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HomeMy WebLinkAbout20171789.tiffJo p,R REG U, 9A 4442 o O H rsy O' ' . ***** UNITED STATES NUCLEAR REGULATORY COMMISSION Mr. Richard Provencher, Manager Department of Energy Idaho Operations Office 1955 Fremont Avenue Idaho Falls, Idaho 83415 WASHINGTON, D.C. 20555-0001 June 6, 2017 RECEIVED JUN 13 2017 WELD COUNTY COMMISSIONERS SUBJECT: AMENDMENT NO. 11 TO MATERIALS LICENSE NO. SNM-2504 FOR THE FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION Dear Mr. Provencher: By letter dated September 8, 2016, the Department of Energy (DOE) requested an amendment to Special Nuclear Materials (SNM) License No. SNM-2504 for the Fort St. Vrain (FSV) Independent Spent Fuel Storage Installation. In its application, the applicant requested to change the licensee delegation of authority in the license, technical specifications, and final safety analysis report. These documents currently delegate authority under the license to the Manager, DOE Idaho Operations Office. The amendment replaces this reference with the Deputy Manager, Idaho Cleanup Project in each of the documents. Based on our review of your application, the NRC staff has determined that there is reasonable assurance that: (i) the activities authorized by the amended 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. 11 meets the criteria for a categorical exclusion in 10 CFR 51.22(c)(11). Therefore, the staff will not prepare an environmental assessment or environmental impact statement. The NRC has approved the requested amendment. The amended license supersedes Special Nuclear Materials License No. SNM-2504, Amendment No. 11, dated March 1.7, 2016. Revised Technical Specifications and the staff's Safety Evaluation Report are also enclosed. Changes made to the enclosed 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. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the publicly available records component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html. C_Atywnonica.+iots (p/Id/I-7 cc= H,LCPPSI LL), PLCmm/Te), OEAY1 CRR), Gck,c& /aC/FH) L4/O4/(7 2017-1789 R. Provencher 2 If you have any questions regarding this matter, you may contact me at (301) 415-5722, or Mr. Jose Cuadrado of my staff at (301) 415-0606. Sincerely, JohncKirgan, Chief Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Docket No.: 72-09 CAC No.: L25150 Enclosures: 1. Materials License No. SNM-2504 Amendment No. 11 2. Revised Technical Specifications 3. Safety Evaluation Report cc: Service List CC: Mr. Richard B. Provencher Manager U. S. Department of Energy 1955 Fremont Avenue Idaho Falls, ID 83415 Mr. Steven Ahrendts Acting DOE -ID NRC Licensing Manager U.S. Department of Energy Idaho Operations Office 1955 Fremont Ave., MS -1222 Idaho Falls, ID 83415 Mr. Scott Ferrara FSV/TMI-2 Facility Director U.S. Department of Energy Idaho Operations Office 1955 Fremont Ave., MS -1222 Idaho Falls, ID 83415 Mr. Jack Zimmerman Deputy Manager for Idaho Cleanup Project U.S. Department of Energy 1955 Fremont Avenue Idaho Falls, ID 83415 Mr. David Bland Program Manager for NRC Licensed Facilities Spectra Tech Inc. 1955 Fremont Ave. Idaho Falls, ID 83401 Mr. Robert Milazzo Business Manager for NRC Licensed Facilities Spectra Tech Inc. 1955 Fremont Ave. Idaho Falls, ID 83401 Chairman Board of County Commissioners of Weld County, Colorado 915 10th Street Greely, CO 80631 Regional Representative Radiation Programs Environmental Protection Agency 1 Denver Place 999 18th Street, Suite 1300 Denver, CO 80202-2413 Director Laboratory R Radiation Services Division VVV VIVIJIVII Colorado Department of Public Health and Environment 8100 Lowry Boulevard Denver, CO 80230-6928 DEPARTMENT OF ENERGY DOCKET NO. 72-9 FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION MATERIALS LICENSE NO. SNM-2504 Amendment No. 11 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. F T r hn McKirgan, Chief Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards E NUCLEAR REGULATORY COMMISSION Enclosed: Amended Renewed License Date of Issuance: 6/6/17 NRC FORM 588 (10-2000) 10 CFR 72 LICENSE FOR INDEPENDENT STORAGE HIGH-LEVEL U. S. NUCLEAR REGULATORY COMMISSION PAGE 1 OF 3 PAGES OF SPENT NUCLEAR FUEL AND RADIOACTIVE WASTE Pursuant to the Atomic Energy Act of 1954, as amended, Title 10, Code of Federal Regulations, Chapter 1, Part 72, by the licensee, a license is hereby issued authorizing the fuel and other radioactive materials associated with spent purpose(s) and at the place(s) designated below; and to accordance with the regulations of the applicable Part(s). Section 183 of the Atomic Energy Act of 1954, as amended, the Nuclear Regulatory Commission now or hereafter in the Energy Reorganization Act of 1974 (Public Law 93-438), and and in reliance on statements and representations heretofore made licensee to receive, acquire, and possess the power reactor spent fuel storage designated below; to use such material for the deliver or transfer such material to persons authorized to receive it in This license shall be deemed to contain the conditions specified in and is subject to all applicable rules, regulations, and orders of effect and to any conditions specified herein. 1. Licensee Department of Energy 3. Renewed SNM-2504 License No. Amendment No. 11 2. 850 Energy Drive Idaho Falls, Idaho 83401-1563 4. Expiration Date November 30, 2031 5. Docket or 72-09 Reference No. 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 C. Irradiated TRISO coated (Th, A. 