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HomeMy WebLinkAbout20252499.tiffUNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 27, 2025 Nicholas A. Balsmeier, Manager (Acting) Idaho Cleanup Project U.S. Department of Energy Idaho Operations Office 1955 Fremont Avenue Idaho Falls, Idaho 83415 SUBJECT: AMENDMENT NO. 12 TO MATERIALS RENEWED LICENSE NO. SNM-2504 FOR THE FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (DOCKET NO. 72-09) Dear Nicholas Balsmeier: By letter dated November 14, 2024 (Agencywide Documents Access and Management System [ADAMS] Package Accession No. ML24324A062), the U.S. Department of Energy (DOE) submitted a request to amend Special Nuclear Materials (SNM) Renewed License No. SNM- 2504 for the Fort St. Vrain Independent Spent Fuel Storage Installation. The proposed license amendment seeks to update the licensee designation of authority title in the renewed license and technical specifications (TS). These documents currently assign licensee authority under the renewed license to the Deputy Manager, Idaho Cleanup Project (ICP). The license amendment request (LAR) removes the specific position title "Deputy Manager, Idaho Cleanup Project" and designates the "Manager for the Idaho Cleanup Project (ICP)," as the designated authority and authorized representative in all matters regarding the renewed license. Additionally, proposed changes would make editorial corrections to limiting conditions of operation 3.3.1 and TS 5.5.2.6 to reflect changes that were both approved under License Amendment No. 10 but were omitted from License Amendment No. 11. The LAR also includes a reference correction for TS 5.5.1.d and other minor editorial and formatting changes. Based on our review of your application, the U.S. Nuclear Regulatory Commission (NRC) staff has determined that there is reasonable assurance that: (i) the activities authorized by the amended renewed license can be conducted without endangering the health and safety of the public, and (ii) these activities will be conducted in compliance with the applicable regulations. NRC staff has further determined that the issuance of the amendment will not be inimical to the common defense and security. In addition, the staff determined that issuance of Amendment No. 12 meets the criteria for a categorical exclusion in Title 10 of the Code of Federal Regulations (10 CFR) 51.22(c)(10). Therefore, the staff will not prepare an environmental assessment or environmental impact statement. The NRC has approved the requested amendment. The amended renewed license supersedes Special Nuclear Materials Renewed License No. SNM-2504, Amendment No. 11, dated June 6, 2017. Revised technical specifications and the staffs safety evaluation report is also enclosed. Changes made to the enclosed renewed license and technical specification pages are indicated by vertical lines in the right margin. In accordance with 10 CFR 72.46, the NRC will publish a Notice of Issuance of the amended license in the Federal Register. CoRItUn : GoL-1-:onS 09 /06r(25 C c : Ia L (TC /13F) PL CbE/MU) cECRR), CA(1es/WA)' F1 0°1/o4/2.5 2025-2499 N. Balsmeier 2 In accordance with 10 CFR Part 2, "Agency Rules of Practice and Procedure," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room (PDR) or from the Publicly Available Records component of the NRC's ADAMS. ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html. The PDR is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.ResourceCc�nrc.gov or call 1-800-397-4209 or 301-415-4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays. If you have any questions regarding this matter, you may contact me at (301) 415-8064, or Ms. Daneira Melendez-Colon of my staff at (301) 415-7295, or via email to Daneira.Melendez- Colon(a�nrc.gov. Sincerely, Signed by Yilma, Haimanot on 08/27/25 Haimanot Yilma, Acting Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-09 EPID No.: L-2024-LLA-0161 Enclosures: 1. Materials Renewed License No. SNM-2504 Amendment No. 12 2. Revised Technical Specifications 3. Safety Evaluation Report N. Balsmeier 3 cc: Nicholas A. Balsmeier, DOE Mary E. Bates, DOE JoVonna Eaton, DOE (CONTR) Aaron S. Nebeker, DOE Tyrone L. Sanders, DOE Steven D. Wahnschaffe, DOE Jonathan A. Zobell, DOE William E. Kirby, DOE Jeffery D. Long, DOE Chairman, Weld County Board of Commissioners Christopher Razzazian, EPA James Grice, Colorado Department of Public Health and Environment N. Balsmeier 4 SUBJECT: AMENDMENT NO. 12 TO MATERIALS RENEWED LICENSE NO. SNM-2504 FOR THE FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION (DOCKET NO. 72-09) DATED: August 27, 2025 Closes EPID No.: L-2024-LLA-0161 DISTRIBUTION: Public JJosey, RIV RAlexander, RIV RidsRgn4MailCenter Resource ADAMS Accession Nos.: ML25191A187 (pkg), ML25191A188 (FRN), ML25191A189 (LTR), ML25191A190 (LIC). ML25191A192 (TS). ML25191A191 (SER) OFFICE NMSS/DFM/STLB NMSS/DFM/STLB OGC NLO NAME DMelendez-Colon WWheatley BRatichek DATE 07/11/2025 07/29/2025 08/08/2025 OFFICE NMSS/DFM/STLB NAME HYilma DATE 08/27/2025 OFFICIAL RECORD COPY [7590-01-P] NUCLEAR REGULATORY COMMISSION [Docket No. 72-09; NRC-2025-0075] Department of Energy; Fort St. Vrain Independent Spent Fuel Storage Installation; License Amendment AGENCY: Nuclear Regulatory Commission. ACTION: Notice of issuance. SUMMARY: The U.S. Nuclear Regulatory Commission (NRC) reviewed an application by the Department of Energy (DOE) for an amendment to Special Nuclear Materials (SNM) License No. SNM-2504, for the Fort St. Vrain (FSV) independent spent fuel storage installation (ISFSI) located in Platteville, Colorado. The requested amendment revises certain license conditions and technical specifications (TS) by adjusting references to relevant organizational components of DOE, correcting prior clerical drafting errors, and changing the description of a DOE official who is responsible for the operation and nuclear safety of the FSV ISFSI and for ensuring its compliance with certain conditions and requirements of the license and applicable regulations. DATES: The license amendment is issued and effective on August 27, 2025. ADDRESSES: Please refer to Docket ID NRC-2025-0075 when contacting the NRC about the availability of information regarding this action. You may obtain publicly available information related to this document using any of the following methods: • Federal Rulemaking Website: Go to https://www.regulations.gov and search for NRC-2025-0075. Address questions about Docket IDs in Regulations.gov to Bridget Curran; telephone: 301-415-1003; email: Bridget.Curran@nrc.gov. For technical questions, contact the individual(s) listed in the "For Further Information Contact" section of this document. • NRC's Agencywide Documents Access and Management System (ADAMS): You may obtain publicly available documents online in the ADAMS Public Documents collection at https://www.nrc.gov/reading-rm/adams.html. To begin the search, select "Begin ADAMS Public Search." For problems with ADAMS, please contact the NRC's Public Document Room (PDR) reference staff at 1-800-397-4209, at 301-415-4737, or by email to PDR.Resource@nrc.gov. For the convenience of the reader, instructions about obtaining materials referenced in this document are provided in the "Availability of Documents" section. • NRC's PDR: The PDR, where you may examine and order copies of publicly available documents, is open by appointment. To make an appointment to visit the PDR, please send an email to PDR.Resource@nrc.govorcall 1-800-397-4209 or 301-415- 4737, between 8 a.m. and 4 p.m. eastern time (ET), Monday through Friday, except Federal holidays. FOR FURTHER INFORMATION CONTACT: Daneira Melendez-Colon, Office of Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, Washington DC 20555-0001; telephone: 301-415-7295, email: Daneira.Melendez- Colon@nrc.gov. SUPPLEMENTARY INFORMATION: I. Introduction By letter dated November 14, 2024, DOE submitted to the NRC an application to amend the license conditions and TS for the FSV ISFSI, located in