North Anna Power Station ISFSI, Evaluations of Seismic ...NORTH ANNA POWER STATION ISFSl EVALUATIONS OF SEISMIC EVENT ON PAD #2 SPENT FUEL STORAGE SYSTEM North Anna Power Station (NAPS)

VIRGINIA ELECTRIC AND POWER COMPANY

RICHMOND, VIRGINIA 23261

January 24, 2013

U.S. Nuclear Regulatory Commission Serial No.: 13-024Attention: Document Control Desk NLOS/TJS: ROWashington, D.C. 20555 Docket No.: 72-56

VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION)NORTH ANNA POWER STATION ISFSlEVALUATIONS OF SEISMIC EVENT ON PAD #2 SPENT FUEL STORAGE SYSTEM

North Anna Power Station (NAPS) has two co-located Independent Spent Fuel StorageInstallations (ISFSIs). One ISFSI (Pad #1) is operated under a specific license andcontains Transnuclear TN-32 type storage casks. The other ISFSI (Pad #2) is operatedunder a general license and uses the Nuclear Horizontal Modular Storage system(NUHOMS®) consisting of dry storage canisters placed horizontally in individual storagebunkers. Pad #2 is not full and present plans are to load future spent fuel using theNUHOMS® system.

On August 23, 2011, a 5.8 magnitude earthquake occurred in central Virginia whichexceeded the design basis earthquake (DBE) for the station and ISFSIs. During thisevent, the peak ground acceleration exceeded the design spectra in only one horizontaldirection and only for a very short period of time (approximately 3.1 seconds). Theimmediate, initial inspection of the ISFSIs identified some movement of the casks onPad #1 and storage bunker components on Pad #2, but no damage was observed thathad any impact on safety-related features, and the facilities continued to perform theirintended design functions. A subsequent, more detailed inspection and monitoring byboth the site and Transnuclear personnel confirmed the initial assessment.

Subsequently, Dominion developed an event assessment plan for both ISFSls tovalidate the sufficiency of the Operability Determination (OD) and to address "goingforward" actions following the event. This plan was pad and storage system specific,and included: further detailed inspections of the concrete pads; vendor recommendeddetailed inspections of accessible portions of a sample of the TN-32 casks; vendorrecommended detailed inspections of a sample of loaded and empty NUHOMS® units;repair of cosmetic concrete damage on NUHOMS® horizontal storage modules (HSMs):an analytical translation of the seismic response spectra measured at the station basemat during the August 23 event to the ISFSI pads; and a structural evaluation of theinternal components of the TN-32 cask and NUHOMS® canister and HSM using thetranslated seismic spectra and assuming the occurrence of an additional DBE. Inaddition, the assessment plan for NUHOMS® HD System (Pad #2) included a shieldingevaluation of the post-earthquake gap condition for the existing HSMs assuming a

C, I/e

Serial No. 13-024Docket No. 72-56

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second beyond DBE occurred that would further increase the worst-case gap betweenHSMs.

The inspections and evaluations performed by Dominion and Transnuclear followingthe earthquake affirm the NUHOMS® HD Dry Storage Systems (Certificate ofCompliance #1030) at NAPS are operable and capable of sustaining another August23, 2011, seismic event or DBE. Accordingly, Transnuclear has recertified theNUHOMS® HD storage systems currently residing on ISFSI Pad #2 to be inconformance with the requirements of the applicable amendment of the Certificate ofCompliance.

The results of these inspections, as well as structural, shielding and licensingevaluations, were presented to the NRC by Dominion and Transnuclear during ameeting on July 23, 2012. At that meeting, it was agreed that a formal 10CFR72.48evaluation should be completed to document the continued technical acceptability ofthe NUHOMS® system for NAPS as well as the continued adequacy of the existingCertificate of Compliance. It was also noted that the existing 10CFR72.212 reportwould be revised to document the occurrence of the August 23, 2011 earthquake andincorporate the results of the aforementioned evaluations.

As this information is not required by regulations to be submitted for formal NRC review,Dominion agreed to submit both the 10CFR72.48 evaluation and the 10CFR72.212report to the NRC for information prior to resumption of loading the NUHOMS® storagesystem at NAPS. Accordingly, attached is the 10CFR72.48 evaluation and revised10CFR72.212 report, including relevant attachments (i.e., Attachment 1). Bothattached documents are non-proprietary. Both documents have had the names of theindividual contributors removed. The complete documents will be available onsite forNRC review, if needed.

Having completed the requisite inspections, evaluations, and recertification of theNUHOMS® HD storage systems, Dominion considers the NUHOMS® HD storagesystem at NAPS ISFSI Pad #2 to be operable and fully qualified. Thus, Dominionintends to resume loading of the NUHOMS® HD storage system at NAPS on March 18,2013.

Actions to document and resolve the results of inspections, evaluations, and licensingassessments for the Transnuclear TN-32 type storage casks on Pad #1 will be thesubject of separate docketed correspondence.


Page 13

Should you have any questions regarding the attached material, please contact Mr. David

A. Sommers at 804-273-2823.

Sincerely,

Leslie N. HartzVice President - Nuclear Support Services

Attachments

Commitments made by this letter: None


Page 14

cc: U.S. Nuclear Regulatory Commission, Region IIMarquis One Tower245 Peachtree Center Avenue, NESuite 1200Atlanta, GA 30303-1257

ATTN: Document Control DeskDirector, Division of Spent Fuel Storage and TransportationOffice of Nuclear Material Safety and SafeguardsU.S. Nuclear Regulatory CommissionWashington, D.C. 20555-0001

Dr. V. Sreenivas (without attachments)NRC Project Manager North AnnaU.S. Nuclear Regulatory Commission, Mail Stop 08 G-9AOne White Flint North11555 Rockville PikeRockville, MD 20852-2738

Ms. K. R. Cotton (without attachments)NRC Project Manager North AnnaU.S. Nuclear Regulatory Commission, Mail Stop 08 G-9AOne White Flint North11555 Rockville PikeRockville, MD 20852-2738

Ms. J. DavisNRC Senior Project ManagerU. S. Nuclear Regulatory Commission, Mail Stop EBB-E3-D2MOne White Flint North11555 Rockville PikeRockville, MD 20852-2738

NRC Senior Resident InspectorNorth Anna Power Station


Attachment 1

Transnuclear 10CFR72.48 Evaluation

North Anna Power StationVirginia Electric and Power Company (Dominion)

T....uc•..,.. :. ... . .!0oCFR71 Review I Pg1o

[_____.........______LR No.-] -7'2130-329i Initiating Document, if applicable . - 2. Applicable System

TIN NCR 2012-111, Revision 0. NUHOMS"ý H-D Horizontal Modular Storage SystemTN Calculation 10494-183, Revision 0.TN Calculation 10494-184. Revls~iol 0,TN Calculation 10494-165, Revision 0.TN Calculation 10494-816, Revision 0.

3. Description of Proposed Activity:.

See Page 24. Licenslng references (FSAR, CoC, FCNs, etc,) for 10 CFR Part 71 and 10 CFR Part 72, as IOCFR72 Open License

applIcable: Reconciliation Requlred?"RC .

-ee Page 2 72.48 (LR) -]Ref. LR

6. General Applicability

A. Would the proposed activity require anr alteration to the terms, conditions, or Technical Specificationsincorporated in the CoC? If yes, cheek conclusion I and skip to question E. If no. explain. El YES

.NOSee Page 2 •] N/A

U. Does a regulation other than 10 CFR 72.48 provide more specific criteria for accomplishing the proposed activity?[See 10 CFR 72.48(c)(4) and NEI 96-07 34.1.4j If YES, reference the nther regulation, check Conclusion 2and skip to Question E. YES

0 NOThe proposed activity does not affect exemptions, emergency plans, physical security, or quality assurance activities E] N/A

,avbject to more specific Criteria provided in other regulations.

C. l-I~ the proposed activity been previously screened Out, or evaluated and accepted, either by a licensee or by

Transnuclear per 10 CFR 72A48, and is bounded by such a review?. If the review was performed by a Licensee,

then verification and approval shall indicate the Company's concurrence with the Licensee's review, If the I] YESp..pi'o0 activity Is bounded, chluck YES, refemrece trlM previou-sly performed evaluaUon, check [ NOP Co ncius 3 and skip to Question E. ! . C N/A

D- Is the proposed activity a minor editorial correction to the design/procurement documents or the UFSAR. for YES

.purposes of clarification? If YES, check Conclusion 3 and explain. If NO, check Conclusion 4. : NO

-[] N/AE. In the case of a system also licensed under 10 CFR Part 71, or a system for which an application for licensing Is

in NRC review, would the proposed activity result in a deviation from complete and verbatim compliance to the 10CFR 71 CoC, including either the authorized contents, or package drawings, or operating controls and [] YESprocedures, or acceptance tests Incorporated by reference? If yes, check Conclusion 5. If not yet licensed 1] NOunder Part 71, nor under NRC review for licensing, check N/A. If under NRC review for licens.ing, check Q] N/AI.OCFR71 Reconciliation Required and check Conclusion 5. For all responses, explain. ' 10CFR71

ReconciliationThe NUHOMS" 32P-T1 and NUHOMS9 32PTH Type 1 DSC are Included as payloads for transpodlation under CoC Required9302, Revision 5, which Is currently under NRC review for licensing,

Conclusion; (check one from 1 through 4, 2nd 5 if appropriate)

* '110 CFR 72.48 is not applicable, proposed activity cannot be made without CoC amendment or exemption, 0i

2 10 CFR 72.48 is not applicable, more specific regulation applies.

3 10 CFR 72.48 is not applicable, proposed activity can be implemented without further review. . [

4 . 10 CFR 72A8 may be applicable, proceed t:3 screening.

5i Revised 10 CFR 71 application or CoC revision, or exemption required for transportation,

Should tho FSAR (O NO FSAR Change Notice (FcN) Number: Report ESbe revised?- I- QYES is the FCN Contingent? O YES O NO 1RCFpo2r48pd)(5)(iii? 9 NO10 VFR7,48Ud)0 (iiP ? [] N

Signature on Fili. " ..... Signature/13

Signature on File . .. Signature on File

)ate Signature/late • Signature/Date

A 10CFR72.48 Applicability and Form 3.5-1AREVA Revision 5TRANSNUCLEAR INC. 10CFR71 Review Page 2 of 3

LR No.: 721030-329

3. Description of Proposed Activity:

Following a 5.8 magnitude seismic event on August 23, 2011 at the North Anna site, Dominion and TN have performed multiple inspectionsof the North Anna ISFSI to determine its status as documented in ETE-NAF-2011-0170, Rev. 1. During these inspections it was noted thatthe HSM-H modules appeared to have shifted during the seismic event. The two non-conforming ISFSI conditions resulting from thisseismic event as summarized in TN NCR 2012-111 are listed below:

Non-Conforming Condition # 1:

Measurements of the gaps between adjacent HSM-H modules are documented in Attachments 2 and Attachment 3 of Dominion InspectionReport ETE-NAF-2011-0170, Rev. 1. Attachment 2 of the referenced ETE records the side-to-side gaps measured between the adjacentHSM-H bases as well as the adjacent roofs. Attachment 3 of the referenced ETE records the gaps between the back to back HSM-Hmodules.

TN Specification NUH-03-0218, section 5.7.D, requires that the gap between the adjacent roofs shall not exceed 0.75". For double rows,the gap between back-to-back roofs shall not exceed 0.75". In addition, section 5.7.C of TN Specification NUH-03-0218 requires maximumside-to-side contact and back-to-back contact (for double arrays) at the bases. Three roof-to-roof gaps measured between HSMs 13 & 15,23 & 25 and 24 & 26 exceed the maximum 0.75" roof-to-roof gap requirement (a maximum roof-to-roof gap of 1.25" exists between HSM-H24 and HSM-H 26). None of the gaps between the back-to-back roofs exceeded the 0.75" criteria. In addition, the base-to-base gapbetween HSM-H 24 and 26 is 1.0" with no contact while other base-to-base gaps are 0.75" or less and appear to be in contact.


Dominion Calculation CE-1974 Revision 0, "Soil Structure Interaction Analysis for ISFSI Pad # 2 for Revised Ground Motion Following8/23/11 Earthquake," determined that the peak seismic accelerations at the CG of the HSM-H resulting from the 8/23/11 seismic event areVertical = 0.39g, Longitudinal (North-South) = 0.56g, Transverse (East-West) = 0.29g. These values exceed the maximum accelerationvalues of 0.37g horizontally (longitudinal and transverse) and 0.2g vertical at the CG of the HSM-H as specified in the NUHOMS® HDUFSAR Section 3.9.9.10.2.

TN has prepared three Structural Calculations (Calculation 10494-183, 10494-185 and 10494-186) and one Shielding Calculation (10494-184) to address the above two non-conforming conditions.

This LR addresses the "use-as-is" disposition of the 2 non-conforming conditions listed above. It incorporates the results of TN's structuraland shielding analysis which demonstrate that the changes to the NUHOMS® HD System at the North Anna ISFSI due to the 8/23/11seismic event do not preclude its continued operation. Dominion intends to update its North Anna 72.212 Report using this LR as an input.

Notes:

1. NCR 2012-090 documents the earthquake damaged concrete areas of the HSM-H modules at the North Anna ISFSI. LR 721030-323 addresses the repair disposition.

2. TN NCR 2012-126 documents the vertical and horizontal misalignment measurements of the loaded and unloaded HSM-Hmodules at the North Anna ISFSI (Reference Dominion ETE-NAF-2012-0019). This non-conforming condition has been reworked(Reference Dominion ETE-NAF-2012-0089) and thus does not require a LR. Dominion ETE-NAF-2012-0019 also records theresults of the temperature measurements taken for the 13 loaded HSM-H modules.

4. Licensing references (FSAR, C of C, FCNs, etc.)

Part 72 Storage License

o Certificate of Compliance for Spent Fuel Storage Casks, No. 1030, Amendment 0 and 1.

o Appendix A to Certificate of Compliance No. 1030, NUHOMS® HD System Generic Technical Specifications.

o NUHOMS® HD Updated Final Safety Analysis Report, Revision 3 and the following approved FCNs:

721030-308, Rev. 0 721030-318, Rev. 0 721030-255, Rev. 0 721030-274, Rev. 0

721030-319, Rev. 0

Part 71 Transportation License

E-32352, "Application for Revision 5 to Certificate of Compliance No. 9302 for the Model No. NUHOMS®-MP197 Packaging,Docket No. 71-9302," dated March 02, 2012.

This application adds NUHOMSP-32PTH and 32PTH Type 1 DSC (along with several other payloads) as authorizedpayloads to CoC 9302 and is currently under NRC review.

5. General Applicability- Question A.

1. NUHOMS® HD System CoC 1030, Amendment 1, Technical Specification 4.2.2, "Storage Pad" states that "For sites for which soilstructure interaction is considered important, the licensee is to perform site specific analysis considering the effects of soilstructure interaction. Amplified seismic spectra at the location of the HSM-H center of gravity (CG) is to be developed based onthe SSI responses.....

A 10CFR72.48 Applicability and Form 3.5-1AREVA 10CFR71 Review Revision 5TRANSNUCLEAR INC. Page 3 of 3

LRNo.: 721030-329

In accordance with the requirements of the above Technical Specification 4.2.2, Dominion has performed an updated SSI analysisusing the same methodology as for the original Pad # 2 analysis but applying the actual ground acceleration time history recordedduring the more severe August 23, 2011 seismic event (Reference Dominion Calculation CE-1974, Revision 0, "Soil StructureInteraction Analysis of ISFSI Pad # 2 for Revised Ground Motion Following 8/23/11 Earthquake"). Calculation CE-1974 determinedthat the updated response spectra at the HSM-H CG are more severe than those described in the NUHOMS® HD UFSAR Section3.9.9.10.2 (See Non-Conforming Condition No. 2 listed above).

II. NUHOMS® HD System CoC 1030, Amendment 1, Technical Specification 4.6.3, "Site Specific Parameters and Analyses", lists 8parameters which are to be verified by the general licensee for applicability at their specific site. Item 8 states:

"8. Seismic loads of up to 0.3g horizontal and up to 0.2g vertical".

Per Dominion ETE-CEM-2012-0001, Revision 0, the peak ground acceleration recorded at the Unit 1 basemat for this event was 0.26gnorth-south, 0.1 1g east-west and 0.12g vertical. The strong ground motion lasted 3.1 seconds. These peak ground accelerations arebelow the limits of 0.30g horizontal and 0.20g vertical specified in Technical Specification 4.6.3.

Ill. Technical Specification 5.4, "HSM-H Dose Rate Evaluation Program", Item 3 specifies that the HSM-H dose rate limits may notexceed the following values:

a. 800 mrem/hr at the front bird screen,b. 2 mrem/hr at the door centerline, andc. 2 mrem/hr at the end shield wall exterior."

TN Calculation 10494-184 determines the dose rates on and around the HSM-H modules loaded with a 32PTH DSC containing 32design basis assemblies but with a maximum gap of 1.5" between adjacent HSM-H modules (non-confirming condition # 1 listedabove). As demonstrated in this calculation, the maximum dose rate limits at the 3 locations listed in TS 5.4.3 are not exceeded.

Hence, no changes are required to CoC 1030 or the associated Technical Specifications for the continued operation (loading and storage) ofthe NUHOMS® HD System ISFSI at the North Anna site to address the "use-as-is" disposition of the two non-conforming conditions listedabove.

A Form 3.5-2AREVA 10CFR72.48 Screening TIP 3.5 (Revision 5)TRANSNUCLEARZ INC. Page 1 of 2

LR No.: 721030-329 Rev. 0

A. Does the proposed activity involve a change to a system structure or component that would adversely affect adesign function described in the UFSAR? The answer must be yes for any alteration to a design basis limit for afission product barrier, adverse or not. (IF NO, PROVIDE JUSTIFICATION)

The proposed activity involves the "use-as-is" disposition of the 2 non-conforming conditions listed in TN NCR 2012-111for the NUHOMS® HSM-H modules at the North Anna ISFSI site. See LR 721030-329 (Form 3.5-1) for a briefdescription of the 2 non-conforming HSM-H conditions resulting from the seismic event at the North Anna site on8/23/2011.

The "use-as-is" disposition of TN NCR 2012-111 of the HSM-H modules at the North Anna site may adversely affect thefollowing design functions of the HSM-H System described in the NUHOMS® HD UFSAR:

* Gaps of up to 1.25" between adjacent HSM-H modules may adversely affect the shielding function of theHSM-H as described in the NUHOMS® HD UFSAR.

" The peak seismic acceleration values at the CG of the HSM-H determined in Dominion Calculation CE-1974[Vertical = 0.39g, Longitudinal (North-South) = 0.56g, Transverse (East-West) = 0.29g] exceed the peakacceleration values specified in the NUHOMS® HD UFSAR Section 3.9.9.10.2 [Vertical = 0.2g, horizontal = Conclusion:0.37g (longitudinal and transverse)]. This non-conforming condition may adversely affect the HSM-H 0 YESstructural design function as described in the NUHOMS® HD UFSAR. NO

" The original analysis for the DSC used seismic acceleration values of 0.65g axial, 0.65g transverse, and 1.3gvertical (includes dead weight) as specified in the NUHOMS® HD UFSAR Section 3.9.1.2.3.C. TN Calculation10494-0185 determined that the revised seismic accelerations, as a result of the 8/23/2011 seismic event, are0.24g axial, 0.57g transverse, and 1.38g vertical. This non-conforming condition may adversely affect theDSC structural design function as described in the NUHOMS® HD UFSAR.

The HSM-H does not perform any confinement or criticality design function. However, the DSC has a confinement andcriticality design function.

The presence of gaps of up to 1.25" between the adjacent HSM-Hs due to non-conforming condition No. 1 allows theinlet vent to have direct access to ambient which reduces the flow resistance and increases the amount of airflow. Thegaps are actually beneficial to the cooling of the HSM-H and do not affect the thermal function adversely. Therefore, itcan be concluded that the thermal design function of the HSM-H modules is not adversely affected as a result of non-conforming conditions #1 and 2. Side-to-side gaps exceeding TN Specification NUH-03-0218 do not create anunanalyzed thermal condition nor change the HSM-H thermal design parameters as described in the NUHOMS® HDUFSAR. All inlet and outlet vents have been visually inspected after the seismic event and no blockage has beenreported (Reference Dominion evaluation ETE-NAF-2012-0019).

B. Does the proposed activity involve a change to a procedure that would have an adverse affect on the method ofperforming or controlling a design function described in the UFSAR? (IF NO, PROVIDE JUSTIFICATION)

No. As noted in TN NCR 2012-126, the horizontal and vertical misalignment condition created by the 8/23/11 seismicevent in the HSM-H modules at the North Anna ISFSI have been reworked in accordance with applicable stationprocedures, work orders and TN Specifications (Reference: Dominion ETE-NAF-2012-0089). Also, the damaged Conclusion:concrete areas of the HSM-H modules affected by the 8/23/11 seismic event have been repaired in accordance with TN C YESNCR 2011-090. Hence, the loading/unloading of the NUHOMS® 32PTH DSC into/from the HSM-H modules at the North 0 NOAnna ISFSI is not adversely affected.

The "use-as-is" disposition of the 2 non-conforming conditions at the North Anna ISFSI listed above does not involve anychange to the procedures described in the NUHOMS® HD UFSAR Chapter 8. The proposed activity does not involve achange to the method of performing or controlling a design function described in the UFSAR.

, .Form 3.5-2I 0CFR72.48 Screening TIP 3.5 (Revision 5)

TErLPNUCLEAK , CO _ "___ Page 2 of 2

LR No.: 721030-329 Rev. 0

C. For methods of evaluation described in the UFSAR, used in the safety analyses or to establish designbases, does the proposed activity involve

. changes to elements of the method that would represent use of the method outside the constraintsand limilaNorm of the method, or

I. replacement by a different method? (IF NO, PROVIDE JUSTIFICATION)::

.-Yes, TN Calculation 10494-183 uses the more severe response spectra determined in Dorrinien Calculation CE-1974as Input to the dynamic seismic analysis Which uses the LS-DYNA code for the determination of the maximum values ofhorizontal sliding and rocking uplift response of the HSM-l and 32PT1 DSC. The use of dynamic seismic analysis forthe HSM-H represents a replacement of the stati seismic analysis described In. Appendix 2.9.9, Sectlork 3.9.9.10.2 ofthe NUHOMS HD UFSAR- 7

No. TN Calculation 10494-184 performed a ie-evalwation of HSM-H dose rates utilizing a more recent version of theMCNP computer code MCNP5 V1,40. The shielding analysis results calculated In TN Calculation 10494-184 determinethe Increase In dose rates due to gaps between adjacent HSM4H modules which are then added to the dose ratescalulated in the UFSAR. This ensures that the absolute dose rates that are employed to demonstrate compliance toapplicable limits are based on the dose rates calbulated in the UFSAR, Further, the differences between the dose ratescalbulated using MCNP5 V1 .40 and the MCNP4C2 (UFSAR) were mostly within 2% with the maximum difference ofapproximately 9.5% (in TN Calculation 10494-1154) Indicating that the dose rate results from these versions are Costastically simril-r. Therefore, there is no deparlure from the method of evaluation described In the UFSAR. c l YES

No. Section 2.2.31 of the NUHOMS* NO UFSAR notes that the design basis response spectra of NRC Regulatory ' NO

Gukde 1.60 are selected as the design earthquake for determilning the seismic accelerations for the HSM-H (and' p-ssocialed componients) and the DSC. The use of these spectra determrines the accelerations that are utilized for the:downstream UFSAR safety analyses such as the concrete HSM-H which utilizes the ultimate strength method inaccordance with ACI 349 (see Section 3.9.9.5). In lieu of Regulatory Guide 1.60, the response spectra at the CG of theHSM¶-H have been developed in Dominion Calculation CE-1974 by utilizing soil structure interaction analysis using thepeak ground acceleration recorded during the 8W23tIl North Anna seismic event. The safety analysis methodologiesdescribed in the UFSAR, for example the ACI 349 ultimate strength method, do notrequire that the input parameter (I.e.,the seismic accelerations at the CG) be calculated in a specific manner. Therefore, it can be concluded that the use ofsoil structure interaction analysis does not constitute a change In the element of a safety analysis method and istherefore not a change In analysis methodology. In addition to this, Footnote 2 on Page 2 of Regulatory Guide 1.60'notes that its Figure 1 response spectro Is not applicable to sites which am relatively close to the epicentaf Of anearthquake. The 1/23111 seismic event's epicenter was about 1I miles from North Anna and therefore the use ofRegulatory Guide 1.60 is not applicable and therefore development of the seismic accelerations via the use of soil -

structure Interaction analysis is appropriate.

