TECHNICAL SPECIFICATIONS FOR TROJAN INDEPENDENT … · TROJAN STORAGE The TROJAN STORAGE SYSTEM is defined as the TranStor™ SYSTEM CONCRETE CASK containing a Holtec MPC-24E or MPC-24EF

TECHNICAL SPECIFICATIONS

FOR

TROJAN

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

Amendment 7 |

TABLE OF CONTENTS

Trojan ISFSI Amendment 4 |i

1.0 USE AND APPLICATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1-1

1.1 Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.1-11.2 Logical Connectors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.2-11.3 Completion Times . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.3-11.4 Frequency . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.4-1

2.0 APPROVED CONTENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-1

2.1 Approved Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-12.1.1 Fuel Stored at the ISFSI . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-12.1.2 Fuel Storage Configuration Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.1-1

2.2 Approved Contents Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2-12.2.1 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits . . . . . . . . . . . 2.2-1

Table 2-1 Spent Fuel Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2-2Table 2-2 Fuel Assembly Inserts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.2-3

3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY . . . . . . . . . 3.0-13.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY . . . . . . . . . . . . . . . . . 3.0-2

3.1 DELETED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.1-1 |3.2 TRANSFER CASK Integrity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.2-1

3.2.1 TRANSFER CASK Ambient Air Temperature Limit . . . . . . . . . . . . . . . . 3.2-13.3 AIR PADS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.3-1

3.3.1 AIR PAD Limits . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3.3-1

4.0 DESIGN FEATURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1-1

4.1 Site Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.1-14.2 Storage Features . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-1

4.2.1 Storage System . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-14.2.2 Storage Capacity . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-14.2.2a Design Features Important for Criticality Control . . . . . . . . . . . . . . . . . . . 4.2-14.2.3 Storage Pad and TRANSFER STATION . . . . . . . . . . . . . . . . . . . . . . . . . . 4.2-1

4.3 Codes and Standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3-14.3.1 MPC . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3-14.3.2 NOT USED . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4.3-1

TABLE OF CONTENTS

5.0 ADMINISTRATIVE CONTROLS .................................................................................. 5.1-1

5 .1 Responsibility .................................................................................................................. 5 .1-1 5 .2 Organization ..................................................................................................................... 5 .2-1 5 .3 ISFSI Staff Qualifications ................................................................................................ 5 .3-1

5.4 Procedures ........................................................................................................................ 5.4-1

5.5 Programs .......................................................................................................................... 5.5-1

5.5.1 Technical Specifications (TS) Bases Control Program ....................................... 5.5-1

5.5.2 Radioactive Effluent Control Program ............................................................... 5.5-1

5.5.3 CONCRETE CASK Thermal Monitoring Program ........................................... 5.5-2 5.5.4 Radiation Protection Program ............................................................................. 5.5-3

5.5.5 Aging Management Program ............................................................................... 5.5-3

5.6 High Radiation Areas ....................................................................................................... 5.6-1

Trojan ISFSI 11 Amendment 7 |

Definitions1.1

1.0 USE AND APPLICATION

1.1 Definitions

Trojan ISFSI Amendment 4 |1.1-1

-------------------------------------------------------NOTE-------------------------------------------------------The defined terms of this section appear in capitalized type and are applicable throughout theseTrojan Independent Spent Fuel Storage Installation (ISFSI)Technical Specifications and Bases. ----------------------------------------------------------------------------------------------------------------------Term Definition

ACTIONS ACTIONS shall be that part of a Specification that prescribesRequired Actions to be taken under designated Conditions withinspecified Completion Times.

AIR PADS The AIR PADS are commercially available lifting devices that are used to move the CONCRETE CASKS. The AIR PADS consist of four air bladders that are inserted into the CONCRETE CASK air inlets and are inflated to lift a CONCRETE CASK up to fourinches off the surface which then allows it to be moved.

CONCRETE CASK The CONCRETE CASK is the structure in which a MULTI-PURPOSE CANISTER (MPC) is stored.

DAMAGED FUEL DAMAGED FUEL ASSEMBLIES are fuel assemblies which can ASSEMBLY be handled by normal means: (1) with known or suspected

cladding defects greater than pinhole leaks or hairline cracks; or (2)with missing fuel rods that are not replaced with dummy fuel rods. Fuel assemblies which cannot be handled by normal means due tofuel cladding damage are considered to be FUEL DEBRIS. DAMAGED FUEL ASSEMBLIES are stored in FAILED FUELCANS or DAMAGED FUEL CONTAINERS.

DAMAGED FUEL DAMAGED FUEL CONTAINERS are specially designed CONTAINER enclosures for DAMAGED FUEL ASSEMBLIES and FUEL

DEBRIS. DAMAGED FUEL CONTAINERS are stored in an MPC.

FAILED FUEL CAN FAILED FUEL CANS are specially designed enclosures for DAMAGED FUEL ASSEMBLIES, FUEL DEBRIS, and

Definitions1.1


1.1 Definitions


PROCESS CAN CAPSULES. FAILED FUEL CANS are storedin an MPC.

FUEL DEBRIS FUEL DEBRIS is fuel with known or suspected defects, such as ruptured fuel rods, severed rods, or loose fuel pellets and fuel pelletfragments. FUEL DEBRIS includes fuel assembly metal fragments such as portions of fuel rods and grid assemblies. Fuel assemblies which cannot be handled by normal means due to fuel cladding damage are considered to be FUEL DEBRIS. FUEL DEBRIS is stored in PROCESS CAN CAPSULES, which arestored in FAILED FUEL CANS, or directly in FAILED FUELCANS or DAMAGED FUEL CONTAINERS depending upon theextent of damage.

INTACT FUEL INTACT FUEL ASSEMBLIES are fuel assemblies which can beASSEMBLY handled by normal means: (1) without known or suspected

cladding defects greater than pinhole leaks or hairline cracks; or (2)with missing fuel rods which are replaced by dummy rods. Fuel assemblies from which fuel rods are missing shall not be classifiedas INTACT FUEL ASSEMBLIES unless dummy fuel rods areused to displace an amount of water equal to or greater than thatdisplaced by the original fuel rod(s).

|MULTI-PURPOSE The MPC is the stainless steel welded container that is designed forCANISTER (MPC) storage and transportation of INTACT FUEL ASSEMBLIES and

FAILED FUEL CANS and DAMAGED FUEL CONTAINERSthat contain DAMAGED FUEL ASSEMBLIES and FUELDEBRIS.

PROCESS CAN PROCESS CAN CAPSULES are sealed, inerted canisters CAPSULE containing FUEL DEBRIS. PROCESS CAN CAPSULES are

stored in FAILED FUEL CANS.

Definitions1.1


1.1 Definitions


STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that areperformed at the ISFSI while a CONCRETE CASK containing anMPC with INTACT FUEL ASSEMBLIES, DAMAGED FUELASSEMBLIES, or FUEL DEBRIS, is located within the ISFSIperimeter including movement of and use of the TRANSFERCASK or a Transport Cask.

TRANSFER CASK The TRANSFER CASK is used to support an MPC at the |TRANSFER STATION.

TRANSFER STATION The TRANSFER STATION is a steel structure, located on theTransfer Pad, to the west of the Storage Pad, designed to safelyfacilitate loading the MPC into a Transport Cask.

|TROJAN STORAGE The TROJAN STORAGE SYSTEM is defined as the TranStor™

SYSTEM CONCRETE CASK containing a Holtec MPC-24E or MPC-24EF. The Holtec MPC-24E and MPC-24EF used at Trojan are modifiedto fit within the TranStor™ CONCRETE CASKS, as described inthe Trojan ISFSI Safety Analysis Report.

|

Definitions1.1


1.1 Definitions


UNLOADING UNLOADING OPERATIONS include activities performed OPERATIONS on an MPC to be unloaded of the contained INTACT FUEL

ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, or FUELDEBRIS. UNLOADING OPERATIONS begin when actions havecommenced to relocate the MPC to the Cask Loading Pit and endwhen the last INTACT FUEL ASSEMBLY, DAMAGED FUELASSEMBLY, or FUEL DEBRIS has been removed from the MPC. |

Logical Connectors1.2



1.2 Logical Connectors

PURPOSE The purpose of this section is to explain the meaning of logical connectors.

Logical connectors are used in Technical Specifications (TS) todiscriminate between, and yet connect, discrete Conditions, RequiredActions, Completion Times, Surveillances, and Frequencies. The onlylogical connectors that may appear in TS are AND and OR. The physicalarrangement of these connectors constitutes logical conventions withspecific meanings.

BACKGROUND Several levels of logic may be used to state Required Actions. Theselevels are identified by the placement (or nesting) of the logical connectorsand by the number assigned to each Required Action. The first level oflogic is identified by the first digit of the number assigned to a RequiredAction and the placement of the logical connector in the first level ofnesting (i.e., left justified with the number of the Required Action). Thesuccessive levels of logic are identified by additional digits of theRequired Action number and by successive indentations of the logicalconnectors.

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

EXAMPLES The following example illustrates the use of logical connectors. The only |logical connector remaining in these TS is “AND.” |





EXAMPLES EXAMPLE 1.2-1 (continued)

ACTIONS

CONDITION REQUIRED ACTION COMPLETION TIME

A. LCO not met A.1 Verify....

AND

A.2 Restore...

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






ACTIONS


A. LCO not met A.1 Stop.....

OR

A.2.1 Verify...

AND

A.2.2.1 Reduce...

OR

A.2.2.2 Perform...

OR

A.3 Remove...

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

Completion Times1.3



1.3 Completion Times

PURPOSE The purpose of this section is to establish the Completion Timeconvention and to provide guidance for its use.

BACKGROUND Limiting Conditions for Operations (LCOs) specify the lowestfunctional capability or performance levels of equipment requiredfor safe operation of the facility. The ACTIONS associated withan LCO state Conditions that typically describe the ways in whichthe requirements of the LCO can fail to be met. Specified witheach stated Condition are Required Action(s) and CompletionTime(s).

DESCRIPTION The Completion Time is the amount of time allowed forcompleting a Required Action. It is referenced to the time ofdiscovery of a situation (e.g., equipment or variable not withinlimits) that requires entering an ACTIONS Condition unlessotherwise specified, providing the facility is in a specifiedcondition stated in the Applicability of the LCO. Required Actionsmust be completed prior to the expiration of the specifiedCompletion Time. An ACTIONS Condition remains in effect andthe Required Actions apply until the Condition no longer exists orthe facility is not within the LCO Applicability.

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

|EXAMPLES The following example illustrates the use of Completion Times. |

The only Completion Time remaining in the LCOs is |“Immediately.” |

Completion Times1.3




EXAMPLES EXAMPLE 1.3-1 | (continued) |

ACTIONS |||

|CONDITION |REQUIRED ACTION |COMPLETION |TIME |

||A. LCO not met. |

|

|A.1 Restore compliance | with LCO. |

|

|Immediately |

|When “Immediately” is used as a Completion Time, the Required Action |should be pursued without delay and in a controlled manner. |

Completion Times1.3





ACTIONS

CONDITION REQUIRED ACTION COMPLETIONTIME

A. One systemnot withinlimits.

A.1 Restore systemto within limit.