Platteville, Colorado. Materials License No. SNM-2504 authorizes the licensee to receive, possess, store, and transfer spent nuclear fuel from the decommissioned FSV Nuclear Generating Station. The proposed amendment revises TS 5.1.1 and 5.2.1.1 so that they explicitly designate 2 the Manager for the Idaho Cleanup Project (ICP) as the DOE official who is responsible for the operation and nuclear safety of the FSV ISFSI and for ensuring its compliance with NRC license conditions and regulatory requirements. TS 5.1.1 currently designates the Deputy Manager for the ICP as the DOE official who is responsible for the operation of the FSV ISFSI and for ensuring its compliance with NRC license conditions and regulatory requirements. The proposed amendment also revises TS 5.6.1 so that it identifies the Manager for the ICP, rather than the Deputy Manager, as one of the two DOE officials who are responsible for submitting certain reports that are required in connection with the license. Additionally, the proposed amendment corrects clerical drafting errors in TS 3.3.1 and 5.5.2.6 so that those technical specifications accurately reflect changes that were previously approved and included in License Amendment No. 10 but were inadvertently omitted from License Amendment No. 11. The proposed amendment also corrects an erroneous regulatory citation in TS 5.5.1.d, corrects a typographical error in TS 5.5.2.5, and adjusts references to relevant organizational components of DOE in License Condition 14 and in TS 5.1.5, 5.4.2, and 5.5.2.7. In a letter dated March 21, 2025, the NRC notified DOE that the application was acceptable to begin a technical review. The NRC's Office of Nuclear Material Safety and Safeguards docketed the application under Docket No. 72-09. In accordance with section 72.16(e) of title 10 of the Code of Federal Regulations (10 CFR), the NRC published a notice of docketing in the Federal Register on May 5, 2025 (90 FR 19011). The NRC prepared a safety evaluation report (SER) to document its review and evaluation of the amendment request. As further explained in the SER, the NRC has determined that the license amendment is administrative in nature and satisfies the criterion of 10 CFR 51.22(c)(10) for categorical exclusion from the requirement to prepare an environmental assessment or an environmental impact statement. This 3 action qualifies for categorical exclusion under 10 CFR 51.22(c)(10) because it is an amendment to a materials license issued under 10 CFR chapter I which merely changes the position titles of relevant officials of the licensee and makes certain editorial, corrective, and minor revisions, as described previously. Consequently, neither an environmental assessment nor an environmental impact statement is required. Upon completing its review, the NRC staff determined the application complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the NRC's regulations. The NRC has made appropriate findings as required by the Act and the NRC's regulations in 10 CFR part 72, which are set forth in the license amendment. The license amendment, Amendment No. 12 to License No. SNM-2504, is issued and effective on August 27, 2025. In accordance with 10 CFR 72.46(b)(2), the NRC has determined that Amendment No. 12 does not present a genuine issue as to whether the health and safety of the public will be significantly affected. Therefore, the publication of a notice of proposed action and an opportunity for hearing or a notice of hearing is not warranted. Notice is hereby given of the right of interested persons to request a hearing on whether the action should be rescinded or modified. II. Availability of Documents The documents identified in the following table are available to interested persons through one or more of the following methods, as indicated. DOCUMENT DESCRIPTION ADAMS ACCESSION NO. OR FEDERAL REGISTER CITATION DOE Letter — License Amendment Request to Update the Licensee Designation of Authority Title for the Fort St. Vrain Independent Spent Fuel Storage Installation, Docket 72-0009, Materials License No. SNM-2504 (CLN250095), dated November 14, 2024. ML24324A062 (Package) 4 NRC Letter — Issuance of Amendment No. 10 to Renewed Materials License No. SNM-2504 for the Fort St. Vrain Independent Spent Fuel Storage Installation (TAC No. L24994), dated March 17, 2016. ML15258A217 (Package) NRC Letter — Amendment No. 11 to Materials License No. SNM-2504 for the Fort St. Vrain Independent Spent Fuel Storage Installation, dated June 6, 2017. ML17151A387 (Package) NRC Letter — Application for License Amendment Request — Amendment No. 12 to Materials License No. SNM-2504 for the Fort St. Vrain Independent Spent Fuel Storage Installation — Accepted for Review (CAC/EPID Nos. 001028/L-2024-LLA-0161), dated March 21, 2025. ML25073A130 Federal Register notice, "Department of Energy; Fort St. Vrain Independent Spent Fuel Storage Installation; License Amendment Request," published May 5, 2025. 90 FR 19011 Special Nuclear Materials License No. SNM-2504, dated August 27, 2025. ML25191A190 SNM-2504 Technical Specifications, dated August 27, 2025. ML25191A192 Fort St. Vrain Independent Spent Fuel Storage Installation, NRC Safety Evaluation Report, dated August 27, 2025. ML25191A191 Dated: August 27, 2025. For the Nuclear Regulatory Commission. /RA/ Haimanot Yilma, Acting Chief, Storage and Transportation Licensing Branch, Division of Fuel Management, Office of Nuclear Material Safety and Safeguards. 5 DEPARTMENT OF ENERGY DOCKET NO. 72-9 FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION MATERIALS LICENSE NO. SNM-2504 Amendment No. 12 Renewed License No. SNM-2504 1 The U.S. Nuclear Regulatory Commission (Commission) has found that: A. The amended Renewed License No. SNM-2504 complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter 1; B. Actions have been identified and have been or will be taken for (i) managing the effects of aging during the period of extended operation on the functionality of structures and components within the scope of license renewal, and (ii) time - limited aging analyses, such that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the current licensing basis; C. There is reasonable assurance that (i) the activities authorized by this amended, renewed license can be conducted without endangering the health and safety of the public, and (ii) such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amended renewed license will not be inimical to the common defense and security or to public health and safety; and E. The issuance of this amended renewed license is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied. 2. Accordingly, the renewed license is amended by the enclosed changes to Renewed Materials License No. SNM-2504, indicated by margin notations. 3. This license amendment is effective as of the date of its issuance. FOR THE NUCLEAR REGULATORY COMMISSION Signed by Yilma, Haimanot on 08/27/25 Haimanot Yilma, Acting Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Enclosed: Amended Renewed License Date of Issuance: 08/27/25 Enclosure 1 NRC FORM 588 (10-2000) 10 CFR 72 U. S. NUCLEAR REGULATORY COMMISSION PAGE 1 OF 3 PAGES LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974 (Public Law 93-438), and Title 10, Code of Federal Regulations, Chapter 1, Part 72, and in reliance on statements and representations heretofore made by the licensee, a license is hereby issued authorizing the licensee to receive, acquire, and possess the power reactor spent fuel and other radioactive materials associated with spent fuel storage designated below; to use such material for the purpose(s) and at the place(s) designated below; and to deliver or transfer such material to persons authorized to receive it in accordance with the regulations of the applicable Part(s). This license shall be deemed to contain the conditions specified in Section 183 of the Atomic Energy Act of 1954, as amended, and is subject to all applicable rules, regulations, and orders of the Nuclear Regulatory Commission now or hereafter in effect and to any conditions specified herein. Licensee 1. Department of Energy 2. 