No. TN ShIelding Calculation 104,4-184 was performed using the same method as descrtbed in the NUHOMS*t 110U.FSAR Chapter 5. TN Structural Calculations 10494-185 Mnd 10494-186 were also performed using the same methodsas described in the NUHOMS' HO UFSAR Chapter 3.

_. Does Ila proposed activity represent a test or experiment not described In the UFSAR, I.e., does It repreentutilization or control of an SSC or the system outside the reference bounds of the design or Inconsistent with theanalysis or the description in the UFSAR? (iF NO, PROVIDE JUSTIFICATION)

No. The proposed activity involves the 'use-as-Is' disposition of the 2 non-conforming conditions listed in TN NCR2012-111. This is not a test or experiment not described in the NUHOMS HD UFSAR. No system testing is required. Conclusion:not changes to any dry runs. Therefore, this change does not Involve a test or experiment not described In the [] YESNUJN NOMS"O 1D UFSAR. - . ,NO,

• . ... . . •.a

CONCLUSION: (check onel

All antwers "NO"; the proposed activity soreens out, and may be implemented without further evaluation I]The change must be evaluated to determine if It may be Implemented without an amendment to the Certificateof Compliank~. Proceed to evaluartion. ___________j .

Prpared By Verifted By -tApproved By

Signature on File i Signature on File Signature on File- Sinaii~~e sgnaurenat -- Slgnatu refi'Oae

Form 3.5-3 :TIP 3.5 (Revision 5)

•10CFR72.48 Evaluation Page 1 of 14IRA)HNUCLF. R IN.G.

LR No. 721030-329, Rev. 0

1.0 DESCRIPTION (Briefly describe the change that is being addressed by the Evaluation. Refer to Drawings,Calculations, DCRs, NCRs, as required.)

See Page 2

2ý0 REFERENCES (State references such as UFSAR sections, Drawings, Calculations, Specifications, DCRs,.

NCRsjSee Page 2.

3.0 COMPONENTS AFFECTED (Staee the specific components of the system affected.)

See Page 3.

4.0 DESIGN FUNCTIONS OF THE AFFECTED COMPONENTS :(&,efly state the funQtions of the affectedcomponents as they are documented in the UFSAR)

See Page 3..5.0 EFFECTS ON DESIGN FUNCTION (D&escribe in detail the effect, if any, of the change on the safety function

ofthe equipment.)

See Page 3.

6.0 72.48 EVALUATION CRITERIA (See following sheet)

See Page 10.

a'n ,--.,r- * ,,o-, ts ,_. _ . ...- --I IV CONCLUSION lcheck onal

All answers under 6.0 "NO"; the change may be implemented without an amendment to theCertificate of Compliance

Any answer under 6.01 "YES'; the change may not be implemented without an amendmentto theC of C F-

Signature on File

Prepared By Date.

Signature on File

Approved By Date

Signature on File

Verified By ... Dte

Signature on File

Approved By Date, . .,Date,, I

Form 3.5-3A TIP 3.5 (Revision 5)

AREVA 10CFR72.48 Evaluation Page 2 of 14TRANSNUCLEAR INC.

LR No. 721030-329, Rev. 0_

1.0 DESCRIPTION

Following a 5.8 magnitude seismic event on August 23, 2011 at the North Anna site, Dominion and TN haveperformed multiple inspections of the North Anna ISFSI to determine its status as documented in ETE-NAF-2011-0170 [15]. During these inspections it was noted that the HSM-H modules appeared to have shifted during theseismic event. The two non-conforming ISFSI conditions resulting from this seismic event as summarized in TNNCR 2012-111 [9] are listed below:


Measurements of the gaps between adjacent HSM-H modules are documented in Attachments 2 and Attachment3 of Dominion Inspection Report ETE-NAF-2011-0170 [15]. Attachment 2 of the referenced ETE records the side-to-side gaps measured between the adjacent HSM-H bases as well as the adjacent roofs. Attachment 3 of thereferenced ETE records the gaps between the back to back HSM-H modules.

TN Specification NUH-03-0218, section 5.7.D, requires that the gap between the adjacent roofs shall not exceed0.75". For double rows, the gap between back-to-back roofs shall not exceed 0.75". In addition, section 5.7.C ofTN Specification NUH-03-0218 requires maximum side-to-side contact and back-to-back contact (for doublearrays) at the bases. Three roof-to-roof gaps measured between HSMs 13 & 15, 23 & 25 and 24 & 26 exceed themaximum 0.75" roof-to-roof gap requirement (a maximum roof-to-roof gap of 1.25" exists between HSM 24 andHSM 26). None of the gaps between the back-to-back roofs exceeded the 0.75" criteria. In addition, the base-to-base gap between HSM 24 and 26 is 1.0" with no contact while other base-to-base gaps are 0.75" or less andappear to be in contact.

Non-Conformingq Condition # 2:

Dominion Calculation CE-1974 Revision 0, "Soil Structure Interaction Analysis for ISFSI Pad # 2 for RevisedGround Motion Following 8/23/11 Earthquake," [8] determined that the peak seismic accelerations at the CG of theHSM-H resulting from the 8/23/11 seismic event are Vertical = 0.39g, Longitudinal (North-South) = 0.56g,Transverse (East-West) = 0.29g. These values exceed the maximum acceleration values of 0.37p horizontally(longitudinal and transverse) and 0.2g vertical at the CG of the HSM-H as specified in the NUHOMS HD UFSARSection 3.9.9.10.2.

TN has prepared the following calculations to address the above two non-conforming conditions:

* TN Calculation 10494-183, Revision 0, "HSM-H Seismic Stability Evaluation for 8/23/11 Seismic Event,"[4].

" TN Calculation 10494-184, Revision 0, "Impact on the HSM-H dose rates due to gaps between HSM-Hmodules - NUHOMS®-32HD," [5].

" TN Calculation 10494-185, Revision 0, "32PTH DSC Structural Evaluation for 08/23/11 Seismic Event,"[6].

* TN Calculation 10494-186, Revision 0, "HSM-H Structural Evaluation for 8/23/11 Seismic Event," [7].

This LR addresses the "use-as-is" disposition of the 2 non-conforming conditions listed above. It incorporates theresults of TN's structural and shielding analysis which demonstrate that the changes to the NUHOMS® HD Systemat the North Anna ISFSI due to the 8/23/11 seismic event do not preclude its continued operation.

Dominion intends to update its North Anna 72.212 Report using this LR as an input.

2.0 REFERENCES

1 NUHOMS® HD System Updated Final Safety Analysis Report, (UFSAR), Revision 3, and approvedFCN's.

2 "Certificate of Compliance for Spent Fuel Storage Casks," 10 CFR Part 72, Certificate Number 1030,Amendment 1.

3 Appendix A to the Certificate of Compliance No. 1030, NUHOMS® HD System Generic TechnicalSpecifications.


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LR No. 721030-329, Rev. 04 TN Calculation 10494-183, Revision 0, "HSM-H Seismic Stability Evaluation for 8/23/11 Seismic Event."

5 TN Calculation 10494-184, Revision 0, "Impact on the HSM-H dose rates due to gaps between HSM-Hmodules - NUHOMS®-32HD."

6 TN Calculation 10494-185, Revision 0, "32PTH DSC Structural Evaluation for 08/23/11 Seismic Event."

7 TN Calculation 10494-186, Revision 0, "HSM-H Structural Evaluation for 8/23/11 Seismic Event."

8 Dominion Calculation CE-1974, Revision 0, "Soil Structure Interaction for ISFSI Pad # 2 for RevisedGround Motion Following 8/23/11 Earthquake."

9 TN NCR 2012-111.

10 Regulatory Guide 1.60, Revision 1, "Design Response Spectra for Seismic Design of Nuclear PowerPlants," U.S. Atomic Energy Commission, December 1973.

11 Regulatory Guide 1.61, Revision 0, "Damping Values for Seismic Design of Nuclear Power Plants," U.S.Atomic Energy Commission, October 1973.

12 NUH-003, Updated Final Safety Analysis Report (UFSAR) for the Standardized NUHOMS® HorizontalModular Storage System for Irradiated Nuclear Fuel, Revision 12, and approved FCN's.

13 "Certificate of Compliance for Spent Fuel Storage Casks," 10 CFR Part 72, Certificate Number 1004,Amendment 10.

14 NEI 96-07, Revision 1, Appendix B, "Guidelines for 10 CFR 72.48 Implementation," March 2001.

15 Dominion ETE-NAF-2011-0170, Rev. 1.

3.0 COMPONENTS AFFECTED

NUHOMS® HSM-H.

4.0 DESIGN FUNCTIONS OF THE AFFECTED COMPONENTS

The NUHOMS® HSM-H protects the NUHOMS® 32PTH DSC from the potentially adverse effects of naturalphenomena hazards, such as earthquake, tornado, tornado missiles, flood, and extreme ambient conditions. Themassive concrete walls of the HSM-H base and roof provide substantial neutron and gamma shielding. The HSM-Hdissipates decay heat from the spent fuel by a combination of radiation, conduction, and convection. Ambient airenters along the bottom side walls of the HSM-H, flows around the 32PTH DSC and exits through the flow channelsbetween the HSM-H roof slab and the upper side walls. The cross-sectional areas of the air inlet and outletopenings, and the interior flow paths are designed to optimize ventilation air flow within the HSM-H for optimal decayheat removal. Thermal radiation heat shields are used to reduce the HSM-H concrete temperatures to withinacceptable limits for all conditions.

5.0 EFFECTS ON DESIGN FUNCTION

5.1 DESIGN CRITERIA

The seismic design criteria for the HSM-H are based on NRC Regulatory Guide 1.60 (R.G.) [10]. Asstated in the NUHOMS® HD UFSAR Section 2.2.3.1, the response spectra are anchored to a maximumground acceleration of 0.30g for the horizontal components and 0.20g for the vertical component. Theresults of the frequency analysis of the HSM-H structure (which includes a simplified model of the DSC)yield a lowest frequency of 23.2 Hz in the transverse direction and 28.4 Hz in the longitudinal direction.The lowest vertical frequency exceeds 33 Hz. Thus, based on the R.G. 1.60 response spectraamplifications, the corresponding seismic accelerations used for the design of the HSM-H are 0.37g and0.33g in the transverse and longitudinal directions, respectively, and 0.20g in the vertical direction. Thecorresponding accelerations applicable to the 32PTH DSC are 0.41g and 0.36g in the transverse andlongitudinal directions, respectively, and 0.2g in the vertical direction.

Dominion Calculation CE-1974 Revision 0, "Soil Structure Interaction Analysis of ISFSI Pad # 2 forRevised Ground Motion Following 8/23/11 Earthquake," [8] determined that the peak seismicaccelerations at the CG of the HSM-H resulting from the 8/23/11 seismic event are Vertical = 0.39g,Lonqitudinal (North-South) = 0.56a. Transverse (East-West) = 0.29a. These values exceed the

aF Form 3.5-3

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LR No. 721030-329, Rev. 0maximum acceleration values of 0.37g horizontally (longitudinal and transverse) and 0.2g vertical at theCG of the HSM-H as specified in the NUHOMS® HD UFSAR Section 3.9.9.10.2.

5.2 STRUCTURAL EVALUATION

5.2.1 NUHOMS® HSM-H Structural Evaluation

The increased seismic accelerations determined in Dominion Calculation CE-1974 [8] are rounded upconservatively as listed below in TN Calculation 10494-186 [7]:

" Vertical = 0.4g

* Side-to-Side = 0.6g and

" Front-to-Back = 0.3g.

As documented in UFSAR Table 3.9.9-3 and 3.9.9-6, load combinations COMB4C and COMB4S havebeen used for the seismic evaluation of the concrete components and support steel respectively.

Load Combination COMB4C for evaluating HSM-H Concrete:

U > DW + LL + TN + EQ

Where,

U = Required Strength

DW = Dead Weight

LL = Live Load

TN Normal Operating Thermal Load

EQ Earthquake Load

Load Combination COMB4S for evaluating HSM-H Support Steel Structure:

(1.6S or 1.4Sv) > DW + LL + TN + EQ

Where,

S = Required Steel Strength

Sv = Required Steel Strength for Critical Sections

TN Calculation 10494-186 [7] evaluates the HSM-H concrete and steel components by recalculating theseismic loads for COMB4C and COMB4S load combinations using the increased seismic accelerationslisted above. Table 1 below presents the results for the COMB4C load combination from [7] for theHSM-H concrete components (See UFSAR Table 3.9.9-11 for nomenclature).


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LR No. 721030-329, Rev. 0

Table IEvaluation of Load Combination COMB4C for the HSM-H Concrete Components

T1 T1 T T2 T2Concrete Q Vi V0o V02 M1 M 2 Tension Comp. Tension Comp.

Component Quantt kips/ft kips/ft kips/ft kip-in/ft kip-in/ft kion C ip./Tenion Cip.kips/ft kips/ft kips/ft kips/ft

Computed 8.26 4.16 2.39 25.66 81.32 12.72 25.33 9.59 33.31Rear Wall Capacity 76.80 14.50 14.50 305.90 305.90 63.00 379.00 63.00 379.00(upper)~

Ratio 0.11 0.29 0.16 0.08 0.27 0.20 0.07 0.15 0.09

Computed 17.00 8.58 4.99 67.14 87.22 3.61 61.54 27.51 69.33Rear Wall Capacity 98.40 36.20 36.20 778.10 778.10 63.00 807.40 63.00 807.40(lower).

Ratio 0.17 0.24 0.14 0.09 0.11 0.06 0.08 0.44 0.09

Computed 9.34 4.53 4.68 96.02 64.77 23.38 120.44 16.39 31.77Side Walls Capacity 55.40 14.80 14.80 202.10 202.10 40.30 365.90 40.30 365.90

(upper).Ratio 0.17 0.31 0.32 0.48 0.32 0.58 0.33 0.41 0.09

Computed 25.74 12.10 9.79 111.24 160.31 31.88 104.72 28.55 32.73Side Walls Capacity 64.00 23.40 23.40 322.90 322.90 40.30 537.30 40.30 537.30

(lower).Ratio 0.40 0.52 0.42 0.34 0.50 0.79 0.19 0.71 0.06

Computed 5.51 6.39 12.95 136.66 489.57 4.49 9.34 14.25 18.55

Roof Capacity 177.6 59.10 59.10 2438.10 2438.10 120.90 1326.2 120.90 1326.2

.Ratio 0.03 0.11 0.22 0.06 0.20 0.04 0.01 0.12 0.01

Computed 26.34 25.74 20.64 929.55 1824.02 41.44 29.45 18.58 73.65Front Wall Capacity 174.7 56.30 56.30 2317.20 2317.20 120.90 1269.1 120.90 1269.1

Ratio 0.15 0.46 0.37 0.40 0.79 0.34 0.02 0.15 0.06

Computed 33.80 38.30 27.53 1555.04 765.87 65.65 94.26 79.80 166.71Front Wall Capacity 192.1 73.60 73.60 3042.50 3042.50 120.90 1611.8 120.90 1611.8(lower).

Ratio 0.18 0.52 0.37 0.51 0.25 0.54 0.06 0.66 0.10

As seen from Table 1 above, the maximum ratio is 0.79 (for the HSM-H Upper Front Wall and theLower Side Wall) which is less than 1.0. All the HSM-H concrete components remain qualified post8/23/11 seismic event. The limiting load case for the HSM-H concrete components is the blocked ventaccident condition (load combination 7c) as reported in UFSAR Table 3.9.9-11 with a maximum ratio of0.97.

The interaction ratios/stress ratios for the COMB4S load combination determined in [7] for the HSM-Hrail, extension plates and the cross members are as listed below in Table 2:


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LR No. 721030-329, Rev. 0_

Table 2Evaluation of Load Combination COMB4S for the HSM-H Steel Components

Component Maximum UFSAR Maximum UFSARInteraction Maximum Stress Ratio Maximum

Ratio [7] Interaction [7] Stress Ratio [1]Ratio [1]

HSM-H Rails 0.56 0.51 0.90 0.96

HSM-H 0.76 0.60 0.05 0.60Extension Plates

HSM-H Cross -- -- 0.23 0.25Members

As seen from Table 2 above, the maximum stress ratio for HSM-H rails, extension plates and cross-members are each less than 1.0 and thus remain acceptable post 8/23/11 seismic event.

The top heat shields, side heat shields, and various embedments of the HSM-H components have allbeen re-evaluated in [7] with the increased seismic accelerations. Each of these components remainsqualified.

5.2.2 NUHOMS® 32PTH DSC Structural Evaluation

The seismic loads used for the 32PTH DSC and the basket analysis in the HD UFSAR Appendix 3.9.1,(See UFSAR Tables 3.9.1-19 and 3.9.1-5) are as follows:

* Transverse = 0.65g

" Longitudinal = 0.65g

* Vertical = 0.3g

The above listed seismic loads envelope the 32PTH DSC seismic loads determined in UFSAR section2.2.3.1. Further, the UFSAR analysis conservatively compares the calculated loads against the lowerASME Level A stress limits instead of Level C stress limits.

TN Calculation 10494-185 [6] uses the increased spectral response determined in Dominion CalculationCE-1974 [8] and applies a damping value of 4% in accordance with Regulatory Guide 1.61 [11] todetermine the new acceleration levels. These values are listed in Table 3. Also shown are the valuesused in the UFSAR 32PTH DSC analysis (See UFSAR Table 3.9.1-19).

Table 3

Maximum Acceleration g-Load Based on Response Spectra from [8]

32PTH DSC UFSAR 32PTHDirection Frequency Maximum DSC Maximum(Hz) Acceleration [6] Acceleration [1]

Axial 60.4 0.24g 0.65gTransverse 54.4 0.579 0.659

Vertical 54.4 1.38g 1) 1.30g91)

Note 1: Includes 1 g down for dead weight.

As shown in Table 3 above, only the vertical acceleration load is increased relative to the UFSARvalues. However, Calculation 10494-185 [6] conservatively scales up the UFSAR loads in all threedirections by the same ratio of 1.38/1.30 or 1.06 for determining the DSC stresses. Also, consistent with



LR No. 721030-329, Rev. 0_

the UFSAR analysis, the calculated stress loads are conservatively compared to ASME Level Aallowable limits. The limiting results from [6] for the DSC, basket and rail are summarized in Table 4.

Table 4

32PTH DSC and Basket Stress Results under Normal and Accident Conditions

Component Loads New Stress Allowable StressIntensity [6] Stress Ratio

DSC 30 psig Internal 30.37 54.3 0.56Pressure +

Seismic Load +Thermal (-20 F)

Basket Seismic 9.33 16.0 0.58

Rails Seismic + Normal 27.16 49.2 0.55Thermal

Based on the results shown in Table 4 above, all the stress ratios are less than 1.0. Hence, the 32PTHDSC and basket remain structurally adequate for the increased seismic loads resulting from the NorthAnna seismic event of 8/23/11.

5.2.3 Time History Evaluation of the HSM-H and 32PTH DSC

Appendix 3.9.9, Section 3.9.9.10.2 of the HD UFSAR [1] performs a seismic equivalent static analysisfor a HSM-H module loaded with a 32PTH DSC.

To demonstrate that no significant load is applied on the 32PTH DSC due to its uplifting during the8/23/11 seismic event, a seismic non-linear time history analysis of a loaded and unloaded HSM-H isperformed using a methodology consistent with that described in Appendix U, Chapter U.3.7 of theStandardized NUHOMS® UFSAR [12]. This methodology has been approved by the NRC for aNUHOMS® HSM-HS module loaded with a 32PTH1 DSC [13]. The NUHOMS® HSM-HS is almostidentical to the NUHOMS® HSM-H module, and thus the use of LS-DYNA code for performing adynamic analysis of HSM-H meets the test of "intended application" specified in NEI 96-07 guidance[14].

This dynamic seismic analysis uses the LS-DYNA 3-D element model of the HSM-H. The maximumacceleration time histories in all three directions obtained from the Dominion SSI analysis [8] are appliedsimultaneously to the HSM-H model in Calculation 10494-183 [4]. Two configurations are analyzed:

* A loaded HSM-H with one rear shield wall and a concrete pad (Model I)

* A loaded HSM-H with one rear shield wall, one end shield wall, one corner wall and a concretepad (Model II).

A minimum coefficient of friction value of 0.2 is used in runs to maximize the sliding displacement, whilea maximum coefficient of friction of 0.8 is used to maximize the vertical uplifting movement.

The results of TN Calculation 10494-183 [4] are as follows:

* The tipping/uplift vertical response is negligibly small for model II, but relatively large for model I.

" Sliding is the primary mode of response of the HSM-H when the friction coefficient is 0.2, whilethe uplifting/rocking is relatively large with friction coefficient of 0.8.

" For friction coefficient of 0.2, the maximum sliding displacements are on the order of 1.221" inthe horizontal X-direction and 0.110" in the horizontal Y-direction. For friction coefficient of 0.8,the maximum sliding displacements are on the order of 0.009" in the horizontal X-direction and



LR No. 721030-329, Rev. 00.013" in the horizontal Y-direction. The maximum uplift is 0.687" for the worst case with frictioncoefficient of 0.8. The maximum rocking is 0.170" and 0.705", about x and y for the worst case.

It is clear from DSC displacement time histories that because of the vertical seismic load, theuplift of DSC from the support rails is instantaneous which is insufficient for the DSC todisengage from the support rails. This demonstrates that the DSC maintains its position andremains constrained within the HSM-H DSC steel support structure.

5.3 SHIELDING EVALUATION

The UFSAR shielding performance of the HSM-H containing a 32PTH DSC loaded with design basisfuel assemblies generating design basis radiological sources was performed using the three-dimensional Monte Carlo particle transport computer code, MCNP, Version 4C2. The evaluationperformed in TN Calculation 10494-184 [5] utilizes a different version of MCNP, MCNP5 version 1.40. Abaseline evaluation is first made in [5] to compare the UFSAR [1] results to those calculated usingMCNP5 version 1.40. The results of this evaluation show that the differences between MCNP4C2 andMCNP5 are within acceptable statistical uncertainty.

TN Calculation 10494-184 [5] is performed to determine the effect of gaps between the HSM-H modulesusing design basis source terms. This shielding calculation models a maximum uniform gap of 1.5"between the HSM-H modules and between the HSM-H modules and the rear shield wall. This isdefined as the "new normal" condition for the North Anna ISFSI following the 8/23/11 seismic event andenvelopes the non-conforming condition # 1 of TN NCR 2012-111.

Dose rates are also determined with a maximum uniform gap of 4.0" between the HSM-H modules andbetween the HSM-H modules and the rear shield wall. This condition assumes an additional seismicevent which is equivalent to the 8/23/11 event and is considered an accident condition. Calculation10494-183 [4] had determined that the 8/23/11 seismic event produces a maximum HSM-Hdisplacement of 1.22" in either direction. This displacement when added to an initial maximum gap of1.5" yields a maximum gap of 4.0" for this accident condition.