7 days

B. RequiredAction andassociatedCompletionTime not met.

B.1 Complete actionB.1

AND

B.2 Complete actionB.2

12 hours

36 hours

When a system is determined to not meet the LCO, Condition A isentered. If the system is not restored within 7 days, Condition B is alsoentered and the Completion Time clocks for Required Actions B.1 and B.2start. If the system is restored after Condition B is entered, Conditions Aand B are exited, and therefore, the Required Actions of Condition B maybe terminated.

Completion Times1.3





ACTIONS

-------------------------------------NOTE---------------------------------------------Separate Condition entry is allowed for each component.

------------------------------------------------------------------------------------------

CONDITION REQUIRED ACTION COMPLETIONTIME

A. LCO not met. A.1 Restore compliancewith LCO.

4 hours

B. RequiredAction andassociatedCompletionTime not met.

B.1 Complete action B.1

AND

B.2 Complete action B.2

6 hours

12 hours

The Note above the ACTIONS Table is a method of modifying how theCompletion Time is tracked. If this method of modifying how theCompletion Time is tracked was applicable only to a specific Condition,the Note would appear in that Condition rather than at the top of theACTIONS Table.

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

Completion Times1.3




not meet the LCO, Condition A is entered for each component andseparate Completion Times start and are tracked for each component.

IMMEDIATE When "Immediately" is used as a Completion Time, theCOMPLETION Required Action should be pursued without delay and in a controlledTIME manner.

Frequency1.4



1.4 Frequency

PURPOSE The purpose of this section is to define the proper use and application ofFrequency requirements.

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

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

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

Frequency1.4



1.4 Frequency

EXAMPLES The following examples illustrate the various ways that Frequencies arespecified.

EXAMPLE 1.4-1

SURVEILLANCE REQUIREMENTS

SURVEILLANCE FREQUENCY

Verify ambient air temperature within limit. |Every 4 hours |

Example 1.4-1 contains the type of SR most often encountered in the TS. The Frequency specifies an interval (every 4 hours) during which the |associated Surveillance must be performed at least one time. Performanceof the Surveillance initiates the subsequent interval. Although theFrequency is stated as every 4 hours, an extension of the time interval to |1.25 times the stated Frequency is allowed by SR 3.0.2 for operationalflexibility. The measurement of this interval continues at all times, evenwhen the SR is not required to be met per SR 3.0.1 (such as when avariable is outside specified limits, or the facility is outside theApplicability of the LCO). If the interval specified by SR 3.0.2 isexceeded while the facility is in a condition specified in the Applicabilityof the LCO, the LCO is not met in accordance with SR 3.0.1.

If the interval as specified by SR 3.0.2 is exceeded while the facility is notin a condition specified in the Applicability of the LCO for whichperformance of the SR is required, the Surveillance must be performedwithin the Frequency requirements of SR 3.0.2 prior to entry into thespecified condition. Failure to do so would result in a violation of SR3.0.4.

Frequency1.4



1.4 Frequency


SURVEILLANCE REQUIREMENTS |


Verify ambient air temperature is within |limits.

Once within 1 hour prior to |starting activity

AND

4 hours thereafter |

Example 1.4-2 has two Frequencies. The first is a one time performanceFrequency, and the second is of the type shown in Example 1.4-1. Thelogical connector “AND” indicates that both Frequency requirements mustbe met. Each time the example activity is to be performed, theSurveillance must be performed within 1 hour prior to starting the activity. |

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

“Thereafter” indicates future performances must be established per SR3.0.2, but only after a specified condition is first met (i.e., the “once”performance in this example). If the specified activity is canceled or notperformed, the measurement of both intervals stops. New intervals startupon preparing to restart the specified activity.

Frequency1.4



1.4 Frequency

EXAMPLES EXAMPLE 1.4-3(continued)



-----------------NOTE-----------------Not required to be met until 96hours after verifying the heliumleak rate is within limit.------------------------------------------Verify MPC cavity dryness iswithin limit.

Once after verifying the helium leak rate is within limit.

As the Note modifies the required performance of the Surveillance, it is construed to be part of the “specified Frequency.” Should the cavitydryness not be met immediately following verification of the MPC lidweld helium leak rate while in LOADING OPERATIONS, this Noteallows 96 hours to perform the Surveillance. The Surveillance is stillconsidered to be performed within the “specified Frequency.”

Once the MPC lid weld helium leak rate has been verified to be acceptable, 96 hours, plus the extension allowed by SR 3.0.2, would be allowed for completing the Surveillance for the cavity dryness. If theSurveillance was not performed within this 96 hour interval, there wouldthen be a failure to perform the Surveillance within the specified Frequency, and the provisions of SR 3.0.3 would apply.

Approved Contents |2.0

2.0 APPROVED CONTENTS |

2.1 Approved Contents |


2.1.1 Fuel Stored at the ISFSI |

The spent nuclear fuel to be stored in CONCRETE CASKS at the Trojan ISFSIshall consist of the following:

a. INTACT FUEL ASSEMBLIES as characterized in Table 2-1,

b. DAMAGED FUEL ASSEMBLIES, |

c. FUEL DEBRIS in a PROCESS CAN CAPSULE, which shall not exceed |7.5 kg of fissile material per MPC and 20 Curies of Plutonium per MPC, |and other FUEL DEBRIS, which shall not exceed the fissile material of an |INTACT FUEL ASSEMBLY, and |

d. Fuel assembly inserts as characterized in Table 2-2. |

2.1.2 Fuel Storage Configuration Limits ||

The spent nuclear fuel to be stored in the MPC shall be limited as follows: ||

a. Up to 24 INTACT FUEL ASSEMBLIES may be stored in either the MPC- |24E or the MPC-24EF. |

|b. DAMAGED FUEL ASSEMBLIES must be stored in FAILED FUEL |

CANS or DAMAGED FUEL CONTAINERS and may be stored in either |the MPC-24E or the MPC-24EF. DAMAGED FUEL ASSEMBLIES are |limited to four per MPC in the oversized corner fuel cell locations. |

|c. FUEL DEBRIS must be stored in FAILED FUEL CANS or DAMAGED |

FUEL CONTAINERS in an MPC-24EF. Up to four FAILED FUEL |CANS and/or DAMAGED FUEL CONTAINERS containing FUEL |DEBRIS or DAMAGED FUEL ASSEMBLIES may be stored in the |MPC-24EF in the oversized corner fuel cell locations. |

|d. Contents of an MPC must not exceed 1,680 lbs in any cell, and the dry |

loaded MPC weight must not exceed 78,700 lbs. |


2.0 APPROVED CONTENTS |

2.2 Approved Contents Violations |


2.2.1 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits: |

If the Approved Contents of 2.1 are violated, the following actions shall be |completed:

a. Within 24 hours, notify the NRC Operations Center, and

b. Within 30 days, submit a special report which describes the cause of theviolation and actions taken to restore compliance and prevent recurrence.



Table 2-1Spent Fuel Limits

CHARACTERISTIC |LIMIT |

Clad |

Cooling Time After Discharge

Fuel Enrichment |

Decay Heat per MPC |

Fuel Design

Burnup

No. of Fuel Rod Locations ||

Fuel Rod Clad O.D. ||

Fuel Rod Clad I.D. ||

Fuel Pellet Diameter ||

Fuel Rod Pitch ||

Active Fuel Length ||

No. of Guide and/or Instrument Tubes ||

Guide/Instrument Tube thickness ||

Weight of MPC Cell Contents |

Zircaloy-4

�9 years |

� 3.7 weight % U235 |

� 17.4 kWt |

B&W 17x17 (Mark-BW-17) andWestinghouse 17x17

� 42,000 Mwd/MTU |

264 ||

� 0.372 in. ||

� 0.331 in. ||

� 0.3232 in. ||

� 0.496 in. ||

� 150 in. ||

25 ||

� 0.014 in. (Nominal design) ||

� 1,680 lbs (including non-fuel hardware and |FAILED FUEL CAN or DAMAGED FUEL |CONTAINER) |



Table 2-2Fuel Assembly Inserts

CHARACTERISTIC |LIMIT

Rod Cluster Control Assemblies (RCCAs)

Number of AssembliesNeutron AbsorberCladding MaterialNumber of Rods per AssemblyBurnup |Cooling Time |

Burnable Poison Rod Assemblies (BPRAs)

Number of AssembliesPoison MaterialCladding MaterialBurnup |Cooling Time |

Thimble Plugs

Number of Thimble PlugsMaterialBurnup |Cooling Time |

Sources

Number of Source AssembliesSecondary Sources/Material

Burnup |Cooling Time |

Primary Sources/MaterialBurnup |Cooling Time |

Cladding Material

61Ag-In-Cd304 SS24� 125,515 MWd/MTU |� 9 years |

92Borosilicate Glass Tubes304 SS� 15,998 MWd/MTU |� 24 years |

140304 SS� 118,674 MWd/MTU |� 11 years |

64/Sb-Be� 88,547 MWd/MTU |� 9 years |2/Californium� 15,998 MWd/MTU |� 24 years |304 SS

Approved Contents2.0

2.0 APPROVED CONTENTS

2.1 Approved Contents


2.1.1 Fuel Stored at the ISFSI

The spent nuclear fuel stored in CONCRETE CASKS at the Trojan ISFSI consists |of the following:

a. INTACT FUEL ASSEMBLIES as characterized in Table 2-1,

b. DAMAGED FUEL ASSEMBLIES,

c. FUEL DEBRIS in a PROCESS CAN CAPSULE, which shall not exceed7.5 kg of fissile material per MPC and 20 Curies of Plutonium per MPC,and other FUEL DEBRIS, which shall not exceed the fissile material of anINTACT FUEL ASSEMBLY, and

d. Fuel assembly inserts as characterized in Table 2-2.

2.1.2 Fuel Storage Configuration Limits

The spent nuclear fuel stored in the MPC is limited as follows: |

a. Up to 24 INTACT FUEL ASSEMBLIES are stored in either the MPC-24E |or the MPC-24EF.

b. DAMAGED FUEL ASSEMBLIES are stored in FAILED FUEL CANS or |DAMAGED FUEL CONTAINERS and are stored in either the MPC-24E |or the MPC-24EF. DAMAGED FUEL ASSEMBLIES are limited to fourper MPC in the oversized corner fuel cell locations.

c. FUEL DEBRIS is stored in FAILED FUEL CANS or DAMAGED FUEL |CONTAINERS in an MPC-24EF. Up to four FAILED FUEL CANSand/or DAMAGED FUEL CONTAINERS containing FUEL DEBRIS orDAMAGED FUEL ASSEMBLIES are stored in the MPC-24EF in the |oversized corner fuel cell locations.

d. Contents of an MPC do not exceed 1,680 lbs in any cell, and the dry |loaded MPC weight does not exceed 78,700 lbs. |


2.0 APPROVED CONTENTS

2.2 Approved Contents Violations


2.2.1 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits:

If the Approved Contents of 2.1 are violated, the following actions shall becompleted:

a. Within 24 hours, notify the NRC Operations Center, and

b. Within 30 days, submit a special report which describes the cause of theviolation and actions taken to restore compliance and prevent recurrence.



Table 2-1Spent Fuel Limits

CHARACTERISTIC LIMIT

Clad

Cooling Time After Discharge

Fuel Enrichment

Decay Heat per MPC

Fuel Design

Burnup

No. of Fuel Rod Locations

Fuel Rod Clad O.D.

