ML18101A020

Independent Spent Fuel Storage Installation - Submittal of Application for the License Renewal

ML18101A020
Person / Time
Site:	07200011
Issue date:	03/19/2018
From:	Tallman D Sacramento Municipal Utility District (SMUD)
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DPG 18-051
Download: ML18101A020 (5)

Text

March 19, 2018 DPG 18-051 Attn: Document Control Desk Director, Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Docket 72-11 Rancho Seco Independent Spent Fuel Storage Installation License No. SNM-2510 SUBMITTAL OF APPLICATION FOR THE RENEWAL OF 10 CFR PART 72 SPECIAL NUCLEAR MATERIALS LICENSE NO. SNM-2510 FOR THE RANCHO SECO INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mr. Layton:

The Nuclear Regulatory Commission (NRC) issued Special Nuclear Materials License SNM-2510 for the Rancho Seco Independent Spent Fuel Storage Installation (ISFSI) to the Sacramento Municipal Utility District (SMUD) on June 30, 2000, with an expiration date of June 30, 2020.

Pursuant to 10 CFR 72.42(a), SMUD hereby submits an application for renewal of the Rancho Seco ISFSI license for a 40-year period of extended operation (PEO) to June 30, 2060.

Because this license renewal application (LRA) is being submitted in proper form more than two years in advance of the expiration date of license SNM-2510, in accordance with 10 CFR 72.42(c), the license should not expire until a final decision concerning the LRA has been made by the Commission (i.e., timely renewal). As such, SMUD requests acknowledgement of the submittal of the Rancho Seco LRA meeting the requirement for timely renewal from the NRC at its earliest convenience.

provides the Rancho Seco ISFSI license renewal application (LRA). The LRA contains proprietary information owned by TN Americas LLC (TN). That information may not be used for any purpose other than NRC staff review of the LRA. Accordingly, a TN affidavit is provided as Enclosure 2 specifically requesting that you withhold this proprietary information from public disclosure. Enclosure 3 provides drawings which were used in the renewal process but are not contained in the Rancho Seco ISFSI FSAR. Those drawings are also proprietary. provides a non-proprietary version of the Enclosure 1 LRA for public release.

The format and content of this LRA follows NUREG-1927, Standard Review Plan for Renewal of Specific Licenses and Certificates of Compliance for Dry Storage of Spent Nuclear Fuel,

Revision 1 and is also informed by Industry Guidance NEI 14-03, Format, Content, and Implementation Guidance for Dry-Cask Storage Operations-Based Aging Management, Revision 2. The LRA contains detailed analysis and supporting information related to the content and assumptions used for justification of aging management activities; however, not all documents referenced in the LRA are being provided at this time. Should the NRC staff reviewing the LRA require any of those additional references, SMUD will provide them. We note that the NRCs Managing Aging Processes for Storage (MAPS) Report was being developed concurrently with the preparation of this LRA and is still not finalized. Therefore, SMUD considered the draft version of the MAPS Report in developing the LRA AMPS on a best-effort basis to the extent the schedule for LRA development could accommodate it.

We also note that Revision 7 of the Rancho Seco ISFSI FSAR, which added changes to support review of the recently-approved Amendment 4 to the license, was submitted to the NRC in Rancho Seco Response To NRC Request For Additional Information Related To The Proposed Amendment To Special Nuclear Material License No. 2510 (DPG 17-147) on August 10, 2017.

However, the scoping evaluations and aging management reviews supporting the LRA were performed using Revision 6 of the Rancho Seco ISFSI FSAR (submitted to the NRC in August 2016, ADAMS Accession No. ML16253A004). SMUD has confirmed that the changes in ISFSI FSAR Revision 7 only pertain to the changes in license amendment 4 and have no impact on the scoping evaluations or aging management reviews supporting the LRA.