A summary of the HSM-H maximum and average dose rates calculated in [5] with 1.5" gap and 4.0" gapare presented in Table 5 and Table 6, respectively.

Table 5

Maximum Maximum Maximum TotalTotal (mrem/hr)

Dose Rate (mrem/hr) (mrem/hr) 4.0"Gap -(mocation 1.5"Gap -4O"a-Location UFSAR [1] - Normal Accident

No gap Condition Condition

HSM-H Roof 170.0 228.2 314.5Birdscreen

HSM-H Front 752.0 752.0 1000.2Birdscreen

HSM-H End(Side) Shield 1.4 1.42 NAWall Surface

HSM-H 1.6 1.68 NA


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LR No. 721030-329, Rev. 0

Table 6

Average Total Average Total Average TotalDose Rate (mrem/hr) (mrem/hr) (mrem/hr)Location UFSAR - No gap 1.5"Gap - Normal 4.0"Gap - Accident

Condition Condition

HSM Roof 15.85 20.85 41.0

HSM Front 20.77 22.73 33.44

Table 7 shows the estimates of the annual dose for 2x10 array ISFSI for the new normal and accident

conditions.

Table 7

ISFSI Annual Dose at 200m for the 2x10 Array - 100% Occupancy

Dose Annual Dose Annual Dose Annual DoseLocation (mrem) (mrem) (mrem)at 200m UFSAR - No 1.5"Gap - Normal 4.0"Gap - Accident

from ISFSI gap Condition Condition

Front of 89 120 240Array

Side of Array 57 80 160

The increase in dose at the site boundary is proportional to the number of loaded HSM-H modules in thearray with gaps. As shown in Table 7, for a 1.5" gap in a 20-module array, the increase in the annualdose at the site boundary at 200m is approximately 30 mrem and is an insignificant increase comparedto the applicable limit per 10 CFR 72.106 (b) discussed below. For a 4.0" gap in a 20-module array, theincrease in the annual dose at the site boundary at 200m is approximately 150 mrem and again is aninsignificant increase compared to the applicable limit per 10 CFR 72.106 (b) discussed below.

The applicable limit per 10 CFR 72.106 (b) is that the dose at the site boundary is limited to 5000 mremper accident. At an assumed site boundary distance of 200m, the maximum calculated dose rate with auniform 4.0" gap between each module for a 40-module array is less than 500 mrem. For the NorthAnna ISFSI with a site boundary of approximately 800m and a 26-module array with a non-uniform gapbetween HSM-H modules, the annual dose at the site boundary due to the ISFSI is expected to beinsignificant (less than 0.5 mrem).

5.4 THERMAL EVALUATION

The thermal design function of the HSM-H modules is not adversely affected as a result of non-conforming conditions #1 and 2. Side-to side gaps exceeding TN Specification NUH-03-0218 do notcreate an unana•zed thermal condition nor change the HSM-H thermal design parameters as describedin the NUHOMS HD UFSAR. All inlet and outlet vent have been visually inspected after the seismicevent and no blockage has been reported (Reference Dominion evaluation ETE-NAF-2012-0019).

5.5 CRITICALITY EVALUATION

The HSM-H does not perform any criticality design function. However, the DSC does have a criticalitydesign function. Section 5.2.2 of the Evaluation discusses the structural evaluation of the DSC due to


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LR No. 721030-329, Rev. 0the increased seismic loads and notes that the stress ratios still remain well below 1.0. As a result ofthis, it can be concluded that the DSC remains structurally unaffected by the increased seismic loadsand therefore the criticality function of the DSC is maintained and not affected.

5.6 CONFINEMENT EVALUATION

The HSM-H does not perform any confinement design function. However, the DSC does have aconfinement design function. Section 5.2.2 of the Evaluation discusses the structural evaluation of theDSC due to the increased seismic loads and notes that the stress ratios still remain well below 1.0. Asa result of this, it can be concluded that the DSC remains structurally unaffected by the increasedseismic loads and therefore there is no impact on the confinement capabilities of the DSC.

6.0 72.48 EVALUATION CRITERIA (In this section, a response to the following questions is required along with anexplanation of each answer.):

A review of the NUHOMS® HD UFSAR [1] results in the following table. It lists all the Accident Load Cases describedin the UFSAR, along with the frequency and the public dose consequences.

ACCIDENT LOAD CASES

Accident/ Incremental Dose ConsequenceEnvironmental FrequencyPhenomena Direct Radiation Effluent Release

No off-site doseComplete Debris Frequency not No off-site dose consequences consequencesblockage of HSM-H Air specified, assumedInlet and Outlet Openings to be One Time (UFSAR 11.3.6, A.11.3.6) (UFSAR 11.3.6,

A. 11.3.6).

Off-site individuals at 100m willTornado Winds and receive doses of 0.0413 mrem/hrGenerated Missiles Natural Phenomena or 0.33 man-mrem in 8 hours. None(HSM-H) (UFSAR Table 10-6, UFSAR

11.3.3.5, A.11.3.3)

Bounded by loss of NeutronTomrado Winds and Natural Phenomena Shield for TC Drop NoneGenerated Missiles (TC) (UFSAR 11.3.4.3, A.11.3.4.3)

NoneDesign Basis Earthquake Natural Phenomena None(UFSAR 11.3.2, A.11.3.2)

"not sufficient to be aNone radiological hazard"

Design Basis Flood Natural Phenomena(UFSAR 11.3.5, A.11.3.5) (UFSAR 11.3.5

A.11.3.5)

Offsite Individuals at 100m will No potential for

Transfer Oask Drop with Frequency not receivel.3 mrem/hr or 10.4 man- release of radioactiveLoss of Neutron Shield specified, assumed mrem in 8 hours materialsto be One Time (UFSAR Table 5-23, UFSAR (UFSAR 11.3.1,

11.3.1, A.11.3.1) A.11.3.1)

No radiologicalNo radiological consequences consequences(UFSAR 11.3.7, A.11.3.7) (UFSAR 11.3.7,

A. 11.3.7)

Postulated DSC Leakage(UFSAR 7.2.1, A.7.2: No None None Nonecredible accident canbreach DSC)



LR No. 1721030-329, Rev. 0

ACCIDENT LOAD CASES

Accident/ Frequency Incremental Dose ConsequencePressurization of DSC Frequency not No off-site doseinterior due to cladding specified, assumed No off-site dose consequences consequencesfailure within DSC to be One Time (UFSAR 7.2.2, A.7.2) (UFSAR 7.2.2, A.7.2)

A review of the above Table shows that the design basis earthquake is the only accident load case which is affectedby the changes addressed in this LR.



LR No. 721030-329, Rev. 0

1) Does the change result in more than a minimal increase in the frequency of an accident previously evaluated

in the UFSAR?

No. For this change, the relevant accident is a seismic event. The frequency of natural phenomena accidents isunchanged. As discussed in Section 5.0 above, the primary safety function of the NUHOMS® HSM-H modulesto provide shielding and maintain structural integrity against the potentially adverse effects of the 8/23/11 NorthAnna seismic event is not adversely affected. Hence the change does not result in more than a minimalincrease in the frequency of an accident previously evaluated in the UFSAR.

2) Does the change result in more than a minimal increase in the likelihood of occurrence of a malfunction ofsystem, structure or component (SSC) important to safety previously evaluated in the UFSAR?

No. As discussed in Section 5 above, the structural integrity and shielding performance of the HSM-H and the32PTH DSC are not challenged by the 8/23/11 North Anna seismic event. The HSM-H remains in compliancewith the allowable criteria (structural, shielding, thermal, criticality and confinement) identified in the UFSAR forthe normal, off-normal, and accident conditions. This seismic event has no adverse impact on operations andthere are no changes to the loading/unloading operations. The NUHOMS® HD system, with this change, willcontinue to meet all design, construction, fabrication, testing, and performance requirements. Thus, it isconcluded that the change does not result in more than a minimal increase in the likelihood of occurrence of amalfunction of an SSC important to safety previously evaluated in the UFSAR.

3) Does the change result in more than a minimal increase in the consequences of an accident previouslyevaluated in the UFSAR?

No. As described in Section 5.3 above, the increase in dose rates resulting from the North Anna seismic eventat 200m is less than 411 mrem (500 mrem - 89 mrem). The applicable limit per 10 CFR 72.106 (b) is that thedose at the site boundary (800m) is limited to 5000 mrem per accident. Conservatively using a site boundarydistance of 200m, the increase in accident consequences would be roughly 8% (411 + 5000). Therefore, it canbe concluded that the increase is less than 10% and is considered a minimal increase. Hence, the change doesnot result in more than a minimal increase in the consequences of an accident previously evaluated in theUFSAR.

4) Does the change result in more than a minimal increase in the consequences of a malfunction of an SSCimportant to safety previously evaluated in the UFSAR?

No. The consequences of a malfunction of components important to safety previously evaluated in the UFSARare not increased, as the North Anna seismic event has been evaluated in Section 5.0 above and the HSM-Hcapabilities (shielding, structural and thermal) are not adversely impacted by the condition. The HSM-H and the32PTH DSC remain in compliance with the allowable criteria identified in the UFSAR for the normal, off-normal,and accident conditions, and there are no changes to loading/unloading/handling operations. The NUHOMS®HD system, with this change, will continue to meet all design, construction, fabrication, testing, and performancerequirements. The DSC will continue to perform its intended design functions. Hence, it is concluded that thechange does not result in more than a minimal increase in the consequences of a malfunction of an SSCimportant to safety previously evaluated in the UFSAR.

5) Does the change create a possibility for an accident of a different type than any previously evaluated in theUFSAR?

No. The concrete damage to the North Anna HSM-H modules resulting from the seismic event has beenrepaired and the module realignments have been re-established (See TN NCR 2011-090 and TN NCR 2012-111). The "new normal" ISFSI configuration with a side-to-side gap of up to 1.50" between the HSM-H moduleshas been evaluated in Section 5.0 above and does not have.any adverse impact on the structural, shielding,thermal, criticality and confinement functions of the HD NUHOMS® System, nor does it adversely affect anyloading/unloading operations as demonstrated in Section 5.0. Hence, the change does not create a possibility ofan accident of a different type than any previously evaluated in the UFSAR.


,REV, 10CFR72.48 Evaluation Page 13 of 14TRANSNUCLEAR INC.

LR No. 721030-329, Rev. 06) Does the change create a possibility for a malfunction of an SSC important to safety with a different

result than any previously evaluated in the UFSAR?

No. As described in Section 5.2.1 and 5.2.2 above, the structural integrity of the HSM-H and the 32PTH DSC isnot challenged by the increased seismic accelerations experienced during the 8/23/11 North Anna seismicevent. The HSM-H remains in compliance with the allowable criteria identified in the UFSAR for the normal, off-normal, and accident conditions. This seismic event has no adverse impact on operations and there are nochanges to the loading/unloading operations. The NUHOMS® HD system, with this change, will continue tomeet all design, construction, fabrication, testing, and performance requirements. Thus, it is concluded that thepossibility of a malfunction of an SSC important to safety with a different result than any previously evaluated inthe UFSAR is not created.

7) Does the change result in a design basis limit for a fission product barrier as described in the UFSAR beingexceeded or altered?

No. The thermal design function of the HSM-H remains unaffected by this change. The 32PTH DSC remains incompliance with the design basis limits for fission product barriers identified in the NUHOMS® UFSAR for thenormal, off-normal, and accident conditions. The Table below lists the specific limits.

Barrier Design Basis Design Basis LimitParameter

Cladding Temperature (752°F for normal /1058'F for off-normal and accident)(UFSAR 4.1, A.4.1)Decay Heat (Per zoning and 34.8 kW

Protection against maximum per canister)Fuel Cladding Gross rupture (UFSAR 4.3.2, A.4.1)

Drop Accelerations (75 g)(UFSAR 3.5.3.1, A.3.5)Subcritical (keff (0.9404) < USL (0.9419))(UFSAR 6.4.3, A.6)

LOADINGS:

Deadweight(UFSAR 3.2.1, A.3.2)Jammed DSC Transfer - (110 kips)(UFSAR Table 3.9.1-17)Internal Pressure(Normal 15 psig, Off-Normal 20 psig, Accident120 psig)(UFSAR 4.6, A.4.1)

Confinement Preservation Of External Pressure (30 psig)Boundary Confinement (UFSAR Table 3.9.1-20)Integrity Seismic (0.30 g Horiz, 0.20 g Vert.)

(UFSAR 2.2.3.1)Flood (50 ft)(UFSAR Tables 3.9.1-19, 3.9.1-20)Leak Rate (No failure)(UFSAR 7.2 & 7.3)STRUCTURAL CRITERIA:

ASME Code with Alternate Table(UFSAR 3.10)



LR No. 721030-329, Rev. 0

8) Does the change result in a departure from a method of evaluation described in the UFSAR used inestablishing the design bases or in the safety analyses.

No.

TN Calculation 10494-183 [4] uses the more severe response spectra determined in [8] as input forperforming the dynamic seismic analysis (using the LS-DYNA code) to determine the HSM-H horizontaldisplacement and vertical rocking/lifting movement. The use of dynamic seismic analysis for the HSM-H in [4]represents a replacement of the static seismic analysis described in Appendix 3.9.9, Section 3.9.9.10.2 of theUFSAR. This dynamic analysis of HSM-H is performed using a methodology consistent with that described inAppendix U, Chapter U.3.7 of the Standardized NUHOMS® UFSAR [12]. This methodology has beenapproved by the NRC for a NUHOMS® HSM-HS module loaded with a 32PTH1 DSC [13]. The NUHOMS®HSM-HS is almost identical to the NUHOMS® HSM-H module, and thus the use of LS-DYNA code forperforming a seismic non-linear time history analysis of HSM-H meets the test of "intended application"specified in NEI 96-07 guidance [14]. Hence, the change from one method of evaluation to another is not adeparture from the method of evaluation described in the UFSAR. [See Section B.4.3.8.2 of Reference 14].

Therefore, this change does not result in a departure from the methods of evaluation described in the UFSAR.


Attachment 2

Dominion NAPS ISFSI 10CFR72.212 Evaluation

North Anna Power StationVirginia Electric and Power Company (Dominion)

L-1Dominion®

Engineering Technical EvaluationCover Sheet and BodyCMA A-EE-0 ATAH .-2 ae1 f3

1. Stations

El MPL [SU NA[I KW[I CO(Note: If both SU and NA, then check CO)

Doc type: Sub type: 2. Document Number 3. Rev. 4. Decommissioning?

ETE 000 ETE-NAF-2010-0003 3 0I Yes Z No

5. Title North Anna Power Station Independent Spent Fuel Storage Installation 10 CFR 72.212 EvaluationReport

6. ETE Level 7. Unit(s): 8. Quality Classification: 9. FSRC Approval Req.?

E]Level1 IZLevel2 L IUnit 1l [ Unit 2 [: Unit 3 ZlSFSl Z SR[1NS[:NSQ 0Yes Z No

10. Preparation, ReWiew, and Approval Signatures (add or delete rows as needed)

Co-Prepared By / Affiliation: (Print) Signature:Signature on File

Reviewed By / Affiliation: (Print) Signature:

Signature on File

Supervisor Approval / Affiliation: (Print) Signature:Inature on File

Not Req.Standard Attachments

11. Design Effects and Considerations (DNES-AA-GN-1003) LI12. Document Impact Summary (DRUL) (DNES-AA-GN-1002) 6 1 LI13. Considerations and Conditions for Document Updates (check N/A E if no document updates are noted on the DRUL)

LI All Document updates noted on the DRUL can be initiated immediately

LI Document updates noted on the DRUL are delayed until the following documents/actions are completed: (e.g., V

CR, etc.) (See DRUL Remarks section)

O,

I FR5..... ........e.... . " Attachment< # of pages Not Reqiý,10CFR50.59 Attachmnents :. . .:, •.... ..... ,•. .... .......... •:. . .•. ..

14.a 10CFR50.59/72.48 applicability review forms (DNAP-3004 or CM-AA-400) 7 2 LI14.b 1OCFR50.59/72.48 screen form (DNAP-3004 or CM-AA-400) 8 8 LI

SE-NAF-2012-0008 (Seismic Event of 8/23/11)

15.a 1OCFR50.59/72.48 applicability review forms (DNAP-3004 or CM-AA-400) 9 2 LI

15.b 1OCFR50.59/72.48 screen form (DNAP-3004 or CM-AA-400) 10 2[SE-NAF-2012-0009 (Update for UFSAR Rev. 3, Exemption forMisloaded Casks, Incorporation of ITTRs)

16. 10CFR50.59/72.48 evaluation form (DNAP-3004 or CM-AA-400)

1.Ad~ditional Attachrnents ~Attachment # of pages Description

1 23 Certificate of Conformance (1030) Evaluation and Appendix A Technical Specifications

2 1 ISFSI Hazards Evaluation

3 2 List of Operating Procedures

4 2 List of Supplier Nonconformance Reports Evaluated

5 2 10 CFR 72.48 ScreeningslEvaluations

Form No. 730801 (June 2010)

ETE -NAF-2010-0003 Rev. 3 Page 2 of 36

1 8 'Distribution,

Primary Recipient(s):

Copy To? Other Recipient I Department or Location Copy To? Other Recipient / Department or Location

[] E]EL ElEL El

Form No. 730801 (June 2010)


Table of Contents

1. SOURCE DOCUMENT .............................................................................................................. 5

2. RECORD OF REVISION ............................................................................................................ 5

3. PURPOSE ............................................................................................................................... 7

4. METHODOLOGY ..................................................................................................................... 7

5. DISCUSSION ........................................................................................................................... 7

5.1 INTRODUCTION ..................................................................................................................... 7

5.2 BACKGROUND ....................................................................................................................... 9

5.3 REGULATORY REQUIREMENTS ........................................................................................... 10

5.4 EVALUATION OF COMPLIANCE WITH THE REGULATORY REQUIREMENTS .......................... 10

5.4.1 10 CFR 72.210 - GENERAL LICENSE ISSUED ................................................... ; ........................ 10

5.4.2 10 CFR 72.212 (A)(1) - SPENT FUEL AUTHORIZED FOR POSSESSION .................... 10

5.4.3 10 CFR 72.212 (A)(2) - APPROVED CASKS ........................................................................... 11

5.4.4 10 CFR 72.212 (A)(3) - UCENSE EXPIRATION ....................................................................... 11

5.4.5 10 CFR 72.212 (B)(1) - NRC NOTIFICATION ......................................................................... 12

5.4.6 10 CFR 72.212 (B)(2) - CASK REGISTRATION ....................................................................... 12

5.4.7 10 CFR 72.212 (B)(3) - CASK CONFORMANCE WITH COC ................................................... 13

5.4.8 10 CFR 72.212 (B)(4) - AMENDMENT CHANGE TO PREVIOUSLY LOADED CASK ................... 13

5.4.9 10 CFR 72.212 (B)(5) - WRITTEN EVALUATIONS PRIOR TO USE ........................................... 14

5.4.9.1 10 CFR 72.212(B)(5)(I) - CERTIFICATE OF COMPLIANCE CONFORMANCE ............................. 14

5.4.9.2 10 CFR 72.212(B)(5)(11) - DESIGN OF ISFSI CASK STORAGE PADS AND AREAS ....................... 14

5.4.9.3 10 CFR 72.212 (B)(5)(III) - RADIOACTIVE MATERIALS IN EFFLUENTS AND DIRECT RADIATION..16

5.4.10 10 CFR 72.212 (B)(6) - REACTOR SITE PARAMETERS ........................................................... 19

5.4.10.1 EVALUATIONS AND CONCLUSIONS ............................................................................. 19

5.4.10.1.1 FSAR 2.2.1 - TORNADO AND WIND LOADINGS ......................................................... 19

ETE -NAF-2010-0003 Rev. 3 Page 4 of 36 $

5.4.10.1.2 FSAR 2.2.2 - WATER LEVEL (FLOOD) DESIGN ........................................................... 20

5.4.10.1.3 FSAR 2.2.3 - SEISM IC DESIGN ................................................................................... 20

5.4.10.1.4 FSAR 2.2.4 - SNOW AND ICE LOADINGS .................................................................... 20

5.4.10.1.5 FSAR 2.2.9.4 AND 4.1 - AMBIENT TEMPERATURES ............................ 20

5.4.10.1.6 FSAR 2.3.6 AND 2.2.9.5 - LIGHTNING ....................................................................... 21

5.4.10.1.7 FSAR 2.3.6 - FIRE AND EXPLOSION .......................................................................... 21

5.4.10.1.8 OTHER SITE PARAMETERS OR CONSIDERATIONS ......................................................... 22

5.4.10.1.8.1 ADMINISTRATIVE CONTROLS ............................................................................... 22

5.4.10.1.8.2 HAUL ROUTE EVALUATION ................................................................................. 23

5.4.11 10 CFR 72.212(B)(7) - CHANGES TO WRITTEN EVALUATIONS ............................................. 23

5.4.12 10 CFR 72.212(B)(8) - TECHNICAL SPECIFICATION AND LICENSE AMENDMENT EVALUATION...23

5.4.13 10 CFR 72.212 (B)(10) - PROGRAM EFFECTIVENESS EVALUATIONS ..................................... 24

5.4.13.1 TRAINING PROGRAM - EVALUATION AND CONCLUSION ............................................. 24

5.4.13.2 EMERGENCY PLAN - EVALUATION AND CONCLUSION ................................................. 26

5.4.13.3 RADIOLOGICAL PROGRAMS - EVALUATION AND CONCLUSION ................................... 27

5.4.13.4 QUALITY ASSURANCE PROGRAM - EVALUATION AND CONCLUSION ............................ 28

5.4.14 10 CFR 72.212 (B)(11) - MAINTAIN A COPY OF THE COC ................................................... 29

6. CONCLUSIONS ..................................................................................................................... 29

7. REQUIRED ACTIONS ............................................................................................................. 30

8. REFERENCES ...................................................................................................................... 30

Attachment 1- Certificate of Compliance (1030) and Appendix A Technical Specifications Evaluation

Attachment 2- ISFSI Hazards Evaluation

Attachment 3- List of Operating Procedures

Attachment 4- List of Supplier Nonconformance Reports Evaluated

Attachment 5- 10 CFR 72.48 Screenings/Evaluations


1. Source Document

Section 72.212 of Title 10 of the Code of Federal Regulations, Part 72, (10 CFR 72) "LicensingRequirements for the Independent Storage of Spent Nuclear Fuel, High-Level RadioactiveWaste, and Reactor Related Greater than Class C Waste", [Reference 41].

2. Record of Revision

The North Anna Power Station 10 CFR 72.212 Evaluation Report was first documented usingTechnical Reports (TR) and later transitioned to Engineering Technical Evaluations (ETE). Thecomplete record of revisions for the 10 CFR 72.212 Evaluation Report (both document types) isas follows:

I

I

Revision Change in Revisioni

TR-NE-1522 Rev. 0

TR-NE-1522 Rev. 1

TR-NE-1522 Rev. 2

TR-NE-1522 Rev. 3

Originally prepared by Dean C. FeathersonReviewed by Kent J. WietharnApproved by Tom A. Brookmire.

Attachment 2, the hazards evaluation report by ACI-NES, wasremoved and is now included as a standalone reference(Reference 16). A summary of the administrative controls forhazards is included in Section 3.8.H of this Technical Report.

Attachment 5 modified to add the 72.48 Regulatory Evaluationsand Screenings documents along with a summary.

Cask loading history added to Attachment 6.

References to procedure HP-1061.500 have been removed orupdated to coincide with the deletion of the procedure.

Attachment 1 has been updated to reflect the storage of fuelassemblies with rod clips and reconstituted assemblies.

Cask loading history [Attachment 6] updated to reflect June 2008cask loadings.

Cask loading history [Attachment 6] updated to reflect July 2009cask loadings.