Fuel Rod Clad I.D.

Fuel Pellet Diameter

Fuel Rod Pitch

Active Fuel Length

No. of Guide and/or Instrument Tubes

Guide/Instrument Tube thickness

Weight of MPC Cell Contents

Zircaloy-4

�9 years

� 3.7 weight % U235

� 17.4 kWt

B&W 17x17 (Mark-BW-17) andWestinghouse 17x17

� 42,000 MWd/MTU

264

� 0.372 in.

� 0.331 in.

� 0.3232 in.

� 0.496 in.

� 150 in.

25

� 0.014 in. (Nominal design)

� 1,680 lbs (including non-fuel hardware andFAILED FUEL CAN or DAMAGED FUELCONTAINER)



Table 2-2Fuel Assembly Inserts

CHARACTERISTIC LIMIT

Rod Cluster Control Assemblies (RCCAs)

Number of AssembliesNeutron AbsorberCladding MaterialNumber of Rods per AssemblyBurnupCooling Time

Burnable Poison Rod Assemblies (BPRAs)

Number of AssembliesPoison MaterialCladding MaterialBurnupCooling Time

Thimble Plugs

Number of Thimble PlugsMaterialBurnupCooling Time

Sources

Number of Source AssembliesSecondary Sources/Material

BurnupCooling Time

Primary Sources/MaterialBurnupCooling Time

Cladding Material

61Ag-In-Cd304 SS24� 125,515 MWd/MTU� 9 years

92Borosilicate Glass Tubes304 SS� 15,998 MWd/MTU� 24 years

140304 SS� 118,674 MWd/MTU� 11 years

64/Sb-Be� 88,547 MWd/MTU� 9 years2/Californium� 15,998 MWd/MTU� 24 years304 SS

LCO and Surveillance Requirements Applicability3.0

3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY


LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, exceptas provided in LCO 3.0.2.

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

If the LCO is met or is no longer applicable prior to expiration of thespecified Completion Time(s), completion of the Required Actions(s) isnot required, unless otherwise stated.

LCO 3.0.3 Not applicable to an ISFSI.

LCO 3.0.4 When an LCO is not met, entry into a specified condition in theApplicability shall not be made except when the associated ACTIONS tobe entered permit continued operation in the specified condition in theApplicability for an unlimited period of time. This Specification shall notprevent changes in specified conditions in the Applicability that arerequired to comply with ACTIONS.

LCO 3.0.5 Equipment removed from service or not in service in compliance withACTIONS may be returned to service under administrative control solelyto perform testing required to demonstrate it meets the LCO or that otherequipment meets the LCO. This is an exception to LCO 3.0.2 for thesystem returned to service under administrative control to perform thetesting.




3.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY


SR 3.0.1 SRs shall be met during specified conditions in the Applicability forindividual LCOs, unless otherwise stated in the SR. Failure to meet a SR,whether such failure is experienced during the performance of theSurveillance or between performances of the Surveillance, shall be failureto meet the LCO. Failure to perform a Surveillance within the specifiedFrequency shall be failure to meet the LCO except as provided in SR3.0.3. Surveillances do not have to be performed on inoperable equipmentor variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance isperformed within 1.25 times the interval specified in the Frequency, asmeasured from the time a specified condition of the Frequency is met.

For Frequencies specified as “once,” the above interval extension does notapply. If a Completion Time requires periodic performance on a “once per...” basis, the above Frequency extension applies to each performance afterthe initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within itsspecified Frequency, then compliance with the requirement to declare theLCO not met may be delayed, from the time of discovery, up to 24 hoursor up to the limit of the specified Frequency, whichever is less. This delayperiod is permitted to allow performance of the Surveillance.

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

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


3.0 SURVEILLANCE REQUIREMENTS (SR) APPLICABILITY


SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not bemade unless the LCO’s SRs have been met within their specifiedFrequency. This provision shall not prevent entry into specified conditionsin the Applicability that are required to comply with ACTIONS or that arerelated to establishing an inert atmosphere in the MPC.

MPC Lid Weld Helium Leak Rate3.1.1

3.1 MPC INTEGRITY


3.1.1 MPC Lid Weld Helium Leak Rate

LCO 3.1.1 The MPC Lid weld helium leak rate shall be � 5x10-6 atm-cc/sec.

APPLICABILITY: LOADING OPERATIONS.

ACTIONS

------------------------------------------------------NOTE--------------------------------------------------------Separate Condition entry is allowed for each MPC.----------------------------------------------------------------------------------------------------------------------


A. MPC lid weld heliumleak rate limit notmet.

A.1 Establish MPC lid weldhelium leak rate withinlimit.

48 hours

B. Required Action A.1and AssociatedCompletion Time notmet.

B.1 Establish cooling to theMPC,

AND

B.2 Unload the MPC.

24 hours

30 days

|3.1 DELETED |


TRANSFER CASK Ambient Air Temperature Limit3.2.1

3.2 TRANSFER CASK INTEGRITY

3.2.1 TRANSFER CASK Ambient Air Temperature Limit


LCO 3.2.1 The TRANSFER CASK shall not be used to support a loaded MPC when |the ambient air temperature is � 0�F.

APPLICABILITY: STORAGE OPERATIONS. |

ACTIONS


A. TRANSFER CASKambient airtemperature is � 0�F.

A.1 Place the TRANSFERCASK in a safe condition.

AND

A.2 Suspend all activitiesinvolving use ofTRANSFER CASK untilambient air temperature hasreturned to > 0�F.

Immediately

Immediately

TRANSFER CASK Ambient Air Temperature Limit3.2.1

3.2 TRANSFER CASK INTEGRITY

3.2.1 TRANSFER CASK Ambient Air Temperature Limit




SR 3.2.1.1 Verify ambient air temperature does notexceed the specified limit.

Within one hour prior to useof the TRANSFER CASK with a loaded MPC.

SR 3.2.1.2 Verify ambient air temperature does notexceed the specified limit.

Every four hours during useof the TRANSFER CASK with a loaded MPC when ambient air temperature is < 5�F.

AIR PAD Limits3.3.1

3.3 AIR PADS

3.3.1 AIR PAD Limits


LCO 3.3.1 The AIR PADS shall not be installed under a CONCRETE CASK containing a loaded MPC:

a. For more than 20 consecutive hours, or

b. When the ambient air temperature is > 100�F.

APPLICABILITY: STORAGE OPERATIONS. |

ACTIONS


A. AIR PADS installed formore than 20 consecutivehours.

A.1 Remove the AIR PADS. Immediately

B. AIR PADS installed andambient air temperature

> 100�F.

B.1 Remove the AIR PADS. Immediately



SR 3.3.1.1 Verify the AIR PADS are not installed for morethan 20 consecutive hours.

Every 10 hours when the AIRPADS are installed.

SR 3.3.1.2 Verify ambient air temperature is � 100�F. Within one hour beforeinstallation and hourly whenambient air temperature is >90�F and the AIR PADS areinstalled.

Design Features4.0

4.0 DESIGN FEATURES


4.1 Site Location

The Trojan INDEPENDENT SPENT FUEL STORAGE INSTALLATION |(ISFSI) facility is located at the Portland General Electric (PGE) Company site in |Columbia County, Oregon, approximately 42 miles north of Portland, Oregon,and approximately 4-1/2 miles southeast of Rainier, Oregon, on the west bank ofthe Columbia River. The site is approximately 3 miles northwest of Kalama,Washington, and 6 miles southeast of Longview, Washington, which are acrossthe Columbia River. |

4.2 Storage Features

4.2.1 Storage System

Portland General Electric Company is licensed to store spent fuel in the TROJAN |STORAGE SYSTEM in a maximum of 34 CONCRETE CASKS at the Trojan |ISFSI. Each CONCRETE CASK can contain one MPC. The MPC can |accommodate up to 24 INTACT FUEL ASSEMBLIES with associated inserts. Up to four FAILED FUEL CANS and/or DAMAGED FUEL CONTAINERS may |also be stored in each MPC as defined in Technical Specification 2.1.2, with the |balance being INTACT FUEL ASSEMBLIES, up to a total of 24 assemblies per |MPC. The MPC will be backfilled with helium and pressurized between 29.3 and |33.3 psig. |

4.2.2 Storage Capacity

The total storage capacity of the Trojan ISFSI is limited to 344.5 MTU as UO2.This total capacity of UO2 is categorized into the following Byproduct, Source,and/or Special Nuclear Material:

INTACT FUEL ASSEMBLIES (Clad with Zircaloy-4)DAMAGED FUEL ASSEMBLIES (Clad with Zircaloy-4) |FUEL DEBRIS

4.2.2.a Design Features Important for Criticality Control |Flux trap size for oversized corner cells � 0.526 in. |Flux trap size for other cells � 1.076 in. |10B loading in Boral absorbers: � 0.0372 g/cm2 |

Design Features4.0

4.0 DESIGN FEATURES


4.2.3 Storage Pad and TRANSFER STATION |

� Loaded CONCRETE CASKS must have a nominal center-to-center 15 |feet spacing with a tolerance of ± 4 inches when stored in their assigned |location on the ISFSI Storage Pad except for the 30 foot ± 4 inch center- |to-center gap in the center of the ISFSI Storage Pad |

|� Operations at the TRANSFER STATION which involve lifts of a loaded |

MPC must be performed using a mobile crane, which shall meet the |guidance of Section 5.1.1 of NUREG-0612, “Control of Heavy Loads at |Nuclear Power Plants,” dated 1980, except that to assure defense in depth: |

1. The mobile crane in its lifting configuration (reeving, placement, |boom length, angle, counterweight, etc.) shall have a rated capacity |of at least two times the weight to be lifted (loaded MPC plus |lifting hardware) in accordance with the guidance of NUREG- |0612. |

2. In accordance with the guidance of NUREG-0612, the mobile |crane must have the ability to safely stop and hold the MPC in the |event of the Seismic Margin Earthquake (SME) applicable to the |Trojan ISFSI. |

3. The mobile crane shall meet the requirements of ANSI B30.5, |“Mobile and Locomotive Cranes,” or equivalent, in lieu of the |requirements of ANSI B30.2, “Overhead and Gantry Cranes.” |

4. The MPC will be restricted to a lift height not to exceed 249 inches |(bottom of raised MPC in the TRANSFER CASK to bottom of |Transport Cask) when being lifted by the mobile crane in the |TRANSFER STATION by the physical limitation of the bottom of |the lid of the TRANSFER CASK. A load cell, or equivalent, on |the mobile crane will indicate contact with the bottom of the lid of |the TRANSFER CASK to limit the lift height of the MPC. |

Design Features4.0

4.0 DESIGN FEATURES


5. Special Lifting Devices as defined in ANSI N14.6-1993 shall have |two times the design safety factors of Section 4.2.1.1 in accordance |with Section 7.2. These special lifting devices shall include the |lifting cleats. |

6. Lifting Devices that are not specifically designed and that are used |for handling heavy loads shall meet the requirements of ANSI |B30.9, “Slings,” except that the load to be used in selecting the |slings is to be twice that specified in NUREG-0612, Section |5.1.1(5). |

� Movements of a CONCRETE CASK are performed using an AIR PADSystem that restricts the lifting height of the CONCRETE CASK to four |inches or less.