850 Energy Drive Idaho Falls, Idaho 83401-1563 3. Renewed License No. Amendment No. 12 _ SNM-2504 4. Expiration Date November 30, 2031 5. Docket or Reference No. 72-09 6. Byproduct, Source, and/or Special Nuclear Material 7. Chemical or Physical Form 8. Maximum Amount That Licensee May Possess at Any One Time Under This License A. Fuel elements from Fort St. A. Vrain (FSV) Nuclear Generating Station using thorium and uranium enriched to not greater than 93.15% in the U-235 isotope B. Transuranium elements, source B. material, byproduct material, and associated radioactive material related to receipt, storage, and transfer of fuel elements C. Byproduct and special nuclear material related to receipt, storage, and transfer of fuel elements Irradiated TRISO coated (Th, U)C2 fuel particles inside graphite fuel elements Irradiated fuel elements, contaminated ISFSI equipment (e.g., fuel storage containers, container handling machine, standby storage wells), depleted uranium shielding materials, and low- level radioactive waste related to receipt, storage, and transfer of fuel elements C. As calibration discs or sealed sources, without restriction to chemical or physical form, for sample analysis and instrument calibration A. 1036 Kg uranium and 14,540 Kg thorium initially contained in 1,482 irradiated HTGR fuel elements B. Quantity contained in 1,482 irradiated HTGR fuel elements, 270 contaminated fuel storage containers, 1 contaminated container handling machine, 3 contaminated storage wells, 3 depleted uranium shielding components of transfer casks, and low-level radioactive waste related to receipt, storage, and transfer of fuel elements C. Radioactive sources used for sample analysis and instrument calibration U. S. NUCLEAR REGULATORY COMMISSION PAGE 2 OF 3 PAGES NRC FORM 588A t� 0-2000 10 CFR 72 LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE SUPPLEMENTARY SHEET Renewed License No. SNM-2504 Amendment No. 12 Docket or Reference No. 72-9 9. Authorized Use: For use in accordance with statements, representations, and the conditions of the Technical Specifications and Safety Analysis Report (SAR) dated December 17, 1996, and supplements dated February 4, February 5, February 18, March 12, March 24, April 2, April 16, April 29, December 10, and December 18, 1997; and February 6, April 7, July 2, July 20, August 24, October 2, October 16 (two letters), November 16, November 19 (two letters), December 1, December 9, and December 24, 1998; and April 27, May 5, May 12, May 13, October 19, and November 24, 1999; January 18, 2000; May 24, 2001; November 10, 2009; June 9, July 30, August 13, September 7, November 9, November 30, and December 23, 2010; July 18, 2011; June 13, 2013; September 8, 2016; and November 14, 2024; and as further supplemented and amended in accordance with 10 CFR 72.70 and 10 CFR 72.48. The material identified in 6.A, 6.B, 7.A, and 7.B above must be related to spent fuel storage and is authorized for receipt, possession, storage, and transfer. Material identified in 6.C and 7.C above shall be related to spent fuel storage, and is authorized for receipt, possession, storage, transfer, and use. 10. Authorized Place of Use: The licensed material is to be received, possessed, transferred, and stored at the FSV Independent Spent Fuel Storage Installation (ISFSI) located in Platteville, Colorado, as described in the Safety Analysis Report. 11. The Technical Specifications contained in Appendix A attached hereto are incorporated into the license. The licensee shall operate the installation in accordance with the Technical Specifications in Appendix A. 12. The licensee shall follow the physical protection plan entitled "DOE -ID Independent Spent Fuel Storage . Installation Security Plan," dated October 9, 1998, with subsequent modifications dated December 1, 1998, April 27, 1999, May 24, 2001, and June 30, 2014 and as it may be further amended under the provisions of 10 CFR 72.44(e) and 72.186(b). 13. The repackaging of fuel assemblies is not authorized. 14. For the duration of the license, the licensee shall inform the Director, Office of Nuclear Material Safety and Safeguards, at least 90 days in advance, of the planned replacement of the entity contracted by Department of Energy (DOE) Idaho Cleanup Project (ICP) to perform the management and operation (the M&O contractor) of the FSV ISFSI. Within 180 days after the replacement of the M&O contractor, the licensee shall assess the performance of the M&O contractor and provide a statement to the NRC verifying that the replacement of the M&O contractor has had no effect on the execution of licensed responsibilities for the FSV ISFSI. 15. DOE shall be responsible for requesting necessary funds from Congress to ensure compliance of FSV operations and decommissioning under this license. DOE will notify the NRC, in writing, of any anticipated or forecasted budget shortfalls, as soon as they are known, along with a plan detailing the specific measures that will be taken by DOE to obtain the required funding and prevent adverse impacts on ISFSI operations. U. S. NUCLEAR REGULATORY COMMISSION PAGE 3 OF 3 PAGES NRC FORM 588A (10-2000) 10CFR72 LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE SUPPLEMENTARY SHEET Renewed License No. SNM-2504 Docket or Reference No. Amendment No. 12 72-9 16. This license is effective as of the date of issuance shown below. FOR THE U.S. NUCLEAR REGULATORY COMMISSION .r.Lax._ Signed by Yilma, Haimanot on 08/27/25 Haimanot Yilma, Acting Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555 Date of Issuance: 08/27/25 Attachment: Appendix A APPENDIX A TECHNICAL SPECIFICATIONS FOR THE FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION SNM-2504 Enclosure 2 TABLE OF CONTENTS 1.0 USE AND APPLICATION 1.1-1 1.1 Definitions 1.1-1 1.2 Logical Connectors 1.2-1 1.3 Completion Times 1.3-1 1.4 Frequency 1.4-1 2.0 FUNCTIONAL AND OPERATING LIMITS 2.0-1 2.1 Functional and Operating Limits 2.0-1 2.1.1 Spent Fuel Elements Stored At ISFSI 2.0-1 2.2 Functional and Operating Limit Violations 2.0-1 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY 3.0-1 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY 3.0-2 3.1 MVDS Cooling System 3.1-1 3.2 Container Handling Machine 3.2-1 3.2.1 Container Handling Machine 3.2-1 3.2.2 Container Handling Machine Lifting Height 3.2-2 3.3 Fuel Storage Container 3.3-1 3.3.1 Seal Leak Rate 3.3-1 3.3.2 FSC Low Temperature 3.3-3 4.0 DESIGN FEATURES 4.0-1 4.1 Site 4.0-1 4.1.1 Site Location 4.0-1 4.2 Storage Features 4.0-1 4.2.1 Fuel Storage Canister 4.0-1 4.2.2 Modular Vault Storage 4.0-1 5.0 ADMINISTRATIVE CONTROLS 5.1-1 5.1 Responsibility 5.1-1 5.2 Organization 5.2-1 5.2.1 Onsite and Offsite Organizations 5.2-1 5.3 Facility Staff Qualifications 5.3-1 5.4 Procedures 5.4-1 5.5 Programs 5.5-1 5.5.1 Technical Specification Bases Control Program 5.5-1 5.5.2 Essential Program Control Program 5.5-2 5.5.3 Natural Gas and Oil Monitoring Program 5.5-3 5.5.4 Radioactive Effluent Control Program 5.5-4 5.6 Reporting Requirements 5.6-1 Definitions 1.1 1.0 USE AND APPLICATION 1.1 Definitions NOTE The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases. Term ACTIONS CONTAINER HANDLING MACHINE (CHM) FUEL STORAGE CONTAINERS (FSC) HANDLING OPERATIONS INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) MODULAR VAULT DRY STORE (MVDS) OPERABLE -OPERABILITY STORAGE OPERATIONS Definition ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times. The CONTAINER HANDLING MACHINE is used to contain and transfer a FSC or an Individual Fuel Element between storage positions or to a transport cask. The FUEL STORAGE CONTAINERS are used to contain the spent fuel stored within the MVDS and transported from the MVDS. HANDLING OPERATIONS includes all licensed activities on a FSC containing spent fuel while the FSC is not within an approved storage position within the MVDS. The facilities within the 100 meter