TR-NE-1522 Rev. 4

ETE-NAF-2010-0003Rev. 0

ETE-NAF-2010-0003Rev. 1

Section 8.G has been updated to include a reference toCalculation SF-0005, which calculates the standoff distances forgasoline that may be used at the ISFSI.

TR-NE-1 522 Rev. 4 has been converted to ETE format.

Attachment 6 of the report has been updated to reflect the 2010cask loading campaign.

Added the following sections to reflect the ETE format:" Source Document* Purpose" Background* Regulatory Requirements

Updated to reflect implementation CoC 1030 Amendment 1 and10 CFR 72.212 revisions.

Deleted Cask Loading History (Attachment 6)

ETE-NAF-2010-0003 Updated to satisfy the requirements of CA205654 in regards toRev. 2 the HSM-H roof fall protection system expansion. All other

changes are editorial.

ETE-NAF-2010-0003 Revised to include:Rev. 3 Evaluation of impact of NUHOMS HD UFSAR Revision 3;

NRC one-time exemption from 10 CFR 72.212(b)(3) and (b)(11)for misloaded DSCs;

FCN 721030-319, Rev.0 with respect to inclusion of ITTRmodified assemblies as acceptable contents for 32PTH DSCs;and,

Impact of 8/23/11 seismic event.


3. Purpose

The purpose of this report is to document the written evaluations required by Section 72.212 ofTitle 10 of the Code of Federal Regulations, Part 72, (10 CFR 72) "Licensing Requirements forthe Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and ReactorRelated Greater than Class C Waste", [Reference 41]. The written evaluations are based onthe use under a general license of the NUHOMS HD System using a 32PTH DSC inaccordance with NRC Certificate of Compliance No. 1030, Docket No. 72-1030 [Reference 1].

Section 72.210 of 10 CFR 72 grants a general license for the storage of spent nuclear fuel at anIndependent Spent Fuel Storage Installation (ISFSI) to holders of a 10 CFR 50 license at theassociated reactor site. Section 72.212 gives the conditions for this general license anddelineates requirements that the general licensee must meet. Dominion Virginia Power(Dominion) has selected the NUHOMS HD System using a 32PTH DSC for storage of spentnuclear fuel. Dominion has evaluated the NUHOMS HD dry storage system for use at the NorthAnna Power Station (NAPS) ISFSI. Pursuant to 10 CFR 72.212, this report documents theevaluations performed by Dominion to demonstrate that the safety analyses for the NRCapproved NUHOMS HD storage system bound the NAPS plant-specific parameters and the useof this storage system does not require a change to the facility Technical Specifications.

Note: ETE-NAF-2010-0003 provides summary documentation of the ISFSI's compliance with10 CFR 72.212. Per procedure NF-AA-NSF-102 a 72.48 screen is required to evaluatechanges to the 72.212 Evaluation Report. This is to satisfy the requirement of 10 CFR 72 thatchanges to the evaluations required by 10 CFR 72.212 be addressed through the 10 CFR 72.48process. Per procedure CM-AA-ETE-101 Section 2.2 [Reference 91], the requirement thatETE-NAF-2010-0003 be reviewed under the 10 CFR 72.48 process forces a designation ofLevel 2 for ETE. Additionally Section 2.4.g of CM-AA-ETE-1 01 supports classification of thisETE as a Level 2 document as documentation of required actions, controlled document andprogram impacts, and a 72.48 review is being provided.

4. Methodology

This report identifies each item required for evaluation or review under 10 CFR 72.212(b)(5) anddescribes how NAPS complies with the requirements for the NUHOMS® HD system.

5. Discussion

5.1 INTRODUCTION

This ETE documents the evaluations performed in accordance with 10 CFR 72.212(b)(5), (b)(6),and (b)(8) for implementation of dry spent fuel storage at North Anna Power Station (NAPS)under the general license provisions of 10 CFR 72, Subpart K, "General License for Storage ofSpent Fuel at Power Reactor Sites". These evaluations are performed to ensure theTransnuclear NUHOMS HD spent fuel dry storage system as implemented at NAPS will


conform to the terms, conditions, and specifications of its Certificate of Compliance. TheNUHOMS HD system was licensed under 10 CFR 72 Subpart L, and implemented at NAPS inaccordance with the conditions set forth under Nuclear Regulatory Commission (NRC)Certificate of Compliance (CoC) No. 1030 [Reference 1]. Certificate of Compliance No. 1030was issued to Transnuclear, Inc. on January 10, 2007 and will expire January 11, 2027.Transnuclear is designated as the "certificate holder" for the NUHOMS HD system. The storagesystem's Final Safety Analysis Report is entitled, "NUHOMS HD Horizontal Modular StorageSystem for Irradiated Nuclear Fuel, Updated Final Safety Analysis Report" [Reference 14].

Dominion also operates an ISFSI at North Anna under the site specific Materials License, SNM-2507, issued June 30, 1998 and expiring June 30, 2018 [Reference 40]. The site specificlicense ISFSI (Pad #1) and the general license ISFSI (Pad #2) are located adjacent to oneanother.

The NUHOMS HD system stores spent fuel horizontally in a seal-welded stainless steel dryshielded canister (DSC). Other components of the NUHOMS HD system include the reinforcedconcrete horizontal storage module (HSM-H), and the on-site OS-1 87H transfer cask (TC). TheNUHOMS HD system was designed for enhanced heat rejection capabilities, and is licensed tostore intact fuel as well as damaged fuel and non-fuel hardware as specified in the NUHOMSHD FSAR [Reference 14]. The welded DSC provides confinement and criticality control for thestorage and transfer of irradiated fuel. The TC is used for transferring the DSC between thespent fuel pool (SFP), cask loading area, and the HSM-H at the ISFSI. The HSM-H providesradiation shielding and physical protection while allowing cooling of the DSC containing spentfuel by natural convection during storage.

The DSC subassembly components include the shell with integral bottom cover plate and shieldplug, ram/grapple ring, inner top cover/shield plug, outer top cover plate, and basket assembly.The 32PTH DSC basket consists of stainless steel square tubes and support strips for structuralsupport and geometry control, aluminum plates for heat transfer, and either borated aluminum,Boral, or metal matrix composite (MMC) for criticality control. The basket assembly is designedto accommodate 32 PWR spent fuel assemblies. The DSC is designed to slide horizontally onrails from the transfer cask into the HSM-H.

The HSM-H is a reinforced concrete structure with penetrations (vents) located at the top andbottom of the sidewalls for air flow. The penetrations are protected from debris intrusion by wiremesh screens. The HSM-H has internal heat shields that provide thermal protection for theHSM-H concrete walls and roof. The DSC support structure, a structural steel frame with rails, isinstalled within the HSM-H module to provide for sliding the DSC in and out of the HSM-H andto support the DSC within the HSM-H during storage. HSM-H modules are arranged in arraysto maximize shielding and minimize offsite dose.

The TC is designed and fabricated as a lifting device to meet ANSI N14.6 requirements. It isused for transfer operations between the NAPS Fuel Building and the HSM-H. The TC is acylindrical vessel with a welded bottom end closure assembly and a bolted top cover plate. Two


lifting trunnions are located near the top of the cask for lifting of the cask. The trunnions locatednear the base of the cask serve as the axis of rotation during transfer cask upending anddownending on the transfer trailer. Both sets of trunnions serve to support the transfer cask in ahorizontal position during transport to and from the ISFSl.

Attachment 1 of this ETE contains an item-by-item evaluation of Certificate of Compliancenumber 1030 compliance and how it is achieved while implementing the NUHOMS HD systemat North Anna.

Attachment 2 of this ETE, ACI-NES REPORT R0726002 Rev 0 "North Anna Power StationISFSI and Heavy Haul Path Hazards Evaluation," has been removed and is now included as astand-alone reference (Reference 16). A summary of the administrative controls for hazards isincluded in Section 5.4.10.1.8.1.

Attachment 3 of this ETE contains a list of procedures used for loading, handling, and transportof the NUHOMS HD system. Additionally, procedures such as fuel selection, which supportimplementation of the general license ISFSI with the NUHOMS HD system are identified.

Attachment 4 of this ETE contains a list of supplier nonconformance reports (SNCRs) evaluatedprior to implementation of the North Anna NUHOMS HD system.

Attachment 5 of this ETE contains a summary of completed 10 CFR 72.48 regulatoryevaluations and regulatory screens completed per CM-AA-400 [Reference 27] that are pertinentto NAPS ISFSI use.

5.2 BACKGROUND

In order to provide adequate spent nuclear fuel storage capacity for the North Anna PowerStation, Dominion constructed an ISFSI at the NAPS site. The ISFSI is encompassed by asecurity protected area outside the plant's protected area inside the southernmost boundary ofthe owner controlled area. The current installation includes two concrete pads or base mats.Dominion operates Pad #1 under a site specific license. Pad #1 is designed to provide astorage area for up to 28 TN-32 vertical casks. Pad #2 is operated under a general license andis designed to provide a storage area for up to 40 NUHOMS HD Horizontal Storage Modules(HSM-Hs) containing 32PTH DSCs.

ISFSI Pad #2 is operated under the conditions of the general license in accordance with 10 CFR72 regulations. Spent nuclear fuel dry cask storage system designs approved for use under ageneral license, including the NUHOMS HD system (Certificate of Compliance 1030), are listedin 10 CFR 72.214. The design basis for this cask dry storage system is provided in the FSARfor the NUHOMS HD System, [Reference 14], as updated by the CoC holder in accordance with10 CFR 72.248, and as supplemented by changes made (if necessary) by Dominion, thegeneral licensee under the provisions of 10 CFR 72.48.


5.3 REGULATORY REQUIREMENTS

Section 72.210 of Title 10 of the Code of Federal Regulations (10 CFR 72.210) grants a generallicense for the storage of spent nuclear fuel at an ISFSI to holders of a 10 CFR 50 license at theassociated reactor site. Section 72.212 gives the conditions for this general license anddelineates requirements that the general licensee must meet for the storage of spent nuclearfuel at an ISFSI.

Regulatory requirements are identified in Section 5.4 of this ETE. Following each regulatoryrequirement is an evaluation of how NAPS complies with the requirement.

5.4 EVALUATION OF COMPLIANCE WITH THE REGULATORY REQUIREMENTS

5.4.1 10 CFR 72.210 - General License Issued

10 CFR 72.210 states the following:

"A general license is hereby issued for the storage of spent fuel in an independent spent fuelstorage installation at power reactor sites to persons authorized to possess or operate nuclearpower reactors under part 50 of this chapter."

5.4.1.1 Evaluation and Conclusion

The NRC issued Operating Licenses NPF-4 and NPF-7 to the Virginia Electric and PowerCompany (herein known as Dominion) for its North Anna Power Station Units 1 and 2,respectively [Reference 2]. These licenses authorize North Anna Units 1 and 2 to possessspecial nuclear material and operate Units 1 and 2 under 10 CFR 50. Under the general licenseprovisions of 10 CFR 72, Dominion elected to use Transnuclear's NUHOMS HD spent fuelstorage system at NAPS for storage of spent fuel discharged from Units 1 and 2. ThisNUHOMS HD system is approved for use under NRC CoC 1030 as listed in 10 CFR 72.214.Dominion notified the NRC of its intent to use the NUHOMS HD system under a 10 CFR 72general license via letter dated September 21, 2007 [Reference 3]. In accordance with 10 CFR72.210 Dominion is therefore authorized to store spent fuel at NAPS ISFSI Pad #2 in the NRC-approved NUHOMS HD system under the 10 CFR 72 Subpart K general license provisions

5.4.2 10 CFR 72.212 (a)(1) -- Spent Fuel Authorized For Possession

"The general license is limited to that spent fuel which the general licensee is authorized topossess at the site under the specific license for the site."


All fuel stored at North Anna's ISFSI Pad 2 must be fuel licensed for possession at North Anna.With the exception of Surry Power Station (SPS), irradiated fuel from another reactor site,


owned by Dominion or not, is not authorized for storage at North Anna's general license ISFSI.As stated in USNRC 10 CFR 50 North Anna Licenses NPF-4 and NPF-7, [Reference 2], NorthAnna is authorized to receive, possess, and store irradiated SPS Units 1 and 2 fuel assembliescontaining special nuclear material, enriched to not more than 4.1 percent by weight U-235under the following conditions: 1) These fuel assemblies must not be placed in North AnnaPower Station (NAPS) Unit 1 and 2 reactors; 2) These fuel assemblies must be removed fromthe SPS reactors no less than 730 days prior to shipment; and 3) No more than 500 SPSirradiated fuel assemblies shall be received for storage at the NAPS Units 1 and 2 spent fuelpool.

5.4.3 10 CFR 72.212 (a)(2) - Approved Casks

10 CFR 72.212(a)(2) states the following:

"This general license is limited to storage of spent fuel in casks approved under the provisionsof this part."


Spent fuel storage casks listed in 10 CFR 72.214 are approved for storage of spent fuel under ageneral license issued under the provisions of 72.210. The NUHOMS HD system identified in 10CFR 72.214 with Certificate of Compliance No. 1030 was approved for use on January 10,2007. Amendment I to Certificate of Compliance No. 1030 was issued on March 29, 2011[Reference 1]. Therefore, Dominion as holder of a license to possess or operate a nuclear Ipower reactor under Part 50 of Chapter 10 of the Code of Federal Regulations is authorized to

store spent fuel under the general license provisions using the NUHOMS HD system.

5.4.4 10 CFR 72.212 (a)(3) - License Expiration

10 CFR 72.212(a)(3) states the following:

"The general license for the storage of spent fuel in each cask fabricated under a Certificate ofCompliance shall commence upon the date that the particular cask is first used by the generallicensee to store spent fuel, shall continue through any renewals of the Certificate ofCompliance, unless otherwise specified in the Certificate of Compliance, and shall terminatewhen the cask's Certificate of Compliance expires. For any cask placed into service during thefinal renewal term of a Certificate of Compliance, or during the term of a Certificate ofCompliance that was not renewed, the general license for that cask shall terminate after astorage period not to exceed the length of the term certified by the cask's Certificate ofCompliance. Upon expiration of the general license, all casks subject to that general licensemust be removed from service."


-5.4.4.1 Evaluation and Conclusion

Certificate of Compliance No. 1030 expires on January 11, 2027. If spent fuel at NAPS is stillrequired to be stored in the NUHOMS HD general license system after this date, Dominionacknowledges that the storage system's license will need to be renewed by application from thecurrent certificate holder (Transnuclear) or its successor, or from the user or user'srepresentative prior to the storage system's expiration date.

5.4.5 10 CFR 72.212 (b)(1) - NRC Notification

10 CFR 72.212(b)(1) states:

"The general licensee must: Notify the Nuclear Regulatory Commission using instructions in§72.4 at least 90 days before first storage of spent fuel under this general license. The noticemay be in the form of a letter, but must contain the licensee's name, address, reactor licenseand docket numbers, and the name and means of contacting a person responsible for providingadditional information concerning spent fuel under this general license. A copy of the submittalmust be sent to the administrator of the appropriate Nuclear Regulatory Commission regionaloffice listed in appendix D to part 20 of this chapter."


Notification of intent to place the NAPS ISFSI Pad #2 in service using the NUHOMS HD Systemunder a 10 CFR 72 general license for storage of spent fuel starting on or about March 3, 2008,was made to the NRC via the letter dated September 21, 2007 [Reference 3]. This letterprovided the information required by 10 CFR 72.212(b)(1). A copy of the submittal was alsosent to the administrator of the NRC Region 2 office.

5.4.6 10 CFR 72.212 (b)(2) - Cask Registration 310 CFR 72.212(b)(2) states:

"The general licensee must: Register use of each cask with the Nuclear RegulatoryCommission no later than 30 days after using that cask to store spent fuel. This registrationmay be accomplished by submitting a letter using instructions in §72.4 containing the followinginformation: the licensee's name and address, the licensee's reactor license and docketnumbers, the name and title of a person responsible for providing additional informationconcerning spent fuel storage under this general license, the cask certificate number, the CoCamendment number to which the cask conforms, unless loaded under the initial certificate, caskmodel number, and the cask identification number. A copy of each submittal must be sent tothe administrator of the appropriate Nuclear Regulatory Commission regional office listed inappendix D to part 20 of this chapter."



Dominion Nuclear Spent Fuel is required by NAF Administrative procedure, NF-AA-NSF-401,"ISFSI Fuel Selection and Certification" [Reference 31], to notify station licensing to prepare acask use registration letter in accordance with 10 CFR 72.212(b)(2). Station Licensing thencompletes this notification in accordance with VPAP-2802, "Notifications and Reports"[Reference 75].

5.4.7 10 CFR 72.212 (b)(3) - Cask Conformance with CoC

10 CFR 72.212(b)(3) states:

"The general licensee must: Ensure that each cask used by the general licensee conforms toterms, conditions, and specifications of a CoC or an amended CoC listed in §72.214."


The NUHOMS HD System, Co( No. 1030 Amendment 1 [Reference 1] issued to TransnuclearInc. and listed in §72.214 was reviewed to identify any changes or additions to NAPS programsand procedures required for use of the storage system under a general license. Attachment 1,"CoC No. 1030 Evaluation" describes the results of this review. Attachment 1 is in a two columnformat with the text of the CoC (and Technical Specifications) in the left column and adescription of the review results, identified changes, and/or explanations of how eachrequirement is satisfied in the right column.

5.4.8 10 CFR 72.212 (b)(4) - Amendment Change to Previously Loaded Cask

10 CFR 72.212(b)(4) states:

"The general licensee must: In applying the changes authorized by an amended CoO to a caskloaded under the initial CoC or an earlier amended CoC, register each such cask with theNuclear Regulatory Commission no later than 30 days after applying the changes authorized bythe amended CoC. This registration may be accomplished by submitting a letter usinginstructions in §72.4 containing the following information: the licensee's name and address, the

licensee's reactor license and docket numbers, the name and title of a person responsible forproviding additional information concerning spent fuel storage under this general license, thecask certificate number, the CoC amendment number to which the cask conforms, cask modelnumber, and the cask identification number. A copy of each submittal must be sent to theadministrator of the appropriate Nuclear Regulatory Commission regional office listed inappendix D to part 20 of this chapter."



Dominion does not currently have plans to apply new amendments to previously loaded DSCs.Should Dominion seek to apply a new amendment to a previously loaded DSC, steps will betaken to ensure compliance with 10 CFR 72.212(b)(4).

5.4.9 10 CFR 72.212 (b)(5) -Written Evaluations Prior to Use

10 CFR 72.212(b)(5) states:

"The general licensee must: Perform written evaluations, before use and before applying thechanges authorized by an amended CoC to a cask loaded under the initial CoC or an earlieramended CoC, which establish that:"

5.4.9.1 10 CFR 72.212(b)(5)(i) - Certificate of Compliance Conformance

"The cask, once loaded with spent fuel or once the changes authorized by an amended CoChave been applied, will conform to the terms, conditions, and specifications of a CoC or anamended CoC listed in §72.214."

5.4.9.1.1 Evaluation and Conclusion

The NUHOMS HD System, CoC No. 1030 Amendment 1 [Reference 1] issued to TransnuclearInc. and listed in §72.214 was reviewed to identify any changes or additions to NAPS programsand procedures required for use of the storage system under a general license. Attachment 1,"CoC No. 1030 Evaluation" describes the results of this review. Attachment 1 is in a two columnformat with the text of the CoC (and Technical Specifications) in the left column and adescription of the review results, identified changes, and/or explanations of how eachrequirement is satisfied in the right column.

Dominion Nuclear Spent Fuel uses NAF Administrative Procedure NF-AA-NSF-401, "ISFSI FuelSelection and Certification," to ensure that Dry Shielded Canisters (DSCs) at North Anna PowerStation are loaded in accordance with the conditions and specifications of CoC 1030.

5.4.9.2 10 CFR 72.212(b)(5)(ii) - Design of ISFSI Cask Storage Pads and Areas

"Cask storage pads and areas have been designed to adequately support the static anddynamic loads of the stored casks, considering potential amplification of earthquakes throughsoil-structure interaction, and soil liquefaction potential or other soil instability due to vibratoryground motion"



The NAPS ISFSI earthwork construction, excavation, and placement of concrete wereperformed in accordance with Dominion Specification NAI-0036, "Specification for Excavation,Fill, Compaction, Testing, and Landscaping Dry Cask ISFSr" [Reference 9].

The NAPS ISFSI Pad #2 is located inside a Protected Area on the south side of the power plantadjacent to the east side of the existing site-specific ISFSI Pad #1. The location contains areinforced concrete storage pad, approach slabs, drainage system and Perimeter IntrusionDetection (PID) System. The NAPS ISFSI Pad #2 was constructed to support a total of 40Horizontal Storage Modules (HSM-H), each of which are approximately 10 ft wide, 21 ft deep,and 19 ft high. The design of the pad accommodates a 2 by 20 array of HSM-H units. Theapproximate dimensions of the concrete storage pad are 85 ft wide, 205 ft long, and 3 ft thick.The independent reinforced concrete approach ramps located on each side of the storage padare 20 ft wide and 2 ft thick.

The reinforced approach ramps are specifically designed to accommodate the weight of a fullyloaded transfer trailer. The pad and ramp designs are specified in Transnuclear Specification E-23051 [Reference 4], "Design Specification for ISFSI Basemat and Approach Slabs." The caskstorage pad and ramps are non-safety-related structures, however they were designed for theNAPS Design Basis Earthquake (DBE), tornado, and all other static and dynamic loadings asdetailed in NA-DCP-05-004, "ISFSI Civil Structures Pad #2" [Reference 5].

Pad #2 is designed to meet ACI 318-95 [Reference 48] and NUREG 1536 [Reference 37]requirements. Guidance was taken from NUREG 1567, the standard review plan for spent fueldry storage [Reference 30]. Calculation CE-1 824 [Reference 6] concludes that the cask storagepad is designed to adequately support the loading combinations for 40 fully loaded NUHOMSHD 32PTH HSMs. Dominion Calculation CE-1 821 [Reference 17] and CE-1 822 [Reference 18]established the soil seismic time-histories and the soil parameters for the ISFSI pad foundation.CE-1 823 [Reference 7] concluded that the DBE enveloped maximum acceleration at the top ofthe concrete pad and at the center of gravity of a loaded HSM-H is 0.27g horizontal and 0.20gvertical based on ground accelerations of 0.18g horizontal and 0.12g vertical. Thus, the siteDBE accelerations were determined to be bounded by the NUHOMS HD FSAR [Reference 14]peak ground acceleration values of 0.3g horizontal and 0.2g vertical.

On August 23, 2011, the North Anna Power Station experienced a seismic event of magnitude5.8 centered approximately 11 miles southwest of the station which transmitted a large groundresponse to the North Anna site. Although inspections and evaluations concluded the ISFSIPad #2 and the NUHOMS HD storage systems remained operational and capable of performingtheir design and safety functions [Reference 92], investigations performed to understand theresponse of plant equipment and assets to the event confirmed that the peak accelerationsmeasured at the containment base mat exceeded the peak acceleration values considered inthe design of the plant and ISFSI. Calculation CE-1973 [Reference 93] performed a strength


evaluation of ISFSI Pad #2 for the seismic event by determining the imposed loads on the padfor the configuration of HSM-Hs at the time of the earthquake as well as for a configurationassuming the pad to be fully loaded. To include the Soil Structure Interaction (SSI) effect due tothe seismic event in the determination of the peak accelerations of the ISFSI pad and at thecenter of gravity (C.G.) of the HSM-H an SSI reanalysis [Reference 94] was performed for Pad#2.

This evaluation was performed to determine if the strength of the ISFSI pad was sufficient toresist the loadings applied during the seismic event while remaining within all original designbases and code requirements. The strength evaluation of the pad determined the internalmoments, shears and soil bearing pressure induced at the time of the seismic event were withinthe code allowable for which the ISFSI pad was designed. Additionally, since the internal forcesand stresses induced in the pad were within the code allowable for which the ISFSI pad wasdesigned, the operability of the pad is confirmed and no additional specific operability concernsdue to the seismic forces seen need to be addressed.