Design Features4.0

4.0 DESIGN FEATURES


4.3 Codes and Standards

4.3.1 MPC |

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section III, 1995 Edition with Addenda through 1997, is the |governing Code for the MPC Storage System used at Trojan. |

4.3.1.1 Design Alternatives to Codes, Standards, and Criteria |

Trojan ISFSI SAR Table 4.2-1a lists approved alternatives to codes, |standards, and criteria governing the design of the MPC. |

4.3.2 NOT USED ||

4.3.3 Construction/Fabrication Alternatives to Design Codes, Standards, and Criteria |

Proposed construction/fabrication alternatives to the MPC design codes and |standards, including alternatives of Specification 4.3.1, may be used when |authorized by the Director of the Office of Nuclear Material Safety andSafeguards or designee. The licensee should demonstrate that:

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

2. Compliance with the specified requirements of ASME Code Section III,1995 Edition with Addenda through 1997, would result in hardship or |unusual difficulty without a compensating increase in the level of qualityand safety.

Requests for relief in accordance with this section shall be submitted in accordance with 10 CFR 72.4.

Section Requirement

Subsection Miscellaneous administrative NCA requirements.

NC-3211.1 Welding configuration NC-3254 requirements allowed in vessels NC-4267 designed per the reql)irements of

NC-3200.

NC-3252 Category C welded joints for NC-5253 vessels designed to NC-3200

NC-3258 Design of head attachments using corner joints

Trojan ISFSI

Table 4-1 ASME Code Deviations

Exception

No Design Specification or Design Report will be required. Manufacturer will not be required to have a Certificate of Authorization or an NCA-4000 Quality Assurance Program. Material Organizations will not be required to have an NCA-3800 Quality Assurance Program. Authorized Inspection will not be required. Code Data Reports and Code Symbol/Stamps will not be required.

Structural attachment welds are permitted to be attached by welds that are not continuous on all sides. These attachments do not serve a pressure retaining function, and, when fuel is loaded, are subject only to accident loads. Cyclic loading, stress ·ratchet, and fatigue are not credible events. Detailed drop analysis includes actual weld configuration and potential load transfer to the pressure retaining boundary.

Subsection NC requires Category C full-penetration corner welded joints to be examined by the radiographic or ultrasonic method. The Category C structural lid closure weld will not be nondestructively examined in accordance with NC-2553. This weld will be examined by the liquid penetrant method (multi-layer procedure that includes the root and final layers and sufficient intermediate layers to detect critical flaws). In addition, the partial penetration weld between the shield lid and the shell will be examined by the liquid penetrant method (as required by NC-5260) and will be helium leak tested, ensuring a leak-tight boundary.

When the head-to-shell weld is a corner joint, NC-3258.3 requires the through-thickness dimension of the weld to exceed the thinner of the head or shell thickness by an amount that varies with the specific joint design. Due to the geometry of the internals and due to lack of access to the inside surface of the structural lid closure weld, the shell-to-bottom-plate weld and the structural-lid-to-shell closure weld do not have the required ~ in. fillet weld or other weld reinforcement on the ID surface.

4.0-5 March 1999

Section Requirement

NC-6000 Hydrostatic pressure test

NG-2121 Material utilized in fabrication· shall conform to the requirements of the specification for material given in Tables 2A, 2B, and 4 of Section II, Part D, Subpart 1 and all special requirements of NG.

Trojan ISFSI

Table 4-1 ASME Code Deviations

Exception

The vessel shell will not be hydrostatically tested in accordance with the code since vessel side walls and bottom are not accessible for inspection. Structural welds will be volumetrically examined, except the structural lid weld, which will be examined by the liquid penetrant method. The partial penetration shield lid weld will be hydrostatically tested, helium leak-tested and liquid penetrant tested.

Not all Basket materials will be selected from materials permitted for use in Section III core support structures. Appropriate material properties will be determined from available technical literature. The primary function is structural, and appropriate structural materials will be selected.

4.0-6 March 1999

Table 4-2

CONCRETE CASK Code Deviations'

'Deviations are from ACI-349.

Amendment 1

Code Section Requirement Exception/Justification

No.

1.2 Specifies how drawings and The loads used in the design are covered in calculations must be handled the calculations rather than the drawings and

specifications. A.4 The limits for bulk, (150'F) & local A long term temperature limitation of

area (2000) concrete temperature. 2250 F is used. This increased limit is based on test data from several research efforts which show that concrete of similar composition to that used in the casks does not suffer loss of strength when exposed to

I temperatures up to 3500F.

I

Trojan ISFSI 4.0-7

Site Location4.1

4.0 DESIGN FEATURES

4.1 Site Location


4.1 Site Location

The Trojan INDEPENDENT SPENT FUEL STORAGE INSTALLATION(ISFSI) facility is located at the Portland General Electric (PGE) Company site inColumbia County, Oregon, approximately 42 miles north of Portland, Oregon,and approximately 4-1/2 miles southeast of Rainier, Oregon, on the west bank ofthe Columbia River. The site is approximately 3 miles northwest of Kalama,Washington, and 6 miles southeast of Longview, Washington, which are acrossthe Columbia River.

Storage Features4.2

4.0 DESIGN FEATURES




4.2.1 Storage System

Portland General Electric Company is licensed to store spent fuel in the TROJANSTORAGE SYSTEM in a maximum of 34 CONCRETE CASKS at the TrojanISFSI. Each CONCRETE CASK contains one MPC. The MPC accommodates |up to 24 INTACT FUEL ASSEMBLIES with associated inserts. Up to fourFAILED FUEL CANS and/or DAMAGED FUEL CONTAINERS may also bestored in each MPC as defined in Technical Specification 2.1.2, with the balancebeing INTACT FUEL ASSEMBLIES, up to a total of 24 assemblies per MPC. The MPC is backfilled with helium and pressurized between 29.3 and 39.3 psig at |a reference temperature of 70�F.

4.2.2 Storage Capacity

The total storage capacity of the Trojan ISFSI is limited to 344.5 MTU as UO2.This total capacity of UO2 is categorized into the following Byproduct, Source,and/or Special Nuclear Material:

INTACT FUEL ASSEMBLIES (Clad with Zircaloy-4)DAMAGED FUEL ASSEMBLIES (Clad with Zircaloy-4)FUEL DEBRIS

4.2.2.a Design Features Important for Criticality ControlFlux trap size for oversized corner cells � 0.526 in.Flux trap size for other cells � 1.076 in.10B loading in Boral absorbers: � 0.0372 g/cm2

4.2.3 Storage Pad and TRANSFER STATION

� Loaded CONCRETE CASKS must have a nominal center-to-center 15feet spacing with a tolerance of ± 4 inches when stored in their assignedlocation on the ISFSI Storage Pad except for the 30 foot ± 4 inch center-to-center gap in the center of the ISFSI Storage Pad

Storage Features4.2

4.0 DESIGN FEATURES



� Operations at the TRANSFER STATION which involve lifts of a loadedMPC must be performed using a mobile crane, which shall meet theguidance of Section 5.1.1 of NUREG-0612, “Control of Heavy Loads atNuclear Power Plants,” dated 1980, except that to assure defense in depth:

1. The mobile crane in its lifting configuration (reeving, placement,boom length, angle, counterweight, etc.) shall have a rated capacityof at least two times the weight to be lifted (loaded MPC pluslifting hardware) in accordance with the guidance of NUREG-0612.

2. In accordance with the guidance of NUREG-0612, the mobilecrane must have the ability to safely stop and hold the MPC in theevent of the Seismic Margin Earthquake (SME) applicable to theTrojan ISFSI.

3. The mobile crane shall meet the requirements of ANSI B30.5,“Mobile and Locomotive Cranes,” or equivalent, in lieu of therequirements of ANSI B30.2, “Overhead and Gantry Cranes.”

4. The MPC will be restricted to a lift height not to exceed 249 inches(bottom of raised MPC in the TRANSFER CASK to bottom ofTransport Cask) when being lifted by the mobile crane in theTRANSFER STATION by the physical limitation of the bottom ofthe lid of the TRANSFER CASK. A load cell, or equivalent, onthe mobile crane will indicate contact with the bottom of the lid ofthe TRANSFER CASK to limit the lift height of the MPC.

5. Special Lifting Devices as defined in ANSI N14.6-1993 shall havetwo times the design safety factors of Section 4.2.1.1 in accordancewith Section 7.2. These special lifting devices shall include thelifting cleats.

6. Lifting Devices that are not specifically designed and that are usedfor handling heavy loads shall meet the requirements of ANSI B30.9,“Slings,” except that the load to be used in selecting the slings is tobe twice that specified in NUREG-0612, Section 5.1.1(5).

Storage Features4.2

4.0 DESIGN FEATURES



� Movements of a CONCRETE CASK are performed using an AIR PADSystem that restricts the lifting height of the CONCRETE CASK to fourinches or less.

Codes and Standards4.3

4.0 DESIGN FEATURES




4.3.1 MPC

The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section III, 1995 Edition with Addenda through 1997, is thegoverning Code for the MPC Storage System used at Trojan.

4.3.1.1 Design Alternatives to Codes, Standards, and Criteria

Trojan ISFSI SAR Table 4.2-1a lists approved alternatives to codes,standards, and criteria governing the design of the MPC.

4.3.2 NOT USED

4.3.3 Construction/Fabrication Alternatives to Design Codes, Standards, and Criteria

Proposed construction/fabrication alternatives to the MPC design codes andstandards, including alternatives of Specification 4.3.1, may be used whenauthorized by the Director of the Office of Nuclear Material Safety andSafeguards or designee. The licensee should demonstrate that:

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

2. Compliance with the specified requirements of ASME Code Section III,1995 Edition with Addenda through 1997, would result in hardship orunusual difficulty without a compensating increase in the level of qualityand safety.

Requests for relief in accordance with this section shall be submitted in accordance with 10 CFR 72.4.

Responsibility5.1


5.0 ADMINISTRATIVE CONTROLS

5.1 Responsibility

5.1.1 The ISFSI Manager shall be responsible for overall facility operation and shall delegate inwriting the succession to this responsibility during his absence.

The ISFSI Manager, or his designee, shall approve prior to implementation, eachproposed test, experiment, or modification to systems or equipment that are important tosafety as defined in 10 CFR 72.3.

Organization5.2



5.2 Organization

5.2.1 Onsite and offsite organizations shall be established for facility operation and corporate |management, respectively, as described in the ISFSI Safety Analysis Report or the TrojanNuclear Quality Assurance Program Topical Report (PGE-8010).

ISFSI Staff Qualifications5.3



5.3 ISFSI Staff Qualifications

5.3.1 Each member of the ISFSI Staff shall meet or exceed the minimum qualificationsdescribed in the ISFSI Safety Analysis Report.

Procedures5.4



5.4 Procedures

5.4.1 Written procedures shall be established, implemented, and maintained covering theimportant to safety activities related to STORAGE OPERATIONS described in the ISFSISafety Analysis Report.

Programs5.5



5.5 Programs

The following programs shall be established, implemented, and maintained.

