OPERATIONS.

DIABLO CANYON ISFSIISFSI TS for RAIResponse -

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ACTIONS (continued)

MPC 3.1.1


C. MPC helium leak rate limit C.1 Perform an engineering 24 hours for vent and drain port evaluation to determine cover plate welds not met. the impact of increased

helium leak rate on heat removal capability and offsite dose.

AND

C.2 Develop and initiate 7 days corrective actions necessary to return the MPC to an analyzed condition.

D. Required Actions and D.1 Remove all fuel 30 days associated Completion assemblies from the Times not met. MPC.


SR 3.1.1.1

SR 3.1.1.2

SR 3.1.1.3

SURVEILLANCE

Verify MPC cavity vacuum drying pressure is :5: 3 torr for;::: 30 min.

OR

While recirculating helium through the MPC cavity, verify that the gas temperature exiting the demoisturizer is:5: 21°F for;::: 30 min.

Verify MPC helium backfill pressure is ;::: 29.3 psig and :5: 33.3 psig.

Verify that the total helium leak rate through the MPC vent and drain port confinement welds meets the leaktight criteria of ANSI N14.5-1977.

DIABLO CANYON ISFSI ISFSI TS for RAI Response - 3.1-2 Markup

FREQUENCY




SFSC Time Limitation in CTF3.1.4


3.1.4 Intentionally left blank


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3.1.4 Intentionally left blank


3.1-5

SFSC Time Limitation in CTF 3.1.4




LCO 3.2.1 The dissolved boron concentration in the water of the MPC cavity shall beas follows:

a. For all MPCs with one or more fuel assemblies having initialenrichment of < 4.1 wt% 235 U: _> 2000 ppmb.

b. For MPC24/24E/24EF with one or more fuel assemblies having initialenrichment of > 4.1 and < 5.0 wt% 235 U: _> 2000 ppmb.

c. For MPC 32 with one or more fuel assemblies having initialenrichment of 5.0 wt% 235 U: >_ 2600 ppmb.

---------------------------- NOTE -------------------------------For MPC-32, with maximum initial enrichments between 4.1 wt% and 5.0 wt% 235 U, theminimum dissolved boron concentration may be determined by linear interpolation between2000 ppmb at 4.1 wt% and 2600 ppmb at 5.0 wt% 235 U, based on the assembly with the highestinitial enrichment to be loaded.

APPLICABILITY: During LOADING OPERATIONS and UNLOADING OPERATIONS withwater and at least one fuel assembly in the MPC.

ACTIONSk I t'• "1" r'--

I•|1 I | I,,,-- ----------------------------------------------------------SeparateConditionentrisallowedforeP---------- ---Separate Condition entry is allowed for each MPC.


A. Dissolved boron A.1 Suspend LOADING Immediatelyconcentration not met. OPERATIONS or

UNLOADINGOPERATIONS

AND

A.2 Suspend positive Immediatelyreactivity additions

AND

A.3 Initiate action to restore Immediatelyboron concentration towithin limits


Markup3.2-1




LCO 3.2.1 The dissolved boron concentration in the water of the MPC cavity shall be as follows:

a. For all MPCs with one or more fuel assemblies having initial enrichment of ::; 4.1 wt% 235 U: ~ 2000 ppmb.

b. For MPC24/24E/24EF with one or more fuel assemblies having initial enrichment of > 4.1 and::; 5.0 wt% 235 U: ~ 2000 ppmb.

c. For MPC 32 with one or more fuel assemblies having initial enrichment of 5.0 wt% 235 U: ~ 2600 ppmb.

--------------------------------------------------------NOT E -------------------------------------------------------------For MPC-32, with maximum initial enrichments between 4.1 wt% and 5.0 wt% 235 U, the minimum dissolved boron concentration may be determined by linear interpolation between 2000 ppmb at 4.1 wt% and 2600 ppmb at 5.0 wt% 235 U, based on the assembly with the highest initial enrichment to be loaded.

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

ACTIONS --------------------------------------------------------NOT E -------------------------------------------------------------Separate Condition entry is allowed for each MPC.