5.4.9.3 10 CFR 72.212 (b)(5)(iii) - Radioactive Materials in Effluents and Direct Radiation

"The requirements of § 72.104 have been met. A copy of this record shall be retained untilspent fuel is no longer stored under the general license issued under §72.210."


10 CFR 72.104, "Criteria for radioactive materials in effluents and direct radiation from an ISFSIor MRS," states the following:

"(a) During normal operations and anticipated occurrences, the annual dose equivalent to anyreal individual who is located beyond the controlled area must not exceed 0.25 mSv (25mrem) to the whole body, 0.75 mSv (75 mrem) to the thyroid and 0.25 mSv (25 mrem) toany other critical organ as a result of exposure to:

- Planned discharges of radioactive materials, radon and its decay products excepted,to the general environment,

- Direct radiation from ISFSI or MRS operations, and

- Any other radiation from uranium fuel cycle operations within the region.

(b) Operational restrictions must be established to meet as low as is reasonably achievableobjectives for radioactive materials in effluents and direct radiation levels associated withISFSI or MRS operations.


(c) Operational limits must be established for radioactive materials in effluents and directradiation levels associated with ISFSI or MRS operations to meet the limits given inparagraph (a) of this section."

The location for the NAPS ISFSI Pad #2 was selected to accommodate a total of 40 HSM-Hs.The modules are to be arranged in two back-to-back rows and are aligned approximately northand south on the pad. The ISFSI is situated about a quarter mile south of the reactorcontainment buildings.

10 CFR 72.106 requires that the minimum distance from the ISFSI to the nearest boundary ofthe controlled area (site boundary or exclusion area for NAPS) must be at least 100 meters. Forthe North Anna ISFSI, the exclusion area is equivalent to the controlled area or site boundary,which is described in the NAPS UFSAR [Reference 11]. Per Reference 10, the closest site areaboundary to the ISFSI is located about 800 meters from the ISFSI perimeter. The site area orexclusion area boundary is also considered the controlled area boundary in the evaluation fordetermination of an annual dose to a real individual at the controlled area boundary.

Interim Staff Guidance- No. 13 (SFPO-ISG-13), "Real Individual," [Reference 12] was reviewedwith respect to dose assessment. It identifies a real individual as "anyone living, working, orrecreating close to the facility for a significant portion of the year." For the purpose ofdetermining a conservative dose assessment, Dominion assumes the occupancy scenario for areal individual at the North Anna Power Station site boundary is that of a hypothetical full timeresident at the controlled area boundary point having the highest dose rate.

Calculation PA-0243, "Dose Rate Evaluation of the North Anna ISFSI Based on the TN32 andNUHOMS HD Storage Systems" [Reference 101 documented the dose requirements of 10 CFR72.104 were satisfied for a fully loaded ISFSI Pad #1 (28 TN32 casks) and the initial 12 HSM-Harray on Pad #2. Addendum A to Calculation PA-0243 [Reference 86] expanded the evaluationof PA-0243 to show the dose requirements of 10 CFR 72.104 remained satisfied if an additionalfourteen (26 total) HSM-H modules on ISFSI Pad #2 were to be loaded.

On August 23, 2011 North Anna experienced a seismic event which resulted in some of themodules experiencing a slight sideways shift in location. Although ISFSI Pad #2 is constructedto accommodate 40 HSM-H modules in a 2X20 array configuration, at the time of the eventISFSI Pad #2 only held 26 HSM-H modules in a 2X13 array of which 13 modules were loaded.After the event it was determined that the gaps between the sides of eight of the HSM-Hs, atotal of four gaps for the array, now exceeded the gap width analyzed in the storage systemradiological dose rate evaluations [Reference 100]. Addendum B to Calculation PA-0243[Reference 96] describes the evaluation performed to address the impact on the dose rate fromthe ISFSI as a result of completely filling ISFSI Pad #2 with loaded HSM-H modules andaccounting for the four gaps in the array which exceed the previously assumed gap size.

The general license ISFSI at NAPS utilizes the NUHOMS HD dry spent fuel storage systemdesigned and licensed by Transnuclear, Inc. The main components of the system are the


32PTH DSCs, a Transfer Cask (TC), and Horizontal Storage Modules (HSM-Hs). TransnuclearSpecification E-21621, "Design Criteria Document (DCD) for the NUHOMS HD System forTransportation and Storage" [Reference 42], contains the system design criteria. The 32PTHDSC is a seal-welded stainless steel canister that provides containment and support for up to 32irradiated fuel assemblies. The TC provides biological shielding for DSC transfer from the spentfuel pool to the HSM-H. The HSM-H provides support, missile protection, and biologicalshielding for the DSC.

As established in the NUHOMS HD system FSAR [Reference 141, the NUHOMS HD DSC isdesigned, fabricated, and tested by Transnuclear for leak tightness using ANSI N 14.5 and ISG-18 criteria. Therefore, no credible release of radioactive material under normal conditions ofstorage is anticipated. The confinement boundary ensures that the inert fill gas does not leak ordiffuse through the weld or base material of the DSC. The continued effectiveness of the DSCconfinement boundary is monitored by the use of radiation dosimetry at the ISFSI perimeterfence required by Dominion's dose rate evaluation program.

Calculation PA-0243 [References 10, 86, and 96] provides the peak dose at the ISFSI perimeterfence, the site boundary annual dose assuming 100% occupancy, and a conservative estimatefor the dose to the hypothetical "nearest permanent resident" at the site boundary. The doserate calculated for the site boundary resulting from direct radiation from ISFSI Pad #1 (28 TN32casks) and Pad #2 (40 loaded HSM-H modules including effect of 4 module-to-module gapsexceeding installation tolerance) is 7.4x10-4 mrem/hr. Using a 100% occupancy assumption fora permanent resident at the site boundary, a conservative estimate of the total annual dose to areal individual from the ISFSI is 6.5 mrem. Using the whole body dose guidelines from 10 CFR50 Appendix I, the maximum permissible annual dose to a real individual outside the perimeterfence is assumed to be 3 mrem due to liquid effluents and 5 mrem due to gaseous effluents foreach unit. The actual North Anna Power Station effluent doses are below the 10 CFR 50Appendix I Guidelines as shown in Appendix 11 B of the NAPS UFSAR making this aconservative assumption. Using these values a conservative estimate of the maximum totalannual dose to a hypothetical real individual at the controlled area boundary is 22.5 mrem. Thisis less than the annual limit of 25 mrem specified in 10 CFR 72.104(a). Note that the dosecalculated from the ISFSI is from direct radiation only as there is no gaseous or liquid effluentrelease postulated during storage or transport due to the DSC confinement design and loadingpractices [Reference 14]. Therefore, ingested or inhaled doses to the thyroid would not beexpected to exceed the whole body limit due to operation of the ISFSI.

Dominion ALARA design objectives were achieved by selecting the Transnuclear NUHOMS HDsystem for the design of the DSC regarding the shield plug sizing of the top and bottom covers,the HSM-H regarding the concrete thickness of the roof and wall components, and the designregarding the lead shielding and neutron shield water layer within the TC shell.

As stated in Chapter 12 of the NAPS UFSAR [Reference 11], the policy of NAPS is toimplement a program that meets the intent of 10 CFR 20 and ensure the occupational radiationexposures at its nuclear facilities are kept ALARA. The ISFSI is operated under the existing

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plant radiation protection program. The Plant Radiological Protection and ALARA Programsestablish and implement operational restrictions associated with the use of the NUHOMS HDSystem at the NAPS for loading and storing spent nuclear fuel.

ALARA considerations for the implementation of the loading process are primarily theresponsibility of Dominion and include the use of remote-controlled automatic weldingprocesses, shielding, and appropriate decontamination and exposure control methods andprocedures.

The NUHOMS HD Technical Specifications for fuel selection (i.e., T.S. 2.1), the HSM-H doserates (i.e., T.S. 5.4), and Table 5.21 of the NUHOMS HD FSAR [Reference 14] ensurecompliance with 10 CFR 72.104(a) limits. This has been demonstrated in Calculation PA-0243[Reference 10], Calculation PA-0243 Addendum A [Reference 86], and Calculation PA-0243Addendum B [Reference 96]. These requirements and limits are included in the proceduresused for selection of fuel and loading and operation of the storage systems. TechnicalSpecification and UFSAR dose rate and cumulative limits can also be found in Health Physicssurveillance procedure 0-HSP-ISFSI-002 [Reference 13].

The direct radiation from the storage systems is measured at the time the ISFSI modules areloaded and during routine, periodic radiation surveys. The HSM-H dose rate evaluationprogram has been included in radiation surveillance survey procedure, 0-HSP-ISFSI-002[Reference 13]. The perimeter of the security/Protected Area fence at the ISFSI containsmounts for radiation measuring thermo-luminescent dosimeters (TLDs) used for collection ofradiation data under the NAPS Radiation Protection Program [Reference 70].

5.4.10 10 CFR 72.212 (b)(6) - Reactor Site Parameters

10 CFR 72.212(b)(6) states the following:

"The general licensee must: Review the Safety Analysis Report (SAR) referenced in the CoC oramended CoC and the related NRC Safety Evaluation Report (SER), prior to use of the generallicense, to determine whether or not the reactor site parameters, including analyses ofearthquake intensity and tornado missiles, are enveloped by the cask system design basesconsidered in these reports. The results of this review must be documented in the evaluationmade in paragraph (b)(5) of this section."

5.4.10.1 Evaluations and Conclusions

An evaluation of each applicable reactor site parameter pertinent to the NUHOMS HD storagesystem is provided in this section. Each parameter was evaluated for acceptability with thebounding value identified in the NUHOMS HD FSAR [Reference 14], and the NRC NUHOMSHD 32PTH Safety Evaluation Report [Reference 15].


5.4.10.1.1 FSAR 2.2.1 - Tornado and Wind Loadings

The NUHOMS HD System is designed to resist the most severe tornado and wind loadsspecified in NRC Regulatory Guide 1.76 and NUREG-0800. The HSM-H is designed towithstand tornado missiles as defined by 10 CFR 72.122(b)(2). Extreme wind effects are muchless than the design basis tornado wind forces. NUHOMS HD design inputs are near equal toNAPS FSAR wind speed and pressure drop values. The NAPS SAR missile types are includedin the NUHOMS HD tornado missile types, but the NUHOMS HD kinetic energies are slightlyhigher. Per the NUHOMS HD FSAR [Reference 14], the effects of tornado missiles on the DSCare not evaluated as there is no sizeable pathway through the HSM-H walls. The NUHOMS HDsystem design is adequate to survive the design basis tornado during transfer and bounds theevaluations described in the NAPS UFSAR [Reference 11]. For the wind pressure loads andmassive missile impact, tip-over should not occur and the stability of the cask/skid trailerarrangement is maintained. Stability for overturning and sliding due to missile impact and windloading are demonstrated for the loaded HSM-H in the NUHOMS HD design basis.

5.4.10.1.2 FSAR 2.2.2 - Water Level (Flood) Design

The NUHOMS HD System is designed to withstand a flood height of 50 feet with a velocity of 15fps. The ISFSI is at elevation 311 ft above msl and the site maximum flood level is 268.6 ftabove msl. Tsunamis and seiches are not considered credible and are not postulated in theNAPS UFSAR [Reference 11].

5.4.10.1.3 FSAR 2.2.3 - Seismic Design

The NUHOMS HD design basis earthquake horizontal acceleration of 0.30g bounds the NAPSUFSAR [Reference 11] design earthquake, which has a maximum horizontal acceleration of0.18g for structures founded in soil. Vertical accelerations are computed at 2/3 horizontal.

On August 23, 2011, the North Anna Power Station experienced a seismic event of magnitude5.8 centered approximately 11 miles southwest of the station which transmitted a large groundresponse to the North Anna site. The peak ground accelerations recorded at the Unit 1basemat for the 8/23/11 event were 0.26g north-south, 0.1 lg east-west and 0.12g vertical[Reference 99]. Although these peak accelerations exceed the design basis earthquake valuesinitially assumed for the North Anna Power Station, they remain less than the 0.30g horizontaland 0.20g seismic loads of Technical Specification 4.6.3.

5.4.10.1.4 FSAR 2.2.4 - Snow and Ice Loadings

Snow and ice loadings for the HSM-H are derived from ASCE-7-95, "Minimum Design Loads forBuildings and Other Structures" [Reference 55]. The maximum 100-year roof snow load for theNUHOMS HD design is 110 psf. This value corresponds to approximately 15 feet of new snow,which bounds the estimated annual snow fall accumulation at the North Anna site of 15 inches.


5.4.10.1.5 FSAR 2.2.9.4 and 4.1- Ambient Temperatures JAmbient temperatures used for the NUHOMS HD operational thermal analyses were -210 F to1150 F. These values bound the mean monthly temperatures for NAPS, which have rangedfrom 33.60 F to 750 F. per the North Anna UFSAR [Reference 11]. The solar insulation'values inthe NUHOMS HD FSAR [Reference 14] are based on 10 CFR 71 requirements and areconservative for NAPS.

5.4.10.1.6 FSAR 2.3.6 and 2.2.9.5 - Lightning

The thunderstorms at NAPS most commonly occur during the late spring and summer months,although they have been observed during all months of the year. Severe thunderstorms withstrong winds, heavy rain, intense lightning, and hail have infrequently affected the region.Although the NAPS site is subject to lightning, the likelihood of lightning striking the HSM-H andcausing an off-normal condition is not likely. The configuration of the ISFSI pad plus individualDSC and HSM-H storage components provides an effective means of protection againstextreme seasonal weather conditions including heavy precipitation, drifting snow, ice flows,lightning strikes, strong winds and wind driven missiles, and blowing dust. The meteorologicalconditions and monitoring program for which the plant is currently licensed are generallyadequate for the NUHOMS HD system.

In the unlikely event that lightning should strike in the vicinity of the HSM-H, the normal storageoperations of the HSM-H will not be affected. The current discharged by the lightning will followthe low impedance path offered by the surrounding structures. Therefore, the HSM-H will notbe damaged by the heat or mechanical forces generated by current passing through the higherimpedance concrete. Since the HSM-H requires no equipment for its continued operation, theresulting current surge from the lightning will not affect the normal operation of the HSM-H.HSMs are inspected daily for vent blockages. Any adverse condition observed at the ISFSIwould be reported and corrected.

Since no off-normal condition for the HSM-H is anticipated as the result of lightning striking inthe vicinity of the HSM-H, no corrective action would be necessary. There would be noradiological consequences due to this event.

NAPS has a restriction in cask transport procedures O-OP-4.54 [Reference 65] and 0-OP-4.55[Reference 66] to prohibit loaded cask transport during severe weather.

5.4.10.1.7 FSAR 2.3.6 - Fire and Explosion

10 CFR 72.122 (c) requires that the structures, systems and components important to safety bedesigned and located so that they can continue to perform their safety functions effectivelyunder credible fire and explosion conditions. Transnuclear's NUHOMS HD UFSAR [Reference14] Section 2.3.6 states that the concrete and steel used in the fabrication of the NUHOMS HDSystem can withstand any credible fire hazard. The HSM-Hs and DSCs contain no flammable


on locating flammable materials nearby, which when added to actual ambient temperatureswould not exceed the postulated ambient temperature range.

ACI-NES Report R0726002 [Reference 16], "North Anna Power Station ISFSI and Heavy HaulPath Hazards Evaluation" contains an evaluation of hazards pertaining to the use of theNUHOMS HD system at North Anna Power Station. Refer to this report for details regarding fireand explosion hazards. Calculation SF-0005 [Reference 84] establishes standoff distances forquantities of gasoline allowed at the ISFSI or nearby the haul path.

5.4.10.1.8 Other Site Parameters or Considerations

5.4.10.1.8.1 Administrative Controls

Certificate of Compliance No. 1030 Appendix A, Technical Specification 4.6.3 (6) - Thepotential for fires and explosions shall be addressed based on site-specific considerations.

Hazards are identified in ACI-NES Report R0726002, [Reference 16]. As part of the analysisthere are several references to administrative controls that ensure there is no credible risk ofany hazard having a significant adverse effect on the spent fuel in transfer cask or at the ISFSI.These controls include:

" Controls on vehicles on or near the heavy haul path during cask transport operations.

" Controls on vehicles within the ISFSI.

" Line-of-sight restrictions on propane powered and natural gas powered vehicles.

" Control of potential transient hazards through performance of a walk down prior tocommencement of transport operations.

" Maintenance of gas bottle stations to plant standards for configuration and restraint.

" Determine if severe weather is forecast at the time of cask transport operations.

" Limitations of any tank or bottle refueling, or vehicle fueling processes along the heavyhaul path during transport operations.

" Limitation of hazardous activities along the heavy haul path during transportoperations.

" Limitation on movement of any hazardous materials within direct line of sight of aloaded transfer cask.


Procedure NF-AA-NSF-601, "NUHOMS Transfer Haul Route Walkdown" [Reference 52],provides guidance for the survey of the OS1 87H Cask haul path in accordance with theNUHOMS FSAR [Reference 14] and cask transport procedures O-OP-4.54 [Reference 65] and0-OP-4.55 [Reference 66]. This procedure mitigates the hazards to spent fuel that could beencountered along the haul path to the ISFSI by identifying and physically controlling theamount of flammable/explosive materials along the cask haul path immediately prior to thetransfer of a DSC to the ISFSI.

5.4.10.1.8.2 Haul Route Evaluation

The transfer trailer loading and the haul path grade were evaluated in ET-CCE-2008-0001,"Evaluation of the ISFSI Haul Routes for NUHOMS 10'6" Wide Cask Transfer Trailer"[Reference 76].

5.4.11 10 CFR 72.212(b)(7) - Changes to Written Evaluations

"The general licensee must: Evaluate any changes to the written evaluations required byparagraphs (b)(5) and (b)(6) of this section using the requirements of §72.48(c). A copy of thisrecord shall be retained until spent fuel is no longer stored under the general license issuedunder §72.210."


Changes to the 72.212 written evaluations required by 10 CFR 72.212(b)(5) and 10 CFR72.212(b)(6) are screened via CM-AA-400, "10 CFR 50.59 and 10 CFR 72.48 - Changes,Tests, and Experiments" [Reference 27]. Screens are given a unique tracking number andattached to the 72.212 report upon submittal to records. Attachment 5 maintains a record ofeach screen conducted on the 72.212 report.

5.4.12 10 CFR 72.212(b)(8) - Technical Specification and License AmendmentEvaluation

"The general licensee must: Before use of the general license, determine whether activitiesrelated to storage of spent fuel under this general license involve a change in the facilityTechnical Specifications or require a license amendment for the facility pursuant to § 50.59(c)(2)of this chapter. Results of this determination must be documented in the evaluations made inparagraph (b)(5) of this section."


North Anna Power Station has operated a site-specific ISFSI since June 30, 1998. Plantsystems and programs existing under the NAPS 10 CFR 50 license were reviewed and revisedto support the operation of the NUHOMS HD system under a general license. Several featuresand attributes of the plant were specifically adapted to the NUHOMS HD system, such as in-


plant handling of the OS187H transfer cask as well as loading, vacuum drying and sealing the32PTH dry shielded canisters.

To utilize the NUHOMS HD system, plant modifications were performed using three DesignChange Packages (DCPs): DCP 05-004 [Reference 5], DCP 05-005 [Reference 34], and DCP05-006 [Reference 38]. These DCPs provided the implementation requirements for the padconstruction, plant modifications, and security and electrical modifications, respectively. The in-pool drop of the OS-1 87H transfer cask was evaluated in Reference 19. A revision to the NorthAnna UFSAR [Reference 11] has been processed to reflect the results of an OS-187H caskdrop accident in Reference 19.

The addition of the NUHOMS HD ISFSI Pad resulted in a modification to the North Anna FSARsite drawings. Section 9.1, Appendix 9B and Appendix 15A of the North Anna UFSAR[Reference 11] were changed to reflect NUHOMS HD operations and drop analyses.Calculation PA-0241, "EAB Dose from the Drop of a NUHOMS Transfer Cask" [Reference 51],estimated the site boundary dose from the isotopic gas inventory of 32 fuel assemblies decayed7 years for the OS187H cask. Calculation CE-1 192, "Fuel Cask and Lid Drop Analysis for theNUHOMS-32 Cask System" [Reference 74] was performed. 10CFR 50.59 screens of theconstruction, operation, and plant interfaces with the NUHOMS HD system were performed forthe DCPs and UFSAR [Reference 11] changes for NUHOMS HD implementation. Theseevaluations concluded that no new Technical Specifications or amendments to the plant licensewere required for NUHOMS HD implementation. Technical Report NE-1 154 "Use of DryStorage Casks at the North Anna Power Station "[Reference 73] documents cask weights,boundary dose rates for UFSAR accidents, NUHOMS lifting controls and concludes that theexisting accident analyses are bounding.

There are no items resulting from the implementation of the NUHOMS HD system at NAPS thatrequire an amendment to the NAPS license.

5.4.13 10 CFR 72.212 (b)(10)- Program Effectiveness Evaluations

'The general licensee must: Review the reactor emergency plan, quality assurance program,training program, and radiation protection program to determine if their effectiveness isdecreased and, if so, prepare the necessary changes and seek and obtain the necessaryapprovals."

5.4.13.1 Training Program - Evaluation and Conclusion

This evaluation has been performed in accordance with 10CFR 72.212(b)(6) and CoC 1030 toensure appropriate training is identified for implementation of dry fuel storage activities.Continued oversight and verification of the effectiveness of any training program at the NAPS isan integral part of Dominion's ongoing evaluation process. Application of the principles of aSystematic Approach to Training and the Nuclear Industry's Accreditation process ensure planttraining programs are properly analyzed, developed, implemented and re-evaluated.


Determination of a training program's effectiveness is defined by the regulatory process through10 CFR 55 [Reference 32] and 10 CFR 50.120 [Reference 8]. NAPS has applied a systematicapproach to training, which has been deemed acceptable by the industry's accreditationprocess in meeting these regulations. The NAPS UFSAR [Reference 11] Section 12.2.providesa basic compendium of the NAPS Training Program.

The training requirements in NUHOMS HD CoC No. 1030 specify a Pre-Operational Testingand Training Exercise. This activity was executed during the week of Feb. 18-22, 2008 usingthe plan described in Reference 49 to successfully demonstrate the NAPS ability to performspent fuel loading into dry storage using the NUHOMS HD system. Prior to the NAPS dry run,personnel were provided classroom training by Transnuclear personnel in subjects listed in theCoC No. 1030 Technical Specifications, paragraph 5.2.2.

A series of training qualification requirements was created to provide selected personnel withthe technical knowledge, skills, and abilities needed to load spent fuel into NUHOMS HD drystorage system at NAPS. The NUHOMS HD training program at NAPS is designed to satisfy10 CFR 72 and the NUHOMS HD Technical Specifications. The NUHOMS HD classroomtraining includes the following modules:

ISFSI/NUHOMS HD General Overview

NUHOMS HD Certificate of Compliance Overview

NUHOMS HD Fuel Loading/Unloading TC Handling, DSC Transfer Process

NUHOMS HD Off-Normal Events

Initial classroom training on the NUHOMS HD system was conducted at North Anna on May 01,2007 through May 4, 2007. This training was provided by Transnuclear, Inc. utilizing approvedlesson materials and vendor equivalent tasks. Also during this time frame, EMS Solutionsprovided classroom training on the el000 Series Vacuum Drying System. During the training,individuals were presented with the knowledge requirements necessary for General NUHOMSHD System Operations, Onsite Transfer Cask/and DSC Preparations, Transfer EquipmentOperation, DCS Sealing, DSC Draining and Drying, Alignment Operation, the Code ofCompliance for NUHOMS (including off normal and accident conditions) and the el000 VacuumDrying System. Additional training, testing, and field operations on the vacuum drying systemwas delivered by EMS Solutions on May 2 9th and 30th, 2007. Individuals were tested on theinformation presented during the classroom training in order to receive classroom credit.