5.5.1 Technical Specifications (TS) Bases Control Program

This program provides a means for processing changes to the Bases of these TechnicalSpecifications.

a. Changes to the Bases of the TS shall be made under appropriate administrativecontrols and reviews.

b. The licensee may make changes to the Bases without prior NRC approvalprovided the changes do not require prior NRC approval pursuant to 10 CFR72.48.

c. The Bases Control Program shall contain provisions to ensure that the Bases aremaintained consistent with the SAR.

d. Proposed changes that do not meet the criteria of 5.5.1.b above shall be reviewedand approved by the NRC prior to implementation. Changes to the Basesimplemented without prior NRC approval shall be provided to the NRC on afrequency consistent with 10 CFR 72.48.

5.5.2 Radioactive Effluent Control Program

This program implements the requirements of 10 CFR 72.44 (d).

a. The Trojan ISFSI does not create any radioactive materials or have anyradioactive waste treatment systems. Therefore, specific operating procedures forthe control of radioactive effluents are not required. The MPC Lid Weld HeliumLeak Rate test that was conducted during cask loading provides assurance thatthere are essentially no measurable radioactive effluents from the ISFSI.

b. This program includes an environmental monitoring program. The environmentalmonitoring program ensures the annual dose equivalent to any real individuallocated outside the ISFSI Controlled Area does not exceed regulatory limits.

|

Programs5.5


5.0 ADMINISTRATIVE CONTROLS |

5.5 Programs

5.5.3 CONCRETE CASK Thermal Monitoring Program

This program provides guidance for temperature measurements that are used to monitor the thermal performance of each CONCRETE CASK.

a. The air outlet temperature and the ambient air temperature are measured daily.The temperature difference between the air outlet temperature and the ambient airtemperature will be calculated and recorded. The air inlet vents will be inspectedand verified free of blockage weekly. In the event of an environmentalphenomenon occurring, the frequency of visual inspection will be increased inaccordance with the severity and consequences of the event.

b. If any air outlet temperature or temperature difference between air outlet andambient temperatures show an unexplained reading, a comparison with predictedand/or baseline data will be performed and appropriate actions taken to determinethe cause and return the temperature to an acceptable value. One of the immediateactions will be to increase the frequency of temperature monitoring.

c. If any air outlet temperature reaches or exceeds the program limit, the NRC willbe notified in accordance with 10 CFR 72.75(b), (e), and (f), and actions will betaken to evaluate the effects and impact of the high temperature on theCONCRETE CASK. Taking actions when air outlet temperature reaches theprogram limit should preclude reaching the short term bulk concrete temperaturelimit which is 350EF. Concrete temperatures in excess of 350EF could potentiallyweaken the concrete strength and tests may have to be performed to evaluate theconcrete and to justify continued use of the CONCRETE CASK.


5.5 Programs

5.5.4 Radiation Protection Program

Programs 5.5

The Radiation Protection Program will establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR 20.

A monitoring program to ensure the annual dose equivalent to any real individual located outside the ISFSI Controlled Area does not exceed regulatory limits is incorporated as part of the environmental monitoring program in the Radioactive Effluent Control Program of Specification 5.5.2.

5.5.5 Aging Management Program

The Aging Management Program will establish the processes and procedures to manage the aging of ISFSI components into extended storage periods. This program will be implemented consistent with ISFSI Safety Analysis Report Section 9.7.8. As part of this program, tollgate assessments will be performed in accordance with ISFSI Safety Analysis Report Section 9.7.10.

The Aging Management Program will be implemented on or before 20 years from the date of the first canister loading.

Trojan ISFSI 5.5-3 Amendment 7 |

High Radiation Areas5.6


5.6 High Radiation Areas

5.6.1 High Radiation Areas, as defined in 10 CFR 20, will be identified and access controlledin accordance with 10 CFR 20.1601 except for the tops of designated CONCRETECASKS. Pursuant to 10 CFR 20, paragraph 20.1601 (c), in lieu of the requirements of 10CFR 20.1601 (a), a CONCRETE CASK where the top is designated a high radiation area,as defined in 10 CFR 20, in which the intensity of radiation is >100 mrem/hr but < 1000mrem/hr, shall be barricaded and conspicuously posted as a high radiation area andentrance thereto does not have to be locked but shall be controlled by the RadiationProtection Program of 5.5.4.

Trojan ISFSI 5.6-1 Amendment 4 |

TECHNICAL SPECIFICATIONS BASES

FOR

TROJAN

INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI)

March 1999

Approved Contents |B 2.0

B 2.0 APPROVED CONTENTS |

Trojan ISFSI Amendment 2 |B2.0-1

BASES

B.2.1.1 and B2.1.2 Fuel Stored at the ISFSI and Fuel Storage Configuration Limits |

BASES

BACKGROUND The design of the MPC and CONCRETE CASK is based on specifications |of spent fuel and fuel related material that will be stored. Thesespecifications include type and quantity of fuel and fuel inserts, conditionof spent fuel, maximum initial enrichment, maximum burnup, andminimum cooling time prior to storage.

These specifications for spent fuel and fuel related material are included inthe thermal, structural, radiological, criticality, and materials evaluations |performed for the TROJAN STORAGE SYSTEM components (e.g., the |CONCRETE CASK and MPC) described in the ISFSI SAR (Ref. 1). |

The design of the TROJAN STORAGE SYSTEM is such that the MPC is |placed in the TRANSFER CASK and loaded with INTACT FUELASSEMBLIES, FAILED FUEL CANS, and DAMAGED FUEL |CONTAINERS in the spent fuel pool (i.e., Cask Loading Pit). |Administrative controls are used to ensure each MPC is loaded with |material meeting the specifications provided in Tables 2-1 and 2-2. Priorto removing the TRANSFER CASK and MPC from the spent fuel pool |(i.e., Cask Loading Pit), the loading of the MPC is verified. |

After loading and placing the MPC lid on the MPC, the TRANSFER |CASK containing the MPC is removed from the spent fuel pool (i.e., Cask |Loading Pit) and transferred to the cask preparation area where closure,MPC cavity drying and helium backfilling are performed on the MPC. |After installation of the MPC vent and drain port cover plates and closure |ring, the MPC is transferred from the TRANSFER CASK to a |CONCRETE CASK in preparation for transportation to and storage at theISFSI.




BASES

After loading, contact surface dose rates and surface contamination of theCONCRETE CASK are measured in accordance with the RadiationProtection Program of Administrative Controls Section 5.5.4. In addition, |the CONCRETE CASK is monitored in accordance with the ThermalMonitoring Program of Administrative Controls Section 5.5.3 to verifythat the thermal performance is in accordance with design limits.

APPLICABLE Administrative controls are established to ensure that misloading of an |SAFETY MPC will not occur. The administrative controls prevent exceeding the |ANALYSES design limits for thermal, structural, radiological, criticality, and material |

parameters assumed in the SAR (Ref. 1). As a result of the permanent |cessation of power operations, the characteristics and inventory available |for loading into the MPCs are known and limited to those fuel assemblies |and fuel related material within the Trojan Nuclear Plant (TNP) spent fuelpool. The design of the MPC and CONCRETE CASK is based on a |maximum heat load of 17.4 kW, a maximum burnup of 42,000 |MWd/MTU, and a minimum cooling time of 9 years. Table 2-1 imposes |these limits. The MPC-24E/24EF design will not accommodate more than |24 INTACT FUEL ASSEMBLIES and/or combination of 20-24 INTACT |FUEL ASSEMBLIES and up to four FAILED FUEL CANS and/or |DAMAGED FUEL CONTAINERS. |

Based on the actual inventory of spent fuel available for storage, nocombination of INTACT FUEL ASSEMBLIES could result in a decay heat load exceeding a limit of 17.4 kW. In addition, the actual inventory |of FUEL DEBRIS stored in Process Can Capsules is less than 7.5 kg of |fissile material and less than 20 Curies of plutonium. Similarly, no |combination of INTACT FUEL ASSEMBLIES, FAILED FUEL CANS, |and DAMAGED FUEL CONTAINERS would result in exceeding the |design limits for radiation dose, criticality, and materials. The |specifications limit the spent fuel to a minimum of nine years of cooling |prior to loading in a CONCRETE CASK to ensure radiation levels are less |than assumed design criteria. No loading combination would result in a |

||||




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|critical configuration given the maximum enrichment of the fuel. The |geometry of and use of solid neutron absorbing material (Boral) in the |MPC is such that a critical mass cannot be achieved. The materials used |in the MPC, CONCRETE CASK, and TRANSFER CASK have been |evaluated and determined to not have an adverse effect on the safe transfer |and storage of spent fuel. The structural analysis of a loaded CONCRETE |CASK was performed assuming a weight of 300,000 lbs, which is greater |that the maximum weight of a loaded CONCRETE CASK with 24 |RCCAs. |

APPROVED The following Approved Contents violation responses are applicable. |CONTENTS Administrative controls ensure that misloading of an MPC will not result |VIOLATIONS in exceeding any of the design limits specified in Table 2-1. The actions |

specified in Section 2.2.1 reflect the reporting requirements of10 CFR 72.75.

References 1. SAR Section 4.2

LCO ApplicabilityB 3.0

B 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY

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LCOs LCO 3.0.1, 3.0.2, 3.0.4 and 3.0.5 establish the general requirements applicable toall Specifications and apply at all times, unless otherwise stated.

LCO 3.0.1 LCO 3.0.1 establishes the Applicability statement within each individualSpecification as the requirement for when the LCO is required to be met (i.e.,when the facility is in the specified conditions of the Applicability statement ofeach Specification).

LCO 3.0.2 LCO 3.0.2 establishes that upon discovery of a failure to meet an LCO, theassociated ACTIONS shall be met. The Completion Time of each RequiredAction for an ACTIONS Condition is applicable from the point in time that anACTIONS Condition is entered. The Required Actions establish those remedialmeasures that must be taken within specified Completion Times when therequirements of an LCO are not met. This Specification establishes that:

a. Completion of the Required Actions within the specified CompletionTimes constitutes compliance with a Specification; and

b. Completion of the Required Actions is not required when an LCO is metwithin the specified Completion Time, unless otherwise specified.

There are two basic types of Required Actions. The first type of Required Actionspecifies a time limit in which the LCO must be met. This time limit is theCompletion Time to restore an inoperable system or component to operable statusor to restore variables to within specified limits. If this type of Required Action isnot completed within the specified Completion Time, a cessation of operationsmay be required to place the system or component in a condition in which the Specification is not applicable. (Whether stated as a Required Action or not,correction of the entered Condition is an action that may always be consideredupon entering ACTIONS.) The second type of Required Action specifies theremedial measures that permit continued operation that is not further restricted bythe Completion Time. In this case, compliance with the Required Actionsprovides an acceptable level of safety for continued operation.



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Completing the Required Actions is not required when an LCO is met or is nolonger applicable, unless otherwise stated in the individual Specifications.

The Completion Time of the Required Actions are also applicable when a systemor component is removed from service intentionally. The reason for intentionallyrelying on the ACTIONS include, but are not limited to, performance ofSurveillances, preventive maintenance, corrective maintenance, or investigation ofoperational problems. Entering ACTIONS for these reasons must be done in amanner that does not compromise safety. Intentional entry into ACTIONS shouldnot be made for operational convenience.