CONDITION

A. Dissolved boron concentration not met.


A.1

AND

A.2

AND

A.3

REQUIRED ACTION

Suspend LOADING OPERATIONS or UNLOADING OPERATIONS

Suspend positive reactivity additions

Initiate action to restore boron concentration to within limits

3.2-1

COMPLETION TIME

Immediately

Immediately

Immediately



SURVEILLANCE FREQUENCY4

NOTE



Within 8 hoursprior tocommencingLOADINGOPERATIONS

AND


NOTE



Within 8 hoursprior tocommencingUNLOADINGOPERATIONS

AND



Markup3.2-2



SURVEILLANCE

NOTE



NOTE

This surveillance is only required to be performed if the MPC is submerged in water or if water is to be added to or recirculated th·rough the MPC.



3.2-2

FREQUENCY

Within 8 hours prior to commencing LOADING OPERATIONS

AND


Within 8 hours prior to commencing UNLOADING OPERATIONS

AND


Design Features4.0

4.0 DESIGN FEATURES




1. Flux trap size: _> 1.09 in.

2. 10B loading in the neutron absorbers: > 0.0267 g/cm 2 (Boral) and _ 0.0223 g/cm2

(Metamic)


1. Flux trap size:

0 Cells 3, 6, 19, and 22: > 0.776 in.

0 All Other Cells: > 1.076 in.

2. 10B loading in the neutron absorbers: Ž0.0372 g/cm2 (Boral) and Ž 0.0310g/cm 2 (Metamic)

c. MPC-32

1. Fuel cell pitch: Ž> 9.158 in.

2. 10B loading in the neutron absorbers: > 0.0372 g/cm2 (Boral) and > 0.0310g/cm 2 (Metamic)


a. Fuel spacers shall be sized to ensure that the active fuel region of intact fuelassemblies remain within the neutron poison region of the MPC basket with water inthe MPC.



The minimum 10B for the neutron absorber shall meet the minimum requirements for each MPCmodel specified in Section 4.1.1 above.4.2 Codes and Standards

The following provides information on the governing codes for the confinement boundary(important to Safety) design:

DIABLO CANYON ISFSIISFSI TS for RAIResponse - 4.0-1Markup

4.0 DESIGN FEATURES




1. Flux trap size: ~ 1.09 in.

Design Features 4.0

2. 10B loading in the neutron absorbers: ~ 0.0267 g/cm2 (Boral) and ~ 0.0223 g/cm2

(Metamic)


1. Flux trap size:

• Cells 3,6, 19, and 22: ~ 0.776 in.

• All Other Cells: ~ 1.076 in.

2. 10B loading in the neutron absorbers: ~ 0.0372 g/cm2 (Boral) and ~ 0.0310 g/cm2 (Metamic)

c. MPC-32

1. Fuel cell pitch: ~ 9.158 in.

2. 10B loading in the neutron absorbers: ~ 0.0372 g/cm2 (Boral) and ~ 0.0310 g/cm2 (Metamic)


a. Fuel spacers shall be sized to ensure that the active fuel region of intact fuel assemblies remain within the neutron poison region of the MPC basket with water in the MPC.



The minimum 1°B for the neutron absorber shall meet the minimum requirements for each MPC model specified in Section 4.1.1 above.4.2 Codes and Standards,

The following provides information on the governing codes for the confinement boundary (important to Safety) design:


4.0-1

Design Features4.0

4.0 DESIGN FEATURES (continued) ',



A site-specific cask transporter is used to transport the TRANSFER CASK between thepower plant and the CASK TRANSFER FACILITY (CTF) and the SPENT FUELSTORAGE CASK (SFSC) between the CTF and ISFSI pad. The requirements for thecask transporter are as follows:


b. The cask transporter fuel tank shall not contain > 50 gallons of diesel fuel at anytime.

c. The cask transporter shall be designed, fabricated, inspected, maintained, operated,and tested in accordance with the applicable guidelines of NUREG-0612.


e. Lifting of a SFSC, loaded TRANSFER CASK, or loaded MPC outside of structuresgoverned by 10 CFR 50 shall be performed with lifting devices that are designed,fabricated, inspected, maintained, operated and tested in accordance with theapplicable guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear PowerPlants."