perimeter around the MVDS licensed for the storage of spent fuel. The MODULAR VAULT DRY STORE is the system used to store, handle, sample, and leak check the FSCs. A system, subsystem, division, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrumentation, controls, normal or emergency electrical power, cooling and seal water, lubrication, and other auxiliary equipment that are required for the system, subsystem, division, component, or device to perform its specified safety function(s) are also capable of performing their related support function(s). STORAGE OPERATIONS include all licensed activities performed at the ISFSI while spent fuel is contained within one of the six modular dry vaults or within one of the three storage wells within the MVDS. STORAGE WELL One of three positions approved for storage of an FSC, including a leaking FSC. These positions are north of the six vaults. Fort St. Vrain ISFSI 1.1-1 Amendment No. 12 Logical Connectors 1.2 1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE The purpose of this section is to explain the meaning of logical connectors. Logical connectors are used in Technical Specifications (TS) to discriminate between, and yet connect, discrete Conditions, Required Actions, Completion Times, Surveillances, and Frequencies. The only logical connectors that appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings. BACKGROUND Several levels of logic may be used to state Required Actions. These levels are identified by the placement (or nesting) of the logical connectors and by the number assigned to each Required Action. The first level of logic is identified by the first digit of the number assigned to a Required Action and the placement of the logical connector in the first level of nesting (i.e., left justified with the number of the Required Action). The successive levels of logic are identified by additional digits of the Required Action number and by successive indentions of the logical connectors. When logical connectors are used to state a Condition, Completion Time, Surveillance, or Frequency, only the first level of logic is used, and the logical connector is left justified with the statement of the Condition, Completion Time, Surveillance, or Frequency. EXAMPLES The following examples illustrate the use of logical connectors. Fort St. Vrain ISFSI 1.2-1 Amendment No. 12 Logical Connectors 1.2 1.2 Logical Connectors EXAMPLES EXAMPLE 1.2-1 (continued) ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Fort St. Vrain ISFSI A. LCO not met. A.1 Verify .. . AND A.2 Restore .. In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed. 1.2-2 Amendment No. 12 Logical Connectors 1.2 1.2 Logical Connectors EXAMPLES EXAMPLE 1.2-2 (continued) ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME Fort St. Vrain ISFSI A. LCO not met. A.1 Trip... OR A.2.1 Verify .. . AND A.2.2.1 Reduce .. . OR A.2.2.2 Perform .. OR A.3 Align .. . This example represents a more complicated use of logical connectors. Required Actions A.1, A.2, and A.3 are alternative choices, only one of which must be performed as indicated by the use of the logical connector OR and the left justified placement. Any one of these three Actions may be chosen. If A.2 is chosen, then both A.2.1 and A.2.2 must be performed as indicated by the logical connector AND. Required Action A.2.2 is met by performing A.2.2.1 or A.2.2.2. The indicated position of the logical connector OR indicates that A.2.2.1 and A.2.2.2 are alternative choices, only one of which must be performed. 1.2-3 Amendment No. 12 Completion Times 1.3 1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE The purpose of this section is to establish the Completion Time convention and to provide guidance for its use. BACKGROUND Limiting Conditions for Operation (LCOs) specify minimum requirements for ensuring safe operation of the ISFSI. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the- LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s). DESCRIPTION The Completion Time is the amount of time allowed for completing a Required Action. It is referenced to the time of discovery of a situation (e.g., inoperable equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the ISFSI is in a specified condition stated in the Applicability of the LCO. Required Actions must be completed prior to the expiration of the specified Completion Time. An ACTIONS Condition remains in effect and the Required Actions apply until the Condition no longer exists or the ISFSI is not within the LCO applicability. Once a Condition has been entered, subsequent divisions, subsystems, components, or variables expressed in the Condition, discovered to be inoperable or not within limits, will not result in separate entry into the Condition unless specifically stated. The Required Actions of the Condition continue to apply to each additional failure, with Completion Times based on initial entry into the Condition. Fort St. Vrain ISFSI 1.3-1 Amendment No. 12 Completion Times 1.3 1.3 Completion Times EXAMPLES The following examples illustrate the use of Completion Times with different types of Conditions and changing Conditions. EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met. B.1 Perform Action B.1 AND B.2 Perform Action B.2 12 hours 36 hours Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced to the time that Condition B is entered. The Required Actions of Condition B are to complete action B.1 within 12 hours AND complete action B.2 within 36 hours. A total of 12 hours is allowed for completing action B.1 and a total of 36 hours (not 48 hours) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within 6 hours, the time allowed for completing action B.2 is the next 30 hours because the total time allowed for completing action B.2 is 36 hours. Fort St. Vrain ISFSI 1.3-2 Amendment No. 12 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued) EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not within limit. A.1 Restore system to within limit. 7 days B. Required Action and associated Completion Time not met. B.1 Complete action B.1 AND B.2 Complete action B.2 12 hours 36 hours When a system is determined to not meet the LCO, Condition A is entered. If the system is not restored within 7 days, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start. If the system is restored after Condition B is entered, Condition A and B are exited, and therefore, the Required Actions of Condition B may be terminated. Fort St. Vrain ISFSI 1.3-3 Amendment No. 12 Completion Times 1.3 1.3 Completion Times EXAMPLES (continued) EXAMPLE 1.3-3 ACTIONS NOTE Separate Condition entry is allowed for each component. CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore compliance with LCO. 7 days B. Required Action and associated Completion Time not met. B.1 Complete action B.1 AND B.2 Complete action B.2 6 hours 12 hours The Note above the ACTIONS Table is a method of modifying how the Completion Time is tracked. If this method of modifying how the Completion Time is tracked was applicable only to a specific Condition, the Note would appear in that Condition rather than at the top of the ACTIONS Table. The Note allows Condition A to be entered separately for each component, and Completion Times tracked on a per component basis. When a component is determined to not meet the LCO, Condition A is entered and its Completion Time starts. If subsequent components are determined to not meet the LCO, Condition A is entered for each component and separate Completion Times start and are tracked for each component. Fort St. Vrain ISFSI 1.3-4 Amendment No. 12 Completion Times 1.3 1.3 Completion Times IMMEDIATE When "Immediately" is used as a Completion Time, the Required Action should COMPLETION TIME be pursued without delay and in a controlled manner. Fort St. Vrain ISFSI 1.3-5 Amendment No. 12 Frequencies 1.4 1.0 USE AND APPLICATION 1.4 Frequency PURPOSE The purpose of this section is to define the proper use and application of Frequency requirements. DESCRIPTION Each