Text

Interim Storage Partners, LLC, Submittal of Revision 3 of the License Application for the WCS CISF
	ML20237F470
Person / Time
Site:	Consolidated Interim Storage Facility
Issue date:	08/24/2020
From:	Isakson J; Consolidated Interim Storage Facility
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards
Shared Package
ML20237F469	List: ML20237F470;
References
	CAC 001028, E-57138, EPID L-2017-NEW-0002
	Download: ML20237F470 (123)
	v • d • e

August 24, 2020 E-57138 Director, Division of Fuel Management Office of Nuclear Material Safety and Safeguards U. S. Nuclear Regulatory Commission Attn: Document Control Desk One White Flint North 11555 Rockville Pike Rockville, MD 20852

Subject:

Submission of Revision 3 of the License Application for the WCS CISF, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002

Reference:

1. Letter from Jeffery D. Isakson to NRC Document Control Desk, Submittal of Partial Response to First RAI, Part 1, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002, E-54257, dated May 31, 2019

2. Letter from Jeffery D. Isakson to NRC Document Control Desk, Submission of ISP Responses for RAIs and Associated Document Markups from First Request For Additional Information, Part 2, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002, E-55362, dated January 17, 2020

3. Letter from Jeffery D. Isakson to NRC Document Control Desk, Submission of ISP Responses for RAIs and Associated Document Markups from First Request for Additional Information, Parts 2, 3, and 4, Docket 72-1050 CAC/EPID 001028/L-2017-NEW-0002, E-56415, dated April 7, 2020 Interim Storage Partners LLC hereby submits Revision 3 of the License Application (LA) for the WCS CISF. Revision 3 incorporates all of the changes submitted via References

[1], [2], and [3] along with additional changes to the proposed Materials License and Technical Specifications requested by NRC Staff. Additional changes to the LA are limited to updating the mailing addresses in Section 1.11 for the Chief Engineer, two Management Board members and a Principle Officer to reflect their new office locations; an editorial change to Section 4, related to the location of a referenced table; updating the table of contents; and pagination changes. No other changes are made to the LA.

P.O. Box 1129

Andrews, Texas 79714

interimstoragepartners.com

Document Control Desk E-57138 Page 2 of 2 The following enclosures are being submitted:

x Enclosure 1 includes an affidavit pursuant to 10 CFR 2.390 for Interim Storage Partners.

x Enclosure 2 provides a proprietary version of LA, Revision 3.

x Enclosure 3 provides a public version of Enclosure 2 (LA Revision 3)

Should you have any questions regarding this submission, please contact Mr. Jack Boshoven, of my staff, by telephone at (410) 910-6955, or by email at jack.boshoven@orano.group.

Sincerely, Digitally signed by ISAKSON Jeffery Jeffery D. Isakson Chief Executive Officer/President Interim Storage Partners LLC cc: John-Chau Nguyen, Senior Project Manager, U.S. NRC Jack Boshoven, ISP LLC Elicia Sanchez, ISP LLC

Enclosures:

1. Affidavit Pursuant to 10 CFR 2.390 of Interim Storage Partners

2. License Application, Revision 3 (Proprietary Version)

3. License Application, Revision 3 (Public Version)

Enclosure 1 to E-57138 Affidavit Pursuant to 10 CFR 2.390

AFFIDAVIT PURSUANT TO 10 CFR 2.390 Interim Storage Partners LLC )

State of Maryland ) ss.

County of Howard )

I, Jeffery Isakson, depose and say that I am Chief Executive Officer/President, Interim Storage Partners LLC duly authorized to execute this affidavit, and have reviewed or caused to have reviewed the information that is identified as proprietary and referenced in the paragraph immediately below. I am submitting this affidavit in conformance with the provisions of 10 CFR 2.390 of the Commission's regulations for withholding this information.

The information for which proprietary treatment is sought applies to the following documents listed below:

Enclosure 2 of E-57138, License Application changed pages (Sections 1.6. l including Table 1-1 and Table 1-2; and Section 1.6.4)

This document has been appropriately designated as proprietary.

I have personal knowledge of the criteria and procedures utilized by Interim Storage Partners LLC in designating information as a trade secret, privileged or as confidential commercial or financial information.

Pursuant to the provisions of paragraph (b) (4) of Section 2.390 of the Commission's regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure, included in the above referenced document, should be withheld.

I) The information sought to be withheld from public disclosure involves information related to the ISP business plan for the WCS CISF, which are owned and have been held in confidence by Interim Storage Partners LLC.

2) The information is of a type customarily held in confidence by Interim Storage Partners LLC, and not customarily disclosed to the public. Interim Storage Partners LLC has a rational basis for determining the types of information customarily held in confidence by it.

3) Public disclosure of the information is likely to cause substantial harm to the competitive position oflnterim Storage Partners LLC, because the information consists of descriptions of the financial basis for the WCS CISF, the application of which provide a competitive economic advantage. The availability of such information to competitors would enable them to modify their business plan or project to better compete with Interim Storage Partners LLC, take marketing or other actions to improve their product's or project's position or impair the position of Interim Storage Partners LLC product or project, and avoid developing a similar approach in support of their business plan.

Further the deponent sayeth not.

Jeffery lsakso Chief Executive Officer/President, Interim Storage Partners LLC Subscribed and sworn before me this 21 st day of August, 2020.

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Enclosure 2 to E-57138 License Application Withheld Pursuant to 10 CFR 2.390

Enclosure 3 to E-57138 License Application, Revision 3 (Public Version)

INTERIM STORAGE PARTNERS LLC LICENSE APPLICATION INTERIM STORAGE PARTNERS LLC (Public Version)

DOCKET 72-1050 ANDREWS COUNTY, TEXAS REVISION 3

INTERIM STORAGE PARTNERS LLC LA TOC LICENSE APPLICATION TABLE OF CONTENTS CHAPTER TITLE PAGE 1 GENERAL AND FINANCIAL INFORMATION 1-1 2 TECHNICAL QUALIFICATIONS 2-1 3 TECHNICAL INFORMATION - SAFETY ANALYSIS REPORT 3-1 4 CONFORMITY TO GENERAL DESIGN CRITERIA 4-1 5 OPERATING PROCEDURES -

ADMINISTRATIVE AND MANAGEMENT CONTROLS 5-1 6 QUALITY ASSURANCE PROGRAM 6-1 7 OPERATOR TRAINING 7-1 8 INVENTORY AND RECORDS REQUIREMENTS 8-1 9 PHYSICAL PROTECTION 9-1 10 DECOMMISSIONING PLAN 10-1 11 EMERGENCY PLAN 11-1 12 ENVIRONMENTAL REPORT 12-1 13 PROPOSED LICENSE CONDITIONS 13-1 Page I Revision 3

INTERIM STORAGE PARTNERS LLC LA TOC LICENSE APPLICATION TABLE OF CONTENTS LIST OF ATTACHMENTS A PROPOSED LICENSE CONDITIONS Page II Revision 3

INTERIM STORAGE PARTNERS LLC LA TOC LICENSE APPLICATION TABLE OF CONTENTS LIST OF APPENDICES A PROPOSED TECHNICAL SPECIFICATIONS B PRELIMINARY DECOMMISSIONING PLAN C NOT USED D DECOMMISSIONING FUNDING PLAN Page III Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION CHAPTER 1 GENERAL AND FINANCIAL INFORMATION 1.1 APPLICATION FOR LICENSE Interim Storage Partners LLC (ISP), a joint venture (JV) between Waste Control Specialists LLC and Orano CIS LLC, proposes to construct and operate a Consolidated Interim Storage Facility (CISF) at an away from reactor site located in Andrews County, Texas. The site is located on Texas Highway 176 West, approximately 32 miles west of Andrews, Texas (Figure 1-1).

Figure 1-1 Map Depicting the Location of the CISF in Andrews County, Texas.

The function of the CISF will be to store spent nuclear fuel and reactor-related Greater Than Class C (GTCC) Low-Level Radioactive Waste (LLRW) (both are collectively referenced henceforth as spent nuclear fuel or SNF) that has been used to generate electricity from commercial nuclear power reactors. The U.S. Department of Energy (DOE) or other holders of the title to SNF at commercial nuclear power facilities (SNF Title Holder(s)) will hold title to the Page 1-1 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION SNF during transportation to and from and while in storage at the CISF. The SNF will be delivered to the CISF by rail.

ISP will use multipurpose canisters in both the shipping casks and storage casks. No handling of bare spent nuclear fuel will occur at the CISF since operations will be restricted to handling of sealed canisters. ISP will operate the facility in a manner that minimizes the likelihood of transporting any externally contaminated canisters to the CISF. The canisters will be stored either in a horizontal or vertical configuration inside concrete storage casks, which will be stored on concrete pads inside the designated Protected Area.

This License Application for the proposed CISF has been prepared in accordance with 10 CFR 72 and the Regulatory Guide 3.50 titled, Standard Format and Content for a License Application to Store Spent Fuel and Radioactive Waste, Standard Format and Content for a Specific License Application for an Independent Spent Fuel Storage Installation or Monitored Retrievable Storage Facility, Rev. 2, September 2014. The License Application includes the technical information as required in 10 CFR 72, Subpart B. Additionally, the following documents are submitted herewith the License Application:

1. The License Application, including the Proposed Technical Specifications, Preliminary Decommissioning Plan, and Decommissioning Funding Plan, required pursuant to 10 CFR §72.26 and 10 CFR §72.30, respectively.

2. A Safety Analysis Report as required by 10 CFR §72.24.

3. The Emergency Plan required pursuant to 10 CFR §72.32.

4. The Environmental Report required as specified in 10 CFR §72.34 and 10 CFR §51.61.

5. Physical protection and safeguards information in accordance with 10 CFR 72, Subpart H, submitted separately as part of this license application to the NRC.

Operations at the originating commercial nuclear reactors in preparation or support of spent nuclear fuel shipments to the CISF are performed under the individual reactor licenses. Any changes to a reactor licensees facilities or procedures needed to accommodate these activities are the responsibilities of the individual reactor licensees and are not part of this License Application.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION Transportation of the spent nuclear fuel shipping casks from the originating commercial nuclear reactor to the CISF will be performed in accordance with 10 CFR 71 and the originating reactor licenses and is not part of this License Application.

1.2 NAME OF THE APPLICANT Interim Storage Partners LLC (ISP) 1.3 ADDRESS OF THE APPLICANT Interim Storage Partners LLC 9998 Highway 176 West Andrews, Texas 79714 Page 1-3 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION

1.4 DESCRIPTION

OF THE LICENSE APPLICANT Interim Storage Partners LLC (ISP) is a limited liability company formed in Delaware with principal offices at Andrews, Texas. ISP is jointly owned by Orano CIS (51%) and Waste Control Specialists LLC (49%). The sole purpose of ISP is to license, design, construct and operate the CISF at the Waste Control Specialists site in Andrews, Texas, referred to as the WCS CISF.

1.5 LEGAL STATUS AND ORGANIZATION ISP is a limited liability company organized and existing under the laws of the State of Delaware. Its principal office is located in Andrews, Texas. The proposed site for the CISF is at the Waste Control Specialists waste disposal and storage facilities located at 9998 Texas Highway 176 West, approximately 32 miles west of Andrews, Texas. The organizational structure for the WCS CISF is further described in Section 13.1 of the Safety Analysis Report.

ISP is majority owned and controlled by Orano CIS, which is owned 100% by Orano USA LLC.

Orano CIS and Orano USA are both limited liability companies formed in the State of Delaware.

Orano USA is ultimately majority owned and controlled by FAE AEC, an entity of the French government. Orano participates in a wide range of nuclear fuel cycle activities in the United States regulated by the NRC. All ISP officers, managers and management board members will be U.S. citizens. Given the nature of the CISF and the role of Orano across the U.S. nuclear fuel cycle, the participation of Orano in this project raises no inimicality concerns. The names of ISP governance and principal officers, all of whom are citizens of the United States, are provided at the end of this chapter.

The oversight and governance of ISP is provided by a Management Board that consists of the head of Orano CIS and one of the key members of its management team and the head of Waste Control Specialists and a key member of its management team.

1.6 FINANCIAL QUALIFICATIONS AND FINANCIAL ASSURANCE This section demonstrates that ISPs financial qualifications are adequate to carry out the activities for which the license is sought in accordance with the applicable regulations and to meet other financial assurance requirements specified in 10 CFR 72.30. The members of ISP, Page 1-4 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION Orano and Waste Control Specialists are well capitalized going concerns in the U.S. nuclear power business.

Below is a summary of the Orano 2018 financial results (results converted to USD based on a 1.10 USD/Euro exchange rate):

Orano Group Positive net cash flow Net cash flow of 177 MUSD, benefiting from good operating momentum, particularly on the Front End of the cycle and in exports (vs. -280 MUSD in 2017, excluding contribution to earmarked funds).

Reduction in the groups debt, with a 0.8 billion USD decline in net debt (2.53 billion USD, compared to 3.3 billion USD at end-2017).

Orano Group Operating performance above expectations Resilient EBITDA margin (22.7% vs. an initial target between 19% and 22%), supported by the strong contribution of the performance plan over the year, despite of a moderate decline in revenue (3,985 million USD; -5.7% like-for-like).

Sharp improvement in operating income, in connection with reversals of provisions and no impairments over the period (568 million USD, an increase of +621 million USD).