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 B. As calibration discs or sealed C. sources, without restriction to chemical or physical form, for sample analysis and instrument calibration 1036 Kg uranium and 14,540 Kg thorium initially contained in 1,482 irradiated HTGR fuel elements 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 Radioactive sources used for sample analysis and instrument calibration NRC FORM 588A U. S. NUCLEAR REGULATORY COMMISSION (10-2000) 10 CFR 72 PAGE 2 OF 3 PAGES Renewed License No. SNM-2504 Amendment No. 11 LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE SUPPLEMENTARY SHEET 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; and September 8, 2016; 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 7.6 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 DOE -ID 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. NRC FORM 588A U. S. NUCLEAR REGULATORY COMMISSION (10-z000) 10CFR72 PAGE 3 OF 3 PAGES Renewed License No. SNM-2504 Amendment No. 11 LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE SUPPLEMENTARY SHEET Docket or Reference No. 72-9 16. This license is effective as of the date of issuance shown below. FOR THE U.S. NUCLEAR REGULATORY COMMISSION )/)) 141°111 J,9tin McKirgan, Chief SSpent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards V,/ajl III Igttll 1, DC 20555 • Date of Issuance: 6/6/17 Attachment: Appendix A APPENDIX A TECHNICAL SPECIFICATIONS FOR THE FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION SNM-2504 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 L A A/4 lILlr //,1 II A\ Ivl/1Vf-1I INC �VrnvI) FUEL STORAGE CONTAINERS (FSC) HANDLING OPERATIONS INDEPENDENT SPENT FUEL STORAGE INSTALLATION (ISFSI) MODULAR VAULT DRY STORE (MVDS) OPERABLE -OPERABILITY STORAGE OPERATIONS STORAGE WELL 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 Fuei 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. 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 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 too in the first level r ti__ left - the wi n ic��Vi i the rn ai ICVCI VI I Ie.JUI ll�. (i.e.,(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 Logical Connectors 1.2 1.2 Logical Connectors EXAMPLES (continued) EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Verify... AND A.2 Restore .. . In this example the logical connector AND is used to indicate that when in Condition A, both Required Actions A.1 and A.2 must be completed. Fort St. Vrain ISFSI 1.2-2 Logical Connectors 1.2 1.2 Logical Connectors EXAMPLES (continued) EXAMPLE 1.2-2 ACTIONS CONDITION A. LCO not met. REQUIRED ACTION A.1 Trip .. . OR A.2.1 Verify .. AND A.2.2.1 Reduce... OR A.2.2.2 Perform ... OR A.3 Align .. . COMPLETION TIME 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. Fort St. Vrain ISFSI 1.2-3 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 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 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 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 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 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 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 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 beperformed 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 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 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 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 LCO 3.0.2 provided in 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 LCO 3.0.5 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. Equipment removed from service or declared inoperable to comply with ACTIONS may be returned 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 returned to service under administrative control to perform the testing required to demonstrate OPERABILITY. LCO 3.0.6 Not applicable to an ISFSI. LCO 3.0.7 Not applicable to an ISFSI. Fort St. Vrain ISFSI 3.0-1 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 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 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 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 Fort St. Vrain ISFSI 3.2-2 Container Handling Machine 3.2 3.2 Container Handling Machine 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 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 x 10-3 standard cc/sec. APPLICABILITY: During STORAGE OPERATIONS • ACTION CONDITION A. If seal leak rate limit is exceeded for one or two FSCs (or storage wells) B. If seal leak rate limit is exceeded for three or more FSCs or storage wells REQUIRED ACTION 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 COMPLETION TIME 7 days 7 days 7 days A.2 Perform leak test on two additional FSCs from each vault 30 days AND A.3 Submit report to NRC describing condition, results of engineering evaluations and actions being taken. B.1 Notify NRC Operations Center Fort St. Vrain ISFSI 3.3-1 90 days Within 24 hours of entry into CONDITION B 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 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 CONDITION A. Ambient air temperature less than limit. REQUIRED ACTION A.1 Place FSC in safe condition AND A.2 Suspend further Handling Operations The ambient air temperature shall not be less than 12 degrees F COMPLETION TIME 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 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 shah 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 Responsibility 5.1 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.1.1 The Deputy Manager for Idaho Cleanup Project (ICP), Office of Environmental Management (DOE -ID), 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 -ID 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 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, �L�11 be documented1shall doin the Safety Analysis Report; 2. The responsible Department executive, as delegated 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 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 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 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 Engineering and Environmental 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 -ID 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 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't meet 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(b)(2). Fort St. Vrain ISFSI 5.5-1 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(b). 