Surveillance Requirement (SR) has a specified Frequency in which the Surveillance must be met in order to meet the associated Limiting Condition for Operation (LCO). An understanding of the correct application of the specified Frequency is necessary for compliance with the SR. The "specified frequency" is referred to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR, as well as certain NOTES in the Surveillance column that modify performance requirements. Sometimes special situations dictate when the requirements of a Surveillance are to be met. They are "otherwise stated" conditions allowed by SR 3.0.1. They may be stated as clarifying Notes in the Surveillance, as part of the Surveillance, or both. Situations where a Surveillance could be required (i.e., its Frequency could expire), but where it is not possible or not desired that it be performed until sometime after the associated LCO is within its Applicability, represent potential SR 3.0.4 conflicts. To avoid these conflicts, the SR (i.e., the Surveillance or the Frequency) is stated such that it is only "required" when it can be and should be performed. With an SR satisfied, SR 3.0.4 imposes no restriction. The use of "met" or "performed" in these instances conveys specific meanings. A surveillance is "met" only when the acceptance criteria are satisfied. Known failure of the requirements of a Surveillance, even without a Surveillance specifically being "performed," constitutes a Surveillance not "met" "Performance" refers only to the requirement to specifically determine the ability Fort St. Vrain ISFSI 1.4-1 Amendment No. 12 Frequencies 1.4 1.4 Frequency DESCRIPTION (continued) to meet the acceptance criteria. SR 3.0.4 restrictions would not apply if both the following conditions are satisfied. a. The Surveillance is not required to be performed, and b. The Surveillance is not required to be met or, even if required to be met, is not known to be failed. Fort St. Vrain ISFSI 1.4-2 Amendment No. 12 Frequencies 1.4 1.4 Frequency EXAMPLES The following examples illustrate the various ways that Frequencies are specified. EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify leak rate within limit. 12 hours Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours, an extension of the time interval to 1.25 times the interval specified in the Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the facility is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the facility is in a condition specified in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified by a specific NOTE, then the LCO is not met in accordance with SR 3.0.1 and SR 3.0.3 becomes applicable. If the interval as specified by SR 3.0.2 is exceeded while the facility is not in a condition specified in the Applicability of the LCO for which performance of the SR is required, the Surveillance must be performed within the Frequency requirements of SR 3.0.2 prior to entry into the specified condition. Failure to do so would result in a violation of SR 3.0.4. Fort St. Vrain ISFSI 1.4-3 Amendment No. 12 Frequencies 1.4 1.4 Frequency EXAMPLES (continued) EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours prior to starting activity AND 24 hours thereafter Example 1.4-2 has two Frequencies. The first is a one time performance Frequency, and the second is of the type shown in Example 1.4-1. The logical connector "AND" indicates that both Frequency requirements must be met. Each time the example activity is to be performed, the Surveillance must be performed within 12 hours prior to starting the activity. The use of "once" indicates a single performance will satisfy the specified Frequency (assuming no other Frequencies are connected by "AND"). This type of Frequency does not qualify for the extension allowed by SR 3.0.2. "Thereafter' indicates future performances must be established per SR 3.0.2, but only after a specified condition is first met (i.e., the "once" performed in this example). If the specified activity is canceled or not performed, the measurement of both intervals stops. New intervals start upon preparing to restart the specified activity. Fort St. Vrain ISFSI 1.4-4 Amendment No. 12 Safety Limits 2.0 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Functional and Operating Limits 2.1.1 Spent Fuel Elements Stored At ISFSI The spent nuclear fuel to be stored in FSCs at the Fort St. Vrain ISFSI shall meet the following requirement: The fuel elements stored at the ISFSI shall be only those within the facility as of February 9, 1996, as specified in the Contract No. DE-AC07-96ID13425 between the United States Department of Energy (DOE) and the Public Service Company of Colorado (PSC). No other spent fuel shall be received and stored in the MVDS. 2.2 Functional and Operating Limit Violations If any Functional and Operating Limit is violated, the following actions shall be completed: 2.2.1 The affected spent fuel shall be placed in a safe condition. 2.2.2 Within 24 hours, notify the NRC Operations Center. 2.2.3 Within 30 days, submit a special report which describes the cause of the violation and actions taken to restore compliance and prevent recurrence. Fort St. Vrain ISFSI 2.0-1 Amendment No. 12 LCO Applicability 3.0 3.0 LIMITING CONDITIONS FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during specified conditions in the Applicability, except as provided in LCO 3.0.2. LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5. If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required, unless otherwise stated. LCO 3.0.3 Not applicable to an ISFSI. LCO 3.0.4 When an LCO is not met, entry into a specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS. LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be retumed to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system retumed to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 LCO 3.0.7 Not applicable to an ISFSI. Not applicable to an ISFSI. Fort St. Vrain ISFSI 3.0-1 Amendment No. 12 SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SR 3.0.2 SR 3.0.3 SRs shall be met during the specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on equipment or variables outside specified limits. The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the frequency is met. For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per ..." basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications. If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours or up to the limit of the specified Frequency, whichever is less. This delay period is permitted to allow performance of the Surveillance. If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered. Fort St. Vrain ISFSI 3.0-2 Amendment No. 12 SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.4 Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's Surveillances have been met within their specified Frequency. This provision shall not prevent entry into specified conditions in the Applicability that are required to comply with ACTIONS. Fort St. Vrain ISFSI 3.0-3 Amendment No. 12 MVDS Cooling System 3.1 3.1 MVDS Cooling System 3.1.1 MVDS Cooling Inlet and Outlet LCO 3.1.1 Blockage of the cooling inlet or outlet protective mesh screen areas shall not exceed 50 percent of either mesh screen area. APPLICABILITY: During STORAGE OPERATIONS. ACTION CONDITION REQUIRED ACTION COMPLETION TIME A. Blockage of cooling inlet or outlet screen area exceeds 50 percent but is less than 95 percent A.1 Clear the blockage 7 days B. Blockage of cooling inlet or outlet screen area equals 95 percent or more B.1 Clear the blockage 24 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Perform a visual inspection of the cooling inlet and outlet screens. 7 days Fort St. Vrain ISFSI 3.1-1 Amendment No. 12 Container Handling Machine 3.2 3.2 Container Handling Machine 3.2.1 Container Handling Machine LCO 3.2.1 The CHM shall be fully operable. APPLICABILITY: During HANDLING OPERATIONS. ACTION CONDITION REQUIRED ACTION COMPLETION TIME A. CHM not fully operable A.1 Place any contained spent fuel in the nearest safe storage location. Immediately. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Visually inspect the CHM raise/lower mechanism components. Within 31 days prior to commencing HANDLING OPERATIONS AND 31 days during HANDLING OPERATIONS SR 3.2.1.2 Functionally test the charge face isolation valves, the CHM isolation valve, and all CHM control interlocks. Within 31 days prior to commencing HANDLING OPERATIONS AND 12 months during HANDLING OPERATIONS 3.2 Container Handling Machine Fort St. Vrain ISFSI 3.2-2 Amendment No. 12 Container Handling Machine 3.2 3.2.2 Container Handling Machine Lifting Height LCO 3.2.2 The MVDS Crane Hoist lift limits shall be operable: APPLICABILITY: During STORAGE OPERATIONS and HANDLING OPERATIONS. ACTION CONDITION REQUIRED ACTION COMPLETION TIME A. The MVDS Crane Hoist lifts the CHM above 3.5" A.1 Lower CHM to the floor. Immediately. SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Visually inspect the MVDS Crane Hoist dead stop device. 12 months SR 3.2.2.2 Functionally test the MVDS Crane Hoist limit switch. Within 31 days prior to lifting the CHM AND 31 days during CHM lifting operations Fort St. Vrain ISFSI 3.2-3 Amendment No. 12 Fuel Storage Container 3.3 3.3 Fuel Storage Container 3.3.1 Seal Leak Rate LCO 3.3.1 The FSC or storage well seal leakage rate shall not exceed 1 x10-3 standard cc/sec. APPLICABILITY: During STORAGE OPERATIONS ACTION CONDITION REQUIRED ACTION COMPLETION TIME A. If seal leak rate limit is exceeded for one or two FSCs (or storage wells) A.1.1 Restore top seal integrity. OR A.1.2.1 Transfer the FSC to a storage well AND A.1.2.2 Verify integrity of storage well. AND A.2 Perform leak test on two additional FSCs from each vault AND A.3 Submit report to NRC describing condition, results of engineering evaluations and actions being taken. 21 days 21 days 21 days 45 days 90 days B. If seal leak rate limit is exceeded for three or more FSCs or storage wells B.1 Notify NRC Operations Center Within 24 hours of entry into CONDITION Fort St. Vrain ISFSI 3.3-1 Amendment No. 12 Fuel Storage Container 3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Leak test one FSC from each vault. NOTE: SR 3.0.2 is not applicable 5 years. Fort St. Vrain ISFSI 3.3-2 Amendment No. 12 Fuel Storage Container 3.3 3.3 Fuel Storage Container 3.3.2 FSC Low Temperature LCO 3.3.2 APPLICABILITY: During HANDLING OPERATIONS. ACTION The ambient air temperature shall not be less than 12 degrees F CONDITION REQUIRED ACTION COMPLETION TIME A. Ambient air temperature less than limit. A.1 Place FSC in safe condition AND A.2 Suspend further Handling Operations Immediately Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2.1 Verify ambient air temperature within limits Within 8 hours prior to lifting an FSC containing spent fuel. AND Immediately prior to each movement of a FSC loaded with spent fuel into or out of the CHM. Fort St. Vrain ISFSI 3.3-3 Amendment No. 12 Design Features 4.0 4.0 DESIGN FEATURES 4.1 Site 4.1.1 Site Location The FSV ISFSI is located on part of the original FSV Nuclear Generating Station site, approximately 1500 feet northeast of the fossil -fueled, power plant building, which is about three and one-half miles northwest of Platteville, CO. Platteville is located in Weld County and is about 35 miles north of Denver. The nearest boundaries of Longmont, Greeley, and Loveland are all about 14 miles from the ISFSI location. 4.2 Storage Features 4.2.1 Fuel Storage Canister The FSV ISFSI is licensed to store spent fuel in the Fuel Storage Canisters within the MVDS. The FSCs shall be constructed of carbon steel with a coating of aluminum applied to the outer surface. Each FSC can store up to six fuel elements. The fuel storage environment is air. Each FSC is stored in a storage position within the six MVDS vaults or within one of the three storage wells. 4.2.2 Modular Vault Dry Store The MVDS structure is reinforced concrete, with three storage wells, six vaults, and a Transfer Cask Reception Bay. Each vault holds up to 45 FSCs, with the FSC storage array determined by a Charge Face Structure at the top of the FSCs and by vault module floor supports at the bottom of the FSCs. Fort St. Vrain ISFSI 4.0-1 Amendment No. 12 Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The Manager for the Idaho Cleanup Project (ICP) is responsible for the operation of the FSV ISFSI and for compliance with all applicable regulatory requirements and license conditions. 5.1.2 The Facility Director is responsible for overall ISFSI operation. The Facility Director and any alternates shall be designated in writing. 5.1.3 Although not in residence at the FSV ISFSI, the Facility Director shall maintain routine electronic and verbal communication with the facility staff. 5.1.4 The Facility Director shall be present during significant operational or maintenance evolutions, emergency exercises, and announced NRC inspections. During prolonged evolutions, the Facility Director shall be present during initial activities and at least monthly thereafter. 5.1.5 The Facility Director shall visit the FSV ISFSI at least twice a year for the purpose of verification or audit of FSV ISFSI compliance with regulatory requirements and licensing basis commitments, to communicate and interface in person with facility staff and to appraise DOE ICP management of FSV ISFSI status based on observations. 5.1.6 The Facility Director shall review and concur with all FSV ISFSI evaluations prepared pursuant to 10 CFR 72.44(e), 10 CFR 72.44(f), 10 CFR 72.48, TS 5.5.1.b, TS 5.5.2.3, and TS 5.5.3.2. Fort St. Vrain ISFSI 5.1-1 Amendment No. 12 Organization 5.2 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Onsite and offsite organizations shall be established for facility operation and support services, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the ISFSI. 1. Lines of authority, responsibility, and communication shall be defined and established throughout the organization, from senior management levels to all operational and support positions. These relationships shall be documented and updated, as appropriate, in organization charts, functional descriptions of departmental responsibilities and relationships, and job descriptions for key positions, or in equivalent forms of documentation. These requirements, including the facility -specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Safety Analysis Report; 2. The responsible Manager for the ICP as designated by the Energy Secretary, shall have Department responsibility for overall facility nuclear safety and shall take any measures needed to ensure acceptable performance of the staff in operating, maintaining, and providing technical support to the facility to ensure nuclear safety; and 3. The individuals who perform quality assurance functions may report to the appropriate onsite manager; however, these individuals shall have sufficient organizational freedom to ensure their independence from operating pressures. 