The Diablo Canyon ISFSl can accommodate up to 4,400 spent fuel assemblies andother NONFUEL HARDWARE. The ISFSI storage capacity will accommodate up to140 SFSCs (138 plus 2 spare locations).


Lifting of a SFSC outside of structures governed by 10 CFR 50 shall be performed withload handling equipment that is designed, fabricated, inspected, maintained, operatedand tested in accordance with the applicable guidelines of NUREG-0612, "Control ofHeavy Loads at Nuclear Power Plants" as clarified by Section 4.3.4 below. The CTFrequirements in Section 4.3.4 below do not apply to heavy loads governed by theregulations of 10 CFR 50.


a. Weldment and Reinforced Concrete

1. The weldment structure of the CTF shall be designed to comply with the stresslimits of ASME Code, Section III, Subsection NF, Class 3 for linear structures. Allcompression-loaded members shall satisfy the buckling criteria of ASMESection III, Subsection NF. The applicable loads, load combinations, andassociated service condition definitions are provided in Diablo Canyon ISFSlSAR Section 4.4.5.

2. The reinforced concrete structure of the CTF shall be designed in accordancewith ACI-349-1997, as clarified in Diablo Canyon ISFSl SAR Section 4.2.1.2.

(continued)

DIABLO CANYON ISFSlISFSI TS for RAIResponse - 4.0-3Markup




Design Features 4.0

A site-specific cask transporter is used to transport the TRANSFER CASK between the power plant and the CASK TRANSFER FACILITY (CTF) and the SPENT FUEL STORAGE CASK (SFSC) between the CTF and ISFSI pad. The requirements for the cask transporter are as follows:


b. The cask transporter fuel tank shall not contain> 50 gallons of diesel fuel at any time.

c. The cask transporter shall be designed, fabricated, inspected, maintained, operated, and tested in accordance with the applicable guidelines of NUREG-0612.


e. Lifting of a SFSC, loaded TRANSFER CASK, or loaded MPC outside of structures governed by 10 CFR 50 shall be performed with lifting devices that are designed, fabricated, inspected, maintained, operated and tested in accordance with the applicable guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants."


The Diablo Canyon ISFSI can accommodate up to 4,400 spent fuel assemblies and other NONFUEL HARDWARE. The ISFSI storage capacity will accommodate up to 140 SFSCs (138 plus 2 spare locations).


Lifting of a SFSC outside of structures governed by 10 CFR 50 shall be performed with load handling equipment that is designed, fabricated, inspected, maintained, operated and tested in accordance with the applicable guidelines of NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants" as clarified by Section 4.3.4 below. The CTF requirements in Section 4.3.4 below do not apply to heavy loads governed by the regulations of 10 CFR 50.


a. Weldment and Reinforced Concrete

1. The weldment structure of the CTF shall be designed to comply with the stress limits of ASME Code, Section III, Subsection NF, Class 3 for linear structures. All compression-loaded members shall satisfy the buckling criteria of ASME Section III, Subsection NF. The applicable loads, load combinations, and associated service condition definitions are provided in Diablo Canyon ISFSI SAR Section 4.4.5.

2. The reinforced concrete structure of the CTF shall be designed in accordance with ACI-349-1997, as clarified in Diablo Canyon ISFSI SAR Section 4.2.1.2.

(continued)


Design Features4.0



Mobile load handling equipment used in lieu of the cask transporter, shall meet theguidelines of NUREG-0612, -Section 5.1, with the following clarifications:

1. Mobile lifting devices shall have a minimum safety factor of two over theallowable load table for the lifting device in accordance with the guidance ofNUREG-0612, Section 5.1.6(1)(a) and shall be capable of stopping and holdingthe load during a Design Basis Earthquake (DBE) event.