Full Orano Group annual results available 2018 Press Release:

https://orano.group/docs/default-source/orano-doc/finance/publications-financieres-et-reglementees/2018/resultats-annuels-2018/pr_orano_2018_financial_results.pdf?sfvrsn=a1c39456_14 2018 Consolidated Financial Statements:

https://orano.group/docs/default-source/orano-doc/finance/publications-financieres-et-reglementees/2018/resultats-annuels-2018/orano_20181231_consolidated_financial_statements.pdf?sfvrsn=e8b5c416_6 Page 1-5 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION Waste Control Specialists Summary Privately-owned Waste Control Specialists is supported by more than $95 million of investor equity at the end of 2019. Extensive investments were made to create the current uniquely-qualified radioactive waste disposal facility in Andrews County, Texas, with licenses, permits, buildings, equipment and site improvements valued at more than $150 million at the end of 2019 against less than $60 million of total debt. The site is also backed by more than $140M of current surety bonds to ensure continued financial regulatory compliance with the State of Texas.

Orano and Waste Control Specialists will provide initial capitalization of ISP. Orano and Waste Control Specialists will provide periodic capitalization as necessary to execute the business plan of ISP.

The CISF will be located in Andrews County, Texas, adjacent to the existing Waste Control Specialists LLRW facilities that were licensed as a 10 CFR Part 61 equivalent by Texas as an NRC Agreement State. ISP requests a license for 40 years.

1.6.1 Funding of Construction Activities The funding for constructing the CISF will be through future contracts for storage of SNF with the DOE or other SNF Title Holder(s). [

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Page 1-6 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION

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The location of the CISF is on land that has already been characterized and has access roads, electricity and water. Existing administration buildings, warehouses and other facilities already being used for non-CISF operations at the ISP joint venture member Waste Control Specialists facilities can supplement the CISF buildings and construction projects as needed. New construction is expected to include a rail side track, a Cask Handling Building and a Security and Administration Building. The storage pads and related storage systems will be constructed, as they are needed, to reduce the initial construction costs. The Environmental Report section of the WCS CISF contains a cost estimate based on an EPRI cost estimate for an away from reactor CISF. The ER cost estimate is conservatively high which is suitable when used for determining the cost benefit of the project for the purposes of the ER. ISP is not updating the ER cost estimate for this reason.

Page 1-7 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION 1.6.2 Funding of Operating Activities ISP has completed a detailed operating budget for the first 5 years of operations including a 3% per year inflation rate which is shown in Table 1-2. The funding of the operating costs will be through contacts with the customers of ISP, whether the DOE or SNF Title holders at all times when ISP is in possession of the authorized material as required by proposed License Condition 23.

Page 1-8 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION Proprietary Information on This Page Withheld Pursuant to 10 CFR 2.390 Page 1-9 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION 1.6.3 Financial Assurance for Decommissioning CISF decommissioning costs will be kept to a minimum by designing and operating the CISF in a manner that minimizes contamination pursuant to 10 CFR 20.1406 and 10 CFR 72.130. Waste canisters will not be opened, so the spent nuclear fuel will not be exposed to the CISF facilities, water, air or the surrounding environment. Therefore, the likelihood of a contamination event is considered very low and unlikely as described in the Safety Analysis Report. As a start-clean/stay-clean facility, the WCS CISF will operate in a manner that supports decommissioning activities throughout the life of the facility.

ISP will use a surety bond combined with a conformity external sinking fund as authorized by 10 CFR 72.30(e)(3). Payments from storage operations will be deposited into the external sinking fund as waste is received. A surety bond will be used to assure the difference in the decommissioning cost estimate and the value of the sinking fund until the sinking fund is fully funded. Proposed License Condition 24 ensures that ISP will have funding in place before SNP is received on site.

Decommissioning costs have been estimated to be $12,650,000. The decommissioning costs were estimated based on the size of the CISF authorized to store 5,000 MTU consistent with NUREG 1757, Consolidated Decommissioning Guidance. Additional information regarding the cost of decommissioning the CISF is provided in Appendix D of the License Application.

Page 1-10 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION Proprietary Information on Pages 1-11 and 1-12 Withheld Pursuant to 10 CFR 2.390 Page 1-11 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION 1.8 EXEMPTIONS ISP is not seeking any regulatory specific exemptions authorized pursuant to 10 CFR 72.7, Specific Exemptions.

1.9 SITE LOCATION AND COMPLETENESS DATES The proposed CISF is located at 9998 Highway 176 West, approximately 32 miles west of Andrews, Texas. It is anticipated that the ISP will receive a specific license authorizing the receipt, and possession of spent nuclear fuel in accordance with the requirements of 10 CFR 72 by September 2020. Construction of the Phase One of the facility shall commence in September 2021 and is expected to be completed within one year or on April 1, 2022. The construction and preoperational testing is expected to be completed allowing the first receipt of spent nuclear fuel no later than July 2023.

1.10 RESTRICTED DATA This application does not contain any Restricted Data, defense or national security information. Furthermore, if Restricted Data does become included as part of the application, the applicant will not permit any individual to have access to Restricted Data except in accordance with the requirements of 10 CFR Part 95.

1.11 COMMUNICATIONS It is requested that all communications pertaining to this application be sent to:

Jack Boshoven Chief Engineer CISF Licensing and Engineering Interim Storage Partners c/o TN Americas LLC 7160 Riverwood Drive, Suite 200 Columbia, Maryland 21046 USA Page 1-13 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 1 LICENSE APPLICATION INTERIM STORAGE PARTNERS LLC Oversight and Governance January 2020 The business and affairs of ISP are managed by its Management Board. The current members of the Management Board are:

David Carlson, U.S. Citizen President & Chief Operating Officer Waste Control Specialists LLC 17101 Preston Road Suite 115 Dallas, Texas 75248 Amir Vexler, U.S. Citizen President, Orano CIS LLC 7160 Riverwood Drive, Suite 200 Columbia, Maryland 20146 Sam Shakir, U.S. Citizen Chief Executive Officer, Orano USA LLC 4747 Bethesda Avenue Suite 1001 Bethesda, MD 20814 Scott State, U.S. Citizen Chief Executive Officer & Chief Nuclear Officer Waste Control Specialists LLC 17101 Preston Road Suite 115 Dallas, Texas 75248 Principal Officers Jeffery D. Isakson, U.S. Citizen Chief Executive Officer and President 7160 Riverwood Drive, Suite 200 Columbia, Maryland 20146 Elicia B. Sanchez, U.S. Citizen Chief Financial Officer 9998 West State Highway 176 Andrews, Texas 79714 Page 1-14 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 2 LICENSE APPLICATION CHAPTER 2 TECHNICAL QUALIFICATIONS The Technical Qualifications that shall be required of the staff to design, construct and operate the CISF are provided in Chapter 13 of the WCS Safety Analysis Report (SAR). ISP hereby commits to staff the project with personnel possessing the required skills throughout all phases of the project.

ISP has evaluated the dry cask storage systems that are currently available and under development and has selected the canister-based system for use at the CISF. ISP has selected TN Americas and NAC International as the vendors to provide the canister-based storage systems at the CISF. TN Americas dry cask storage systems described in the SAR include the TN NUHOMS, Standardized NUHOMS, Standardized Advanced NUHOMS. The TN Americas and NAC International dry cask storage systems described in the SAR are depicted in Table 2-1. Each of these dry cask storage systems have been licensed by the Nuclear Regulatory Commission.

Table 2-1 Dry Cask Storage Systems.

Cask System NRC Docket No. Canister Overpack FO-DSC NUHOMS MP187 Cask 71-9255 FC-DSC HSM (Model 80)

System 72-11 (SNM-2510) FF-DSC GTCC Canister Advanced Standardized 71-9255 NUHOMS 24PT1 AHSM NUHOMS System 72-1029 NUHOMS Standardized NUHOMS 71-9302 61BT HSM Model 102 System 72-1004 NUHOMS 61BTH Type 1 Yankee Class Connecticut Yankee 71-9235 NAC-MPC LACBWR VCC 72-1025 GTCC-Canister-CY GTCC-Canister-YR 71-9270 Classes 1 through 5 NAC-UMS VCC 72-1015 GTCC-Canister-MY 71-9356 MAGNASTOR TSC1 through TSC4 CC1 through CC4 72-1031 Page 2-1 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 2 LICENSE APPLICATION The CISF will be designed, engineered and constructed by ISP. The ISP joint venture members and affiliated companies have significant experience in the design, licensing, fabrication, installation and placing of SNF and GTCC waste into dry storage and the design, licensing, construction and operations at the Waste Control Specialists' LLRW Facilities in Andrews County, Texas. ISP staff assigned to this project are qualified in licensing, engineering, health physics, environmental science, nuclear operations, quality assurance, maintenance, administration and legal support.

Details of ISPs organizational structure, preoperational testing and operations of the CISF, as well as the CISF training program, physical security, and emergency planning are described in Chapters 7, 9 and 11, respectively, of the License Application.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 3 LICENSE APPLICATION CHAPTER 3 TECHNICAL INFORMATION - SAFETY ANALYSIS REPORT Phase one of the CISF is designed to provide storage for the material defined in Conditions 8A and 8B of the license received from commercial nuclear power reactors across the United States. Small amounts of mixed oxide fuels are anticipated to require storage at the CISF. The spent nuclear fuel received at the CISF will be placed into dry cask storage. ISP will employ the dry cask storage system technology that has been used, and licensed by the Nuclear Regulatory Commission pursuant to 10 CFR 72, at various commercial nuclear reactors across the country.

The dry cask storage systems that will be employed at the CISF are passive and provide physical protection, containment, nuclear criticality controls and radiation shielding required for the safe storage of spent nuclear fuel. Heat dissipation is accomplished by radiant natural convective cooling. The CISF is designed to store spent nuclear fuel until a permanent repository is constructed and operating. The initial request for a license is for a term of 40 years.

These canister-based dry cask storage systems are designed and licensed to store multiple spent nuclear fuel assemblies inside a metal canister in a dry inert environment. Phase one of the CISF is designed to store the material defined in Conditions 8A and 8B of the license. ISP anticipates that each of the storage casks will be placed on concrete pads constructed at the CISF.

The SNF will originate from commercial nuclear power plants across the United States. The spent nuclear fuel will be placed inside a dual purpose canister and transported to the CISF.

Activities at the commercial nuclear power plants and during transport to the CISF are required to comply with 10 CFR 50 and 10 CFR 71, respectively, and are not part of this license application. Activities conducted at the CISF include receipt of the dual purpose canisters and transfer of the dual purpose canisters into the dry cask storage systems. The dry cask storage systems will be located on top of the concrete pads constructed at the CISF. These activities will be performed in compliance with 10 CFR 72.

ISP anticipates only small quantities of LLRW will be generated at the CISF. Upon receipt of the dual purpose canisters, staff will be required to perform radiation and contamination surveys to ensure all regulatory and license limits and requirements are fulfilled. Only small quantities of Page 3-1 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 3 LICENSE APPLICATION radioactive waste are anticipated to be generated during these survey activities. Radioactive waste generated at the CISF may be disposed of at one of Waste Control Specialists radioactive waste disposal facilities pursuant to Waste Control Specialists current TCEQ radioactive material license.

The SAR documents the adequacy of the dry cask storage system components to safely store spent nuclear fuel and comply with the requirements specified in 10 CFR 72. The SAR adequately describes the safety basis for the components needed to protect workers, the general public and the environment during normal and off-normal events.

The SAR was prepared using Regulatory Guide 3.48, Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation or Monitored Retrievable Storage Installation (Dry Storage), Revision 1, and August 1989, Standard Review Plan for Spent Fuel Dry Storage Facilities, Final Report, March 2000, and the Interim Staff Guidance used by the Spent Fuel Project Office.

The dry cask storage systems that will be employed at the CISF are provided in Table 3-1.

Table 3-1, Dry Cask Storage Systems Cask System NRC Docket Canister Overpack NUHOMS MP187 Cask FO-DSC System 72-11 FC-DSC HSM (Model 80)

(SNM-2510) FF-DSC GTCC Canister Standardized Advanced NUHOMS 24PT1 72-1029 AHSM NUHOMS System Standardized NUHOMS NUHOMS System 61BT 72-1004 HSM Model 102 NUHOMS 61BTH Type 1 NAC-MPC Yankee Class Connecticut Yankee 72-1025 LACBWR VCC GTCC-Canister-CY GTCC-Canister-YR NAC-UMS Classes 1 thru 5 72-1015 VCC GTCC-Canister-MY MAGNASTOR TSC1 thru TSC4 72-1031 CC1 through CC4 GTCC-Canister-ZN Page 3-2 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 4 LICENSE APPLICATION CHAPTER 4 CONFORMITY TO GENERAL DESIGN CRITERIA The WCS CISF complies with the general design criteria of 10 CFR 72, Subpart F. The CISF's specific conformance to the general design criteria is covered in more detail in the Safety Analysis Report and other documents submitted with this License Application. A cross reference to the applicable SAR sections is provided in SAR Table 4-2 below.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 5 LICENSE APPLICATION CHAPTER 5 OPERATING PROCEDURES -

ADMINISTRATIVE AND MANAGEMENT CONTROLS Procedures for operating the CISF will be developed under the Quality Assurance Program described in Chapter 6 of this License Application. Procedures will include those necessary for each operating mode as well as the various mechanical, electrical, and instrument operating and maintenance functions. Procedures will also be in place for the handling of Special Nuclear Material (SNM) in accordance with 10 CFR 72.72. The CISF procedures will consider all license terms and restrictions and will reflect the commitments made in the Safety Analysis Report regarding CISF operations. Operating procedures will be reviewed and approved by Operations Management, Radiation Safety Management and Health and Safety Management; and will be maintained in a controlled manner to ensure that only current copies are available for staff usage in operating or maintaining the facility. Operating procedures will cover shipping cask receipt, inspection and unloading; canister transfer between shipping cask and storage cask; movement of storage cask between Cask Handling Building and Storage Area; assembly of storage cask instrumentation; preparation and release of shipping cask for off-site transport; and periodic monitoring of storage casks.