In preparing this license renewal application, SMUD has not changed or modified any technical parameters or licensed materials (quantities or types). As previously discussed with our NRC project manager, there are two administrative changes to the license proposed, as described in LRA Chapter 1 and Appendix D. In addition, this LRA has no proposed changes to the Rancho Seco ISFSI physical security plan. The most recent biennial Rancho Seco ISFSI 10 CFR 72.48 summary report (DPG 16-167) was transmitted to the NRC on July 14, 2016, in accordance with 10 CFR 72.48(d)(2) (ADAMS Accession No. ML16208A109).

Lastly, we believe it is important to the NRC staff for us to note that the material licensed to be stored at the Rancho Seco ISFSI is limited to the Rancho Seco spent nuclear fuel and Greater-Than-Class-C (GTCC) low-level waste generated during the operation of the Rancho Seco Nuclear Generating Station, which permanently ceased operation in 1989. This material is specified in Conditions 6A/B, 7A/B, and 8A/B of license SNM-2510. The last of the spent nuclear fuel and GTCC waste material was emplaced at the ISFSI in 2006 and no additional material will be added to the ISFSI under these license conditions. Thus, the very low radiation source term and decay heat of the radioactive material being stored at the ISFSI will reflect an approximately 31-year cooling time at the start of the PEO. Additionally, a small quantity of byproduct material is authorized for possession and use for instrument response checks under license conditions 6C, 7C, 8C and 13-19.

This submittal is being provided as an electronic submission, using the optical storage media (OSM) provision from Section 4 of the NRC Guidance for Electronic Submissions to the NRC.

Powering forward. Together.

DPG-18-051 SMUD is submitting this license renewal application under oath or affirmation. Accordingly, pursuant to 10 CFR 72. l 6(b ), I declare under penalty of perjury that the information contained in SMUD letter DPG 18-051, "Submittal of Application for the Renewal of 10 CFR Part 72 Special Nuclear Materials License No. SNM-2510 for The Rancho Seco Independent Spent Fuel Storage Installation" is true and correct to the best of my knowledge.

Should you have questiOns or require additional information, please contact me directly at (916) 732-4893.

Enclosures:

Sincerely,

~1--

Dan Tallman Manager, Rancho Seco Assets

1. Rancho Seco ISFSI License Renewal Application, Revision 0 (proprietary version)

2. Affidavit Pursuant to 10 CFR 2.390

3. Non-FSAR Drawings Associated with the Rancho Seco ISFSI License Renewal Application (proprietary)

4. Rancho Seco ISFSI License Renewal Application, Revision 0 (non-proprietary version) cc: Wendy Reed, NRC (w/enclosures, Hardcopy (proprietary) plus five electronic copies (i.e.,

five OSM#l disks))

William Allen, NRC, (w/o enclosures)

Meraj Rahimi, NRC, (w/o enclosures)

Administrator, NRC Region IV (w/o enclosures)

Radiological Health Branch of the California State Department of Health Services (w/o enclosures) 3 Rancho Seco Nuclear Generating Station [ 14440 Twin Cities Road [ Herald, CA 95638-9799 [ 916.452.3211 [ smud.org

Document Components:

001 Public Transmittal Letter.pdf, 4,945,861 bytes 002 SUNSI Encl 1 LRA proprietary version.pdf, 39,620,115 bytes 003 Public Encl 2 Affidavit.pdf, 194,520 bytes 004 SUNSI Encl 3 Non-FSAR drawings proprietary versions.pdf, 21,610,598 bytes 005 Public Encl 4 LRA public version.pdf, 39,069,439 bytes OSM#1 (Entire Submittal) (Disk):

001 Public Transmittal Letter.pdf, 4,945,861 bytes 002 SUNSI Encl 1 LRA proprietary version.pdf, 39,620,115 bytes 003 Public Encl 2 Affidavit.pdf, 194,520 bytes 004 SUNSI Encl 3 Non-FSAR drawings proprietary versions.pdf, 21,610,598 bytes 005 Public Encl 4 LRA public version.pdf, 39,069,439 bytes OSM#2 (Public Information Only) (Disk):

001 Public Transmittal Letter.pdf, 4,945,861 bytes 003 Public Encl 2 Affidavit.pdf, 194,520 bytes 005 Public Encl 4 LRA public version.pdf, 39,069,439 bytes

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