2. Mobile lifting devices shall conform to the requirements of ASME B30.5, "Mobileand Locomotive Cranes," in lieu of the requirements of ASME B30.2, "Overheadand Gantry Cranes."

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

4. Horizontal movements of the TRANSFER CASK and MPC using a mobile craneare prohibited.


Markup4.0-4

Design Features 4.0



Mobile load handling equipment used in lieu of the cask transporter, shall meet the guidelines of NUREG-0612, Section 5.1, with the following clarifications:

1. Mobile lifting devices 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 Basis Earthquake (DBE) event.

2. Mobile lifting devices shall conform to the requirements of ASME B30.5, "Mobile and Locomotive Cranes," in lieu of the requirements of ASME B30.2, "Overhead and Gantry Cranes."

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

4. Horizontal movements of the TRANSFER CASK and MPC using a mobile crane are prohibited.


Administrative Controls5.0



This program shall be established and maintained to implement Diablo Canyon ISFSISAR Section 10.2 requirements for loading fuel and components into MPCs, unloadingfuel and components from MPCs, and preparing the MPCs for storage in the SFSCs.The requirements of the program for loading and preparing the MPC shall be completeprior to removing the MPC from the fuel handling building/auxiliary building. Theprogram provides for evaluation and control of the following requirements during theapplicable operation:

a. Verify that no transfer cask handling operations are allowed at environmentaltemperatures below -18 0C [0 0F].

b. Based on the drying process used and the heat load of the fuel involved, verify themaintenance of the required conditions in the annular gap between the loaded MPCand TRANSFER CASK during MPC moisture removal operations (loading) or MPCreflooding operations (unloading).

c. The water temperature of a water-filled or partially filled loaded MPC shall be shownby analysis to be less than boiling at all times.

d. Verify that the drying times and pressures assure that fuel cladding temperature limitis not violated and the MPC is adequately dry.

e. Verify that the inerting backfill pressure and purity assure adequate heat transfer andcorrosion control.

f. Verify that leak testing assures adequate MPC integrity and consistency with offsitedose analysis.

g. Verify surface dose rates on the TRANSFER CASK are adequate to assure properloading and consistency with the offsite dose analysis.

h. Verify surface dose rates on the SFSCs are adequate to assure proper storage andconsistency with the offsite dose analysis. -

i. During MPC re-flooding, verify the helium exit temperature is such that waterquenching or flashing does not occur.

j. Verify that combustible gasses in the MPC are monitored and controlled to avoidcombustion during MPC lid-to-shell welding or MPC cutting activities.

k. Verify that fuel cladding is not exposed to an oxidizing environment by maintainingthe cladding in water or an inert atmosphere.

This program will control limits, surveillances, compensatory measures and appropriatecompletion times to assure the integrity of the fuel cladding at all times in preparation ofand during LOADING, UNLOADING or TRANSPORT OPERATIONS, as applicable.

(continued)

DIABLO CANYON ISFSIISFS1 TS for RAIResponse - 5.0-2Markup



Administrative Controls 5.0

This program shall be established and maintained to implement Diablo Canyon ISFSI SAR Section 10.2 requirements for loading fuel and components into MPCs, unloading fuel and components from MPCs, and preparing the MPCs for storage in. the SFSCs. The requirements of the program for loading and preparing the MPC shall be complete prior to removing the MPC from the fuel handling building/auxiliary building. The program provides for evaluation and control of the following requirements during the applicable operation:

a. Verify that no transfer cask handling operations are allowed at environmental temperatures below -18°C [0 OF].

b. Based on the drying process used and the heat ioad of the fuel involved, verify the maintenance of the required conditions in the annular gap between the loaded MPC and TRANSFER CASK during MPC moisture removal operations (loading) or MPC reflooding operations (unloading).

c. The water temperature of a water-filled or partially filled loaded MPC shall be shown by analysis to be less than boiling at all times.

d. Verify that the drying times and pressures assure that fuel cladding temperature limit is not violated and the MPC is adequately dry.

e. Verify that the inerting backfill pressure and purity assure adequate heat transfer and corrosion control.