Administrative and management controls will be developed to ensure the principles of protecting human health and the environment, including the public and staff, and protecting against danger to SSCs important to safety, are placed ahead of other considerations. Chapter 13 of the Safety Analysis Report provides specific information regarding the organizational structure and training program which have been outlined for the CISF. Operating controls and limits are further addressed in Chapters 4, 5, 10, and 13 of the Safety Analysis Report and in the Technical Specifications which have been proposed for the CISF.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 6 LICENSE APPLICATION CHAPTER 6 QUALITY ASSURANCE PROGRAM All CISF activities affecting quality associated with the site investigation, design, licensing, procurement, construction, operation and decommissioning, which are classified as important-to-safety or safety-related are subject to the requirements of the TN Americas Quality Assurance (QA) program which has been established in accordance with the requirements of 10 CFR 72, Subpart G in accordance with 10 CFR § 72.24(n). ISP has adopted the TN Americas Quality Assurance Program for its use. The TN Americas Quality Assurance Program Description Manual (QAPDM) is Docketed under 71-0250. TN Americas will submit an update to the QAPDM to add Interim Storage Partners and its locations to the list of entities covered by the QAPDM.

Personnel who perform quality related and important to safety functions governed by this QA Program, to include activities performed prior to submittal of the License Application, are responsible for the understanding and proper implementation of the requirements of this QA Program.

The QA Program is applied to activities, structures, systems, and components of the CISF commensurate with their importance to safety.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 7 LICENSE APPLICATION CHAPTER 7 OPERATOR TRAINING The Operator Training Program will meet the requirements of 10 CFR Part 72, Subpart I, and will consist of a combination of on-the-job training (OJT) and classroom training leading to qualification. The OJT requirements will be documented in a set of qualification cards containing the Job Performance Measures (JPM) of practical factors that are required to be performed by the operator. Each person to become qualified must have these qualification cards completed prior to being allowed to independently perform the applicable tasks.

The operators will have to pass comprehensive written and practical examinations in order to become qualified. The trainee must score 80% or higher on the written exam to pass. The practical exam shall be on a pass/fail basis, as evaluated by previously qualified personnel.

The Operator Training Program will include requirements regarding the physical condition and general health of personnel certified for the operations of equipment and controls that are important to safety such that they may not cause operational errors that could endanger other in-facility personnel or the public health and safety. Any condition that might cause impaired judgement or motor coordination will be considered in the selection of personnel for activities that are important to safety. However, these conditions will not categorically disqualify a person, if appropriate provisions are made to accommodate such defect.

The CISF training program's content, documentation and recordkeeping requirements are more fully set forth in the SAR.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 8 LICENSE APPLICATION CHAPTER 8 INVENTORY AND RECORDS REQUIREMENTS Records showing the receipt, inventory, location, disposal, acquisition and transfer of all spent nuclear fuel at the CISF will be maintained in accordance with the requirements of 10 CFR 72.72. The CISF material status reports and nuclear material transaction reports will be maintained in accordance with the requirements of 10 CFR 72.76 and 10 CFR 72.78. It is expected that material accountability at the CISF will be under a separate Reporting Identification Symbol (RIS) number to be designated by the NRC.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 9 LICENSE APPLICATION CHAPTER 9 PHYSICAL PROTECTION Pursuant to Subpart H of 10 CFR 72, Physical Protection, the WCS CISF Physical Security Program is described in the following documents:

Physical Security Plan

Security Force Training & Qualification Plan

Safeguards Contingency Plan These plans are marked and protected as Safeguards Information and are thereby controlled and withheld from public disclosure pursuant to 10 CFR 73.21, Protection of Safeguards Information: Performance Requirements. The plans referenced above are submitted separately, under separate cover, as part of this License Application.

ISP as the licensee will have responsibility for all NRC security requirements. ISP will contract with Waste Control Specialists, as a member of the ISP joint venture and in coordination with existing security activities at the site, to implement (under ISP's direction and oversight) the Physical Security Program and provide Security for the WCS CISF.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 10 LICENSE APPLICATION CHAPTER 10 DECOMMISSIONING PLAN 10.1 GENERAL The decontamination and decommissioning (D&D) cost estimate is based on the guidance of NUREG-1757, Consolidated Decommissioning Guidance, and is developed on the basis that the CISF will be constructed and operated under the requirements of 10 CFR 20.1406 Minimization of Contamination. This regulation requires that the applicant design and operate the facility to minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize, to the extent practicable, the generation of radioactive waste. As a temporary storage facility, waste containers will not be opened at the CISF. Continual radiological surveillance during the operational period will ensure that contamination is quickly discovered, identified, and removed in a timely manner before the decommissioning period begins.

NUREG-1757 allows the assumption that routine conditions prevail at the time of the decommissioning and that a worst-case decommissioning scenario need not be considered. At the end of the storage period, all of the spent nuclear fuel located at the CISF will be removed and shipped for permanent disposal in a geologic repository. Once the fuel is removed and the CISF is no longer being used for its principal licensed purpose, ISP must prepare a Decommissioning Plan (DP) for review and approval by the NRC pursuant to the Timeliness Rule (10 CFR 72.54).

10.2 BACKGROUND

10 CFR § 72.30, Financial assurance and recordkeeping for decommissioning, requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a decommissioning funding plan that contains information on how reasonable assurance will be provided that funds will be available to decommission the CISF.

10.3 CISF DESCRIPTION The CISF will utilize the NUHOMS storage systems (AREVA TN Americas) along with the NAC-MPC, NAC-UMS, and MAGNASTOR storage systems (NAC International). The facility will provide storage of the material defined in Conditions 8A and 8B of the license.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 10 LICENSE APPLICATION 10.4 COST ESTIMATE APPROACH The decommissioning cost estimate is based on the condition of the CISF after all of the spent nuclear fuel has been removed from the site. No interior or exterior radioactive surface contamination is expected. During the lifetime of the facility, only sealed canisters will be accepted for storage. The facility does not open the canisters at any time and therefore does not perform any sampling or processing of waste. Canisters are only accepted into the facility after a radiological survey has determined that they are free from contamination. Only small quantities of radioactive waste are expected to be generated during routine operations, attributable primarily to performing radiological surveys at the facility.

Radioactive surface contamination at the time of decommissioning will be minimized due to radiological survey and monitoring activities during and after fuel transfer operations through the life of the facility. Due to this limited scope of operational activity and the survey controls, it is anticipated that the CISF storage modules, storage pads, and the Cask Handling Building area will not be contaminated. The decommissioning cost estimate conservatively assumes that some contamination will exist at decommissioning.

Decommissioning is assumed to be performed by an independent contractor. Labor rates used in the estimate are based on 2015 industry labor rates. These rates were compiled from current Waste Control Specialists labor rates. Waste Control Specialists employs a wide range of people including: Laborers, Equipment Operators, Radiation Technicians (RT), Health Physicists, Engineers, Administrative Assistants, and other labor categories that are directly applicable to a decommissioning project. The cost estimate uses the direct labor rate with a multiplier of 2.5 applied to account for fringe benefits, indirect labor costs, and profit.

Additional cost estimate approach information can be found in the Preliminary Decommissioning Plan (Appendix B). The cost estimate development is located in the Decommissioning Funding Plan (Appendix D).

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 10 LICENSE APPLICATION Table 10 CISF Decommissioning Costs Task/Component Cost Planning and Preparation $444,300 Decontamination and/or Dismantling of Radioactive $489,000 Facility Components Packaging, Shipping, and Disposal of Radioactive $74,400 Wastes Restoration of Contaminated Areas on Facility $0 Grounds Final Radiation Survey $5,755,400 Site Stabilization and Long-Term Surveillance $0 Packing Materials Costs $61,805 Shipping Costs $11,160 Waste Disposal Costs $24,579 Equipment/Supply Costs $397,825 Laboratory Costs $915,408 Miscellaneous Costs $441,000 Contractor Overhead and Profit $1,500,000 SUBTOTAL $10,114,877 25% Contingency $2,528,719 TOTAL DECOMMISSIONING COST ESTIMATE $12,643,596 Page 10-3 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 11 LICENSE APPLICATION CHAPTER 11 EMERGENCY PLAN The Emergency Plan (EP) has been prepared to establish the procedures and practices for management control over unplanned or emergency events that may occur at the CISF, and to meet the requirements of 10 CFR 72.32(a).

The CISF EP considers and evaluates the consequences of credible events and emergencies hypothesized to occur at the CISF. The EP details the types of accidents, accident classification, notification requirements, protective response, organizational control, safe condition of reentry and recovery planning. The EP also describes the required training of emergency response personnel, maintenance of emergency preparedness and emergency response records and resources available at the CISF.

There is a single emergency classification level for events at the CISF, the Alert classification.

This is based on worst-case consequences of potential accidents at the CISF and the guidance of NUREG-1567, and is consistent with NUREG-1140, which concluded that the worst-case accident involving a CISF has insignificant consequences to the public health and safety.

The CISF EP has been shared with Andrews County and Lea County, the off-site authorities expected to respond to the site in the event of an accident, with local law enforcement, fire support and medical services and their comments have been addressed.

ISP as the licensee will have responsibility for all NRC emergency planning requirements. ISP will contract with Waste Control Specialists, as a member of the ISP joint venture and in coordination with existing emergency planning activities at the Waste Control Specialists site, to maintain the Emergency Plan and implement the Emergency Plan (under ISP's direction and oversight) in the event of an emergency at the WCS CISF.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 12 LICENSE APPLICATION CHAPTER 12 ENVIRONMENTAL REPORT The proposed site for the CISF is located in Andrews County, Texas, which is in the northwestern portion of the state, bordered on the north by Gaines County; on the east by Martin County; on the south by Winkler, Ector and Midland Counties; and on the west by the State of New Mexico (Lea County). The CISF will be located in the High Plains region, which is part of the Central Great Plains. Andrews County environments are typical of the much larger region of western Texas and adjacent areas of New Mexico. The terrain is gently rolling and is characterized by shallow washes, some of which are bordered by trees. Soil texture ranges from clay loam to fine sand. A few rocky outcrops are present approximately 1.5 miles west of the proposed CISF. Natural vegetation in the region consists primarily of low desert grassland with scattered shrubs and cacti. With few exceptions, the flora and fauna on and in the vicinity of the site consists of species that occur widely throughout the region. Most of the area is or was grazed.

The CISF site is situated within Andrews County, about 1.25 miles north of Texas Highway 176, and about 0.25 mile east of the Texas-New Mexico state boundary on Waste Control Specialists property. The Waste Control Specialists property consists of approximately 14,000 acres of land. Figure 12-1 depicts the site location and land use within a 5-mile radius surrounding the property. The nearest towns to the proposed disposal Site are Andrews, Texas located 32 miles east and the City of Eunice, New Mexico located approximately 6 miles west of the proposed facility. The nearest residence is situated approximately 3.8 miles west of the site. The portion of the Waste Control Specialists land on which the WCS CISF would be constructed and operated would be controlled by ISP through a long term lease from ISP joint venture member Waste Control Specialists.

Outside of the Waste Control Specialists footprint, industries include gravel and caliche mining, oil and gas production, landfill operations, cattle grazing and ranching. Louisiana Energy Services (LES) operates the National Enrichment Facility as URENCO, USA, about 1 mile southwest of the site, under license by the Nuclear Regulatory Commission. The majority of the land within five miles of the Site is used for grazing and ranching activities. Other businesses in proximity to the Waste Control Specialists property include Permian Basin Materials, Sundance, Inc., and DD Land farm located about one mile northwest and west of the proposed Page 12-1 Revision 3

INTERIM STORAGE PARTNERS LLC LA CHAPTER 12 LICENSE APPLICATION CISF. The remaining land in the vicinity of the proposed CISF is used for livestock grazing, oil and gas production or is unused land. No other significant business development within a 10-mile radius is identified at this time. The Lea County, New Mexico Landfill occupies approximately 40 acres and is located about 1.25 miles south southwest of the proposed CISF.

Subsurface petroleum product exploration and production have been conducted in the area of the Central Basin Platform for over 75 years. The local area has been heavily explored for oil and gas reserves over the last 35 years. Most of the oil wells in the vicinity of the CISF site have been abandoned or are in the process of secondary or tertiary recovery. The absence of oil wells on the site supports the absence of favorable conditions for oil production. Oil and gas wells are also located to the west in New Mexico.

The effects to the environment associated with the construction, operation, and decommissioning of the CISF have been evaluated and are documented in the CISF Environmental Report. These effects were found to be minimal due, among other things, to the passive design features of the canister-based storage system that has been selected for use at the CISF and the location of the facility. Radiation doses resulting from storage of spent nuclear fuel at the CISF to areas outside of the Restricted Area, Owner Controlled Area and nearest residence have been determined to be within 10 CFR 20 and 10 CFR 72 limits.

The Environmental Report, which is being submitted with this License Application, was prepared in accordance with the requirements of 10 CFR 72.34, Environmental Report. 10 CFR 72.34 requires applicants to submit, as part of the license application, an environmental report that satisfies the requirements in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, Subpart A, National Environmental Policy ActRegulations Implementing Section 102(2). Also used in preparation of the Environmental Report was Chapter 6 of NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, which was issued August 2003, and provides format and technical content information for the Environmental Report that is required by 10 CFR 72.34.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 12 LICENSE APPLICATION Figure 12-1 5-Mile Radius.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 13 LICENSE APPLICATION CHAPTER 13 PROPOSED LICENSE CONDITIONS The proposed license conditions for this license application are listed in Attachment A.

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INTERIM STORAGE PARTNERS LLC LA CHAPTER 13 LICENSE APPLICATION ATTACHMENT A PROPOSED LICENSE CONDITIONS Page A-1 Revision 3

NRC FORM 558 U.S. NUCLEAR REGULATORY COMMISSION (10-2000) 10 CFR 72 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.