LCO 3.03 This specification is not applicable to an ISFSI. The placeholder is retained forconsistency with the power reactor technical specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in specified conditions in theApplicability when an LCO is not met. It precludes placing the unit in a specifiedcondition stated in that Applicability (e.g., Applicability desired to be entered)when the following exist:

a. Facility conditions are such that the requirements of the LCO would not bemet in the Applicability desired to be entered; and

b. Continued noncompliance with the LCO requirements, if the Applicabilitywere entered, would result in the facility being required to exit theApplicability desired to be entered to comply with the Required Actions.

Compliance with the Required Actions that permit continued operation of thefacility for an unlimited period of time in a specified condition provides anacceptable level of safety for continued operation. This is without regard to thestatus of the facility. Therefore, in such cases, entry into a specified condition inthe Applicability may be made in accordance with the provisions of the RequiredActions. The provisions of this Specification should not be interpreted asendorsing the failure to exercise the good practice of restoring systems orcomponents before entering an associated specified condition in the Applicability.



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The provisions of LCO 3.0.4 shall not prevent changes in specified conditions inthe Applicability that are required to comply with ACTIONS. In addition, theprovisions of LCO 3.0.4 shall not prevent changes in specified conditions in theApplicability that are related to establishing and maintaining the spent fuel in aninert atmosphere.

Exceptions to LCO 3.0.4 are stated in the individual Specifications. Theseexceptions allow entry into specified conditions in the Applicability when theassociated ACTIONS to be entered do not provide for continued operation for anunlimited period of time. Exceptions may apply to all the ACTIONS or to aspecific Required Action of a Specification.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service underadministrative controls when it has been removed from service or determined to not meet the LCO to comply with ACTIONS. The sole purpose of thisSpecification is to provide an exception to LCO 3.0.2 (e.g., to not comply with theapplicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The equipment being returned to service meets the LCO: or

b. Other equipment meets the applicable LCOs.

The administrative controls ensure the time the equipment is returned to service inconflict with the requirements of the ACTIONS is limited to the time absolutelynecessary to perform the allowed surveillance. This Specification does notprovide time to perform any other preventive or corrective maintenance.

LCO 3.0.6 This specification is not applicable to an ISFSI. The placeholder is retained forconsistency with the power reactor technical specifications.



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LCO 3.0.7 This specification is not applicable to an ISFSI. The placeholder is retained forconsistency with the power reactor technical specifications.

Surveillance Requirement ApplicabilityB 3.0

B 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY


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SRs SR 3.0.1 through SR 3.0.4 establish the general requirements applicable to allSpecifications and apply at all times, unless otherwise stated.

SR 3.0.1 SR 3.0.1 establishes the requirement that SRs must be met during the specifiedconditions in the Applicability for which the requirements of the LCO apply,unless otherwise specified in the individual SRs. This Specification is to ensurethat Surveillances are performed to verify systems, components, and variables arewithin specified limits. Failure to meet a SR within the specified Frequency, inaccordance with SR 3.0.2, constitutes a failure to meet an LCO.

Systems and components are assumed to meet the LCO when the associated SRshave been met. Nothing in this Specification, however, is to be construed asimplying that systems or components meet the associated LCO when:

a. The systems or components are known to not meet the LCO, although stillmeeting the SRs; or

b. The requirements of the Surveillance(s) are known not to be met betweenrequired Surveillance performances.

Surveillances do not have to be performed when the facility is in a specifiedcondition for which the requirements of the associated LCO are not applicable,unless otherwise specified.

Unplanned events may satisfy the requirements (including applicable acceptancecriteria) for a given SR. In this case, the unplanned event may be credited asfulfilling the performance of the SR. This allowance includes those SRs whoseperformance is normally precluded in a specified condition.

Surveillances, including Surveillances invoked by Required Actions, do not haveto be performed on equipment that has been determined to not meet the LCObecause the ACTIONS define the remedial measures that apply. Surveillances have to be met and performed in accordance with SR 3.0.2, prior toreturning equipment to service.



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Upon completion of maintenance, appropriate post maintenance testing isrequired. This includes ensuring applicable Surveillances are not failed and theirmost recent performance is in accordance with SR 3.0.2. Post maintenancetesting may not be possible in the current specified conditions in the Applicabilitydue to the necessary facility parameters not having been established. In thesesituations, the equipment may be considered to meet the LCO provided testing hasbeen satisfactorily completed to the extent possible and the equipment is nototherwise believed to be incapable of performing its function. This will allowoperation to proceed to a specified condition where other necessary postmaintenance tests can be completed.

SR 3.0.2 SR 3.0.2 establishes the requirements for meeting the specified Frequency forSurveillances and any Required Action with a Completion Time that requires theperiodic performance of the Required Action on a “once per...” interval.

SR 3.0.2 permits a 25% extension of the interval specified in the Frequency. Thisextension facilitates Surveillance scheduling and considers facility conditions thatmay not be suitable for conducting the Surveillance (e.g., transient conditions orother ongoing Surveillance or maintenance activities).

The 25% extension does not significantly degrade the reliability that results fromperforming the Surveillance at its specified Frequency. This is based on therecognition that the most probable result of any particular Surveillance beingperformed is the verification of conformance with the SRs. The exceptions to SR3.0.2 are those Surveillances for which the 25% extension of the interval specifiedin the Frequency does not apply. These exceptions are stated in the individualSpecifications as a Note in the Frequency stating, “SR 3.0.2 is not applicable.”

As stated in SR 3.0.2, the 25% extension also does not apply to the initial portionof a periodic Completion Time that requires performance on a “once per...” basis. The 25% extension applies to each performance after the initial performance. Theinitial performance of the Required Action, whether it is a particular Surveillanceor some other remedial action, is considered a single action with a singleCompletion Time. One reason for not allowing the 25% extension to thisCompletion Time is that such an action usually verifies that no loss of function



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has occurred by checking the status of redundant or diverse components oraccomplishes the function of the inoperable equipment in an alternative manner.

The provisions of SR 3.0.2 are not intended to be used repeatedly merely as aconvenience to extend Surveillance intervals or periodic Completion Timeintervals beyond those specified.

SR 3.0.3 SR 3.0.3 establishes the flexibility to defer declaring affected equipment as notmeeting the LCO or an affected variable outside the specified limits when aSurveillance has not been completed within the specified Frequency. A delayperiod of up to 24 hours or up to the limit of the specified Frequency, whichever isless, applies from the point in time that it is discovered that the Surveillance hasnot been performed in accordance with SR 3.0.2, and not at the time that thespecified Frequency was not met.

This delay period provides adequate time to complete Surveillances that havebeen missed. This delay period permits the completion of a Surveillance beforecomplying with Required Actions or other remedial measures that might precludecompletion of the Surveillance.

The basis for this delay period includes consideration of facility conditions,adequate planning, availability of personnel, the time required to perform theSurveillance, the safety significance of the delay in completing the requiredSurveillance, and the recognition that the most probable result of any particularSurveillance being performed is the verification of conformance with therequirements. When a Surveillance with a Frequency based not on time intervals,but upon specified facility conditions or operational situations, is discovered notto have been performed when specified, SR 3.0.3 allows the full delay period of24 hours to perform the Surveillance.

SR 3.0.3 also provides a time limit for completion of Surveillances that become applicable as a consequence of changes in the specified conditions in theApplicability imposed by Required Actions.

Failure to comply with specified Frequencies for SRs is expected to be aninfrequent occurrence. Use of the delay period established by SR 3.0.3 is a



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flexibility which is not intended to be used as a convenience to extendSurveillance intervals.

If a Surveillance is not completed within the allowed delay period, then theequipment is considered to not meet the LCO or the variable is considered outsidethe specified limits and the Completion Time of the Required Actions for theapplicable LCO Conditions begin immediately upon expiration of the delayperiod. If a Surveillance is failed within the delay period, then the equipmentdoes not meet the LCO, or the variable is outside the specified limits and theCompletion Time of the Required Actions for the applicable LCO Conditionsbegin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by thisSpecification, or within the Completion Time of the ACTIONS, restorescompliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met beforeentry into a specified condition in the Applicability.

This Specification ensures that system and component requirements and variablelimits are met before entry into specified conditions in the Applicability for whichthese systems and components ensure safe operation of the facility.

The provisions of this Specification should not be interpreted as endorsing thefailure to exercise the good practice of restoring systems or components beforeentering an associated specified condition in the Applicability.

However, in certain circumstances, failing to meet an SR will not result in SR3.0.4 restricting a change in specified condition. When a system, subsystem, component, device, or variable is outside its specified limits, the associated SR(s)are not required to be performed, per SR 3.0.1, which states that surveillances donot have to be performed on such equipment. When equipment does not meet theLCO, SR 3.0.4 does not apply to the associated SR(s) since the requirement forthe SR(s) to be performed is removed. Therefore, failing to perform theSurveillances(s) within the specified Frequency does not result in an SR 3.0.4restriction to changing specified conditions of the Applicability. However, since



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the LCO is not met in this instance, LCO 3.0.4 will govern any restrictions thatmay (or may not) apply to specified condition changes.

The provisions of SR 3.0.4 shall not prevent changes in specified conditions in theApplicability that are required to comply with ACTIONS. In addition, theprovisions of LCO 3.0.4 shall not prevent changes in specified conditions in theApplicability that are related to the establishment and maintenance of an inertatmosphere in the MPC. |

The precise requirements for performance of SRs are specified such thatexceptions to SR 3.0.4 are not necessary. The specific time frames and conditionsnecessary for meeting the SRs are specified in the Frequency, in the Surveillance,or both. This allows performance of Surveillances when the prerequisitecondition(s) specified in a Surveillance procedure require entry into the specifiedcondition in the Applicability of the associated LCO prior to the performance orcompletion of a Surveillance. A Surveillance that could not be performed untilafter entering the LCO Applicability, would have its Frequency specified such thatit is not “due” until the specific conditions needed are met. Alternately, theSurveillance may be stated in the form of a Note as not required (to be met orperformed) until a particular event, condition, or time has been reached. Furtherdiscussion of the specific formats of SRs annotation is found in Section 1.4,Frequency.

MPC Lid Weld Helium Leak Rate |B 3.1.1

B 3.1 MPC INTEGRITY |

B 3.1.1 MPC Lid Weld Helium Leak Rate |

Trojan ISFSI Amendment 2 |B 3.1-1

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BACKGROUND The TRANSFER CASK containing an MPC is placed in the spent fuel |pool (i.e., Cask Loading Pit) and loaded with spent fuel (i.e., INTACTFUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, and FUEL |DEBRIS) meeting the requirements specified in Table 2-1 and Fuel |Assembly Inserts meeting the requirements specified in Table 2-2. WhenMPC loading is complete, the MPC lid is placed onto the MPC prior to |lifting the TRANSFER CASK from the spent fuel pool (i.e., Cask LoadingPit). The TRANSFER CASK containing a loaded MPC is lifted from the |spent fuel pool (i.e., Cask Loading Pit), and moved to the cask preparationarea for decontamination and assembly to prepare the MPC for STORAGE |OPERATIONS. The MPC lid is seal welded. To ensure the confinement |integrity of the MPC lid weld, the MPC is hydrotested and helium leak |rate tested. A helium leak detector is used to ensure a leak rate of |� 5x10-6atm-cc/sec is not exceeded.