f. Verify that leak testing assures adequate MPC integrity and consistency with offsite dose analysis.

g. Verify surface dose rates on the TRANSFER CASK are adequate to assure proper loading and consistency with the offsite dose analysis.

h. Verify surface dose rates on the SFSCs are adequate to assure proper storage and consistency with the offsite dose analysis. .,

i. During MPC re-flooding, verify the helium exit temperature is such that water quenching or flashing does not occur.

j. Verify that combustible gasses in the MPC are monitored and controlled to avoid combustion during MPC lid-to-shell welding or MPC cutting activities.

k. Verify that fuel cladding is not exposed to an oxidizing environment by maintaining the cladding in water or an inert atmosphere.

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 of and during LOADING, UNLOADING or TRANSPORT OPERATIONS, as applicable.


(continqed)

5.0-2


Holtec AffidavitHoltec Affidavit


M E N E MHoltec Center, 555 Lincoln Drive West, Marlton, NJ 08053H O LTEC Telephone (856) 797-0900INTERNATIONAL Fax (856) 797-0909

U.S. Nuclear Regulatory CommissionATTN: Document Control Desk

AFFIDAVIT PURSUANT TO 10 CFR 2.390

I, Evan Rosenbaum, depose and state as follows:

(1) I am the Holtec International Adjunct Project Manager for the Diablo CanyonIndependent Spent Fuel Storage Installation Project and have reviewed theinformation described in paragraph (2) which is sought to be withheld, and amauthorized to apply for its withholding.

(2) The information sought to be withheld is Revision 6 of Holtec Report HI-2053376 and the accompanying CD-ROM with computer data files therefrom,which contain Holtec Proprietary information and are appropriately marked assuch.

(3) In making this application for withholding of proprietary information of which itis the owner, Holtec International relies upon the exemption from disclosure setforth in the Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4) andthe Trade Secrets Act, 18 USC Sec. 1905, and NRC regulations 10CFR Part9.17(a)(4), 2.390(a)(4), and 2.390(b)(1) for "trade secrets and commercial orfinancial information obtained from a person and privileged or confidential"(Exemption 4). The material for which exemption from disclosure is here soughtis all "confidential commercial information", and some portions also qualifyunder the narrower definition of "trade secret", within the meanings assigned tothose terms for purposes of FOIA Exemption 4 in, respectively, Critical MassEnergy Project v. Nuclear Regulatory Commission, 975F2d871 (DC Cir. 1992),and Public Citizen Health Research Group v. FDA, 704F2dl280 (DC Cir.1983).

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HOLTEC INTERNATIONAL

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk

Holtec Center, 555 Lincoln Drive West, Marlton, NJ 08053

Telephone (856) 797-0900

Fax (856) 797-0909


I, Evan Rosenbaum, depose and state as follows:

(1) I am the Holtec International Adjunct Project Manager for the Diablo Canyon Independent Spent Fuel Storage Installation Project and have reviewed the information described in paragraph (2) which is sought to be withheld, and am authorized to apply for its withholding.

(2) The information sought to be withheld is Revision 6 of Holtec Report HI-2053376 and the accompanying CD-ROM with computer data files therefrom, which contain Holtec Proprietary information and are appropriately marked as such.

(3) In making this application for withholding of proprietary information of which it is the owner, Holtec International relies 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 10CFR Part 9. 17(a)(4), 2.390(a)(4), and 2.390(b)(l) for "trade secrets and commercial or fmancial information obtained from a person and privileged or confidential" (Exemption 4). The material for which exemption from disclosure is here sought is all "confidential commercial information", and some portions also qualify under the narrower definition of "trade secret", within the meanings assigned to those terms for purposes ofFOIA Exemption 4 in, respectively,Critical Mass EnergyProjectv. Nuclear Regulatory Commission, 975F2d871 (DC Cir.1992), and Public Citizen Health Research Group v. FDA, 704F2d1280 (DC Cir. 1983).