This license is conditioned upon fulfilling the requirements of 10 CFR Part 72, as applicable, the attached Appendix A (Technical Specifications), and the conditions specified below Licensee

1. Interim Storage Partners LLC (ISP) 3. License No. SNM-1050 Amendment No. 0

2. WCS CISF 4. Expiration Date December XX, 20XX 9998 Highway 176 West Andrews, Texas, 79714 5. Docket or Reference No. 72-1050

6. Byproduct, Source, and/or 7. Chemical and/or Physical Form 8. Maximum Amount That Licensee May Special Nuclear Material Possess at Any One Time Under This License A. Spent nuclear fuel elements from A. Intact fuel assemblies, damaged fuel A. 5,000 MT of Uranium or Mixed-Oxide commercial nuclear utilities licensed assemblies, failed fuel and fuel debris, (MOX) in the form of intact spent fuel pursuant to 10 CFR Part 50 , including as allowed by Materials License SNM- assemblies, damaged fuel assemblies, those stored under either a Part 50 2510, Amendment 4; Table 1-1c or failed fuel assemblies, and fuel debris.

general license or Part 72 specific Table 1-1j of Certificate of Compliance In addition, the cumulative amount of license, and associated fuel assembly No. 1004, Amendments 3 through 13; material received and accepted during control components and associated Table 1-1t of Certificate of Compliance the licensed term of the facility may not radioactive materials related to the No. 1004, Amendments 10 through 13; exceed 5,000 Metric Tons of Uranium receipt, transfer, and storage of that Section 2.1 of Certificate of plus MOX.

spent nuclear fuel. Compliance No. 1029, Amendments 0, 1, and 3; Section B 2.1 of Certificate of Compliance No. 1025, Amendments 0 through 6; Section B 2.1.2 of Certificate of Compliance No. 1015, Amendments 0 through 5; Table B 2-1 of Certificate of Compliance No. 1031, Amendments 0 through 3 Revision 1, and 4 through 5, modified as described in Condition 9 below.

B. Greater than Class C Waste, reactor B. Greater than Class C Waste, as B. 231.3 MT (510,000 pounds) of Greater related material generated as a result activated and potentially surface than Class C Waste.

of plant operations and contaminated metals comprised of decommissioning where radionuclide miscellaneous solid waste resulting concentration limits of Class C waste in from segmentation and 10 CFR 61.55 are exceeded. decommissioning processes.

NRC FORM 558 U.S. NUCLEAR REGULATORY COMMISSION PAGE 2 of 3 PAGES (10-2000) 10 CFR 72 License No. Amendment No.

LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR SNM-1050 0 FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Docket or Reference No.

SUPPLEMENTARY SHEET 72-1050

9. Authorized Use: The material identified in 6.A, 6.B, 7.A and 7.B above is authorized for receipt, possession, storage, and transfer at the WCS Consolidated Interim Storage Facility (WCS CISF),

as described in the WCS CISF Final Safety Analysis Report (FSAR) as updated. Storage of fuel is authorized only in canisters referenced in Section 2.1 of the Attachment, Appendix A Technical Specifications and all fuel with assembly average burnup greater than 45 GWd/MTHM shall be canned inside the canister.

10. Authorized Place of Use: The licensed material is to be received, possessed, transferred, and stored at the WCS CISF, geographically located within Andrews County, Texas.

11. The Technical Specifications contained in the Appendix attached hereto are incorporated into the license. The Licensee shall operate the installation in accordance with the Technical Specifications in the Appendix.

12. Reserved.

13. Reserved.

14. Reserved.

15. Reserved.

16. The Licensee shall:

(1) follow the Physical Protection Plan entitled, WCS Consolidated Interim Storage Facility (CISF) Physical Security Plan, Revision 5, dated September 18, 2019, as it may be further amended under the provisions of 10 CFR 72.44(e) and 72.84(d);

(2) follow the Safeguards Contingency Plan entitled, "WCS Consolidated Interim Storage Facility (CISF) Training and Qualification Plan Appendix B to the CISF Physical Security Plan," Revision 5, dated September 18, 2019, as it may be further amended under the provisions of 10 CFR 72.44(e) and 72.84(d);

(3) follow the Guard Training and Qualification Plan entitled "WCS Consolidated Interim Storage Facility (CISF) Safeguards Contingency Plan Appendix C to the CISF Physical Security Plan," Revision 5, dated September 18, 2019, as it may be further amended under the provisions of 10 CFR 72.44(e) and 72.84(d);

(4) follow the Additional Security Measures for the Physical Protection of Dry Independent Spent Fuel Storage Installations; and (5) follow the Additional Security Measures for Access Authorization and Fingerprinting at Independent Spent Fuel Storage Installations.

17. Construction of the WCS CISF shall not commence before funding (equity, revenue, and debt) is fully committed, that is adequate to construct a facility with the initial capacity as specified by the Licensee to the NRC. Construction of any additional capacity beyond the initial capacity amount shall commence only after funding is fully committed that is adequate to construct such additional capacity.

18. The Licensee shall:

(1) include in the contracts provisions requiring clients to retain title to the material identified in 6.A, 6.B, 7.A or 7.B, and allocating legal and financial liability among the Licensee and the client(s);

(2) include in the contracts provisions requiring clients to periodically provide credit information, and, when necessary, additional financial assurances such as guarantees, prepayment, or payment bond(s);

(3) include in the contracts a provision requiring the Licensee not to terminate the license prior to furnishing storage services covered by the contract.

NRC FORM 558 U.S. NUCLEAR REGULATORY COMMISSION PAGE 3 of 3 PAGES (10-2000) 10 CFR 72 License No. Amendment No.

LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR SNM-1050 0 FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Docket or Reference No.

SUPPLEMENTARY SHEET 72-1050

19. The Licensee shall obtain onsite and offsite insurance coverage in the amounts committed to by ISP in the ISP license application.

20. The Licensee shall submit License Amendment(s) to this license containing 10 CFR 72.42 compliant AMPs and TLAAs based on License Renewals of the following CoCs listed below, within 120 days of the effective date of CoC Approval for each of the following:

AMP for NAC Systems The Licensee shall commit to the AMPs committed to in the approved CoC Renewal of CoC 1015 AND 1025 AND 1031 for all applicable NAC Spent Fuel Canisters and storage overpacks.

In the event that the current CoC holder for CoC 1015 and/or 1025 and/or 1031 does not submit a timely renewal as defined in 10 CFR Part 72.240, ISP shall submit a license amendment with AMP and TLAA information within one (1) year following the timely renewal deadline defined in 10 CFR 72.240 (b), for the applicable CoC.

21. The Licensee shall submit a Startup Plan to the NRC at least 90 days prior to receipt and storage of the material identified in 6.A, 6.B, 7.A or 7.B at the facility.

22. Reserved.

23. Prior to commencement of operations, the Licensee shall have an executed contract with the U.S. Department of Energy (DOE) or other SNF Title Holder(s) stipulating that the DOE or the other SNF Title Holder(s) is/are responsible for funding operations required for storing the material identified in 6.A, 6.B, 7.A or 7.B at the CISF as licensed by the U.S. Nuclear Regulatory Commission.

24. Prior to receipt of the material identified in 6.A, 6.B, 7.A or 7.B, the Licensee shall have a financial assurance instrument required pursuant to 10 CFR 72.30 acceptable to the U.S.

Nuclear Regulatory Commission.

25. This license is effective as of the date of issuance shown below.

FOR THE NUCLEAR REGULATORY COMMISSION John McKirgan, Chief Spent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Date of Issuance December XX, 20XX Attachments: Appendix A -WCS Interim Storage Facility Technical Specifications

INTERIM STORAGE PARTNERS LLC LA APPENDIX A PROPOSED TECHNICAL SPECIFICATIONS APPENDIX A PROPOSED TECHNICAL SPECIFICATIONS Revision 3

PROPOSED MATERIALS LICENSE No. SNM-1050 APPENDIX A WCS CONSOLIDATED INTERIM STORAGE FACILITY TECHNICAL SPECIFICATIONS Docket 72-1050 Amendment 0

TABLE OF CONTENTS PAGE 1.0 Use and Application ................................................................................................1-1 1.1 Definitions .................................................................................................. 1-1 1.2 Logical Connectors .................................................................................... 1-5 1.3 Completion Times ...................................................................................... 1-7 1.4 Frequency ................................................................................................ 1-10 2.0 Functional and Operating Limits .............................................................................2-1 2.1 Functional and Operating Limits ................................................................. 2-1 2.2 Functional and Operating Limits Violations................................................. 2-2 3.0 Limiting Condition for Operation (LCO) and Surveillance Requirement (SR)

Applicability.............................................................................................................3-1 3.1 Radiation Protection ................................................................................... 3-3 3.1.1 SHIPPING/TRANSFER CASK Exterior Surface Contamination .......3-3 3.2 NAC-MPC SYSTEM Integrity ..................................................................... 3-5 3.2.1 CANISTER Maximum Time in the TRANSFER CASK .....................3-5 3.2.2 VCC Heat Removal System.............................................................3-6 3.3 NAC-UMS SYSTEM Integrity ................................................................... 3-8 3.3.1 CANISTER Maximum Time in the TRANSFER CASK .....................3-8 3.3.2 VCC Heat Removal System.............................................................3-9 3.4 MAGNASTOR SYSTEM Integrity ............................................................. 3-11 3.4.1 CANISTER Maximum Time in the TRANSFER CASK ...................3-11 3.4.2 VCC Heat Removal System...........................................................3-13 4.0 Design Features .....................................................................................................4-1 4.1 Site............................................................................................................. 4-1 4.2 Storage System Features........................................................................... 4-1 4.2.1 Storage Systems .............................................................................4-1 4.2.2 Storage Capacity .............................................................................4-1 4.3 Storage Area Design Features ................................................................... 4-2 4.3.1 Storage Configuration ......................................................................4-2 4.3.2 Concrete Storage Pad Properties to Limit CANISTER Gravitational Loadings Due to Postulated Drops ............................4-2 4.4 Cask Receipt and CTS ............................................................................... 4-2 4.4.1 Lifting ...............................................................................................4-2 4.4.2 Post-transportation Verification ........................................................4-3 4.5 Design Basis Site Specific Parameters and Analyses ................................ 4-4 5.0 Administrative Controls ...........................................................................................5-1 5.1 Programs ................................................................................................... 5-1 5.1.1 Radiological Environmental Monitoring Program .............................5-1 5.1.2 Radiation Protection Program ..........................................................5-1 5.1.3 HSM Thermal Monitoring Program ..................................................5-2 5.1.4 Corrective Action Program ...............................................................5-2 5.2 Lifting Controls ........................................................................................... 5-3 5.2.1 Lifting Height and Temperature Limits .............................................5-3 5.2.2 Cask Drop .......................................................................................5-3 5.3 Concrete Testing ........................................................................................ 5-4 WCS Consolidated Interim Storage Facility Technical Specifications ii

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 Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

CANISTER CANISTERs are the sealed used nuclear fuel containers that consist of a fuel basket contained in a cylindrical shell, which is a welded pressure vessel that provides confinement of used fuel assemblies in an inert atmosphere or a cylindrical shell containing GTCC waste.

CANISTER TRANSFER SYSTEM The CTS is a structure designed for the transfer of a (CTS) CANISTER from or to the TRANSPORTATION CASK to or from a VCC.

CASK HANDLING BUILDING (CHB) The CASK HANDLING BUILDING (CHB) CRANES CRANES are minimum 130 ton overhead cranes used with special lifting devices as a single-failure-proof handling system to upright and transfer vertical TRANSPORTATION CASKS between the railcar and a laydown area permitting cask movement using the VCT. The CHB CRANES also support STC transfer and receipt inspection and shipment preparation for both TRANSPORTATION CASKS and STCs.

HORIZONTAL An HSM (Standardized HSM, AHSM or other models STORAGE MODULE (HSM) enveloped by these designs) is a reinforced concrete structure for storage of a CANISTER at a used fuel storage installation (e.g., Standardized HSM includes the HSM Model 80 and Model 102 as described in the SAR.)

WCS CONSOLIDATED INTERIM The WCS CISF is a complex designed and STORAGE FACILITY (CISF) constructed for the interim storage of canisterized used nuclear fuel and other canisterized radioactive materials associated with used fuel. The canisterized material is stored within HSMs or VCCs.

(continued)

WCS Interim Storage Facility Technical Specifications 1-1

Definitions 1.1 1.1 Definitions (continued)

LOADING OPERATIONS LOADING OPERATIONS for NUHOMS Systems (for NUHOMS Systems) include all licensed activities associated with the horizontal raising or lowering of the CANISTER and STC from the transport conveyance to the transfer vehicle.

LOADING OPERATIONS begin when the Impact Limiters are removed from the STC and end when the STC is ready for TRANSFER OPERATIONS.

LOADING OPERATIONS LOADING OPERATIONS for Vertical Systems include (for Vertical Systems) all licensed activities associated with the VCT lifting the TRANSPORTATION CASK from the transport conveyance and placing in/under the CTS. LOADING OPERATIONS begin when the Impact Limiters are removed from the TRANSPORTATION CASK and end when the TRANSPORTATION CASK is ready for TRANSFER OPERATIONS.

OPERABLE An OPERABLE VCC heat removal system transfers sufficient heat away from the fuel assemblies such that the fuel cladding, CANISTER component and CONCRETE CASK temperatures do not exceed applicable limits.

SHIPPING/TRANSFER CASK A 10 CFR Part 71 licensed TRANSPORTATION CASK (STC) that is also licensed under 10 CFR Part 72 as a Transfer Cask will be used to transport the CANISTER to the WCS CISF and will be placed on a transfer vehicle for movement of a CANISTER to the HSM. (NUHOMS Systems)

STORAGE OPERATIONS STORAGE OPERATIONS include all licensed activities that are performed at the WCS CISF, while a CANISTER is located in an HSM or VCC on the storage pad within the WCS CISF perimeter. STORAGE OPERATIONS do not include CANISTER transfer between the STC and the HSM or transfer of the VCC between the CTS and storage pad.