APPLICABLE The confinement of radioactivity during the storage of spent nuclear fuelSAFETY is ensured by the use of multiple confinement barriers and systems. TheANALYSES barriers relied upon are the uranium dioxide fuel pellet matrix, the metallic

fuel clad tubes in which the fuel pellets are contained, and the MPC in |which the INTACT FUEL ASSEMBLIES are stored. Long term integrityof the fuel clad depends on storage in an inert atmosphere. This is |accomplished by removing water from the MPC and backfilling it with an |inert gas. The failure of all confinement barriers is considered an |incredible event in the accident analysis (Ref. 1). In addition, the thermal |analysis of the MPC and CONCRETE CASK assumes that the MPC is |filled with dry helium.

DAMAGED FUEL ASSEMBLIES have already released the fission |product gases so they do not have the same confinement requirements of |INTACT FUEL ASSEMBLIES. DAMAGED FUEL ASSEMBLIES and |FUEL DEBRIS have been placed in FAILED FUEL CANS or |DAMAGED FUEL CONTAINERS in designated MPCs. |Short term fuel clad temperatures less than 752�F limit do not result in |degradation of the clad. The maximum fuel clad temperature would occur |




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during the vacuum drying process and not during the MPC Lid Weld |Helium Leak Rate check. The maximum fuel clad temperature has been |calculated and found to not exceed the short term fuel clad temperature |limit for the 17.4 kW loaded basket (Ref. 2). |

During STORAGE OPERATIONS, the helium atmosphere providesimproved heat transfer characteristics which have been credited in theanalysis of off-normal and accident conditions (Ref. 1).

LCO Verifying that the MPC is sealed by measuring the lid weld helium leak |rate will ensure that assumptions made in the accident analysis andradiological evaluations are maintained and that the inert gas cover ismaintained for the duration of long term storage. The criterion of� 5x10-6atm-cc/sec is consistent with the leak rate assumed in the |confinement analysis. As a practical matter, the MPC is leaktight and will |retain all of the helium injected into the MPC cavity during backfill |operations. The LCO does not have to be met until 72 hours after |removal of the loaded TRANSFER CASK from the spent fuel pool (i.e.,Cask Loading Pit).

APPLICABILITY The maximum fuel clad temperature during LOADING OPERATIONS is |659�F during vacuum drying operations (Ref. 2). Since this maximum |temperature is 93�F below the short term fuel clad temperature limit of |752�F, no degradation of fuel clad is anticipated. |

ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, aseparate Condition entry is allowed for each MPC. This is acceptable |since the Required Actions for each Condition provide appropriatecompensatory measures for each MPC not meeting the LCO. Subsequent |MPCs that do not meet the LCO are governed by subsequent Condition |entry and application of the associated Required Actions.




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A.1

If the helium leak rate limit is not met, actions must be taken to meet theLCO. A possible corrective action is weld repair. The Completion Timeof 48 hours provides adequate time to correct conditions that wouldprevent satisfying the MPC lid weld helium leak rate requirements. |Specifying a maximum time for completion ensures that completing theMPC lid leak rate testing is expedited. |

B.1

In the event the MPC lid helium leak rate cannot be satisfied within the |allowed Completion Time of ACTION A.1, a cooling flow path will beestablished to the MPC (Ref. 3). The MPC lid helium leak rate test will be |performed with the MPC filled with water except for approximately 20 |gallons that has been drained. Therefore, it is relatively easy to establish |cooling by recirculating helium or borated water through the MPC cavity. |Establishment of MPC cooling will maintain the fuel clad temperature less |than the 647�F long term storage limit (Ref.4), thereby allowing repair of |the MPC lid weld or helium leak detector as appropriate. The cooling |flow path shall remain available, however, flow may be interrupted tocomplete MPC lid weld repairs and perform the helium leak rate test. |

B.2

In the event the MPC lid helium leak rate cannot be satisfied within the |allowed Completion Time of ACTION A.1, steps will also be taken toreturn the MPC to the spent fuel pool (i.e., Cask Loading Pit) for |unloading within 30 days. Since cooling of the MPC was reestablished by |ACTION B.1, there is no thermal limit or safety parameter that could beexceeded by not meeting the helium leak rate LCO. Thirty days was

MPC Cavity Dryness |B 3.1.1


B 3.1.1 MPC Lid Weld Helium Leak Rate

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determined to be reasonable to make welding repairs or obtainreplacement parts for the helium leak detector.

SURVEILLANCE SR 3.1.1.1REQUIREMENTS

A primary design consideration of the MPC is that it is leak tight. The |surveillance requirement to verify that the Confinement Boundary heliumleak rate is � 5 X 10-6 atm-cc/sec ensures that the assumptions in the |confinement analysis are preserved. The measured leak rate will be a |function of the test pressure and the sensitivity of the instrumentation. The |results at test conditions are corrected for comparison with the 5 X 10-6 |atm-cc/sec LCO limit. |

Measurement of the MPC lid weld helium leak rate must be performed |successfully on each MPC prior to performance of MPC cavity |drying. Subsequent to the completion of the MPC cavity drying, the vent |and drain port cover plates are welded in place and helium leak rate |tested. Finally, after the port covers are helium leak rate tested, a |redundant confinement boundary is provided by the closure ring seal |welds. |

A Note has been added to the SR to indicate it is not required to be met |until 72 hours after the TRANSFER CASK loaded with the MPC has been |removed from the spent fuel pool (i.e., Cask Loading Pit). This allowssufficient time to complete the closure weld, perform the hydrostatic test,and prepare to perform the helium leak rate test.

REFERENCES 1. SAR Sections 8.1.4, 8.2.1, 8.2.2, 8.2.6, and 8.2.7 |2. SAR Table 4.2-123. SAR Section 5.1.1.24. SAR Table 3.1-3

|



B 3.1.2 MPC Cavity Dryness |

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BACKGROUND The TRANSFER CASK containing a MPC is placed in the spent fuel pool |(i.e., the Cask Loading Pit). The MPC is loaded with spent fuel (i.e., |INTACT FUEL ASSEMBLIES, DAMAGED FUEL ASSEMBLIES, and |FUEL DEBRIS) meeting the requirements specified in Table 2-1 and Fuel |Assembly Inserts meeting the requirements specified in Table 2-2. WhenMPC loading is complete, the lid is placed onto the MPC prior to lifting |the TRANSFER CASK from the spent fuel pool (i.e., Cask Loading Pit). The TRANSFER CASK containing a loaded MPC is lifted from the spent |fuel pool (i.e., Cask Loading Pit), and moved to the cask preparation areafor decontamination and assembly to prepare the MPC for STORAGE |OPERATIONS. Prior to commencement of MPC cavity drying, the top of |the MPC is decontaminated, the lid is seal welded in place, and the helium |leak test is performed on the closure weld of the lid. Once the water isremoved from the MPC cavity, drying operations can begin. |

The required MPC cavity dryness is obtained by vacuum drying to a |specific pressure. The pressure chosen to ensure that any remaining water |vapor in the cavity is of such a small quantity that it is of no concern for |corrosion. |

Vacuum drying is aided by a temperature increase in the MPC due to |heating from the fuel which removes residual moisture. In light of the factthat the helium leak rate test has been performed and the MPC lid is |welded in place, the integrity of the MPC has been demonstrated. |

The purpose of the MPC cavity drying process is to remove moisture from |the MPC prior to backfilling it with helium for long-term storage. An |inert environment in the MPC cavity ensures that there will be no |significant corrosion of the fuel clad during STORAGE OPERATIONS at |the ISFSI. |




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APPLICABLE The confinement of radioactivity during the storage of spent nuclear fuelSAFETY is ensured by the use of multiple confinement barriers and systems.ANALYSES The barriers relied upon are the uranium dioxide fuel pellet matrix, the

metallic fuel clad tubes in which the fuel pellets are contained, and the |MPC in which the INTACT FUEL ASSEMBLIES are stored. Long term |integrity of the fuel clad depends on storage in an inert atmosphere. This |is accomplished by removing water from the MPC and backfilling it with |an inert gas. The failure of all confinement barriers is considered anincredible event and is discussed in the accident analysis (Ref. 1). Inaddition, the thermal analysis of the MPC and CONCRETE CASK assume |that the MPC is filled with dry helium. |

DAMAGED FUEL ASSEMBLIES have already released the fission |product gases so they do not have the same confinement requirements of |INTACT FUEL ASSEMBLIES. DAMAGED FUEL ASSEMBLIES and |FUEL DEBRIS have been placed in FAILED FUEL CANS or |DAMAGED FUEL CONTAINERS in designated MPCs. |

Short term fuel clad temperatures less than 752�F do not result in grossdegradation of the clad. Calculations demonstrate that the maximum |steady state fuel clad temperature that would occur during the vacuumdrying process is 659�F for the 17.4 kW loaded basket. This is 93�F less |than the short term fuel clad temperature limit. |

LCO A vacuum drying pressure of � 3 torr held for � 30 minutes assures that |water within the MPC cavity has been evaporated and removed. |

Removal of water before filling the MPC with an inert gas ensures |optimum long term storage conditions by inhibiting the potential for fuelclad and confinement boundary degradation. |

Fuel clad temperatures are not a concern while the MPC is submerged |within the spent fuel pool (i.e., Cask Loading Pit). However, following




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removal from the spent fuel pool (i.e., Cask Loading Pit), heat transfer islimited with worst case conditions occurring during vacuum drying whenconductive heat transfer is limited. Even under these conditions, steadystate (i.e., equilibrium) clad temperatures for a 17.4 kW loaded MPC will |not exceed 659�F which is 93�F below the 752�F short term clad |temperature limits identified in Interim Staff Guidance 11, Revision 2. Although no fuel clad damage is anticipated to occur at temperatures lessthan 752�F, a 96 hour administrative limit to complete the MPC cavity |drying has been established to minimize the time period in which the MPC |cavity atmosphere is not inert. The 96 hour administrative limit allowsadequate time to complete the MPC preparations and the MPC cavity |drying.

APPLICABILITY This LCO is APPLICABLE during LOADING OPERATIONS but onlyafter the helium leak rate test has been completed. LOADINGOPERATIONS begin with the loading of the MPC within the spent fuel |pool (i.e., Cask Loading Pit) and end when the MPC is loaded into a |CONCRETE CASK.

ACTIONS A Note has been added to the ACTIONS which states that, for this LCO, aseparate Condition entry is allowed for each MPC. This is acceptable |since the Required Actions for each Condition provide appropriatecompensatory measures for each MPC not meeting the LCO. Subsequent |MPCs that do not meet the LCO are governed by subsequent Condition |entry and application of the associated Required Actions.

A.1

If the MPC cavity dryness limit cannot be met, actions must be taken to |meet the LCO. Since the MPC cavity drying process is initiated after the |MPC has been hydrostatically and helium leak rate tested, and the closure |weld dye penetrant tested, there is a high level of assurance that the




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confinement boundary is intact and properly sealed. The most likelymechanism preventing meeting the LCO is a failure of the Vacuum DryingSystem and/or associated hardware.