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M E M M INHoltec Center, 555 Lincoln Drive West, Marlton, NJ 08053

H O LTEC Telephone (856) 797-0900INTERNATIONAL Fax (856) 797-0909

U.S. Nuclear Regulatory CommissionAT'TN: Document Control Desk


(4) Some examples of categories of information which fit into the definition ofproprietary information are:

a. Information that discloses a process, method, or apparatus, includingsupporting data and analyses, where prevention of its use by Holtec'scompetitors without license from Holtec International constitutes acompetitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditureof resources or improve his competitive position in the design,manufacture, shipment, installation, assurance of quality, or licensing of asimilar product.

c. Information which reveals cost or price information, production,capacities, budget levels, or commercial strategies of Holtec International,its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future HoltecInternational customer-funded development plans and programs ofpotential commercial value to Holtec International;

e. Information which discloses patentable subject matter for which it may bedesirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for thereasons set forth in paragraphs 4.a and 4.b, above.

(5) The information sought to be withheld is being submitted to the NRC inconfidence. The information (including that compiled from many sources) is of

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Telephone (856) 797-0900

Fax (856) 797-0909


(4) Some examples of categories of information which 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 Holtec's competitors without license from. Holtec International constitutes a competitive economic advantage over other companies;

b. Information which, ifused by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product.

c. Information which reveals cost or price information, production, capacities, budget levels, or commercial strategies ofHoltec International, its customers, or its suppliers;

d. Information which reveals aspects of past, present, or future Holtec International customer-funded development plans and programs of potential commercial value to Holtec International;

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

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

(5) The information sought to be withheld is being submitted to the NRC in confidence. The information (including that compiled from many sources) is of

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M E E S EHoltec Center, 555 Lincoln Drive West, Marlton, NJ 08053

H O LT E C Telephone (856) 797-0900INTERNATIONAL Fax (856) 797-0909



a sort customarily held in confidence by Holtec International, and is in fact soheld. The information sought to be withheld has, to the best of my knowledgeand belief, consistently been held in confidence by Holtec International. Nopublic disclosure has been made, and it is not available in public sources. Alldisclosures to third parties, including any required transmittals to the NRC, havebeen made, or must be made, pursuant to regulatory provisions or proprietaryagreements which provide for maintenance of the information in confidence. Itsinitial designation as proprietary information, and the subsequent steps taken toprevent its unauthorized disclosure, are as set forth in paragraphs (6) and (7)following.

(6) Initial approval of proprietary treatment of a document is made by the managerof the originating component, the person most likely to be acquainted with thevalue and sensitivity of the information in relation to industry knowledge.Access to such documents within Holtec International is limited on a "need toknow" basis.

(7) The procedure for approval of external release of such a document typicallyrequires review by the staff manager, project manager, principal scientist orother equivalent authority, by the manager of the cognizant marketing function(or his designee), and by the Legal Operation, for technical content, competitiveeffect, and determination of the accuracy of the proprietary designation.Disclosures outside Holtec International are limited to regulatory bodies,customers, and potential customers, and their agents, suppliers, and licensees,and others with a legitimate need for the information, and then only inaccordance with appropriate regulatory provisions or proprietary agreements.

(8) The information classified as proprietary was developed and compiled by HolteceInternational at a significant cost to Holtec International. This information isclassified as proprietary because it contains detailed descriptions of analytical

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Telephone (856) 797-0900

Fax (856) 797-0909


a sort customarily held in confidenc'e by Holtec International, and is in fact so held. The information sought to be withheld has, to the best of my knowledge and belief, consistently been held in confidence by Holtec International. 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 paragraphs (6) and (7) following.

(6) Initial approval of proprietary treatment of a document is made by the manager of the originating component, the person most likely to be acquainted with the value and sensitivity of the information in relation to industry knowledge. Access to such documents within Holtec International is limited on a "need to know" basis.

(7) The procedure for approval of external release of such a document typically requires review by the staff manager, project manager, principal scientist or other equivalent authority, by the manager ofthe cognizant marketing function (or his designee), and by the Legal Operation, for technical content, competitive effect, and determination of the accuracy of the proprietary designation. Disclosures outside Holtec. International are limited to regulatory bodies, customers, and potential customers, and their agents, suppliers, and licensees, and others with a legitimate need for the information,. and then only in accordance with appropriate regulatory provisions or proprietary agreements.