TRANSFER CASK TRANSFER CASK is a shielded device designed to hold the CANISTER during LOADING OPERATIONS, and UNLOADING OPERATIONS for the Vertical Systems.

(continued)

WCS Interim Storage Facility Technical Specifications 1-2

Definitions 1.1 1.1 Definitions (continued)

TRANSFER OPERATIONS TRANSFER OPERATIONS for NUHOMS Systems (NUHOMS Systems) include all licensed activities involving the movement of an STC loaded with a loaded CANISTER. TRANSFER OPERATIONS begin when the STC has been placed horizontal on the transfer vehicle ready for TRANSFER OPERATIONS and end when the CANISTER is located in an HSM on the storage pad within the WCS CISF perimeter. TRANSFER OPERATIONS include CANISTER transfer between the STC and the HSM.

TRANSFER OPERATIONS TRANSFER OPERATIONS for Vertical Systems include (Vertical Systems) all licensed activities involved in using a TRANSFER CASK to move a loaded and sealed CANISTER.

TRANSPORT OPERATIONS TRANSPORT OPERATIONS for Vertical Systems (Vertical Systems) include all licensed activities performed on a loaded VERTICAL CONCRETE CASK when it is being moved to and from its designated location on the storage pad.

TRANSPORT OPERATIONS begin when the loaded VERTICAL CONCRETE CASK is placed on or lifted by a VCT and end when the CONCRETE CASK is set down in its storage position on the storage pad.

TRANSPORTATION CASK A 10 CFR Part 71 licensed TRANSPORTATION CASK used to transport CANISTERS for the Vertical Systems.

UNLOADING OPERATIONS UNLOADING OPERATIONS for NUHOMS Systems (NUHOMS Systems) include all licensed activities on a CANISTER to ready it for shipment off-site. UNLOADING OPERATIONS begin when the CANISTER and STC is removed from the transfer vehicle and end when the CANISTER and STC is loaded on the transport conveyance and is being prepared for transport.

UNLOADING OPERATIONS UNLOADING OPERATIONS for Vertical Systems (Vertical Systems) include all licensed activities on a CANISTER to ready it for shipment off-site. UNLOADING OPERATIONS begin when the CANISTER is placed in the TRANSPORTATION CASK and end when the CANISTER and TRANSPORTATION CASK is loaded on the transport conveyance and is being prepared for transport.

(continued)

WCS Interim Storage Facility Technical Specifications 1-3

Definitions 1.1 1.1 Definitions (continued)

VERTICAL CONCRETE CASK VERTICAL CONCRETE CASK is the cask that receives (VCC) and holds a sealed CANISTER. It provides the gamma and neutron shielding and convective cooling of the spent fuel confined in the CANISTER.

VERTICAL CANISTER The VCT is used to move the TRANSPORTATION TRANSPORTER (VCT) CASK within the cask handling building to or from the CTS. The VCT is also used to move the loaded VCC for TRANSPORT OPERATIONS.

WCS Interim Storage Facility Technical Specifications 1-4

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:

EXAMPLE 1.2-1 ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO (Limiting A.1 Verify Condition for AND Operation) not met.

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.

(continued)

WCS Interim Storage Facility Technical Specifications 1-5

Logical Connectors 1.2 1.2 Logical Connectors (continued)

EXAMPLES EXAMPLE 1.2-2 (continued)

ACTIONS:

COMPLETION CONDITION REQUIRED ACTION TIME A. LCO not met. A.1 Stop OR A.2 A.2.1 Verify AND A.2.2 A.2.2.1 Reduce OR A.2.2.2 Perform OR A.3 Remove This example represents a more complicated use of logical connectors.

Required Actions A.1, A.2, and A.3 are alternative choices, only one 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 indented 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.

WCS Interim Storage Facility Technical Specifications 1-6

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 the lowest functional capability or performance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically describe the ways in which the requirements of the LCO are not met. Specified with each stated Condition are Required Action(s) and Completion Times(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., equipment or variable not within limits) that requires entering an ACTIONS Condition unless otherwise specified, providing the facility 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 facility is not within the LCO Applicability.

Once a Condition has been entered, subsequent subsystems, components, or variables expressed in the Condition, discovered to be 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.

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 B.1 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated B.1 Completion AND Time not met.

B.2 Perform Action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2 (continued)

WCS Interim Storage Facility Technical Specifications 1-7

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES Condition B has two Required Actions. Each Required Action has its own (continued) 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND complete action B.2 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . A total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is allowed for completing action B.1 and a total of 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months (not 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months ) is allowed for completing action B.2 from the time that Condition B was entered. If action B.1 is completed within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the time allowed for completing action B.2 is the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months because the total time allowed for completing action B.2 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

EXAMPLES EXAMPLE 1.3-2 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One system not A.1 Restore system 7 days within limit. to within limit.

B. Required Action B.1 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and associated B.1.

Completion Time AND not met.

B.2 Perform Action 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months B.2.

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.

(continued)

WCS Interim Storage Facility Technical Specifications 1-8

Completion Times 1.3 1.3 Completion Times (continued)

EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS

NOTE----------------------------------------------

Separate Condition entry is allowed for each component.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met. A.1 Restore 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months compliance with LCO.

B. Required Action B.1 Perform Action 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and associated B.1.

Completion Time AND not met.

B.2 Perform Action 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months B.2.

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.

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

TIME WCS Interim Storage Facility Technical Specifications 1-9

Frequency 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, Limiting Condition for Operation (LCO) and 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.

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 a SR satisfied, SR 3.0.4 imposes no restriction.

(continued)

WCS Interim Storage Facility Technical Specifications 1-10

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES The following examples illustrate the various ways that Frequencies are specified:

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify pressure within limit. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) 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 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the stated 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 determined to not meet the LCO, a variable is outside specified limits, or the unit 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, the LCO is not met in accordance with SR 3.0.1.

If the interval as specified by SR 3.0.2 is exceeded while the facility is 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.

(continued)

WCS Interim Storage Facility Technical Specifications 1-11

Frequency 1.4 1.4 Frequency (continued)

EXAMPLES EXAMPLE 1.4-2 (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Verify flow is within limits. Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to starting activity AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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 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 25% 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" performance 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.

WCS Interim Storage Facility Technical Specifications 1-12

Functional and Operating Limits 2.1 2.0 FUNCTIONAL AND OPERATING LIMITS 2.1 Functional and Operating Limits Subject to the limitation of the last sentence of Condition 9 of this license SNM-1050, the used nuclear fuel and GTCC Waste to be stored in an HSM or VCC at the WCS CISF shall meet the Approved Contents requirements of one of the following:

2.1.1 NRC Materials License SNM-2510, Amendment 4.

2.1.2 Table 1-1c or Table 1-1j (NUHOMS 61BT DSC) of Certificate of Compliance 1004 Appendix A Technical Specifications For The Standardized NUHOMS Horizontal Modular Storage System, including Amendments 3 through 13 inclusive.

2.1.3 Table 1-1t (NUHOMS 61BTH DSC) of Certificate of Compliance 1004 Appendix A Technical Specifications For The Standardized NUHOMS Horizontal Modular Storage System, including Amendments 10 through 13 inclusive.

2.1.4 Section 2.1 (NUHOMS 24PT1) of Certificate of Compliance 1029 Appendix A Technical Specifications For The Standardized Advanced NUHOMS System Operating Controls And Limits, including Amendments 0, 1, and 3.

2.1.5 Section B 2.1 (NAC-MPC System) of Certificate of Compliance 1025 Appendix B Technical Specification For The NAC-MPC System Approved Contents and Design Features, including Amendments 0 through 6.

2.1.6 Section B 2.1.2, Maine Yankee SITE SPECIFIC FUEL Preferential Loading, (NAC-UMS System) of Certificate of Compliance 1015 Appendix B Technical Specification For The NAC-UMS System Approved Contents and Design Features, including Amendments 0 through 5.

2.1.7 Table B.2-1, PWR Fuel, (MAGNASTOR System) of Certificate of Compliance 1031 Appendix B Technical Specification For The MAGNASTOR System Approved Contents, including Amendments 0 through 3, Revision 1, and Amendments 4 and 5.

WCS Interim Storage Facility Technical Specifications 2-1

Functional and Operating Limits Violations 2.2 2.0 FUNCTIONAL AND OPERATING LIMITS 2.2 Functional and Operating Limits Violations If any Functional and Operating Limit of 2.1 is violated, the following actions shall be completed:

2.2.1 The affected CANISTER shall be placed in a safe condition.

2.2.2 Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months of discovering the event, notify the NRC Operations Center of the violation.

2.2.3 Within 60 days, submit a special report which describes the cause of the violation and the actions taken to restore compliance and prevent recurrence.

WCS Interim Storage Facility Technical Specifications 2-2

LCO and SR Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) AND SURVEILLANCE REQUIREMENT (SR) APPLICABILITY LIMITING CONDITION FOR OPERATION 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 a spent fuel storage cask.

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.

Exceptions to this Specification are stated in the individual Specifications.

These exceptions allow entry into specified conditions in the Applicability when the associated ACTIONS to be entered allow operation in the specified condition in the Applicability only for a limited period of time.

LCO 3.0.5 Equipment removed from service or not in service in compliance with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate it meets the LCO or that other equipment meets the LCO. 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 that the LCO is met.

LCO 3.0.6 Not applicable to a spent fuel storage cask.

LCO 3.0.7 Not applicable to a spent fuel storage cask.

(continued)

WCS Interim Storage Facility Technical Specifications 3-1

LCO and SR Applicability 3.0 SURVEILLANCE REQUIREMENTS SR 3.0.1 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.

SR 3.0.2 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.

SR 3.0.3 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 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 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.

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.

WCS Interim Storage Facility Technical Specifications 3-2

Radiation Protection 3.1 3.0 Limiting Condition For Operation (continued) 3.1 Radiation Protection 3.1.1 SHIPPING/TRANSFER CASK Exterior Surface Contamination LCO 3.1.1 Removable surface contamination on the STC shall not exceed:

a. 2,200 dpm/100 cm2 from beta and gamma sources; and

b. 220 dpm/100 cm2 from alpha sources.

APPLICABILITY: During LOADING OPERATIONS (NUHOMS Systems)

ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each STC.

CONDITION REQUIRED ACTION COMPLETION TIME A. SHIPPING/TRANSFER A.1 Decontaminate the 7 days CASK removable surface SHIPPING/TRANSFER AND contamination limits not met. CASK to bring the removable Prior to TRANSFER contamination to within OPERATIONS limits WCS Interim Storage Facility Technical Specifications 3-3

Radiation Protection 3.1 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify by either direct or indirect methods Once, prior to TRANSFER that the removable contamination on the OPERATIONS.

exterior surfaces of the SHIPPING/TRANSFER CASK is within limits.

WCS Interim Storage Facility Technical Specifications 3-4

System Integrity 3.2 3.2 NAC-MPC SYSTEM Integrity 3.2.1 CANISTER Maximum Time in the TRANSFER CASK LCO 3.2.1 The CANISTER shall be transferred from the TRANSFER CASK to a VCC, or to a TRANSPORTATION CASK.

APPLICABILITY: During TRANSFER OPERATIONS and prior to TRANSPORT OPERATIONS (NAC MPC Systems)

ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER transfer not A.1 Complete CANISTER 25 days completed. TRANSFER OPERATIONS B. Required Action and B.1 Return CANISTER to 5 days associated completion TRANSPORTATION time not met CASK or VCC SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.1.1 Verify CANISTER transfer completed Once within 25 days.

WCS Interim Storage Facility Technical Specifications 3-5

System Integrity 3.2 3.2 NAC-MPC SYSTEM Integrity 3.2.2 VCC Heat Removal System LCO 3.2.2 The VCC Heat Removal System shall be OPERABLE. The VCC heat removal system is considered OPERABLE if the difference between the WCS CISF ambient temperature and the average outlet air temperature is 92°F for the YANKEE-MPC and for the MPC-LACBWR; or 110°F for the CY-MPC, or if all four air inlet and outlet screens are visually verified to be unobstructed. Failing this, a VCC heat removal system may be declared OPERABLE if an engineering evaluation determines the VCC has adequate heat transfer capabilities to assure continued spent nuclear fuel, CANISTER and VCC integrity.

APPLICABILITY: During STORAGE OPERATIONS (NAC MPC Systems)

ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each NAC-MPC SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met A.1 Restore VCC Heat 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Removal System to OPERABLE status B. Required Action A.1 and B.1 Perform SR 3.2.2.1 Immediately and every 6 associated completion hours thereafter time not met AND B.2.1 Perform an 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months engineering evaluation to determine that the VCC Heat Removal System is OPERABLE OR B.2.2 Place the NAC-MPC 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SYSTEM in a safe condition WCS Interim Storage Facility Technical Specifications 3-6

System Integrity 3.2 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.2.1 Verify the difference between the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average VCC air outlet temperature and WCS CISF ambient temperature is 92°F for the YANKEE-MPC CANISTER and the MPC-LACBWR CANISTER or 110°F for the CY-MPC CANISTER OR Visually verify all four air inlet and outlet 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

screens are unobstructed WCS Interim Storage Facility Technical Specifications 3-7

System Integrity 3.3 3.3 NAC-UMS SYSTEM Integrity 3.3.1 CANISTER Maximum Time in the TRANSFER CASK LCO 3.3.1 The CANISTER shall be transferred from the TRANSFER CASK to a VCC, or to a TRANSPORTATION CASK.

APPLICABILITY: During TRANSFER OPERATIONS and prior to TRANSPORT OPERATIONS (NAC UMS Systems)

ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. 600 hour0.00694 days 0.167 hours 9.920635e-4 weeks 2.283e-4 months cumulative A.1 Load CANISTER into 5 days time limit not met VCC OR A.2 Load CANISTER into 5 days TRANSPORTATION CASK SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.1.1 Monitor elapsed time for compliance with As required to meet the time limit.