Since the maximum steady-state temperature which the spent nuclear fuelwould experience during the duration of fuel loading and vacuum dryingoperations is 659�F (Ref . 2) which is 93�F below the short term fuel clad |temperature limit of 752�F, no degradation of fuel clad is anticipated. A |48 hour Completion Time is considered appropriate for making repairs andcorrecting failures of the affected components. |

B.1.1 and B.1.2

If the Required Action of A.1 cannot be satisfied, either a method ofcooling the spent fuel must be established or an inert atmosphere needs tobe established for the spent fuel. If the water is not completely drainedfrom the MPC, use of cooling water is desirable to maintain spent fuel |temperatures at lower values. However, once the water has been removed,the most efficient means to protect the spent fuel is by creating an inertatmosphere around the spent fuel. The inert atmosphere will help toremove heat. Cooling the spent fuel can be accomplished by establishingcooling water circulation to the MPC as described in the SAR (Ref. 3). |

An inert atmosphere can be established by creating a helium atmosphere inthe MPC as described in the SAR (Ref. 3). Either of these actions will |reduce fuel clad temperature and minimize the potential for fuel clad degradation until repairs are completed as necessary to perform MPC |cavity drying until the LCO is satisfied. |

B.2

In the event the MPC cavity dryness limit cannot be satisfied within the |allowed Completion Time of ACTION A.1, steps will also be taken to




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return the MPC to the spent fuel pool (i.e., Cask Loading Pit) for |unloading within 30 days. Since cooling of the MPC was reestablished by |ACTION B.1, there is no thermal limit or safety parameter that could beexceeded by not meeting the MPC cavity dryness LCO. Thirty days was |determined to be reasonable to make repairs or obtain replacement partsfor the affected components. |


The long-term integrity of the stored fuel is dependent on storage in a dry,inert environment. Cavity dryness is demonstrated by evacuating thecavity to a very low pressure and verifying that the pressure is held overthe specified period of time.

This dryness test must be performed on each MPC within 96 hours after |verifying the helium leak rate is within limit. A Note has been added tonot require the SR be APPLICABLE until 96 hours after the helium leakrate is acceptable. This allows sufficient time to complete the MPC |preparations and perform the drying operations. The 96 hours is a |reasonable amount of time to allow the MPC to be without an inert |atmosphere.

REFERENCES 1. SAR 8.2.1 |2. SAR Table 4.2-12 |3. SAR 5.1.1.2 |

TRANSFER CASK Ambient Air Temperature Limit |B 3.2.1

B 3.2 TRANSFER CASK INTEGRITY

B 3.2.1 TRANSFER CASK Ambient Air Temperature Limit |

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BACKGROUND In addition to its functions in the Fuel Building in transporting an MPC |loaded with spent fuel from the spent fuel pool (i.e., Cask Loading Pit) to aCONCRETE CASK, the TRANSFER CASK is used as a support andshielding container in the TRANSFER STATION during the process oftransferring an MPC into a Transport Cask. The activities involving the |TRANSFER CASK in the Fuel Building will be in a controlledenvironment, ensuring that ambient air temperatures are controlled andthat solar heating does not become a factor. However, the activities at theTRANSFER STATION will not be in a controlled environment, andambient air temperatures cannot be controlled. The analysis of theTRANSFER CASK design assumed an ambient air temperature equal to |or greater than 0�F. Since the TRANSFER STATION ambient air |temperatures cannot be controlled, use of the TRANSFER CASK must berestricted to occur only when the ambient air temperature is above this |limit. |

APPLICABLE The design characteristics of the TRANSFER CASK are considered in the |SAFETY Safety Analysis for handling spent fuel. Inherent in the design is theANALYSES assumption that use of the TRANSFER CASK will occur at ambient air |

temperatures greater than 0�F. Establishing an ambient air temperature |limit for use of the TRANSFER CASK ensures that its integrity is |maintained and the Safety Analysis is valid.

LCO Limiting use of the TRANSFER CASK to periods when the ambient airtemperature is > 0�F ensures the TRANSFER CASK will not fail by |brittle fracture. |

APPLICABILITY The APPLICABILITY for this LCO is LOADING, UNLOADING, and STORAGE OPERATIONS. In the event a loaded MPC is to be |transferred into a Transport Cask, the TRANSFER CASK will be used to |support the MPC after it has been raised out of a CONCRETE CASK and |

TRANSFER CASK Ambient Air Temperature Limit |B 3.2.1

B 3.2 TRANSFER CASK INTEGRITY

B 3.2.1 TRANSFER CASK Ambient Air Temperature Limit |

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until it is lowered back into a Transport Cask at the TRANSFER |STATION. The APPLICABILITY ensures that the LCO applies to allactivities involving the use of the TRANSFER CASK.

ACTIONS A.1 and A.2

If ambient air temperature decreases to 0�F or less during use of the |TRANSFER CASK to lift, support, or transport a loaded MPC, |immediate steps will be taken to place the TRANSFER CASK in a safecondition and suspend all further operations involving use of theTRANSFER CASK with a loaded MPC until ambient air temperatures |have returned to greater than 0�F. A safe condition is one in which the |TRANSFER CASK is not being used to lift, support, or transport a loaded |MPC. This may involve unloading the TRANSFER CASK. |


This SR ensures that the TRANSFER CASK is not used to lift, support, or |transport a loaded MPC whenever the ambient air temperature is outside |its limit at the locations where the TRANSFER CASK is being used prior |to use.

SR 3.2.1.2

This SR ensures that when the TRANSFER CASK is being used to lift, |support, or transport a loaded MPC with an ambient air temperature less |than 5�F, the ambient air temperature is verified greater than 0�F every |four hours at the locations where it is being used.

REFERENCES 1. SAR, Section 4.7.3.1

SURVEilLANCE SR3.2.1.1 REQUIREMENTS

REFERENCES

Trojan ISFSI

This SR ensures that the TRANSFER CASK is not used whenever the ambient air temperatures are outside their limits at the locations where the TRANSFER CASK is being used prior to use.

SR 3.2.1.2

This SR ensures that when the TRANSFER CASK is being used with an ambient air temperature greater than 90°F, the ambient air temperature is verified equal to or less than 100 op every four hours at the locations where it is being used.

SR 3.2.1.3

This SR ensures that when the TRANSFER CASK is being used with an ambient air temperature less than 45 °F, the ambient air temperature is verified greater than 40 op every four hours at the locations where it is being used.

1. SAR, Section 4.7.3.1

B 3.2-3 March 1999

AIR PAD LimitsB 3.3.1

B 3.3 AIR PADS

B 3.3.1 AIR PAD Limits

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BACKGROUND The AIR PADS are used to move CONCRETE CASKS (References 1 and 2). The AIR PADS are inserted into the air inlets at the bottom of the CONCRETE CASK. Air compressors are used to inflate and maintain pressure in the AIR PADS. The inflated AIR PADS lift the CONCRETE CASK above the ground and allow it to float on a cushion of air. A transport vehicle is connected to the CONCRETE CASK to move it.

When installed, the AIR PADS partially block the CONCRETE CASK air inlets and reduce the cooling air flow. However, when the AIR PADS are inflated, for analysis purposes, it is assumed that all air flow is blocked even though there is some natural circulation through an unblocked opening and forced air flow from the AIR PAD itself. In either case (i.e., AIR PADS installed or inflated), although the air flow from natural draft air flow or forced air flow, respectively, will provide cooling, the extent of that cooling has not been determined.

APPLICABLE The CONCRETE CASK bulk concrete temperature is the limiting thermal SAFETY design parameter (References 3 and 6). Because of the temperature ANALYSES gradient across the concrete, the bulk concrete temperature is difficult to

determine and use in analyses. Therefore, the inner concrete temperatureis used in lieu of the bulk concrete temperature and is limited to 225�F for long-term normal operational storage (Reference 3). This is conservative since the bulk concrete temperature will not exceed the inner concrete temperature.

In the Full Blockage of Air Inlets accident evaluated in the SAR |(Reference 4), 100�F ambient air and complete air flow blockage of all |inlets is assumed. For a CONCRETE CASK loaded with an MPC with a |17.4 kW heat load, the inner concrete temperature will increase, reaching |the long-term normal operation storage limit of 225�F in approximately 20 |hours, the short-term off-normal limit of 300�F in approximately 39.5 |hours, and the short-term accident limit of 350�F in approximately 57.1 |hours (Reference 3). In order to prevent the inner concrete temperaturefrom reaching the long-term normal storage limit, installation of the AIRPADS will be restricted to no more than 20 consecutive hours. Twenty |

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B 3.3 AIR PADS


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B 3.3 AIR PADS


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|hours is more than sufficient time to complete the movement of the |CONCRETE CASK using the AIR PADS. However, the analysis shows |that the AIR PADS could be installed for 57 hours without exceeding the |short-term accident limit for concrete. Should the 20 consecutive hours |limit be approached, it is expected the AIR PADS would be removed until |the recirculation is restored and the difficulty in moving the CONCRETE |CASK would be resolved. |

Since the Full Blockage of Air Inlets accident evaluated in the SAR |assumes an initial ambient air temperature of 100�F, a 100�F temperature |limit is placed upon installation and use of the AIR PADS on a loadedCONCRETE CASK.

In the Blockage of One-Half of the Air Inlets case in the SAR (Reference5), which assumes blockage of one-half of the air inlets, for a CONCRETE CASK loaded with an MPC with a 17.4 kW heat load, the inner concrete |temperature will not reach the long-term storage limit of 225�F. Thisanalysis also assumes an initial ambient air temperature of 75�F.

LCO Restricting installation of the AIR PADS to no more than 20 consecutive |hours ensures that the long-term inner concrete storage temperature is not |exceeded and that the CONCRETE CASK is not adversely affected.

Restricting the installation of the AIR PADS on a loaded CONCRETE CASK to periods when the ambient air temperature is less than or equal to 100�F ensures that the long-term inner concrete storage temperature is not |exceeded. |

APPLICABILITY The loaded CONCRETE CASKS will only be moved in LOADING, TRANSPORT, or STORAGE OPERATIONS. Therefore, this LCO and SR are only applicable during these conditions.


B 3.3 AIR PADS


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B 3.3 AIR PADS


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ACTIONS A.1

If the AIR PADS are installed for more than 20 consecutive hours, the |AIR PADS must be immediately removed. This will reestablish air flowto cool the concrete.

B.1

If ambient air temperature exceeds 100�F, the AIR PADS must be |immediately removed. This will reestablish air flow to cool the concrete and stay within analyzed limits. |


Since the long term integrity of the concrete is ensured by maintaining its temperature below the specified limits, the length of time during which the AIR PADS can be installed is monitored every 10 hours while they are |installed.

SR 3.3.1.2

The ambient air temperature is monitored hourly whenever it is greater |than 90�F and the AIR PADS are installed. The long term integrity of the |concrete is ensured by maintaining its temperature below the specified |limits. To ensure the temperature of the concrete does not exceed its |limits, the ambient temperature during the period of time in which the AIR |PADS are installed is monitored hourly when ambient temperature |is > 90�F. |


B 3.3 AIR PADS


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B 3.3 AIR PADS


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REFERENCES 1. SAR Section 5.1.1.4 |2. SAR Section 5.2.1.1.8 |3. SAR Table 4.2-124. SAR Section 8.2.75. SAR Section 8.1.2.26. SAR Table 4.2-2a

Documents

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