(8) The information classified as proprietary was developed and compiled by Holtec' International at a significant cost to Holtec International. This information is classified as proprietary because it contains detailed descriptions of analytical

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MN M NHoltec Center, 555 Lincoln Drive West, Marlton, NJ 08053

H O LTEC Telephone (856) 797-0900INTERNATIONAL Fax (856) 797-0909



approaches and methodologies not available elsewhere. This information wouldprovide other parties, including competitors, with information from HoltecInternational's technical database and the results of evaluations performed byHoltec International. A substantial effort has been expended by HoltecInternational to develop this information. Release of this information wouldimprove a competitor's position because it would enable Holtec's competitor tocopy our technology and offer it for sale in competition with our company,causing us financial injury.

(9) Public disclosure of the information sought to be withheld is likely to causesubstantial harm to Holtec International's competitive position and foreclose orreduce the availability of profit-making opportunities. The information is part ofHoltec International's comprehensive spent fuel storage technology base, and itscommercial value extends beyond the original development cost. The value ofthe technology base goes beyond the extensive physical database and analyticalmethodology, and includes development of the expertise to determine and applythe appropriate evaluation process.

The research, development, engineering, and analytical costs comprise asubstantial investment of time and money by Holtec International.

The precise value of the expertise to devise an evaluation process and apply thecorrect analytical methodology is difficult to quantify, but it clearly issubstantial.

Holtec International's competitive advantage will be lost if its competitors areable to use the results of the Holtec International experience to normalize orverify their own process or if they are able to claim an equivalent understandingby demonstrating that they can arrive at the same or similar conclusions.

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Telephone (856) 797-0900

Fax (856) 797-0909


approaches and methodologies not available elsewhere. This information would provide other parties, including competitors, with information from Holtec International's technical database and the results of evaluations perfol111ed by Holtec International. A substantial effort has been expended by Holtec International to develop this information. Release of this information would improve a competitor's position because it would enable Holtec's competitor to copy our technology and offer it for sale in competition with our company, causing us financial injury.

(9) Public disclosure' of the information sought to be withheld is likely to cause substantial harm to Holtec International's competitive position and foreclose or reduce the availability of profit-making opportunities. The information is part of Holtec International's comprehensive spent fuel storage technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology, and includes development of the expertise to determine and apply the appropriate evaluation process.

The research, development, engineering, and analytical costs comprise a substantial Investment of time and money by Holtec International.

The precise value ofthe expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial. .

Holtec International's competitive advantage will be lost if its competitors are able to use the results of the Holtec International experience to normalize or verify their own process or if they are able to claim an equivalent understanding by demonstrating that they can arrive at the same or similar conclusions.

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NEESEHOLTECINTERNATIONAL


Telephone (856) 797-0900

Fax (856) 797-0909



The value of this information to Holtec International would be lost if theinformation were disclosed to the public. Making such information available tocompetitors without their having been required to undertake a similarexpenditure of resources would unfairly provide competitors with a windfall,and deprive Holtec International of the opportunity to exercise its competitiveadvantage to seek an adequate return on its large investment in developing thesevery valuable analytical tools.

Executed at Marlton, New Jersey, this 12 th day of August, 2009.

Evan RosenbaumHoltec International

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I .




Telephone (856) 797-0900

Fax (856) 797-0909


The value of this infonnation to Holtec International would be lost if the infonnation were disclosed to the public. Making such infonnation available to competitors without their having been required to undertake a similar expenditure of resources would unfairly provide competitors with a windfall, and deprive Holtec International of the opportunity to exercise its competitive advantage to seek an adequate return on its large investment in developing these very valuable analytical tools.

Executed at Marlton, New Jersey, this lih day of August, 2009 .

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. f}--v''V ~~ Evan Rosenbaum

Holtec International

Gas s-and and -4 · A member of the STARS (Strategic Teaming and Resource Sharing) Alliance...

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