LCO 3.3.1 WCS Interim Storage Facility Technical Specifications 3-8

System Integrity 3.3 3.3 NAC-UMS SYSTEM Integrity 3.3.2 VCC Heat Removal System LCO 3.3.2 The VCC Heat Removal System shall be OPERABLE. The VCC heat removal system is considered OPERABLE if the difference between the ISFSI ambient temperature and the average outlet air temperature is 102°F for the PWR CANISTER, or if all four air inlet and outlet screens are visually verified to be unobstructed. Failing this, a VCC heat removal system may be declared OPERABLE if an engineering evaluation determines the VCC has adequate heat transfer capabilities to assure continued spent nuclear fuel and CANISTER integrity.

APPLICABILITY: During STORAGE OPERATIONS (NAC UMS Systems)

ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each NAC-UMS SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met A.1 Ensure adequate Immediately heat removal to prevent exceeding short-term temperature limits AND A.2 Restore VCC Heat 25 days Removal System to OPERABLE status B. Required Action A.1 or B.1 Perform an 5 days A.2 and associated engineering completion time not met evaluation to determine that the VCC Heat Removal System is OPERABLE OR B.2 Place the NAC-UMS 5 days SYSTEM in a safe condition WCS Interim Storage Facility Technical Specifications 3-9

System Integrity 3.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.2.1 Verify the difference between the WCS 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CISF ambient temperature and the average outlet air outlet temperature is 102°F for the PWR CANISTER OR Visually verify all four air inlet and outlet 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

screens are unobstructed SR 3.3.2.2 Verify the difference between the WCS Once between 5 and 30 days after CISF ambient temperature and the STORAGE OPERATIONS begin average outlet air outlet temperature is 102°F for the PWR CANISTER WCS Interim Storage Facility Technical Specifications 3-10

System Integrity 3.4 3.4 MAGNASTOR SYSTEM Integrity 3.4.1 CANISTER Maximum Time in the TRANSFER CASK LCO 3.4.1 The maximum time a CANISTER can remain in the MAGNASTOR TRANSFER CASK without the active cooling system running is shown below for the initial and subsequent transfer attempts. If the initial transfer attempt cannot be completed within the time limits shown in Table A, then subsequent transfer attempts shall comply with the time limits in Table B after the Required Actions in Condition A are met.

This time frame starts from the time a loaded MAGNATRAN TRANSPORTATION CASK is received and the MAGNATRAN TRANSPORTATION CASK is no longer in the horizontal orientation until the CANISTER is placed on the pedestal in a VCC. Likewise, this time frame also starts from the time a loaded CANISTER is lifted off the VCC pedestal until it is placed in the MAGNATRAN TRANSPORTATION CASK and the MAGNATRAN TRANSPORTATION CASK is placed in the horizontal orientation.

A. Initial Transfer Attempt Time Limits Total PWR Heat Load (kW) Maximum CANISTER Transfer Time (hours) 23 41 B. Subsequent Transfer Attempt Time Limits Total PWR Heat Load (kW) Maximum CANISTER Transfer Time (hours) 23 31 APPLICABILITY: During LOADING OPERATIONS, TRANSFER OPERATIONS or UNLOADING OPERATIONS (NAC MAGNASTOR Systems)

WCS Interim Storage Facility Technical Specifications 3-11

System Integrity 3.4 3.4.1 CANISTER Maximum Time in the TRANSFER CASK ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. CANISTER transfer time A.1 Return the loaded Immediately limit not met. CANISTER to the MAGNASTOR TRANSFER CASK AND A.2 Initiate the Immediately MAGNASTOR TRANSFER CASK active cooling system.

AND A.3 Maintain the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months MAGNASTOR TRANSFER CASK active cooling system for a minimum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.1.1 Monitor elapsed time that a loaded Continuous during TRANSFER CANISTER is not sitting on a VCC OPERATIONS and prior to pedestal or in a MAGNATRAN TRANSPORT OPERATIONS.

TRANSPORTATION CASK that is not in the horizontal orientation and while the MAGNASTOR TRANSFER CASK active cooling system is not in operation.

WCS Interim Storage Facility Technical Specifications 3-12

System Integrity 3.4 3.4 MAGNASTOR SYSTEM Integrity 3.4.2 VCC Heat Removal System LCO 3.4.2 The VCC Heat Removal System shall be OPERABLE.

APPLICABILITY: During STORAGE OPERATIONS (MAGNASTOR Systems)

ACTIONS:

NOTE ---------------------------------------------------------------

Separate condition entry is allowed for each MAGNASTOR SYSTEM.

CONDITION REQUIRED ACTION COMPLETION TIME A. VCC Heat Removal A.1 Ensure adequate Immediately System inoperable heat removal to prevent exceeding short-term temperature limits AND A.2 Restore VCC Heat 30 days Removal System to OPERABLE status SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.2.1 Verify the difference between the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months average VCC air outlet temperature and the WCS CISF ambient temperature indicates that the VCC Heat Removal System is operable in accordance with the MAGNASTOR thermal evaluation.

OR Visually verify all VCC air inlet and outlet 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

screens are free of blockage WCS Interim Storage Facility Technical Specifications 3-13

Design Features 4.0 4.0 DESIGN FEATURES The specifications in this section include the design characteristics of special importance to each of the physical barriers and to the maintenance of safety margins in the WCS CISF design.

4.1 Site The WCS CISF is located approximately 30 miles west of the City of Andrews, Texas, and five miles east of the City of Eunice, New Mexico. The WCS CISF is located approximately one-half mile east of the Texas-New Mexico boundary and approximately one mile north of Texas State Highway 176.

4.2 Storage System Features 4.2.1 Storage Systems The WCS CISF is licensed to store spent fuel and GTCC waste in various NUHOMS System HSMs. Each CANISTER shall be loaded at a 10 CFR Part 50 licensees facility in accordance with one of the following 10 CFR Part 72 Materials License or Certificates of Compliance (CoC):

SNM-2510, or CoC No. 1004, or CoC No. 1029 and shipped to the WCS CISF in a 10 CFR Part 71 certified shipping package (the STC).

The CANISTER shall be transferred directly from the STC to the HSM at the Storage Pad.

In addition, the WCS CISF is licensed to store spent fuel and GTCC waste in various NAC VCCs, which include VCCs for the NAC-MPC, NAC-UMS, and MAGNASTOR. Each CANISTER shall be loaded at a 10 CFR Part 50 licensees facility in accordance with one of the following 10 CFR Part 72 Certificates of Compliance (CoC):

CoC No. 1025, or CoC No. 1015, or CoC No. 1031 and shipped to the WCS CISF in a 10 CFR Part 71 certified TRANSPORTATION CASK.

The CANISTER shall be transferred from the TRANSPORTATION CASK to the VCC with the CTS and the VCC and CANISTER will be transferred from the CTS to the Storage Pad with the VCT.

4.2.2 Storage Capacity The total storage capacity of the WCS CISF is limited to the material defined in Conditions 8A and 8B of the license. This total capacity of spent fuel assemblies is in the form of intact fuel assemblies, damaged fuel assemblies, failed fuel assemblies and fuel debris, as defined in SNM-2510; CoC No. 1004; CoC No. 1029, CoC No. 1025, CoC No. 1015, and CoC No. 1031.

(continued)

WCS Interim Storage Facility Technical Specifications 4-1

Design Features 4.0 4.0 Design Features (continued) 4.3 Storage Area Design Features The following storage location design features and parameters shall be implemented at the WCS CISF.

4.3.1 Storage Configuration HSMs are placed together in single rows or back-to-back arrays. An end shield wall is placed on the outside end of any loaded outside HSM. A rear shield wall is placed on the rear of any single row loaded HSM.

The VCCs for NAC-MPC, NAC-UMS, and MAGNASTOR Systems shall meet the minimum center-to-center spacing requirements presented in the SAR.

4.3.2 Concrete Storage Pad Properties to Limit CANISTER Gravitational Loadings Due to Postulated Drops The STCs with NUHOMS CANISTERs have been evaluated for drops of up to 80 inches onto a reinforced concrete storage pad.

For concrete storage pads loaded with NAC-MPC, NAC-UMS, and/or MAGNASTOR VCC systems, the storage pad shall meet the concrete storage pad properties presented in CoC No. 1025, Section B 3.4, CoC No. 1015, Section B 3.4, and CoC No. 1031, Sections 4.3.1 and 5.4.

4.4 Cask Receipt and CTS 4.4.1 Lifting Vertical lifting of the STC with a NUHOMS CANISTER is not allowed. Horizontal lifting of the TRANSPORTATION CASK or TRANSFER CASK with an NAC-MPC, NAC-UMS or MAGNASTOR CANISTER is not allowed.

Lifting of a loaded TRANSPORTATION CASK, TRANSFER CASK, or VCC with an NAC-MPC, NAC-UMS or MAGNASTOR CANISTER shall be performed with the CHB CRANES, CTS, or VCT in accordance with the guidelines of NUREG-0612, Control of Heavy Loads at Nuclear Power Plants, July 1980. The lifting devices used with the CHB CRANES, CTS, and VCT shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with the guidelines of NUREG-0612 with the following clarifications.

The CTS shall be classified as a Type 1 crane in accordance with ASME NOG-1, 2015. Load Combinations and allowable stresses used in the CTS structural design shall be in accordance with ASME NOG-1. The CTS shall be designed, fabricated, operated, tested, inspected, and maintained in accordance with the guidelines of NUREG-0612. The specific applicable standard being applied to each primary gantry system component is as follows:

Hydraulic Locking Telescoping Boom Gantry Leg Assemblies on Self Propelled Dollies - ASME B30.1 Lift Beams (spanning the Telescoping Gantry Leg Assemblies) -

ASME NOG-1 for design, fabrication, and initial testing; ANSI N14.6 for testing, inspection, and maintenance WCS Interim Storage Facility Technical Specifications 4-2

Design Features 4.0 4.0 Design Features (continued)

Trolley Beam (spanning the Lift Beams & also mounted on Self Propelled Dollies) - ASME NOG-1 for design, fabrication, and initial testing; ANSI N14.6 for testing, inspection, and maintenance Standard Lift Links - ASME B30.26 Standard Shackles - ASME B30.26 Standard Slings - ASME B30.9 Transfer Cask Lift Plates - ANSI N14.6 Air Operated Chain Hoist (suspended from Trolley Beam) - ASME NUM-1, Type 1-B for design, fabrication, and initial testing; ASME B30.16 for testing, inspection, and maintenance Canister Lift Adapter (which mates with canister) - ANSI N14.6 The VCT with TRANSPORTATION CASK lifting devices shall be designed, fabricated, operated, tested, inspected and maintained in accordance with the guidance of NUREG-0612, Section 5.1. The specific applicable standard being applied to each primary VCT is as follows:

Hydraulic Locking Telescoping Boom Assemblies - ASME B30.1 Lift Beam(s) (spanning the Telescoping Boom Assemblies) ANSI N14.6 Cask Lift Links - ANSI N14.6 The CHB CRANES with TRANSPORTATION CASK lifting devices shall be designed, fabricated, operated, tested, inspected and maintained in accordance with the guidance of NUREG-0612, Section 5.1. The specific applicable standard being applied to each crane is as follows:

Crane structure and main hoist system: ASME NOG-1, 2015 Type I for design, fabrication and initial testing; ASME B30.2 for operation, testing, inspection, and maintenance Cask Lifting Devices - ANSI N14.6 4.4.2 Post-transportation Verification The design and licensing basis analysis provides reasonable assurance of the confinement effectiveness of the canisters allowed for storage at the WCS CISF. The confinement boundary of each canister type authorized for storage at the WCS CISF is evaluated to demonstrate that the loads during normal conditions of transport (NCT) do not exceed ASME B&PV Subsection NB Article NB-3200 (level A allowable). In addition, a Post-Transportation Verification shall include (1) visual inspection on a minimum of two bounding canisters from each site of origin, and (2) helium leak test on all canisters shipped to the WCS CISF.

Criteria used to screen and select the two bounding canisters from each reactor site are based on the canister susceptibility assessment criteria developed in the Electric Power Research Institute (EPRI) report, Susceptibility Assessment Criteria for Chloride-Induced Stress Corrosion Cracking (CISCC) of Welded Stainless Steel Canisters for Dry Cask Storage Systems (Report No.

3002005371).

WCS Interim Storage Facility Technical Specifications 4-3

Design Features 4.0 4.0 Design Features (continued)

Personnel performing visual examinations shall be qualified and certified in accordance with the American Society of Mechanical Engineers (ASME) Code Section XI, IWA 2300, Visual Examination, Personnel Qualification and the Responsible Individual, including the requirements of ASME XI, Appendix VI, Rounded Indications, latest edition.

Post transportation leakage testing shall comply with ANSI N 14.5 - 1997, American National Standard for Radioactive Materials - Leakage Tests on Package for Shipment.

Post transportation leakage testing shall be conducted in accordance with approved procedures by a Nondestructive Testing (NDT) Level III specialist or examiner.

Personnel performing post transport leak testing shall be certified as LT Level II, or LT Level III in accordance with the American Society for Nondestructive Testing (ASNT) Practice No. SNT-TC-1A, Personnel Qualification and Certification in Nondestructive Testing, up to the 2006 edition as permitted by the 2013 Code Edition.

4.5 Design Basis Site Specific Parameters and Analyses The potential for fire and explosion shall be addressed by limiting the amount of flammable liquids during LOADING OPERATIONS below the fire load limits for the respective systems in the SAR. This includes the condition that the fuel tank of the cask handling equipment used to move the loaded VCC onto or from the Storage Pads contains no more than 50 gallons of fuel and no more than 300 gallons for the NUHOMS Systems.