On-the-Job training is also used to reinforce the classroom training and qualify the individual.Job Performance Measures (JPM) are used to specify on-the-job knowledge and performanceobjectives. JPMs for Spent Fuel Dry Cask Storage Qualification are conducted by the FuelHandling Supervisor or a designated qualified Refueling Special Projects operator.

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Therefore, NAPS training standards are met and the effectiveness of the training program is notdecreased by the inclusion of the NUHOMS HD ISFSI activities.

5.4.13.2 Emergency Plan - Evaluation and Conclusion

The NAPS Emergency Plan documents the philosophy and organization for implementing aresponse to a radiological emergency at the NAPS Station.

The analysis of potential onsite and offsite consequences of accidental releases associated withthe operation of an ISFSI is contained in NUREG-1 140 [Reference 21]. NUREG-1 140concluded that the postulated worst-case accident involving an ISFSI has insignificantconsequences to the public health and safety. The source term and motive force available atthe ISFSI is insufficient to warrant classifications above the Notification of Unusual Event(NOUE) level.

NAPS currently implements Emergency Action Levels (EALs) based on the existing NAPSISFSI SAR [Reference 64] and NRC SER, "Safety Evaluation Report for the North AnnaIndependent Spent Fuel Storage Installation," [Reference 87]. EALs have been incorporatedinto NAPS Emergency Plan using the guidance of NEI 99-01, "Methodology for theDevelopment of Emergency Action Levels" [Reference 57], 10 CFR 50.54(q), and NRCRegulatory Issue Summary (RIS) 2003-18, "Use of Nuclear Energy Institute (NEI) 99-01,Methodology for the Development of Emergency Action Levels" [Reference 56]. In addition tothe Emergency Plan, the two existing EALs have been incorporated into the NAPS site specificEmergency Plan Implementing Procedure EPIP-1.01 [Reference 22]. The associated TechnicalBasis document has been revised to include the applicability of the general license use of theNUHOMS HD system. Due to the location of the ISFSI within a Protected Area of the facility,the existing Security EAL encompasses the 'Security Event' EAL for Unusual Event.

The addition of the NUHOMS HD ISFSI will not decrease the capability to:

- Respond to an emergency or meet actions or other requirements described in theEmergency Plan.

- Protect the health and safety of plant personnel and the general public in the event of anemergency.

- Implement a federal regulation or formal commitment.

Based on the above, no changes to the Emergency Plan are needed for the NUHOMS HDISFSI.


5.4.13.3 Radiological Programs - Evaluation and Conclusion

The NAPS station radiological program is described in VPAP-2101, "Radiation ProtectionProgram" [Reference 70]. Additional information regarding the NAPS Health Physics Program isdescribed in Section 12.3 of the North Anna UFSAR [Reference 11]. The radiation protectionprogram was developed and implemented using the applicable guidance of the following:a) INPO 05-008, "Guidelines for Radiological Protection at Nuclear Power Plants" [Reference58]; b) Regulatory Guide 8.2, "Guide for Administrative Practice in Radiation Protection"[Reference 59]; c) Regulatory Guide 8.9, "Acceptable Concepts, Models, Equations, andAssumptions for a Bioassay Program" [Reference 71]; d) Regulatory Guide 8.8, "InformationRelevant to Ensuring that Occupation Radiation Exposures at Nuclear Power Stations Will BeAs Low As Is Reasonably Achievable" [Reference 60]; and, e) Regulatory Guide 8.10,"Operating Philosophy for Maintaining Occupational Radiation Exposures As Low As IsReasonably Achievable" [Reference 61].

NUHOMS ISFSI radiological protection complies with 10 CFR 72.126. It is the policy of theNAPS to keep personnel radiation exposure within the applicable regulations, and to keep it aslow as reasonably achievable (ALARA). This policy is documented in station procedures. Healthphysics survey and posting programs are established at the NAPS to characterize radiologicalconditions and properly identify these conditions to workers. Radiation and contamination levelsare monitored on a prescribed frequency and surveys are documented to provide personnelwith current radiological information.

Radiological controls for NUHOMS loading and transfer operations are identified in an approvedRadiation Work Permit (RWP) that establishes the requirements for HP coverage (survey typeand frequency for example) and all worker instructions (such as stay times, protective clothingrequirements, and respiratory protection). The RWP provides guidance to workers that ensuresound radiological practices. The RWP also prescribes the allowable dose and dose rates toalert workers of changing radiological conditions. Access to high radiation areas by workersrequires additional radiological controls.

Direct radiation will be measured as the HSM-H modules are loaded. The gamma dose at theperimeter of the NUHOMS ISFSI Protected Area is continuously monitored withthermoluminescent dosimeters (TLDs) in accordance with the established surveillance program.Additional TLDs may be used at desired locations to evaluate the ISFSI performance and forcomparison with calculated doses. Neutron surveys are conducted regularly at establishedISFSI and offsite locations. ISFSI-specific activities are conducted using procedure 0-HSP-ISFSI-002, "NUHOMS Dry Spent Fuel Storage System; Preparation, Loading, Transport, andT.S. Surveillance Surveys" [Reference 13].

The NAPS Radiological Environmental Monitoring Program (REMP) [Reference 63] includes theISFSI. No changes to the NAPS REMP are required for implementing dry storage using the


NUHOMS HD system as there are no additional emissions or effluents created by employingthis system.

No changes to the Radiation Protection Program elements were required to implement theNUHOMS HD system. Specific procedural guidance for NUHOMS HD operation andsurveillance has been provided in station ISFSI Health Physics operations procedures. Theactivities associated with the operation and maintenance of the ISFSI are adequately controlled.NUHOMS HD system activities do not decrease the effectiveness of the Health PhysicsProgram.

5.4.13.4 Quality Assurance Program - Evaluation and Conclusion

Pursuant to 10 CR 72.140(d) Dominion takes credit for an NRC approved 10 CFR Part 50Quality Assurance (QA) program that is fully described in the Dominion Topical Report, "QualityAssurance Program", DOM-QA-1 [Reference 23]. NAPS currently operates the existing sitespecific ISFSI under its 10 CFR50 QA program. The plan is NRC-approved and satisfies therequirements of 10 CFR 50, Appendix B and 10 CFR 72 Subpart G.

CoC 1030, Condition 4 also specifies that activities at the ISFSI shall be conducted inaccordance with a commission approved Quality Assurance program, which satisfies theapplicable requirements of 10 CFR 50, Appendix B and which is established, maintained andexecuted with regard to the ISFSI.

The QA Plan was reviewed in accordance with 10 CFR 72.212(b)(10). The effectiveness of theQA Plan is not decreased by inclusion of the ISFSI activities. Existing QA activities meet therequirements of CoC No. 1030, Appendix A, Condition 4. The QA program activities areadequate to cover the NUHOMS HD storage system on ISFSI Pad #2.

The Transnuclear QA program described in the NUHOMS HD FSAR [Reference 14] fallsspecifically under the requirements of 1 OCFR72 Subpart G. Dominion has approvedTransnuclear as a supplier of safety-related spent fuel storage products and services. NUHOMSHD components are given a quality classification based on the component's importance-to-safety (ITS). The graded quality system uses categories ITS-A, ITS-B, ITS-C, and NITS (notimportant to safety). These categories map to Dominion's three quality categories [safety-related (SR), non-safety related but having special regulatory significance (NSQ), and non-safety related (NS)] in the following manner: In the purchase order, ITS-A maps to safety-related; ITS-B and ITS-C map to Dominion's NSQ category with specific attributes called out inthe Equipment Data System. The NITS classification maps to Dominion's non-safety relatedcategory (NS). The quality classification is primarily used to ensure items are properly fabricatedwith the appropriate level of quality control. These quality classifications also establish the levelof requirement for on-site storage, inspection, and maintenance.

Dominion imparts additional quality assurance requirements on fabrication of NUHOMS HDcomponents. Source inspections are performed at the fabricator's shops during fabrication of


DSCs, HSM components, and the OS-1 87 transfer cask. The source inspectors overseeattributes of the fabrication process as delineated in Dominion's NUHOMS HD specification[Reference 24] in accordance with Dominion's Quality Assurance Program Elements for SupplyChain Management [Reference 35]. Inspection attributes are identified on Vendor FinalInspection Reports (VFIRs) [Reference 35]. Inspection status and progress are identified onperiodic Trip Reports [Reference 35]. Deviation and/or nonconformance with Dominion-approved design and fabrication documents are documented on a supplier nonconformancereport (SNCR) and evaluated by Dominion Supply Chain Management and Engineering[Reference 35]. When all inspection attributes are successfully completed, a Shipping Releaseper Reference 35 is authorized by the source inspector allowing the product to be released toDominion.

5.4.14 10 CFR 72.212 (b) (11) - Maintain a Copy of the CoC

10 CFR 72.212(b)(11) states:

"The general licensee must: Maintain a copy of the CoC and, for those casks to which thelicensee has applied the changes of an amended CoC, the amended CoC, and the documentsreferenced in such Certificates, for each cask model used for storage of spent fuel, until use ofthe cask model is discontinued. The licensee shall comply with the terms, conditions, andspecifications of the CoC and, for those casks to which the licensee has applied the changes ofan amended CoC, the terms, conditions, and specifications of the amended CoC, including butnot limited to, the requirements of any AMP put into effect as a condition of the NRC approval ofa CoC renewal application in accordance with § 72.240."


Dominion Nuclear Spent Fuel uses NAF Administrative Procedure NF-AA-NSF-105, "DocumentControl for Spent Fuel Storage Systems Under General License," to ensure that copies of theCoC and amendments to the CoC are maintained for each cask model used for storage of spentfuel at the North Anna Power Station, until use of the cask model is discontinued.

6. Conclusions

Appropriate steps have been taken by Dominion, the general licensee, to satisfy the

requirements of Certificate of Compliance (CoC) 1030. Spent fuel meeting the restrictions forstorage specified in the CoC has been placed in dry storage. NAPS meets the design andoperating criteria set forth for NUHOMS HD dry storage of spent fuel, CoC 1030 and itsassociated Technical Specifications" the NRC NUHOMS HD SER, and the NUHOMS HD FSAR.

The NUHOMS HD System has been reviewed for compatibility with the NAPS operatinglicenses, Technical Specifications, UFSAR, and physical plant. Changes to the existing plantbasis for implementation of the ISFSl were reviewed under 10 CFR 50.59. A reevaluation of the


transfer cask top (lifting) trunnions load stresses for a universal lift yoke with 2.25 inch thickyoke arms was performed and reviewed by Transnuclear under 10 CFR 72.48.

The NAPS site parameters are bounded by the design of the NUHOMS HD system. Reviews ofthe NAPS Emergency Plan, the Quality Assurance Program, the Training Program, and theRadiation Protection Program have shown that the effectiveness of these programs is notreduced by the NUHOMS HD system. Appropriate programs and procedures are in place toensure safe dry spent fuel transfer and storage operations.

Based upon the findings established in this Engineering Technical Evaluation, NAPS has metthe conditions/ requirements to operate an ISFSI under the general license provisions of 10CFR 72, Subpart K utilizing the NUHOMS HD dry storage system.

7. Required Actions

No Required Actions

8. References

1. USNRC Certificate of Compliance 1030, Issued 1/10/2007; Amendment 1, Issued3/29/11

2. USNRC 10 CFR 50 North Anna Licenses NPF-4 and NPF-7 (See References 77 & 78)

3. Dominion Notification Letter to NRC, No. 07-0619, 9/21/2007

4. Transnuclear Specification E-23051, "Design Specification for ISFSI Basemat andApproach Slabs"

5. DCP 05-004, "ISFSI Civil Structures Pad #2"

6. CALC-STR-CE-1824, "Design of ISFSI Pad # 2"

7. CALC-STR-CE-1823, "ISFSI Pad #2 Seismic Soil Structure Interaction Analysis"

8. 10 CFR 50.120, 'Training and Qualification of Nuclear Power Plant Personnel"

9. SPEC-DOM-NAI-0036, "Specification for Excavation, Fill, and Compaction, Testing andLandscaping Dry Cask ISFSI"

10. Calculation PA-0243, "Dose Rate Evaluation of the North Anna ISFSI Based on TN32and NUHOMS Storage Systems"


11. North Anna Power Station UFSARs, Units 1 and 2

12. NRC SFPO Interim Staff Guidance ISG-13, "Real Individual"

13. 0-HSP-ISFSI-002, "NUHOMS Dry Spent Fuel Storage System; Preparation, Loading,Transport, and T.S. Surveillance Surveys"

14. NUHOMS HD FSAR Rev. 2, (and approved FCNs), "NUHOMS HD Horizontal ModularStorage System for Irradiated Nuclear Fuel, Updated Final Safety Analysis Report",10/2009. (Proprietary)

15. NRC NUHOMS HD SER, "Transnuclear, Inc. NUHOMS HD Horizontal Modular StorageSystem for Irradiated Nuclear Fuel"

16. ACI-NES Report R0726002, "North Anna Power Station ISFSI and Heavy Haul Path

Hazards Evaluation," ACI Nuclear Energy Solutions, June 2007. (Proprietary)

17. CE-1821, "Development of Soil Profile"

18. CE-1 822, "Soil Parameters for the ISFSI Pad #2 Foundation Design"

19. SWEC Calculation 11715-NS(B)-029, "Fuel Cask Drop"

20. NAI-0035, "Installation Specification for Reinforced Concrete ISFSI Pad #2"

21. NUREG-1 140, "A Regulatory Analysis on Emergency Preparedness for Fuel Cycle andOther Radioactive Material Licensees"

22. Procedure EPIP-1.01, "Emergency Manager Controlling Procedure"

23. DOM-QA-1, "Nuclear Facility Quality Assurance Program Description"

24. NAP-0134/SUP-0127, "Specification for NUHOMS Spent Fuel Storage System," North

Anna Power Station Unit Nos. 1 and 2, Surry Power Station Unit Nos. 1 and 2"

25. DNAP-1 802, "Quality Assurance Program Elements for Supply Chain Management(Generation)"

26. Transnuclear Certificate of Conformance Rev. 1 for NAPS PAD/HSM Array, 5/17/2011

27. CM-AA-400, "10 CFR 50.59 and 10 CFR 72.48 - Changes, Tests, and Experiments"

28. PROC59-000-0-OP-4.33 " Pre-Cask Loading Verification"


29. 0-PT-4.50, "NUHOMS OS187H Transfer Cask Leak Test and Inspection"

30. NUREG 1567, "Standard Review Plan for Spent Fuel dry Cask Storage Facilities"

31. PROCNA-ADM-NF-AA-NSF-401, "ISFSI Fuel Selection and Certification"

32. 10 CFR 55, "Requirements for Physical Protection of Licensed Activities in NuclearPower Reactors Against Radiological Sabotage"

33. MS-AA-WHR-401, "Receiving"

34. DCP- 05-005, "ISFSI Pad #2 Plant Modifications"

35. MS-AA-VEN-101 "Vendor Surveillance"

36. Letter Serial No. 11-262, from Dominion to NRC requesting one-time exemption fromrequirements of 10 CFR 72.212(b)(3) for NUHOMS HD Dry Shielded Canisters SerialNumbers DOM-32PTH-004-C, -005-C, -007-C, -010-C, -013-C, -019-C, and GBC-32PTH-011-C, dated July 21, 2011.

37. NUREG 1536, "Standard Review Plan for Dry Cask Storage"

38. DCP 05-006, "ISFSI Pad #2 Electrical/Security Modifications"

39. VPAP-0809, "NUREG-0612 Heavy Load Program"

40. NRC Material License No. SNM-2507, "North Anna Independent Spent Fuel StorageInstallation"

41. 10 CFR 72, "Licensing Requirements for the Independent Storage of Spent NuclearFuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste"

42. Transnuclear Specification E-21621, "Design Criteria Document (DCD) for the NUHOMSHD System for Transportation and Storage"

43. Transnuclear Specification E-21249, "Procurement Specification for Boral Paired withAluminum 1100 Plates, for the NUHOMS-32PTH, Type IIC Dry Shielded Canister"

44. AAR Manufacturing Specification, "Standard Specification for Boral Composite Panels"

45. Transnuclear Specification E-20932, "Procurement Specification for the NUHOMS-32PTH HD System OS187H Transfer Cask"


46. Transnuclear Specification E-20763, "Procurement Specification for the NUHOMS-32PTH HD System Dry Shielded Canister (DSC)"

47. Transnuclear Specification NUH-03-0214, "Precast Concrete Construction of NUHOMSHSM-H"

48. ACI 318-95, "Building Code Requirements for Structural Concrete"

49. NUHOMS 32PTH Pre-Operational Testing and Training Exercise Plan for North AnnaPower Station, Rev. 0, 01/29/2008 11:42 am email from Jay Leberstien to Scott Atwater(NRC).

50. Transnuclear Specification NUH-03-0218, "Field Erection of NUHOMS HSM-H Array"

51. Calculation PA-0241, "EAB Dose from a Drop of the NUHOMS Transfer Cask"

52. NF-AA-NSF-601, "NUHOMS Transfer Haul Route Walkdown"

53. NRC Letter "Exemption from Parts of 10 CFR 72.212 - Storage of the NUHOMS HDDry Shielded Canisters at North Anna Power Station Independent Spent Fuel StorageInstallation (TAC No. L24551)", dated April 12, 2012 from Doug Weaver, DeputyDirector, Division of Spent Fuel Storage and Transportation, Office of Nuclear MaterialSafety and Safeguards, to L. N. Hartz, Vice President, Nuclear Support Services,Virginia Electric and Power Company

54. 0-HSP-ISFSI-001, "Independent Spent Fuel Storage Installation (ISFSI) Health PhysicsTLD Survey Surveillance

55. ASCE-7-95, "Minimum Design Loads for Buildings and Other Structures"

56. NRC Regulatory Issue Summary (RIS) 2003-18, "Use of Nuclear Energy Institute (NEI)99-01, Methodology for the Development of Emergency Action Levels"

57. NEI 99-01, "Methodology for the Development of Emergency Action Levels"

58. INPO 05-008, "Guidelines for Radiological Protection at Nuclear Power Plants"

59. Regulatory Guide 8.2, "Guide for Administrative Practice in Radiation Protection"

60. Regulatory Guide 8.8, Rev. 3, "Information Relevant to Ensuring that OccupationRadiation Exposures at Nuclear Power Stations Will Be As Low As Is ReasonablyAchievable"


61. Regulatory Guide 8.10, Rev. 1, "Operating Philosophy for Maintaining OccupationalRadiation Exposures As Low As Is Reasonably Achievable"

62. 0-OP-4.50, "NUHOMS-32PTH Dry Shielded Canister Loading and Handling".

63. HP-3051.010, "Radiological Environmental Monitoring Program"

64. North Anna [Site Specific] ISFSI SAR

65. 0-OP-4.54, "Transfer Cask/Dry Shielded Canister Transfer to ISFSI and Dry ShieldedCanister Transfer from Transfer Cask to Horizontal Storage Module"

66. 0-OP-4.55, "Transfer Dry Shielded Canister from Horizontal Storage Module to TransferCask and Transfer to Decon Bay"

67. GMP-C-128, "Horizontal Storage Module (HSM-H) Assembly for Spent Fuel"

68. Transnuclear Calculation 10494-138, "Trunnion Reevaluations Due to Lift BeamModifications"

69. DCP-05-004 FC2, "Fall Protection Guard Rail System"

70. VPAP-2101, "Radiation Protection Program"

71. Regulatory Guide 8.9, "Acceptable Concepts, Models, Equations, and Assumptions for aBioassay Program"

72. NRC Letter "ASME Code Alternative Request, Temporary Welded Attachment Records,Docket -72-1030(TAC) L24163)", dated January 9, 2008 from Nader L. Mamish, DeputyDirector, Licensing and Inspection Directorate, Division of Spent Fuel Storage andTransportation, Office of Nuclear Material Safety and Safeguards, to Tara Neider,President of Transnuclear, Inc.

73. Technical Report NE-1 154, "Use of Dry Storage Casks at the North Anna Power Station"

74. Calculation CE-1 192, "Fuel Cask and Lid Drop Analysis for the NUHOMS-32 CaskSystem"

75. VPAP-2802, "Notifications and Reports"

76. ET-CCE-2008-0001, "Evaluation of the ISFSI Haul Routes for NUHOMS 10'6" WideCask Transfer Trailer"


77. North Anna Power Station Unit No. 1 Renewed License No. NPF-4, issued 3/20/2003,expires 4/1/2038 )

78. North Anna Power Station Unit No. 2 Renewed License No. NPF-7, issued 3/20/2003,expires 8/21/2040

79. ET-NAF-2007-0045 "North Anna Universal Lifting Yoke (ULY) Arm Mod"

80. Letter to NRC Spent Fuel Project Office from Eugene Grecheck, Serial No. 07-0290,"Notification of Intent to Apply Previously Approved 10CFR Part 50 Quality AssuranceProgram to Independent Spent Fuel Storage Installation Activities," dated March 16,2007.

81. 50.59/72.48 Screen # SE-NAF-20080005-0-0 for the optional use of the trunnion towercover plates during TC/DSC transfer, dated 2/14/2008.

82. 0-PT-4.51," Horizontal Storage Module Thermal Performance Verification"

83. Calculation PA-0205, Rev. 0, "Rod Clips Evaluation for Dry Cask Storage at North AnnaPower Station", April 2003.

84. Calculation SF-0005 "Standoff Distances for Gasoline Use at the ISFSI"

85. 0-OP-4.51, "Unloading a Loaded NUHOMS 32PTH Dry Shielded Canister"

86. Calculation PA-0243 Addendum A, "Dose Rate Evaluation of the North Anna ISFSIBased on TN32 and NUHOMS HD Storage Systems"

87. NRC SER, "Safety Evaluation Report for the North Anna Independent Spent FuelStorage Installation."

88. North Anna Technical Specifications, Unit 1

89. DCP-NA-10-00001, "Expanded Fall Protection System for HSM Shield Wall Array, NAPSISFSI Pad No. 2"

90. Transnuclear Letter E-32856, Ken Boone (TN) to Cary Laroe (Dominion), titled"Evaluation of the ITTR storage in the 32PTH," dated May 18, 2012.

91. Procedure CM-AA-ETE-1 01, Engineering Technical Evaluation (ETE)

92. OD-440, Revision 1, "Revision 1 to the Operability Determination Evaluation performedfor the North Anna ISFSI after the 8/23/11 Seismic Event"


93. Calculation CE-1 973, Revision 0, "Reanalysis of ISFSI Pad #2 for Revised GroundMotion Following 8/23/11 Earthquake"

94. Calculation CE-1974, Revision 0, "Soil/Structure Interaction for ISFSI Pad #2 for RevisedGround Motion Following 8/23/11 Earthquake"

95. Transnuclear NCR 2012-111, "Evaluation of Non-conforming Conditions Resulting from8/23/11 Seismic Event"

96. Calculation PA-0243, Addendum B, "Dose Rate Evaluation of the North Anna ISFSIBased on TN32 and NUHOMS HD Storage Systems"

97. Transnuclear Calculation 10494-186, "HSM-H Structural Evaluation for 8/23/11 SeismicEvent"

98. Transnuclear Calculation 10494-185, "32PTH DSC Structural Evaluation for 8/23/11Seismic Event"

99. ETE-CEM-2012-0001, Revision 0, "Seismic Design Inputs for ISFSI"

100. ETE-NAF-2011-0170, Revision 1, "North Anna ISFSI NUHOMS Horizontal StorageModules (HSM) Concrete Gap Inspection"

101. Recertification and Earthquake Evaluation NCR Package for Dominion Energy-NorthAnna Power Station Phase 2 Modules HSMH-13 through 26", 11/8/12, Revision 1

102. Recertification and Earthquake Evaluation NCR Package for Dominion Energy-NorthAnna Power Station Phase 1 Modules HSMH-1 through 12", 11/8/12, Revision 2

ETE -NAF-2010-0003 Rev. 3

Attachment 1

Certificate of Compliance (1030) Evaluation and Appendix A Technical Specifications

Pagelof23 * I

CERTIFICATE OF COMPLIANCEFOR DRY SPENT FUEL STORAGE CASKS

No Action Required.