4. The Safety Review Committee shall provide oversight of FSV ISFSI operation by performing reviews of: a. Performance indicators (audit findings, reportable events and conditions, Technical Specification violations); b. Evaluations performed pursuant to 10 CFR 72.44(e), 10 CFR44(f), 10 CFR 72.48, TS 3.3.1(A)(3), TS 5.5.1.b, TS 5.5.2.3, and TS 5.5.3.2; c. Proposed license amendments; d. Selected activities of the ALARA committee and the staff level document review committee; e. Preparation for major operations (such as defueling) for potential safety hazards; and f. Special reviews at the direction of the Facility Director. Fort St. Vrain ISFSI 5.2-1 Amendment No. 12 Organization 5.2 The Safety Review Committee members and chair shall be appointed in writing. The Facility Director shall be informed of all appointments to the Safety Review Committee The Safety Review Committee membership shall represent the following disciplines: Radiological Safety, Criticality Safety, Nuclear Facility Operation, Nuclear Quality Assurance, and Engineering. A quorum for a Safety Review Committee meeting shall include a minimum of three committee members including members representing the technical disciplines appropriate for matters under consideration. The Facility Director, acting in an ex -officio capacity, shall be present to constitute a quorum. The Safety Review Committee shall meet at least once every twelve months and at least once not more than three months prior to the start of defueling operations. Fort St. Vrain ISFSI 5.2-2 Amendment No. 12 Facility Staff Qualifications 5.3 5.0 ADMINISTRATIVE CONTROLS 5.3 Facility Staff Qualifications 5.3.1 Each member of the facility staff shall meet the minimum qualifications specified in the Safety Analysis Report. Personnel who operate or supervise the operation of equipment identified as important to safety in the Safety Analysis Report shall be trained and certified under the NRC approved training program. Fort St. Vrain ISFSI 5.3-1 Amendment No. 12 Procedures 5.4 5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures 5.4.1 Written procedures shall be established, implemented, and maintained for the following activities: a. Administrative controls; b. Routine ISFSI operations; c. Emergency response; d. Design Control; e. Facility changes, tests and experiments; f. Control of Surveillances and tests; g. Control of special processes; h. Maintenance; i. Health physics, including ALARA practices; j. Spent fuel management; k. Quality assurance inspection and audits; I. Physical protection; m. Records management n. Reporting; and o. All programs specified in Specification 5.5 Implementing procedures may be common with the Idaho National Laboratory procedures provided that all ISFSI requirements are met. 5.4.2 The FSV Facility Director will ensure performance, and review the results of DOE - performed surveillances, assessments, or audits of changes to procedures described above. The DOE Idaho Operations Office QA manager is responsible to ensure audits of the Quality Assurance Program. Each area will be reviewed at least biennially. Fort St. Vrain ISFSI 5.4-1 Amendment No. 12 Programs 5.5 5.0 ADMINISTRATIVE CONTROLS 5.5 Programs The following programs shall be established, implemented, and maintained. 5.5.1 Technical Specifications (TS) Bases Control Program This program provides a means for processing changes to the Bases of these Technical Specifications. a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews. b. Changes may be made to Bases without prior NRC approval provided the changes do not involve either of the following: 1. A change in the TS incorporated in the license; or 2. A change to the SAR or Bases which requires a license amendment according to the criteria of 10 CFR 72.48. c. The Bases Control Program shall contain provisions to ensure the Bases are maintained consistent with the SAR. d. Proposed changes which don'tmeet the criteria of 5.5.1.b above shall be reviewed and approved by the NRC before implementation. Changes to the Bases implemented which do not require prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 72.48(d)(2). Fort St. Vrain ISFSI 5.5-1 Amendment No. 12 Programs 5.5 5.5.2 Essential Program Control Program 1. This program provides a means for processing changes to the following essential programs. a. Quality Assurance Program b. Radiological Environmental Monitoring Program c. Training Program 2. Changes to essential programs shall be made under appropriate administrative controls and reviews. 3. The licensee may make changes to essential programs without prior NRC approval provided the changes do not involve either of the following: a. A change in the Technical Specification incorporated in the license; or b. A decrease in effectiveness. 4. The Essential Programs Change Control program shall contain provisions to ensure essential programs are maintained consistent with the regulations. 5. Proposed changes to essential programs which don't meet the criteria of 5.5.2.3 above shall be reviewed and approved by the NRC before implementation. 6. Changes to essential program implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 72.70(c)(6). 7 DOE ICP will review and approve all submittals to the NRC made pursuant to TS 5.5.2.5 and TS 5.5.2.6. Fort St. Vrain ISFSI 5.5-2 Amendment No. 12 Programs 5.5 5.5 Programs 5.5.3 Natural Gas and Oil Monitoring Program This program provides a means for monitoring the development of natural gas and oil infrastructure and assessing the risk that such development poses to the FSV ISFSI. 1. The licensee shall establish and maintain a database of all natural gas and oil infrastructure within one-half mile of the FSV ISFSI. 2. The database shall include an analysis of the hazard posed by failure of individual infrastructure components (such as gas well, collector pipes, transmission pipelines, or feeder pipes). Such analysis may be a quantitative evaluation of the effect of postulated failures on the MVDS or may be a qualitative comparison to the hazard analysis of bounding cases provided by the safety analyses supporting the initial issuance of and Amendment No. 1 to Materials License SNM-2504. The licensee shall ensure that the database is updated at least once every six months. 4. For any new natural gas or oil infrastructure planned or completed installation within one-half mile of the ISFSI, the licensee shall submit a report describing the new infrastructure and a summary of the hazard analysis to the NRC Document Control Desk with a copy to the Director, Office of Nuclear Material Safety and Safeguards and the Regional Administrator, NRC Region IV: a. Within 60 days of identifying the new infrastructure if that new infrastructure poses a hazard which exceeds that analyzed in the initial issuance of and Amendment No. 1 to Materials Licence SNM-2504, or; b. With the periodic SAR update if the new infrastructure poses a hazard bounded by that analyzed in the initial issuance of and Amendment No. 1 to Materials License SNM-2504. Fort St. Vrain ISFSI 5.5-3 Amendment No. 12 Programs 5.5 5.5 Programs 5.5.4 Radioactive Effluent Control Program This program implements the requirements of 10 CFR 72.44(d) a. The FSV ISFSI does not create any new radioactive materials or have any radioactive waste treatment system. Some low level radioactive waste may be created during the course of periodic maintenance and surveillance activity or during future defueling operations as authorized by Condition 7B of this license. Procedures for the control of radioactive waste shall be developed and implemented. In addition to the procedural controls for low level radioactive waste, Technical Specification 3.3.1, Seal Leak Rate, provide assurance that there are essentially no radioactive effluents from the FSV ISFSI. b. This program includes an environmental monitoring -program as described in the FSV ISFSI Safety Analysis Report. c. An annual report shall be submitted pursuant to 10 CFR 72.44(d)(3) specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the previous calendar year of operation. This report shall be submitted within 60 days after January 1 of each year. 5.5.5 Aging Management Program This program provides a means for monitoring and mitigating potential aging effects of the modular vault system. a. The licensee shall establish and implement procedures for remote visual inspection of the FSC, SS, CFS underside (vault ceiling), and vault wall and floor surfaces for signs of degradation. b. The licensee will repair and/or perform additional inspection of concrete and metal conditions exceeding second tier -criteria within the guidance of ACI 349.3R-02 or later editions. c. The licensee will develop concrete inspector training and qualification program in accordance with ACI 349.3R-02 or later editions, prior to the next MVDS inspection in June 2014. Fort St. Vrain ISFSI 5.5-4 Amendment No. 12 Reporting Requirements 5.6 5.0 ADMINISTRATIVE CONTROLS 5.6 REPORTING REQUIREMENTS 5.6.1 All reports required by 10 CFR Part 72 for the FSV ISFSI and all reports required by the FSV ISFSI license and Technical Specifications, shall be submitted by the Manager for the ICP or the Facility Director. 