WCS Interim Storage Facility Technical Specifications 4-4

Administrative Controls 5.0 5.0 ADMINISTRATIVE CONTROLS 5.1 Programs Interim Storage Partners shall implement the following programs to ensure the safe operation and maintenance of the WCS CISF:

Radiological Environmental Monitoring Program (see 5.1.1 below)

Radiation Protection Program (see 5.1.2 below)

HSM Thermal Monitoring Program (see 5.1.3 below) 5.1.1 Radiological Environmental Monitoring Program

a. A radiological environmental monitoring program will be implemented to ensure that the annual dose equivalent to an individual located outside the WCS CISF controlled area does not exceed the annual dose limits specified in 10 CFR 72.104(a).

b. Operation of the WCS CISF will not create any radioactive materials or result in any credible liquid or gaseous effluent release.

5.1.2 Radiation Protection Program

a. The Radiation Protection Program will establish administrative controls to limit personnel exposure to As Low As Reasonably Achievable (ALARA) levels in accordance with 10 CFR Part 20 and Part 72.

b. Dosimetry will be used to monitor direct radiation around the WCS CISF.

c. In accordance with 10 CFR 72.44(d), a periodic report will be submitted specifying the quantity of each of the principal radionuclides released to the environment in liquid and gaseous effluents during the previous calendar year of operation.

(continued)

WCS Interim Storage Facility Technical Specifications 5-1

Administrative Controls 5.0 5.0 Administrative Controls (continued) 5.1.3 HSM Thermal Monitoring Program This program provides guidance for temperature measurements that are used to monitor the thermal performance of each HSM. The intent of the program is to prevent conditions that could lead to exceeding the concrete and fuel clad temperature criteria.

Each user must implement TS 5.1.3(a).

a. Daily Visual Inspection of HSM Inlets and Outlets (Front Wall and Roof Birdscreens)

The user shall develop and implement procedures to perform visual inspection of HSM inlets and outlets on a daily basis. There is a possibility that the HSM air inlet and outlet openings could become blocked by debris, as postulated and analyzed in the SAR accident analyses for air vent blockage. The procedures shall ensure that blockage will not exist for periods longer than assumed in the SAR analyses.

Perform a daily visual inspection of the air vents to ensure that HSM air vents are not blocked for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months . If visual inspection indicates blockage, clear air vents and replace or repair birdscreens if damaged. If the air vents are blocked or could have been blocked for more than 40 hours4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months , evaluate existing conditions in accordance with the site corrective action program to confirm that conditions adversely affecting the concrete or fuel cladding do not exist.

5.1.4 Corrective Action Program If a non-conforming canister is found during the receipt inspection, the canister shall be placed in a safe condition and a corrective action will be initiated in accordance with the licensees approved quality assurance program.

The corrective action shall address the regulatory requirements for reporting to the appropriate agency, including the deadlines for such notification and the appropriate licensing actions initiated to resolve the situation. The corrective actions shall include, but are not limited to the following:

Notify the NRC as required, conferring with the NRC as needed.

Maintain the canister inside the transportation cask in its transportation configuration until appropriate corrective actions are determined. The safety for temporary storage will be confirmed using Part 71 analysis as appropriate.

Develop an action plan with a time frame which will include input from the NRC discussion.

Obtain NRCs approvals as necessary.

Proceed with corrective actions.

The timeline by which a canister will be returned to the place of origin, or other facility licensed for canister operations, will depend on the specific corrective actions required to address the condition identified by the corrective action evaluation performed.

(continued)

WCS Interim Storage Facility Technical Specifications 5-2

Administrative Controls 5.0 5.0 Administrative Controls (continued) 5.2 Lifting Controls 5.2.1 Lifting Height and Temperature Limits The requirements of TS 4.4 apply to the CHB CRANES, VCT, and CTS and associated lifting devices. Confirm the surface temperature of the STC or TRANSPORTATION CASK is above 0 °F before beginning LOADING OPERATIONS and UNLOADING OPERATIONS The lifting height of a STC, TRANSPORTATION CASK with CANISTER, or TRANSFER CASK with CANISTER is limited as a function of low temperature and the type of lifting/handling device, as follows:

No lifts or handling of the STC or TRANSFER CASK with CANISTER at any height are permissible at STC or TRANSFER CASK surface temperatures below 0 °F.

The maximum lift height of the STC with CANISTER shall be 80 inches if the surface temperature of the SHIPPING/TRANSFER CASK is above 0 °F and a non-single failure proof lifting/handling device is used.

For vertical cask systems, LOADING OPERATIONS, TRANSFER OPERATIONS, and UNLOADING OPERATIONS shall be conducted using a single failure proof lifting/handling system.

No lift height restriction is imposed on the STC, TRANSPORTATION CASK with CANISTER, or TRANSFER CASK with CANISTER if the STC or TRANSFER CASK or TRANSPORTATION CASK surface temperature is higher than 0 °F and a single failure proof lifting/handling system is used.

The requirements of 10 CFR Part 72 apply when the STC with CANISTER is in a horizontal orientation on the transfer vehicle.

The VCC loaded with an NAC-MPC, NAC-UMS, or MAGNASTOR CANISTER is not permitted to be lifted greater than 6 inches, 24 inches, and 24 inches in the vertical direction, respectively, and shall be transported by the VCT.

5.2.2 Cask Drop Inspection Requirement The NUHOMS CANISTER will be inspected for damage after any STC with CANISTER side drop of 15 inches or greater.

Safety Analysis The analysis of bounding drop scenarios shows that the STC will maintain the structural integrity of the CANISTER confinement boundary from an analyzed side drop height of 80 inches. The 80-inch drop height envelopes the maximum height from the bottom of the STC when secured to the transfer vehicle while enroute to the HSM.

(continued)

WCS Interim Storage Facility Technical Specifications 5-3

Administrative Controls 5.0 5.0 Administrative Controls (continued)

Although analyses performed for cask drop accidents at various orientations indicate much greater resistance to damage, requiring the inspection of the CANISTER after a side drop of 15 inches or greater ensures that:

1. The CANISTER will continue to provide confinement.

2. The STC can continue to perform its design function regarding CANISTER transfer and shielding.

5.3 Concrete Testing HSM concrete shall be tested during the fabrication process for elevated temperatures to verify that there are no significant signs of spalling or cracking and that the concrete compressive strength is greater than that assumed in the structural analysis. Tests shall be performed at or above the calculated peak temperature and for a period no less than the 40 hour4.62963e-4 days 0.0111 hours 6.613757e-5 weeks 1.522e-5 months duration of HSM blocked vent transient for components exceeding 500 °F.

HSM concrete temperature testing shall be performed whenever:

There is a change in the supplier of the cement, or There is a change in the source of the aggregate, or The water-cement ratio changes by more than 0.04.

WCS Interim Storage Facility Technical Specifications 5-4

INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN APPENDIX B PRELIMINARY DECOMMISSIONING PLAN

INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN TABLE OF CONTENTS CHAPTER TITLE PAGE 1 INTRODUCTION 1-1 2 DECOMMISSIONING OBJECTIVE, ACTIVITIES 2-1 AND TASKS 2.1 Decommissioning Objective 2-1 2.2 Decommissioning Activities 2-1 2.3 Decommissioning Tasks 2-2 2.4 Decommissioning Organization 2-3 3 DECOMMISSIONING RECORDS 3-1 4 DECOMMISSIONING COST ESTIMATE 4-1 4.1 Summary 4-1 4.2 Background 4-1 4.3 CISF Description 4-1 4.4 Cost Estimate Approach 4-2 4.5 Contingency 4-3 5 DECOMMISSIONING FACILITATION 5-1 6 REFERENCES 6-1 Page i Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN CHAPTER 1 INTRODUCTION This Preliminary Decommissioning Plan has been developed to comply with the requirements of 10 CFR 72.30 and describes the proposed approach for decommissioning of the WCS Consolidated Interim Storage Facility (WCS CISF). The Final Decommissioning Plan containing specific information and details will be submitted to the NRC for review and approval prior to the commencement of decommissioning activities.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN CHAPTER 2 DECOMMISSIONING OBJECTIVE, ACTIVITIES, AND TASKS 2.1 DECOMMISSIONING OBJECTIVE The objective of decommissioning activities at the WCS CISF is to verify that any potential radioactive contamination is below established release limits, and in the unlikely event of contamination, to identify and remove radioactive contamination having activities above the NRC release limits, so that the site may be released for unrestricted use and the NRC license terminated.

2.2 DECOMMISSIONING ACTIVITIES A Final Decommissioning Plan detailing activities and procedures for decommissioning will be provided after the spent nuclear fuel and GTCC waste are removed from the facility. The facility is configured and will be operated as a clean facility. All components of the facility including the transport casks and storage canisters are designed to minimize the potential for any contamination. Continual radiological survey throughout the life of the facility will be performed to identify any possible contamination and to verify that the facility remains clean. The actual decommissioning activities presented in the Final Decommissioning Plan will depend on the operating history of the facility and the results of the initial characterization survey performed at the beginning of the decommissioning period. This preliminary plan will outline the planned approach to decommissioning.

As indicated previously, the WCS CISF will be operated as a clean facility. Residual radioactive contamination is not anticipated at the WCS CISF for several reasons:

Canisters are surveyed and decontaminated at the generator facility to ensure the outer surfaces are clean before shipment to the WCS CISF.

Canisters are welded shut and sealed to prevent leaks.

Canisters will not be opened during transport to the WCS CISF or during storage at the WCS CISF at any time.

Radiological activation of storage modules and pad materials is expected to be insignificant with radiation levels below the applicable NRC criteria for unrestricted release.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN The Final Decommissioning Plan will address final status survey of the site and termination of the license. The Final Decommissioning Plan will include detailed information on the following:

1. A current description of the existing conditions of the site including all facilities sufficient to evaluate the acceptability of the plan;

2. The choice of the alternative for decommissioning and a description of the activities involved including:

Organization and staffing Site Preparation Procedures for removal of systems and components Design activities Procurement Outside contractors Procedures for decontamination Procedures for radiological survey Schedule

3. A description of controls and limits on procedures and equipment to protect occupational and public health and safety;

4. A description of the planned final radiation survey;

5. An updated detailed cost estimate for the chosen alternative for decommissioning, a comparison of that estimate with present funds set aside for decommissioning, and a plan for assuring the availability of adequate funds for completion of the decommissioning including means for adjusting cost estimates and associated funding levels over any storage or surveillance period; and

6. A description of technical specifications and quality assurance provisions in place during decommissioning.

The final plan will evaluate NRC criteria for decommissioning to ensure all requirements are satisfied. Decommissioning activities will be planned using ALARA principles and in a manner that protects the public and environment during the process.

2.3 DECONTAMINATION TASKS Once all of the spent nuclear fuel canisters stored at the WCS CISF have been shipped off-site and the decommissioning period begins, characterization surveys will be performed to verify that the storage modules and the storage pads are free of contamination. It is anticipated that the storage modules and pads will not be contaminated and will be left in place or removed as determined by ISP. In the unlikely event the characterization surveys identify contamination Page 2-2 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN levels above the NRC limits for unrestricted release, conventional decontamination techniques will be used which minimize the volume of waste. Any waste generated will be sent to a licensed facility for disposal. For conservatism in Financial Assurance, ISP assumes some contamination will be present.

2.4 DECOMMISSIONING ORGANIZATION Successful planning and execution of the Decommissioning Plan will include utilizing individuals from the ISP organization. In addition to ISP staff, many of the decommissioning activities will be performed by contractors. The Final Decommissioning Plan will provide information on ISP staff organization, Contractor organization, and qualifications for working with radiological materials and health and safety issues. Work performed by contractors will be controlled under the NRC license for the WCS CISF.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN CHAPTER 3 DECOMMISSIONING RECORDS ISP will maintain records until the facility is released for unrestricted use. The records, in accordance with 10 CFR 72.30(f), will be used to plan final decommissioning efforts. The following records will be maintained:

Records of spills or un-planned occurrences involving the spread of radiation As-built drawings of structures, components and equipment used in the storage of radioactive materials Documentation containing a list of all areas designated at any time as a restricted area and all other areas involved in the spread of contamination Decommissioning cost estimates and the funding method used.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN CHAPTER 4 DECOMMISSIONING COST ESTIMATE 4.1

SUMMARY

The decommissioning cost estimate (Appendix D) is based on the guidance of NUREG-1757, Consolidated Decommissioning Guidance, and is developed on the basis that the WCS CISF will be constructed and operated under the requirements of 10 CFR 20.1406, Minimization of Contamination. This regulation requires that the applicant design and operate the facility to minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize, to the extent practicable, the generation of radioactive waste. As a temporary storage facility, waste containers will not be opened at the WCS CISF. Continual radiological surveillance during the operational period will ensure that any contamination is promptly discovered, identified and removed in a timely manner before the decommissioning period begins.

At the end of the storage period, all of the spent nuclear fuel located at the WCS CISF will be removed and shipped for final disposal in a geologic repository. Once the fuel and GTCC waste are removed and the CISF is no longer being used for its principal licensed purpose, ISP will prepare a Decommissioning Plan for review and approval by the NRC pursuant to the Timeliness Rule (10 CFR § 72.54).

4.2 BACKGROUND

10 CFR § 72.30, Financial assurance and recordkeeping for decommissioning, requires that each holder of, or applicant for, a license under this part must submit for NRC review and approval a Decommissioning Funding Plan that contains information on how reasonable assurance will be provided that adequate funds will be available to decommission the CISF.

The CISF decommissioning process will commence after the spent nuclear fuel is removed from the facility.

4.3 CISF DESCRIPTION The WCS CISF will utilize the NUHOMS storage system (TN Americas) along with the MAGNASTOR, NAC-UMS and NAC- MPC storage systems (NAC International). The CISF will have 450 storage modules placed on approximately 125,000 square feet of storage pad.