0

S

0

S

0

0

0

a

CERTIFICATE NUMBER: 1030EFFECTIVE DATE: January 10, 2007EXPIRATION DATE: January 11, 2027DOCKET NO. 72-1030AMENDMENT NO. 1AMENDMENT EFFECTIVE DATE: March 29, 2011PACKAGE IDENTIFICATION NUMBER: USA/72-1030ISSUED TO: Transnuclear, IncSAFETY ANALYSIS REPORT TITLE: Transnuclear, Inc."Safety Analysis Report for the NUHOMS HD Horizontal ModularStorage System for Irradiated Nuclear Fuel"

CONDITIONSThis certificate is conditioned upon fulfilling the requirements of 10 CFR Part72, as applicable, the attached Appendix A (Technical Specifications) andthe conditions specified below;

NAPS Units I and 2 are permitted to store irradiated nuclearfuel under the general license provisions of 10 CFR 72. TheCONDITIONS and Appendix A of NRC CoC No. 1030 apply tothis activity. Dominion is legally obligated to fulfill therequirements of 10 CFR 72 and NRC CoC No. 1030[Reference 1].

1. CASK

a. Model No. NUHOMS HD 32PTH

The two digits refer to the number of fuel assemblies stored in the dry The NUHOMS HD Horizontal Modular Storage System is theshielded canister (DSC), the character P for pressurized water reactor spent fuel dry storage system authorized by NRC CoC No.(PWR) is to designate the type of fuel stored, T is to designate that the 1030 [Reference 1].DSC is intended for transportation in a 10 CFR Part 71 approvedpackage, and the last character H to designate that the design isqualified for fuel with burnup greater than 45 GWd/Mtu.


Attachment I


b. Description

The NUHOMS HD System is certified as described in the finalsafety analysis report (FSAR) and In the NRC's Safety EvaluationReport (SER). The NUHOMS HD System is a horizontal canistersystem composed of a steel dry shielded canister (DSC), areinforced concrete horizontal storage module (HSM-H), and atransfer cask (TC). The NUHOMS HD has been designed forenhanced heat rejection capabilities, and to permit the storage ofnon fuel assembly hardware with the fuel and/or damaged spentfuel assemblies. The welded DSC provides confinement andcriticality control for the storage and transfer of irradiated fuel. Theconcrete module provides radiation shielding while allowing coolingof the DSC and fuel by natural convection during storage. The TC isused for transferring the DSC from/to the Spent Fuel Pool Buildingto/from the HSM-H.

The principal component subassemblies of the DSC are the shell withintegral bottom cover plate and shield plug and ram/grapple ring, topshield plug, top cover plate, and basket assembly. The shell length isfuel-specific. The 32PTH DSC basket consists of stainless steel squaretubes and support strips for structural support, and geometry control,and aluminum/borated aluminum/Boral or Metal Matrix Composite forheat transfer and criticality control. The assembly is designed toaccommodate 32 PWR assemblies. The DSC is designed to slide fromthe transfer cask into the HSM-H and back without damage to the slidingsurfaces.

The HSM-H is a reinforced concrete unit with penetrations located at thetop and bottom of the sidewalls for airflow. The penetrations areprotected from debris intrusions by wire mesh screens during storageoperation. The HSM-H has heat shields that provide thermal protectionfor the HSM-H concrete. The DSC Support Structure, a structural steelframe with rails, is installed within the HSM-H module to provide forsliding the DSC in and out of the HSM-H and to support the DSC withinthe HSM-H. HSM-Hs are arranged in arrays to minimize space andmaximize self-shielding.

The NUHOMS HD Horizontal Storage System as described inCoC No. 1030 [Reference 1] is used by NAPS for the dry storageof spent nuclear fuel. Components include the 32PTH DSC, theOS187H Transfer Cask, and the HSM-H horizontal storagemodule. Other equipment required to transfer and store spentfuel at NAPS is not subject to CoC No. 1030 [Reference 1]except as required to comply with Appendix A of CoC No.1030.


Attachment I


The TC is designed and fabricated as a lifting device to meet ANSIN14.6 requirements. It is used for transfer operations within the SpentFuel Pool Building and for transfer operations to/from the HSM-H. TheTC is a cylindrical vessel with a bottom end closure assembly and abolted top cover plate. Two upper lifting trunnions are located near thetop of the cask for downending/uprighting and lifting of the cask in theSpent Fuel Pool Building. The lower trunnions, located near the base ofthe cask, serve as the axis of rotation during downending/uprightingoperations and as supports during transport to/from the IndependentSpent Fuel Storage Installation (ISFSI).

With the exception of the TC, fuel transfer and auxiliary equipmentnecessary for ISFSI operations are not included as part of theNUHOMS HD System referenced in this Certificate of Compliance.

c. Drawings

The drawings for the NUHOMS HD System are contained in The NUHOMS HD Horizontal Storage System drawings areSection 1 of the SAR. found in Section 1 of the "Safety Analysis Report for the

NUHOMS HD Horizontal Modular Storage System for IrradiatedFuel" [Reference 14].

d. Basic Components

The basic components of the NUHOMS HD System that are The three basic components of the NAPS NUHOMS HDimportant to safety are the DSC, HSM-H, and TC. These Horizontal Modular Storage System that are important to safetycomponents are described in Section 2.5 and Table 2-5 of the SAR. are described in Section 2.5 and Table 2-5 of the SAR.

2. OPERATING PROCEDURES

Written procedures shall be prepared for cask handling, loading, NAPS site specific procedures have been prepared for operatingsurveillance, and movement. The user's site specific written operating and maintaining the NUHOMS HD System. These proceduresprocedures shall be consistent with the technical bases described in are listed in Attachment 3.Chapter 8 of the SAR.


Attachment I


3. ACCEPTANCE TESTS AND MAINTENANCE PROGRAM

Written cask acceptance tests and maintenance program shall beprepared consistent with the technical bases described in Chapter 9 ofthe SAR.

9.1 Acceptance Criteria9.1.1 Visual Inspection and Non- Destructive Examination9.1.2 Structural and Pressure Tests9.1.3 Leak Tests9.1.4 Components9.1.5 Shielding Integrity9.1.6 Thermal Acceptance9.1.7 Neutron absorber Tests9.2 Maintenance9.2.1 Inspection9.2.2 Tests9.2.3 Repair, Replacement and Maintenance9.3 Marking9.4 Pre-Operational testing and Training Exercise9.5 Specification for Neutron Absorbers9.5.1 Specification for Thermal Conductivity Testing for NeutronAbsorbers9.5.2 Specification for Acceptance Testing for Neutron Absorbers byNeutron Transmission9.5.3 Specification for Qualification testing of Metal Matrix Composites9.5.4 Specification for Process Controls for Metal Matrix Composites

Acceptance testing is performed by the fabricators and verified byTransnuclear and Dominion. Certifications for major componentsare provided by the fabricators, Transnuclear, and Dominion. Theacceptance testing for the 32PTH DSC is described inTransnuclear Specification E-21621, "Design Criteria Document(DCD) for the NUHOMS HD System for Transportation andStorage" [Reference 42]. The testing and acceptancerequirements for the DSCs are in Transnuclear Specification E-20763, "Procurement Specification for the NUHOMS 32PTH HDSystem Dry Shielded Canister (DSC)" [Reference 46].Transnuclear Specification E-20932, "Procurement Specificationfor the NUHOMS 32PTH HD System OS187H Transfer Cask"[Reference 45], provides the testing and acceptance criteria forthe TC, which were performed by the fabricator, Hitachi Zosen.

Transnuclear Specification E-21249, "Procurement Specificationfor Boral Paired with Aluminum 1100 Plates for the NUHOMS-32PTH, Type IIC Dry Shielded Canister", [Reference 43] statesthe requirements for the manufacture, testing, and inspection ofBoral neutron absorber plates used in the DSC. Boral materialsmust meet specific ASTM thermal conductivity requirements asIdentified in the specifications. Thermal testing was performed byTransnuclear and therefore not required to be performed by theuser, Dominion. All components are processed at NAPS underMS-AA-WHR-401,"Receiving" [Reference 33].

Station testing and inspection of the TC is done annually under0-PT-4.50, "NUHOMS HD OS187H Transfer Cask Inspection"[Reference 29). This includes leak testing, visual inspections, andnon-destructive evaluations of trunnion welds.

The DSC and the HSMs have been marked as indicated in theNUHOMS HD 32PTH FSAR [Reference 141.


Attachment 1


A pre-operational testing and training plan [Reference 49] wasdeveloped in accordance with NUHOMS HD FSAR Section 9.4.This "dry run" was witnessed by the NRC. It simulated theclosure, handling, unloading, and transfer capabilities of theprocedures for the NUHOMS HD System. The procedures usedin the dry run performed the critical steps by simulating theconditions used for licensed NUHOMS HD System operations.

Boral plates were manufactured and certified by AAR CargoSystems under Transnuclear Specification E-21249,"Procurement Specification for Boral Paired with Aluminum 1100Plates, for the NUHOMS-32PTH, Type IIC Dry Shielded Canister"[Reference 43). B1O concentration may be verified by chemicaland isotopic B10 sampling, or by neutron transmission testing.Material thermal conductivity ASTM E1225 values are identifiedin AAR manufacturing "Standard Specification for BoralComposite Panels" [Reference 44]. Qualification reports andprocess controls that are in the AAR QA program were reviewedand approved by Transnuclear. DSCs are procured byTransnuclear using E-20763, "Procurement Specification for theNUHOMS 32PTH HD_ System Dry Shielded Canister (DSC)"[Reference 46). DSC borated materials are certified by themanufacturer. DSCs are also certified by Transnuclear.Transnuclear Procurement Specifications and componentfabrication data packages are reviewed and approved byDominion.

4. QUALITY ASSURANCE

Activities in the areas of design, purchase, fabrication, assembly, Pursuant to 10 CFR 72.140 (d) requirements, Dominioninspection, testing, operation, maintenance, repair, modification of possesses an NRC-approved 10 CFR Part 50 QA Program that isstructures, systems and components, and decommissioning shall be fully described in the Dominion Topical Report. Dominion notifiedconducted in accordance with a quality assurance program that satisfies NRC in a March 16, 2007 letter of the intent to apply thethe applicable requirements of 10CFR72 Subpart G, and that is Dominion common Nuclear Facility 0CGFR50 Appendix B Qualityestablished, maintained, and executed with regard to the cask system. Assurance Program (labeled Topical Report DOM-QA-1) to all

NAPS ISFSI construction and general license activities[Reference 80].


Attachment 1


The 32PTH dry shielded canisters are considered QA Safety-Related. The TCs and the horizontal storage modules areclassified as non-safety related with special quality/regulatoryrequirements (NSQ). These classifications translate from the 10CFR 72 classifications for Important to Safety (A) and Importantto Safety (B) respectively. The cask restraint system is also NSQ,and was designated by Transnuclear as ITS-C. Dominioncomponent quality classifications do not supersede those ofTransnuclear, but serve to map these Transnuclear componentsinto the Dominion/NAPS classification system.

Transnuclear designed the NUHOMS HD System andsubcontracted manufacture of the NUHOMS HD components.Transnuclear possesses an NRC approved 10 CFR 72 Subpart GQA program. The TC was purchased as a complete unit fromTransnuclear, Inc, and was fabricated by Hitachi Zosen Corp inJapan. The HSM-Hs were manufactured by Bayshore ConcreteProducts in Cape Charles, Va. These components have beenprovided Certificates of Compliance documenting that they meetthe conditions of Transnuclear CoC 1030. Each HSM array iscertified by Transnuclear after HSM assembly has beencompleted.

While the primary QA direction and oversight is provided byTransnuclear for manufacture of these NUHOMS HDcomponents, Dominion provides additional source inspection andoversight as required for procurement under its own QA program.Dominion's vendor surveillance procedure, MS-AA-VEN-101[Reference 35] ensures manufacturing requirements andstandards are met through surveillances performed at criticalstages of component manufacture. To ensure that the specificquality control requirements of the General License were met,Dominion and Transnuclear established specified Hold andWitness points during the fabrication and testing of the storagemodules.

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Attachment 1


5. HEAVY LOADS REQUIREMENTS

Each lift of a DSC and TC must be made in accordance with the existingheavy loads requirements and procedures of the licensed facility atwhich the lift is made. A plant-specific safety review under 10 CFR 50.59or 10 CFR 72.48, if applicable) is required to show operationalcompliance with existing plant-specific heavy loads requirements.

Each lift of a loaded DSC and TC is to be made with procedure 0-OP-4.50, "NUHOMS-32PTH Dry Shielded Canister Loading andHandling" [Reference 62] or 0-OP-4.51, "Unloading a LoadedNUHOMS 32PTH Dry Shielded Canister [Reference 85]. Theseprocedures specify lifting limitations based on a drop analysisperformed under 10 CFR 50 for the loaded TC. Dominionprocedure VPAP-0809, "NUREG-0612 Heavy Load Program"[Reference 39] incorporates NUREG-0612 requirements for liftingand identifies the NAPS cask crane as NUREG 0612 equipment.North Anna NUHOMS HD loading and transfer procedures havebeen verified to be in compliance with NUREG 0612requirements.

6. APPROVED CONTENTS

Contents of the NUHOMS HD System must meet the fuel specifications See discussion for Appendix A Technical Specifications in thisin Appendix A (Technical Specifications). Attachment.

7. DESIGN FEATURES

Features or characteristics for the site, cask, or ancillary equipment must Per T.S. 4.1.1, the site characteristic "location" is not applicablebe in accordance with Appendix A (Technical Specifications) for a general license. The storage capacity of the NAPS ISFSI is

not limited by license. It is limited by design capacity or theinstalled capacity of the NUHOMS HD spent fuel storage system.Design features are evaluated in the discussion for Section 4 ofAppendix A to CoC No.1030 (in this Attachment).

8. PRE-OPERATIONAL TESTING AND TRAINING EXERCISE

A dry run training exercise of the loading, closure, handling, unloading, The Pre-Operational Testing and Training Exercise is required toand transfer of the NUHOMS HD System shall be conducted by each satisfy the requirements specified in the NUHOMS HD 32 PTHlicensee prior to the first use of the system to load spent nuclear fuel Horizontal Modular Storage System CoC No. 1030 [Reference 11.assemblies. The training exercise shall not be conducted with spent The Pre-Operational Testing and Training Exercise [Referencenuclear fuel in the canister. The dry run may be performed in an 49] was conducted in four (4) phases. The individual phasesalternate step sequence from the actual procedural guidelines in Chapter were completed at NAPS or were demonstrated previously at the8 of the SAR. The dry run shall include but not be limited to the following: Surry Power Station depending on equipment availability and

facility readiness. The Pre-Operational Testing and Training


Attachment 1


I

Loading Operations Exercise was conducted by performing the applicable sections ofthe NUHOMS HD operating procedures to demonstrateproficiency.

a.b.C.d.

Fuel LoadingDCS sealing, drying, and backfilling operations.TC down ending and transport to the ISFSIDSC transfer to the HSM-H

Unloading Operations

e.f.g.

DSC retrieval from HSM-HFlooding of DSCOpening of DSC

9. HSM-H THERMAL PERFORMANCE METHODOLOGY

The use of HSM-H thermal performance methodology is allowed forevaluating HSM-H configuration changes except for changes to theHSM-H cavity height, cavity width, elevation and cross-sectional areas ofthe HSM-H air inlet/outlet vents, total outside height, length and width ofHSM-H if these changes exceed 8% of their nominal design valuesshown on the approved CoC drawings.

I

The NUHOMS HD system designer, Transnuclear, hasperformed the required thermal evaluations. These evaluationsare described in Chapter 4 of the FSAR [Reference 14].Condition 9 of the CoC limits changes to HSM-H configurationsthat are equal to or less than 8% of nominal design values on theapproved CoC drawings. By contract Dominion has the right toapprove evaluations performed by Transuclear to ensure thatchanges will be in compliance with the system CoC. Dominionprocedures require surveillance of the HSM vents to verify thereis no vent blockage.

10. AUTHORIZATION

The NUHOMS HD System, which is authorized by this certificate, is NRC licenses NPF-4 and NPF-7 were issued to Dominion tohereby approved for general use by holders of 10 CFR Part 50 licenses operate two PWR reactors under 10 CFR 50 at the North Annafor nuclear reactors at reactor sites under the general license issued Power Station. 10 CFR 72.210 authorizes the general licensee,pursuant to 10 CFR 72.210, subject to the conditions specified by 10 CFR NAPS, to use the NUHOMS HD System in accordance with the72.212, and the attached Appendix A. requirements of CoC No. 1030 [Reference 1].

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Appendix A to COC 1030 No Action Required.

NUHOMS HD SYSTEM GENERIC TECHNICAL SPECIFICATIONS

1.0 USE AND APPLICATION

1.1. Definitions Dominion acknowledges the terms, definitions, logical1.2. Logical Connectors connectors, completion times, and frequency conventions1.3. Completion Times specified in TS 1.0 in describing, operating, and maintaining the1.4. Frequency NUHOMS HD System.

2.0 FUNCTIONAL AND OPERATING LIMITS

2.1 Fuel to be Stored in the 32PTH DSC The NAPS fuel assemblies that may be stored in a 32PTH DSCare delineated in the CoC No. 1030 Technical Specifications. Therequirements of T.S. 2.1 have been addressed in the fuelcertification procedure NF-AA-NSF-401 "ISFSI Fuel Selection andCertification" [Reference 31]. The purpose of this procedure is toensure the requirements of CoC No. 1030 Appendix A are metfor each fuel assembly loaded into a DSC and for the aggregateheat load.

Reference 83 indicates that fuel assemblies with up to 14 rodclips each may contain up to 4.90 kg of Inconel in the grids androd clips. Table 5-7 of the NUHOMS HD FSAR indicates that theshielding evaluation for the NUHOMS HD storage systemassumed that fuel assemblies each contained 5.9 kg of Inconel inthe grids. The storage of fuel assemblies with rod clips in theNUHOMS HD storage system is bounded by the shieldinganalysis in the NUHOMS HD FSAR. Rod clips do not affect otherstorage system analyses (structural, thermal, criticality orretrievability).

Reconstituted fuel assemblies have had fuel rods with claddingdefects removed and replaced with equivalent stainless steelrods. Chapter 5.2 of the NUHOMS HD FSAR states that "ifreconstituted fuel assemblies (considered as intact fuel in thecriticality analyses) with stainless steel rods undergo furtherirradiation, their gamma source term on a per DSC basis shall be

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Attachment 1


bounded by the total design basis gamma source terms".

Chapter 6.2 of the NUHOMS HD FSAR states that "reconstitutedfuel assemblies, where the fuel pins are replaced with stainlesssteel (or Zircaloy) pins that displace the same amount of boratedwater, are considered to be intact fuel assemblies." Replacementrods are lighter than fuel rods and have no decay heat, sostructural and thermal analyses remain bounding. The storage ofreconstituted fuel assemblies is acceptable in the NUHOMS HDstorage system.

NEI Letter to NRC, dated 2/22/2012, "RIRP Issue Closure FormTop Nozzle SCC 1-10-01," ML 12054082 states:

"For modified assemblies (variants #3 and #4), the ITTR/GTAhardware does not need to be explicitly listed in the cask's"Approved Contents" in the CoC or license because they are non-separable constituent hardware, integral to the fuel assembly.For these variants, a revision to the "Approved Contents" in theCoC or license is not necessary as long as 1) the assembly typebeing modified is already included in the "Approved Contents", 2)the assembly, as modified, is bounded by the parameters for thatassembly listed in the "Approved Contents" (e.g., total weight,overall length, etc.), AND 3) the 72.48 review for storing thishardware concludes prior NRC approval is not required."

NRC Letter to NEI, dated 4/27/2012, "Response to NEI LetterRegarding Regulatory Issue Resolution Protocol Issue ClosureForm for Top Nozzle Stress Corrosion Cracking," ML 1209A137states:

"The NRC staff has reviewed the closure form and determinedthat it accurately documents the resolution of the RIRP TopNozzle SCC issue. The Top Nozzle closure is consistent with theNEI guidelines established in the "Used Fuel and TransportationIssue Resolution Protocol, A Methodology for Resolving Issueswith Generic Implications, NEI 10-03, Revision 0." The UsedFuel Storage and Transportation Issue Closure Form, IssueNumber 1-10-1 (ML12108A180) will document closure of the Top


Attachment I


Nozzle SCC issue and will constitute a durable record, in theinterim, until such time as NRC issues a generic communication.NRC intends to issue a Regulatory Issue Summary (RIS) as thefinal generic communication."

Using the resolution criteria above, Transnuclear (the certificateholder) has justified the acceptability of loading WE15x15 andWE17x17 fuel assemblies containing Instrument Tube Tie Rods(ITTR) without prior NRC approval through the 10 CFR 72.48process [Reference 84]. A marked up copy of the applicableNUHOMS HD UFSAR pages and drawings clearly showing thechange implemented through the 72.48 process is given by FCN-721030-319, Revision 0.

Contrary to the requirements of 10 CFR 72.212(b)(3) and theTechnical Specifications for NUHOMS HD 32PTH Dry ShieldedCanisters (DSC), for DSCs with Serial Numbers DOM-32PTH-004-C, -005-C, -007-C, -010-C, -013-C, -019-C, and GBC-32PTH-01 1-C, a total of twelve fuel assemblies were placed inDSC locations where their decay heat at the time of loadingslightly exceeded the functional and operational limits provided inCoC 1030 Amendment 0, Technical Specification Section 2.1.

The decay heats of the twelve fuel assemblies distributed overthe identified seven DSCs have decreased over time and nowmeet the decay heat limits as stated in the CoC 1030 TechnicalSpecifications. As a response to the violation, Virginia Electricand Power Company (Dominion) requested a one-timeexemption from the requirements of 10 CFR 72.212(b)(3)pursuant to 10 CFR 72.7, for the seven affected DSCs withrespect to the decay heat requirements [Reference 36].

On April 12, 2012, the Nuclear Regulatory Commission issued toVirginia Electric and Power Company (Dominion) a one-timeexemption from the requirements of 10 CFR 72.212(b)(3) withrespect to the zone decay heat loading limits for DSCs DOM-


Attachment 1


I

2.2 Functional and Operating Limits Violations

32PTH-004-C, -005-C, -007-C, -010-C, -013-C, -019-C, andGBC-32PTH-011-C [Reference 531.

Any violation of CoC 1030 Technical Specifications functional oroperating limits must be promptly reported (as per procedure) tothe shift supervisor and entered into the Dominion NuclearCentral Reporting System. As required by licensing procedurethe NRC must be notified in accordance with TechnicalSpecification time constraints. The cask loading procedure, 0-OP-4.50 [Reference 62] and, the notification/reporting procedure,VPAP-2802 [Reference 75], indicate the actions to be taken inthe case of heat load limit violations or a cask misloading (T.S.2.2).

3.0 LIMITING CONDITION FOR OPERATION (LCO) ANDSURVEILLANCE REQUIREMENT (SR) APPLICABILITY

3.1 32PTH DSC Fuel Integrity

Dominion acknowledges the LCO and SR applicability rulesstated in TS 3.0 for operating and maintaining the NUHOMS HDSystem. Dominion understands that if an LCO is not met then theassociated Actions for that LCO must be met, unless it applies toequipment that has been removed from service and is beingreturned to service under administrative control solely to performtesting required to demonstrate it meets the LCO or that otherequipment meets the LCO.