7. DOE 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 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. 3. 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 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 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 Deputy Manager for 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 UNITED STATES NUCLEAR REGULATORY COMMISSION 2oNx REG V�4 O9 Wy 70 n a � n **** WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT FORT ST. VRAIN INDEPENDENT SPENT FUEL STORAGE INSTALLATION MATERIALS LICENSE NO. SNM-2504 AMENDMENT NO. 11 1.0 SUMMARY This safety e oluation report (CER) documents the review and evaluation of a ii�ciac amendment request to Special Nuclear Materials (SNM) License No. 2504 for the Fort St. Vrain (FSV) Independent Spent Fuel Storage Installation (ISFSI). By letter dated September 8, 2016, the Department of Energy (DOE) submitted a request to the 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, technical specifications(TS), and final safety analysis report (FSAR). These documents currently delegate authority under the license to the Manager, DOE Idaho Operations Office. The amendment replaces this reference with the Deputy Manager, Idaho Cleanup Project in each of the documents. 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 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-1567, "Standard Review Plan for Spent Fuel Dry Storage Facilities," 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. 3.0 TECHNICAL SPECIFICATIONS EVALUATION In its amendment application, DOE requested to revise the licensee delegation of authority in the license, TS, and FSAR. These documents currently delegate authority under the license to the Manager, DOE Idaho Operations Office. The amendment request replaces this reference with the Deputy Manager, Idaho Cleanup Project in each of the documents. In its application, DOE stated that the Secretary of Energy has designated the Deputy Manager, DOE Idaho Cleanup Office to be the DOE Responsible Official for the FSV ISFSI. DOE states that this -2 - revised designation aligns the FSV license, TS and FSAR with the DOE office that has programmatic responsibility for NRC-licensed operations at the FSV ISFSI. To implement the proposed delegation of authority changes, DOE requested to revise Section 5.1, "Responsibility" and Section 5.6, "Reporting Requirements," of the FSV ISFSI TS. In addition, DOE made conforming changes in Chapter 9, "Conduct of Operations," and Chapter 11, "Quality Assurance," of the FSV ISFSI FSAR. 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 of meeting 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 February 23, 2017 (82 FR 11484). 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)(11), and determined that the amendment request is administrative in nature. Under 10 CFR 51.22(c)(11), 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) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, (ii) there is no significant increase in individual or cumulative occupational radiation exposure, (iii) there is no significant construction impact, and (iv) there is no significant increase in the potential for or consequences from radiological accidents. After evaluating the amendment request, staff has determined that the amendment: (i) would not produce a significant change in either the type or amount of effluents released to the environment because the amendment does not affect the design, fabrication, or operations of the facility, and consequently does not affect the type or amount of effluents released to the environment; that (ii) the amendment would not produce a significant increase in occupational radiation exposure because changes to these administrative programs do not affect the operations at the facility, nor the amounts of radioactive material authorized for storage at the facility, and consequently would not produce a significant increase in occupational radiation exposure; that (iii) the amendment would not have significant construction impacts because the amendment only impacts the process by which administrative programs are revised, does not involve construction, and consequently would not have significant construction impacts; and that (iv) the amendment would not produce a significant increase in the potential for or consequences from radiological accidents because the amendment does not decrease the capabilities of personnel to perform their duties or decrease DOE's control of the design, -3 - fabrication and operation of the facility, and consequently would not produce a significant increase in the potential for or consequences from radiological accidents. Consequently, staff finds that the amendment request meets the categorical exclusion criteria in 10 CFR 51.22(c)(11). 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 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. 11 to Materials License No. SNM-2504 for the FSV ISFSI. Issued with Materials License No. SNM-2504, Amendment No. 11, dated: 6/6/17 Hello