5.6.2 All instances of noncompliance with the Limiting Conditions for Operation, Surveillance Requirements, Design Features or Administrative Controls contained within these Technical Specifications shall be reported in writing to the NRC Document Control Desk within 30 days of discovery of the non-compliance. Copies shall be provided to the Director, Office of Nuclear Material Safety and Safeguards and the Regional Administrator, NRC Region IV. Fort St Vrain ISFSI 5.6-1 Amendment No. 12 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION MATERIALS RENEWED LICENSE NO. SNM-2504 AMENDMENT NO. 12 1.0 SUMMARY This safety evaluation report (SER) documents the review and evaluation of a license amendment request (LAR) to Special Nuclear Materials (SNM) Renewed License No. 2504 for the Fort St. Vrain (FSV) Independent Spent Fuel Storage Installation (ISFSI). By letter dated November 14, 2024, the U.S. Department of Energy (DOE), Idaho Cleanup Project submitted a request to the U.S. Nuclear Regulatory Commission (NRC) in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 72.56, to amend the licensee delegation of authority in the license and technical specifications (TS). These documents currently assign licensee authority under the license to the Deputy Manager, Idaho Cleanup Project (ICP). The LAR removes the specific position title "Deputy Manager, Idaho Cleanup Project" and designates the "Manager for the Idaho Cleanup Project (ICP)," as the designated authority and authorized representative in all matters regarding the license. Additionally, the proposed amendment corrects clerical drafting errors in TS 3.3.1 and 5.5.2.6 so that those TS accurately reflect changes that were previously approved and included in License Amendment No. 10 but were inadvertently omitted from License Amendment No. 11. The proposed amendment also corrects an erroneous regulatory citation in TS 5.5.1.d, corrects a typographical error in TS 5.5.2.5, and adjusts references to relevant organizational components of DOE in License Condition 14 and in TS 5.1.5, and 5.5.2.7. The NRC staff has reviewed the application, including the justifications for the requested changes. As discussed below, based on the staff's evaluation of the statements and representations in the application, the staff finds that the requested amendment to Renewed License No. SNM-2504 for the FSV ISFSI meets the regulatory requirements of 10 CFR Part 72. 2.0 EVALUATION CRITERIA The staff conducted an evaluation of the changes requested by the applicant to ensure that they meet the applicable requirements of 10 CFR Part 72 and 10 CFR Part 20. The staff used the guidance provided in NUREG-2215, "Standard Review Plan for Spent Fuel Dry Storage Systems and Facilities, Final Report" to conduct the evaluation. The staff's evaluation focused on the changes to SNM-2504 requested in the application and did not reassess previously approved portions of the license, TS, the final safety analysis report (FSAR) or any changes to the FSAR made by DOE under the provisions of 10 CFR 72.48. The evaluation for each applicable review discipline is described below. Enclosure 3 3.0 TECHNICAL SPECIFICATIONS EVALUATION In its license amendment application, DOE requested to revise the SNM renewed license and applicable TS to modify the title of the designated DOE licensee position with the authority to serve as the Secretary of Energy's authorized representative in accordance with NRC regulations at 10 CFR 72.16(b). These documents currently assign licensee authority under the license to the Deputy Manager, Idaho Cleanup Project. The LAR removes the specific position title "Deputy Manager, Idaho Cleanup Project" and designates the "Manager for the Idaho Cleanup Project (ICP)," as the designated authority and authorized representative in all matters regarding the license. Additionally, the proposed amendment corrects clerical drafting errors in TS 3.3.1 and 5.5.2.6 so that those technical specifications accurately reflect changes that were previously approved and included in License Amendment No. 10 but were inadvertently omitted from License Amendment No. 11. The proposed amendment also corrects an erroneous regulatory citation in TS 5.5.1.d, corrects a typographical error in TS 5.5.2.5, and adjusts references to relevant organizational components of DOE in License Condition 14 and in TS 5.1.5, and 5.5.2.7. The staff reviewed the proposed changes requested by the applicant and determined that they are administrative in nature, and do not affect or change licensed operations nor the type and amount of material licensed for storage at the site. The staff finds that the proposed change in the licensee delegation does not affect the ability of the FSV ISFSI to meet the regulatory requirements of 10 CFR Part 72. 4.0 REQUIREMENTS FOR NOTICING PROPOSED ACTION In accordance with 10 CFR 72.16, a Notice of Docketing was published in the Federal Register on May 5, 2025 (90 FR 19011). During its acceptance review of the proposed amendment, staff determined that the proposed amendment did not present a genuine issue to public health and safety. Accordingly, pursuant to 10 CFR 72.46(b)(2), the staff has determined that the publication of a notice of proposed action and opportunity for hearing, or the publication of a notice of hearing, is not warranted and has taken immediate action on the proposed amendment. A Federal Register Notice of Issuance will be issued notifying the public of the action taken and of the right of interested persons to request a hearing on whether this action should be rescinded or modified. 5.0 ENVIRONMENTAL REVIEW The staff reviewed the proposed amendment request against the categorical exclusion criteria in 10 CFR 51.22(c)(10) and determined that the amendment request is administrative in nature. Under 10 CFR 51.22(c)(10), a categorical exclusion from the requirement to prepare an environmental impact statement for such a change is allowed provided the following conditions are satisfied: (i) changes surety, insurance and/or indemnity requirements; (ii) changes recordkeeping, reporting, or administrative procedures or requirements; (iii) changes the licensee's or permit holder's name, phone number, business or e-mail address; (iv) changes the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager; or (v) changes the format of the license or permit or otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. After evaluating the amendment request, staff has determined that the amendment: (i) changes the name, position or title of an officer of the licensee or permit holder, including but not limited -2- to, the radiation safety officer or quality assurance manager, and (ii) the amendment changes the format of the license or permit or otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. The amendment does not impact any structures, systems, or components (SSC) of the FSV ISFSI and will not affect ISFSI operations, any design function, or an analysis that verifies the capability of an SSC to perform a design function. Consequently, staff finds that the amendment request meets the categorical exclusion criteria in 10 CFR 51.22(c)(10). 6.0 CONCLUSION Based on its review of the proposed amendment, the staff has determined that there is reasonable assurance that: (i) the activities authorized by the amended renewed license will be conducted without endangering the health and safety of the public, and (ii) these activities will be conducted in compliance with the applicable regulations. The staff has further determined that the issuance of the amendment will not be inimical to the common defense and security. The staff approves Amendment No. 12 to Materials Renewed License No. SNM-2504 for the FSV ISFSI. Issued with Materials Renewed License No. SNM-2504, Amendment No. 12, dated: 08/27/2025. -3- Hello