Each spent fuel assembly stored in a 32PTH DSC/HSM-H at theISFSI must meet the requirements of TS 2.1, "Fuel to be Storedin the 32PTH DSC". This is accomplished by certifying each caskload using Administrative Procedure NF-AA-NSF-401 "ISFSI FuelSelection and Certification" [Reference 31]. This proceduredictates that each assembly/control component loaded meetsmechanical design, integrity, enrichment, burnup, cooling time,and heat load requirements. The identity of each assemblyloaded is verified using 0-OP-4.33," Pre-Cask LoadingVerification" [Reference 28]. Also, each DSC fuel load must meetaggregate limits for number, zoning, heat load, andgamma/neutron source terms. 0-OP-4.33, "Pre-cask LoadingVerification" contains the verification steps that ensure the fuelloaded in the DSC is as specified in the DSC load certification.


Attachment 1


I

3.1.1 DSC Bulkwater Removal Medium and Vacuum Drying Pressure3.1.2 32PTH DSC Helium Backfill Pressure

3.1.3 Transfer Cask Cavity Helium Backfill Pressure

3.2 Cask Criticality Control

Cask Loading and Handling operating procedure, O-OP-4.50,includes the LCOs and SRs of TS section 3.1. During loadingoperations, this procedure requires high purity helium to be usedas the cover gas during drainage of bulkwater from the DSC.The requirements to ensure DSC dryness by monitoring the DSCvacuum drying pressure and backfilling of the DSC with helium toensure proper heat transfer are also implemented throughoperating procedure O-OP-4.50.

The TC annulus is filled with 99.99% pure helium and maintainedat a 2 psig pressure during transport to the ISFSI as directed inNAPS procedure O-OP-4.54, "Transfer Cask /Dry ShieldedCanister Transfer to ISFSI and DSC Transfer from TC to HSM."NAPS procedure O-OP-4.52, "NUHOMS Vacuum Drying SystemOperation" provides steps for meeting the T.S. 3.1.3 for initial TChelium backfill pressure and time requirements.

DSC Loading procedure, O-OP-4.50, [Reference 62] implementsthe LCO and SRs of TS Section 3.2. Prior to loading andunloading operations the Table 7 boron concentrations areverified for loading. If the LCO for dissolved boron concentrationlimit is not met then all fuel is removed and placed in a safecondition in the Spent Fuel Pool.

4.0 DESIGN FEATURES

4.1 Site4.1.1 Site Location

4.2 Storage System Features

4.2.1 Storage Capacity

Per Appendix A, Step 4.1.1, the site characteristic "location" isnot applicable for a general license.

The storage capacity of the NAPS ISFSI Is not explicitly limited bythe plant license conditions. It is primarily limited by designcapacity or the installed capacity of the NUHOMS HD spent fuelstorage system taking into account IOCFR20 site boundary doserestrictions. Currently there are 26 HSM-H modules located onPad #2; however the pad was constructed to accommodate 40HSM-H modules.


Attachment I


1,

4.2.2 Storage Pad

4.3 Canister Criticality Control

The storage pad was built under DCP-05-004 [Reference 5] tothe requirements of Transnuclear specification E-3051, "DesignRequirements Document for the Independent Spent Fuel StorageInstallation Basemats and Approach Slabs at the North Anna andNorth Anna Power Stations", [Reference 4]. DCP-05-004[Reference 5] was the Dominion Nuclear primary document forconstruction of Pad #2. The storage pad soil structure wasinitially analyzed in Dominion Engineering Calculation CE-1824[Reference 6] and determined to meet the applicable loadrequirements of NUHOMS HD FSAR [Reference 14], App. 3.9.

The pad was reanalyzed after the 8/23/11 seismic event[Reference 93], to determine the imposed loads on the pad forthe configuration of.HSM-Hs at the time of the earthquake as wellas for a configuration assuming the pad to be fully loaded. SoilStructure Interaction (SSI) effects based on the event weremodeled and included in this reanalysis. This strength evaluationof the pad determined the internal moments, shears and soilbearing pressure induced at the time of the seismic event werewithin the code allowables for which the ISFSI pad was designed.

For criticality control, DSCs are fabricated with borated materialpoison plates incorporated into the DSC fuel baskets. By design,the DSC has multiple basket configurations based on the materialtype and boron content in the poison plates. Transnuclearcertifies that each DSC has been fabricated in accordance withCoC 1030. The documentation package for each serial numbercomponent provides the fabrication record.

As per design, DSCs are loaded with fuel appropriate for theDSC type, based on criteria for enrichment, burnup, and coolingtime in accordance with Technical Specification 2.1. Guidancefor the fuel selection process is given in procedure NF-AA-NSF-401, "ISFSI Fuel Selection and Certification" [Reference 31]. Asdirected by procedure 0-OP-4.50, spent fuel pool water boronconcentration is sampled prior to DSC loading and verified to beqreater than that reauired by the NUHQMS HD Technical


Attachment I


4.3.1 Neutron Absorber Tests

4.4 Codes and Standards

4.4.1 Horizontal Storage Module (HSM-H)

4.4.2 Dry Shielded Canister (32 PTH DSC)

4.4.3 Transfer Cask (OS187H)

Specifications.

DSCs are procured by Transnuclear, using Specification E-20763, "Procurement Specification for the NUHOMS -32PTH HDSystem Dry Shielded Canister (DSC)" [Reference 46]. DSCborated materials (neutron absorbers) are certified by themanufacturer to meet the requirements of the FSAR. The testingand fabrication of the poison materials are surveilled byTransnuclear to ensure the requirements are met.

The reinforced concrete HSM-H is designed to TransnuclearSpecification E-21621, "Design Criteria Document for theNUHOMS HD System for Transportation and Storage"[Reference 42]. The HSM-Hs are built to TransnuclearSpecification NUH-03-0214, "Precast Concrete Construction ofNUHOMS HD HSM-H" [Reference 47]. The HSM-H moduleswere constructed in accordance with ACI 318-95, "Building CodeRequirements for Structural Concrete" [Reference 48], and theconcrete formulation used for the HSM-H modules was tested at4500 F for 40 hours.

The dry shielded canister design is described in E-21621,"Design Criteria Document (DCD) for the NUHOMS HD Systemfor Transportation and Storage" [Reference 42]. Thisspecification identifies the applicable ASME Boiler and PressureVessel Codes for the DSC. The DSCs are fabricated andinspected to Transnuclear specification E-20763, "ProcurementSpecification for the 32PTH-HD System Dry Shielded Canister(DSC)" [Reference 46].

The OS187H TC design is described in TransnuclearSpecification E-21621, "Design Criteria Document for theNUHOMS HD System for Transportation and Storage"[Reference 42]. Section 9 requires the design meet ASME CodeSection III, Subsection NC for Class 2 components. The TC wasfabricated and inspected to Transnuclear Specification E-20932,"Procurement Specification for the NUHOMS HD-32PTH SystemOS187H Cask" TReference 451. The General Requirements of


Attachment I


this specification require that the cask structural shell andtrunnion material, fabrication, welding, and inspection complywith the rules of Subsection NC with special provisions forvessels designed to NC-3200, unless noted otherwise.

Bearing Stresses at Trunnion - FSAR Section 3.9.5.6.1.D:The bearing stress evaluation for the upper trunnions of theOS187H Transfer Cask assumes the yoke lifting arms are 2.5inches thick. The lifting yoke to be used at North Anna for theOS187H Transfer cask has lifting arms which are 2.25 inchesthick. The reduced thickness results in a smaller contact areabetween the yoke arm and the top trunnion creating a slightlygreater bearing stress. Transnuclear has performed a calculation[Reference 681 using the same methods as used in the FSAR[Reference 14] to evaluate the impact of the reduced thickness ofthe yoke arm on the trunnion bearing stress. This evaluationshows the OS187H Transfer Cask top trunnion bearing stressremains below the allowable bearing stress when the North Annalifting yoke is used.

Table 2-5 of the NUHOMS HD FSAR [Reference 14] lists thecask lifting yoke as Safety Related. Transnuclear FSAR ChangeNotice (FCN) 721030-186 revised the NUHOMS HD FSAR toreflect the yoke is to be classified under the plant-specific heavyloads program. The North Anna cask lifting yoke has beenclassified as Non-Safety Quality (NSQ) under the DominionNuclear 10 CFR 50 QA program classification system. The liftingyoke is maintained under a NRC approved NUREG 0612program. The lifting yoke is documented in ET.NAF-2007-0045"North Anna Universal Lifting Yoke (ULY) Arm Mod" [Reference79] to be safe for lifting NUHOMS HD cask loads.

Trunnion tower closure plates are now mentioned as optional inthe NUHOMS HD FSAR, and are not used at NAPS.Discontinuance of the use of trunnion tower closure platesbenefits personnel safety and has no impact on the safeoperation and function of the loaded transfer cask. This isaddressed in the loading procedure and its accompanying 72.48screen IReference 811. Transnuclear revised the NUHOMS HD


Attachment 1


I

4.4.4. Alternatives to Codes and Standards

FSAR in TN letter E-26931 transmitting FCN 721030-267, whichmade use of the closure plates optional.

All components procured by Dominion are certified to meet theapplicable code requirements as justified in Section 4.4.4. Thislist of justifications and compensatory measures has beenapproved by the NRC. All exceptions to the applicable codesmust be approved by the NRC.

Via letter in Reference 72, the NRC approved an alternative codeapplication for specified DSCs that had improperly documentedtemporary weld attachments removal. The 32PTH DSCs thatwere granted relief are: DOM-32PTH-001-C, DOM-32PTH-002-C,DOM-32PTH-003-C, DOM-32PTH-004-C, DOM-32PTH-005-C,DOM-32PTH-006-C, and DOM-32PTH-007-C. CoCs for theseDSCs have incorporated the SNCR that dispositions the codedeviations.

4.5 HSM-H Side Heat Shields

4.6 Storage Location Design Features

4.6.1 Storage Configuration

The NAPS NUHOMS HD heat shields are flat stainless steel(SS), an alternate material, and are analyzed for 34.8 KW. Thethermal analysis for flat SS heat shields is described in theNUHOMS HD FSAR [Reference 14].

The site features meet the NUHOMS HD requirements for ISFSIpad construction and use. Site conditions are near identical tothose for the NAPS site-specific licensed ISFSI, which existsadjacent to the NUHOMS HD general license pad. The NUHOMSHD site location features were reviewed [Reference 5] byDominion Nuclear Civil Engineering and found to be acceptable,prior to installation.

The HSM-H modules are assembled on the pad in an array inaccordance with Transnuclear Specification NUH-03-0218, "FieldErection of NUHOMS HD HSM-H Array" [Reference 50]. TheNorth Anna HSM-H modules are to be arranged in one back toback 2 x 20 array. An end shield wall is installed at the end ofeach row. No rear shield walls were required in this back-to-backconfiguration. This TN specification is implemented at the NAPSISFSI usina NAPS procedure GMP-C-128, "Storacle Module


Attachment I


II

(HSM-H) Assembly for Spent Fuel" [Reference 67]. A Certificateof Conformance certifying the NUHOMS HD HSM array and padare in compliance with CoC 1030 Amendment 0 was issued byTransnuclear on 11/7/2007. At this time 12 HSM-Hs wereerected on Pad #2. This array was later expanded to 26 HSM-Hsand the array was recertified on 5/17/2011 [Reference 26]indicating that HSM-H-1 through HSM-H-10 conformed to CoC1030 Amendment 0 requirements and HSM-H-1 I through HSM-H-26 now conformed to the requirements of CoC 1030Amendment 1. The certifications were revised on 11/8/12[References 101,102] to incorporate documentation evaluatingthe impact of the 8/23/11 seismic event. Based on theevaluations the applicable NUHOMS HD storage systems wererecertified indicating they remain compliant and in conformancewith the requirements of CoC 1030 Amendment 0 or Amendment1.

DCP-05-004 FC2, "Fall Protection Guard Rail System"[Reference 69), was used to add rooftop perimeter safety rails tothe HSM array (HSM-Hs 1-12). DCP-NA-10-00001, "ExpandedFall Protection System for HSM Shield Wall Array, NAPS ISFSIPad No. 2" [Reference 89], was used to expand the current fallprotection system to encompass the current HSM-H array (HSM-Hs 1-26).

The storage pad was built to the requirements of Transnuclearspecification E-23051, "Design Requirements Document for theIndependent Spent Fuel Storage Installation Basemats andApproach Slabs at the North Anna and North Anna PowerStations" [Reference 41.

The North Anna UFSAR [Reference 11] and site specific ISFSISAR [Reference 64] analysis model 300 mph rotational and 60mph translational tornado wind speeds very similar to theNUHOMS HD limits.

4.6.2 Concrete Storage Pad Properties to Limit 32PTH GravitationalLoadings Due to Postulated Drops

4.6.3 Site Specific Parameters to Analyses

4.6.3 (1) Tornado maximum wind speeds: 290 mph rotational, 70translational

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4.6.3 (2) Flood up to 50ft. and water velocity of 15 fps

4.6.3 (3) One hundred year roof snow load of 110 psf

4.6.3 (4) Normal ambient temperatures of 0 deg F to 100 deg F

4.6.3 (5) Of normal ambient temperature range of -21 deg F withoutsolar insolation to 115 deg F with full solar insolation.

4.6.3 (6) The potential for fires and explosions shall be addressedbased on site-specific considerations.

4.6.3 (7) Supplemental Shielding: In cases where engineeredfeatures(i.e. berms, shield walls) are used to ensure the requirements of10 CFR 72.104 (a) are met, such features are to be consideredimportant to safety and must be evaluated to determine the applicableQuality assurance Category.

4.6.3 (8) Seismic loads of up to 0.30 g horizontal and up to 0.20 g vertical.

Based on the North Anna site specific ISFSI SAR [Reference 64]the ISFSI is 45 feet above maximum flood level.

Based on the North Anna ISFSI SAR [Reference 64] theexpected annual site snow fall Is about 15 inches or 7.8 psf,

Per the North Anna UFSAR [Reference 11] the normal dailytemperature range is from 100 F to 950 F.

Per the North Anna ISFSI SAR [Reference 641 the extremetemperature range is -120 F to 1070 F (1898-1991, Richmond,Va.).

The potential for fire and explosions is fully discussed in the ACI-NES Report "North Anna Power Station ISFSI and Heavy HaulPath Hazards Evaluation" [Reference 16]. The potential fire andexplosion effects for the NAPS ISFSI are bounded by the tornadowind/missile effects.

Technical Specification 4.6.3 (7) requires that supplementalshielding be evaluated to determine the Quality AssuranceCategory. No berms or permanent supplemental shielding isrequired for the NAPS NUHOMS HD ISFSI to meet 10 CFR72.104 (a). Shielding is an integral part of the HSM constructionand is achieved by adequate concrete module wall thickness.End shield walls are a permanent engineered component in theNUHOMS HD concrete module system design. The end shieldwalls have been determined to be important-to-safety. This QAcategory designation was assigned to the end shield wallmodules by Transnuclear. Additional temporary or local shieldingmay be employed if required by the NAPS Health Physics orALARA functions to control worker dose.

Per the North Anna ISFSI SAR [Reference 64] the design basisearthquake peak acceleration are 0.18 g horizontal and 0.12 gvertical.


Attachment 1


I

The peak ground accelerations recorded at the Unit 1 basematfor the 8/23/11 event were 0.26 g north-south, 0.11 g east-westand 0.12 g vertical [Reference 99]. Although these peakaccelerations exceed the design basis earthquake values initiallyassumed for the North Anna Power Station, they remain lessthan the 0.30 g horizontal and 0.20 g seismic loads of TechnicalSpecification 4.6.3.

5.0 ADMINISTRATIVE CONTROLS

5.1 Procedures

5.2 Programs

5.2.1 Safety Review Program

5.2.2 Training Program

5.2.3 Radiological Environmental Monitoring Program

NAPS has established a comprehensive set of procedures thatcover all normal NUHOMS HD operations, maintenance, andtesting at the NUHOMS HD ISFSI prior to its operation. Asimilar set of procedures are already established for theexisting NAPS ISFSI, operated under a site specific 10 CFR72 license. Procedures have been created for the handling,loading of DSCs and the TC, inspection and maintenance ofthe TC, and the surveillance of the HSM-H modules. Individualprocedures are identified in Attachment 3.

Changes to the NAPS NUHOMS HD system must be reviewedin accordance with 10 CFR 72.48. All changes to theTechnical Specification Bases and other licensing basesdocuments are conducted in accordance with approvedadministrative procedures. All substantive changes impactingthe ISFSI are screened and evaluated (if necessary) usingprocedure CM-AA-400 [Reference 27]. This procedurerequires that the UFSAR [Reference 14] be reviewed prior toapproval of a change.

The NAPS ISFSI Training and Certification Program isaddressed in Section 4.4.15.1 of the 72.212 Evaluation.

NAPS takes quarterly TLD readings at locations on the site andthe surrounding area. These are described by HP-3051.010,"Radiological Environmental Monitoring Program" [Reference 63].Dose rates have been calculated for the nearest resident and are


Attachment I


5.2.4 Radiation Protection Program

5.2.5 HSM-H Thermal Monitoring Program

5.3 Lifting Controls

5.3.1 Transfer Casks Lift Heights

5.3.2 Cask Drop

within regulatory limits.

Dose at the ISFSI perimeter is measured and read quarterlyunder procedure 0-HSP-ISFSI-001, "Independent Spent FuelStorage Installation (ISFSI) Health Physics TLD SurveySurveillance" [Reference 541.

Thermal monitoring has been included in procedure 0-PT-4.51, "Horizontal Storage Module Thermal PerformanceVerification" [Reference 82].

Lifting controls are specified for cask loading and. handlingoperations. A cask drop analysis has been performed and isdiscussed in Technical Report NE-1154, "Use of Dry StorageCasks at the North Anna Power Station" [Reference 73].

The limiting lift height values from the drop analysis and from theTechnical Specifications are contained in the following NAPSprocedures. Cask lift heights are controlled during loading byprocedure 0-OP-4,50, "NUHOMS 32PTH Dry Shielded CanisterLoading and Handling" [Reference 62], and during transfer byprocedure 0-OP-4.54, "Transfer/Dry Shielded Canister Transferto ISFSI and Dry Shielded Canister Transfer from Transfer Caskto Horizontal Storage Module" [Reference 65].

Stone and Webster Calculation 11715-NS(B)-029, "Fuel CaskDrop" [Reference 19] and Calculation CE-1192, "Spent Fuel CaskLid Drop onto Cask Impact Pad for the NUHOMS-32 CaskSystem" [Reference 74], were performed to support the cask dropanalysis. These calculations establish the impact of cask drops inthe fuel building and were used to establish cask lifting controls.

Calculation PA-0241, "EAB Dose from a Drop of the NUHOMSTransfer Cask" [Reference 51], concludes that the estimated EABdose from a NUHOMS cask drop where all the fuel rods areruptured is 8.7E-07 Rem. This value represents the dose from therelease of all the gaseous inventory of 32 fuel assemblies. This Isless than the UFSAR fuel handling accident EAB dose value of1.0 Rem TEDE and much less than the Reg Guide 1.183 EAB

ETE -NAF-2010-0003 Rev. 3 Page 22 of 23 ' iAttachment 1


5.4 Dose Rate Evaluation Program

5.5 Concrete Testing

5.6 Hydrogen Gas Monitoring

dose limit of 6.3 Rem TEDE.

NUHOMS HD FSAR [Reference 14] paragraph 3.1.1.4 states thatthe user will perform a site-specific fuel structural evaluation for10 CFR 50 cask drops. The Dominion cask drop accident forcomputing EAB dose assumes all fuel rods fail. This conservativeapproach resulted in acceptable results and obviates the need formore detailed structural analyses.

In addition, NAPS cask handling operations employ a defense-in-depth philosophy which provides the intended level of protectionagainst load drop accidents of concern to the NRC. Thesecontrols ensure that a spent fuel cask handling accident aspostulated by the NRC is not credible at North Anna.

Casks dropped from 15 inches or more would be reported inaccordance with 0-OP-4.50, "NUHOMS-32PTH Dry ShieldedCanister Loading and Handling" [Reference 62].

The site dose rates for the NUHOMS HD ISFSI have beencalculated and are well below regulatory limits for the nearestresident. Because the values were estimated by Dominionusing the same source term as described in the NUHOMSFSAR [Reference 14], the dose rate limits for 5.4.1 are thesame as for 5.4.2. The ISFSI dose rate values are monitoredas per the HP surveillance procedure 0-HSP-ISFSI-002[Reference 13]. In the event a limit is exceeded actionsspecified in the Technical Specifications will be taken.

HSM-H concrete modules are certified to be built as specifiedin NUH-03-0214, "Precast Concrete Construction of NUHOMSHD HSM-H" [Reference 47]. Concrete testing requirementsare addressed in this Transnuclear specification. Dominionverifies CoC compliance for each HSM-H module built byBayshore Products.

Hydrogen gas monitoring has been included in 0-OP-4.50,"NUHOMS 32 PTH Dry Shielded Canister Loading andHandlinq".

ETE -NAF-2010-0003 Rev. 3 Page 23 of 23 ' .

Attachment 1


Summary of Surveillance and Monitoring Requirements

Technical Specifications Surveillance and When NAPS ImplementationMonitoring Requirements

SR 3.1.1 DSC Vacuum Pressure During Drying After NDE of Inner Cover O-OP-4.50, NUHOMS 32PTH Dry Shielded Canister Loading andWeld Handling"

SR 3.1.2 DSC Helium Backfill Pressure After completion of T.S. 3.1.1 O-OP-4.50, "NUHOMS 32PTH Dry Shielded Canister Loading andHandling"

SR 3.1.3.1 OS187H Helium Backfill After 3.1.2 and TC Lid Set O-OP-4.50, "NUHOMS 32PTH Dry Shielded Canister Loading andHandling"

SR 3.2 1 SFP/DSC Boron concentration (loading) 4HrsPL,48HrsDL O-OP-4.50, "NUHOMS 32PTH Dry Shielded Canister Loading andHandling"

SR 3.2.2 SFP/DSC Boron Concentration (unloading) 4HrsPUL,48HrsDUL O-OP-4.51 "Unloading a Loaded NUHOMS 32PTH Dry ShieldedCanister"

5.2.5 (a) HSM-H Air Temperature Delta 24 Hrs AL HSM, and 7 Days O-PT-4.51," Horizontal Storage Module Thermal Performance

AL HSM Verification"

5.2.5 (b) HSM-H Inlets and Outlets Daily Daily Operator Logs

5.3.2 Inspection of Cask after 15" Side Drop As needed O-OP-4.50, "NUHOMS32PTH Dry Shielded Canister Loading andHandling"

5.4 HSM Dose Rate Evaluation As per procedure 0-HSP-ISFSI-002, "NUHOMS Dry Spent Fuel Storage System;Preparation, Loading, Transport and T.S. Surveillance Surveys"

5.5 Concrete Testing During Supplier Fabrication NUH-03-0214, "Precast Concrete Construction of NUHOMS HSM-- H"

5.6 Hydrogen Gas Monitoring Prior to the welding of the O-OP-4.50, "NUHOMS 32 PTH Dry Shielded Canister Loadinginner lid and DW and Handling".

Legend: PL - Prior to Loading; DL - During Loading; PUL - Prior to Unloading; DUL - During Unloading; AL - After Loading;DW - During Welding

Attachments 2 through 10 of ETE-NAF-2010-0003 Revision 3 are not included in this transmittal.

Documents

North Anna Power Station ISFSI, Evaluations of Seismic ...NORTH ANNA POWER STATION ISFSl EVALUATIONS OF SEISMIC EVENT ON PAD #2 SPENT FUEL STORAGE SYSTEM North Anna Power Station (NAPS)