Page 4-1 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN 4.4 COST ESTIMATE APPROACH The decommissioning cost estimate (Appendix D) is based on the condition of the CISF after all of the spent nuclear fuel and GTCC waste have been removed from the site. No interior or exterior radioactive surface contamination is expected. During the lifetime of the facility, only sealed canisters will be accepted for storage. The facility does not open the canisters at any time and therefore does not perform any sampling or processing of waste. As a start-clean/stay-clean facility, the WCS CISF will operate in a manner that supports decommissioning activities throughout the life of the facility.

Radioactive surface contamination at the time of decommissioning will be minimized due to radiological survey and monitoring activities during and after fuel transfer operations through the life of the facility. Due to this limited scope of operational activity and the survey controls, it is anticipated that the CISF storage modules, storage pad, and the Cask Handling Building area will not be contaminated. The decommissioning cost estimate conservatively assumes that some contamination will exist at decommissioning.

Decommissioning is assumed to be performed by an independent contractor. Labor rates used in the estimate are based on 2015 industry labor rates. These rates were compiled from ISP joint venture member Waste Control Specialists current labor rates. Waste Control Specialists employs a wide range of people including: Laborers, Equipment Operators, Radiation Technicians (RT), Health Physicists, Engineers, Administrative Assistants, and other labor categories that are directly applicable to a decommissioning project. The cost estimates uses direct labor rate with a multiplier of 2.5 applied to account for fringe benefits, indirect labor costs, and profit.

The initial step in development of the D&D cost estimate is to determine the required activities to complete D&D. The basic activities for D&D of the WCS CISF are:

4.4.1 Decommissioning Plan (DP)

The DP will be developed and submitted for NRC review and approval before any D&D activities occur. The DP will include Derived Concentration Guideline Levels (DCGLs) or clean-up criteria and a Final Status Survey Plan consistent with the requirements in NUREG-1757. Costs associated with the DP include time and materials for a consultant to prepare the DP for submittal. Initial site Characterization Survey results will be included in the DP.

Page 4-2 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN 4.4.2 Decontamination and Waste Disposal Initial characterization surveys will be performed to identify any areas of contamination requiring decontamination and/or disassembly. These areas will be decontaminated using conventional methods to the extent practical. Contaminated components will be disassembled as necessary and sent to a licensed facility for disposal. Major components of this portion of the D&D estimate include the following:

Initial characterization survey Decontamination work activities Decontamination waste disposal 4.4.3 Final Status Survey The Final Status Survey will consist of a thorough investigation of the facility to demonstrate that the facility meets the DCGLs established for decommissioning. The investigation will include:

Radiation survey over the interior and exterior of each storage module container Radiation survey of the storage pad Radiation survey of the Cask Handling Building The methods used to estimate the time required for survey activities are based on ISP joint venture member Waste Control Specialists current procedures for radiological survey.

4.4.4 Final Report The Final Report contains the analysis results of the Final Status Survey and the completion of the DP. This document will be submitted to the NRC for approval and termination of the Part 72 license.

4.5 CONTINGENCY Because of uncertainty associated with decommissioning, a contingency factor of 25 percent is then applied to the sum of all estimated decommissioning costs.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN CHAPTER 5 DECOMMISSIONING FACILITATION The configuration of the storage systems used at the WCS CISF allow for decommissioning in conformance with 10 CFR § 72.130. The facility and storage systems are designed with decommissioning as one of the primary functions.

Canisters containing spent nuclear fuel and GTCC waste are loaded at the generating reactor facility. Procedures are implemented by the generators to ensure loading operations occur without contamination remaining on the exterior of the canister. Before the canisters arrive and are accepted at the WCS CISF, they are surveyed to verify that any contamination on the canister is below acceptable limits. Once at the WCS CISF for storage, sealed canisters are not opened. Therefore, canisters arriving at the WCS CISF will have contamination below acceptable release limits, and since they will remain sealed during storage, there is no expectation that contamination in excess of those limits will exist at the CISF at decommissioning.

The storage modules that hold the canisters are clean and have no contamination when they are fabricated. Health physics technicians are involved in all parts of canister movement and transfer operations and will perform surveys of all applicable components during and after the transfer process. These measures identify and control the spread of contamination should an unexpected spread of contamination occur. These measures ensure that in the small chance there is contamination from a canister shipped to the WCS CISF, there will be no spread of contamination from the Transfer Facility to the Storage Pads. Any contamination found during operations will be identified and decontaminated promptly while the facility is still in the operations phase.

Facility design, planning and operations have been established in a manner to produce a site that maintains a start clean/stay clean philosophy. This purpose built facility is established so that decommissioning activities can be completed in a safe, timely and straightforward manner.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX B PRELIMINARY DECOMMISSIONING PLAN CHAPTER 6 REFERENCES

1. 10 CFR 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.

2. 10 CFR 20, Standards for Protection Against Radiation.

3. NUREG-1757, Consolidated Decommissioning Guidance.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX C APPENDIX C NOT USED

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN APPENDIX D DECOMMISSIONING FUNDING PLAN

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN TABLE OF CONTENTS CHAPTER TITLE PAGE 1 INTRODUCTION 1-1 2 DECOMMISSIONING FUNDING METHODS 2-1 3 SITE SPECIFIC DECOMMISSIONING COST ESTIMATE 3-1 3.1 Summary 3-1 3.2 Adjusting the Cost Estimate 3-5 3.3 Decommissioning Cost Estimate 3-6 4 REFERENCES 4-1 Page i Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN CHAPTER 1 INTRODUCTION This Decommissioning Funding Plan has been developed to describe the proposed approach for funding decommissioning activities and to provide a decommissioning cost estimate using the approach provided in NUREG 1757, Volume 3.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN CHAPTER 2 DECOMMISSIONING FUNDING METHODS A fully executed written contract between ISP and the United States Government, Department of Energy (DOE) or the other SNF Title Holder(s), will be established prior to receipt of SNF or reactor-related GTCC LLW at the CISF. Pursuant to this contract, if the DOE shall take legal title of the SNF and reactor-related GTCC LLW prior to receipt, DOE shall also be responsible for all costs associated with the decommissioning of the CISF allowing for its unrestricted release pursuant to 10 CFR 20 Subpart E at the time of license termination. If other SNF Title Holder(s), other than DOE, (Client(s)), enter into a contract with ISP for storage services, the contract shall allocate legal and financial liability among the licensee and the clients and shall include provisions requiring clients to periodically provide credit information, and, when necessary financial assurances to cover their decommissioning obligations.

ISP shall provide a financial assurance method, as specified in 10 CFR 72.30(e), to provide the necessary funds to decommission equipment and facilities at the CISF to levels allowing for its unrestricted use prior to receipt of SNF or reactor-related GTCC LLW.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN CHAPTER 3 SITE SPECIFIC DECOMMISSIONING COST ESTIMATE 3.1 Summary The decommissioning cost estimate is based on the guidance of Section A.3 of Appendix A of NUREG-1757, Vol. 3, Consolidated Decommissioning Guidance, and is developed on the basis that the WCS CISF will be constructed and operated under the requirements of 10 CFR 20.1406 Minimization of Contamination. This regulation requires that the applicant design and operate the facility to minimize, to the extent practicable, contamination of the facility and the environment, facilitate eventual decommissioning, and minimize, to the extent practicable, the generation of radioactive waste. As a temporary storage facility, waste containers will not be opened at the WCS CISF. Continual radiological surveillance during the operational period will ensure that any contamination is promptly discovered, identified and removed in a timely manner before the decommissioning period begins.

3.1.1 Facility Description At the time of decommissioning, there will be no radiological materials at the site. The License will allow for the storage of material defined in Conditions 8A and 8B of the license.. All of this material will be removed before decommissioning begins. During the operational life of the facility, the spent fuel is stored in storage modules on concrete pads placed on the ground.

Support facilities include a Security and Administration Building as well as a Cask Handling Building. As a start-clean/stay-clean facility, the WCS CISF will operate in a manner that supports decommissioning activities throughout the life of the facility There are no facility components (e.g. fume hoods, glove boxes, laboratory benches, ductwork) that will require decontamination. In order to provide a conservative value to the decommissioning cost estimate, ISP assumes that a portion of the storage pad and the storage modules will require decontamination.

3.1.2 Estimated Decommissioning Costs The Decommissioning Cost Estimate accounts for all phases of the decommissioning process.

The cost estimate distinguishes between labor and non-labor costs and includes a contingency factor.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN 3.1.2.1 Labor Costs Labor costs associated with decommissioning tasks and activities have been used in the cost estimate for this facility. These costs have been gathered to provide sufficient cost data that would allow an independent third party to carry out the decommissioning project. The following sources have been used to provide labor rates:

ISP joint venture member Waste Control Specialists LLC Employment Data RSMeans 2015 Heavy Construction Cost Data, Construction Publishers & Consultants, Norwell, MA Waste Control Specialists currently (2015) employs personnel in the same occupational job categories that would be required for the decommissioning project. Current Waste Control Specialists rates are competitive with other employers to ensure a stable and efficient workforce at the existing facility. Data on current Waste Control Specialists labor rates for applicable job descriptions provide an accurate labor estimate for the job type and area of the country. Table 3-1 provides standard Labor rates provided by Waste Control Specialists.

The table breaks the rate down into the Direct Cost (rate paid to employee), Fringe Costs (rate that covers additional labor costs associated with employees such as: insurance, benefits, and taxes), and Indirect Costs (rate that covers overhead costs such as property costs, support staff, depreciation, etc.). The Loaded Labor Rate (Direct Cost + Fringe Costs + Indirect Costs) can be determined by applying a multiplier of 2.5 to the labor Direct Cost.

Table 3-1, Waste Control Specialists 2015 Labor Rates Labor Category Direct Cost Fringe Indirect Loaded Costs Costs Rate Laborer/Operator $24.00 $24.00 $12.00 $60.00 Foreman Laborer $30.00 $30.00 $15.00 $75.00 Administrative Assistant $20.00 $20.00 $10.00 $50.00 Engineer $50.00 $50.00 $25.00 $125.00 Radiation Technician (RT) $40.00 $40.00 $20.00 $100.00 RT Supervisor $45.00 $45.00 $22.50 $112.50 Health Physicist $50.00 $50.00 $25.00 $125.00 Project Manager $100.00 $100.00 $50.00 $250.00 Security Guard $25.00 $25.00 $12.50 $62.50 Security Supervisor $30.00 $30.00 $15.00 $75.00 Page 3-2 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN RSMeans (2015) is a commonly used standard cost estimating manual used to provide comprehensive construction cost data. Cost information includes data on materials, labor, equipment, management, and overhead and profit. Costs used from this reference will already include allowances for overhead and profit. Most of the RSMeans costs used in this estimate are a combination of Labor and Non-Labor rates. This is noted where applicable.

Labor totals broken out and are estimated in Tables 3-5 through 3-14 for different decommissioning activities.

3.1.2.2 Non-Labor Costs Non-Labor costs will be a part of the decommissioning effort. Equipment, Shipping, and Disposal costs will be the main components. Cost information for these items was referenced from RSMeans (2015) and potential vendor product information. Significant Non-Labor costs fall into the following areas:

Decontamination Equipment The Decommissioning Cost Estimate assumes that decontamination efforts will involve standard concrete scabbleing techniques. ISP joint venture member Waste Control Specialists has received quotes from Pentek Inc. for their Nuclear Decon tools for use in the cost estimate.

These tools that are in the decontamination industry for the safe decontamination of concrete components. Components include scabblers, concrete shavers, vacuum packages, hoses, and other appurtenances.

Waste Shipping Waste generated during decontamination activities will be drums for transport to a licensed disposal cell. The existing Waste Control Specialists Low Activity Waste (LAW) disposal cell is less than 2 miles from the CISF. RSMeans (2015) was used to estimate equipment (fork truck, tractor, and trailer) necessary to transport the waste to the LAW cell. RSMeans combines Non-Labor and Labor costs for these activities by also including a crew used to operate the equipment. This has been accounted for and noted where applicable in the cost estimate.

Waste Disposal Waste generated during decontamination activities will be disposed of at the Waste Control Specialists LAW disposal cell. The cost estimate used a current disposal price for bulk waste disposal in the cell.

Non-Labor quantities and costs are listed in Tables 3-15 through 3-18.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN 3.1.2.3 Contingency Factor A contingency factor of 25% was applied to the total cost estimate amount. Due to the uncertainty of contamination levels, waste disposal costs, and unforeseen circumstances, a contingency factor is used to provide a factor of safety to the cost estimate. While some costs are known exactly with more certainty than others, the contingency factor is applied to everything. This percentage of contingency should be sufficiently large especially when taken with the conservative assumptions made in the required activities of the decommissioning project. The contingency factor is included in Table 3-19, Total Decommissioning Costs.

3.1.3 Key Assumptions The decommissioning estimate is based on the condition of the CISF after all of the canisters have been removed from the site. No interior or exterior radioactive surface contamination is expected. During the lifetime of the facility, only sealed canisters (welded) will be accepted for storage. The facility does not open the canisters at any time. The canisters are surveyed at the generator facility and will not be transported to the WCS CISF unless surface contamination levels are below specified limits. Only small quantities of radioactive waste are expected to be generated, attributable primarily to performing radiological surveys at the facility. No other waste is generated by the facility. Canisters are only accepted at arrival at the facility after a radiological survey has determined that they are free from contamination. The cost estimate for decommissioning will conservatively assume that certain areas and components will require decontamination.

Disposal Costs and Transportation rates are assumed to be applicable disposal rates at the Waste Control Specialists licensed disposal facility. Transportation will occur over a short distance all within Waste Control Specialists private property.

Potential areas for contamination are discussed below:

Storage Modules: The storage module vendors have indicated that contamination is not anticipated from the stored waste. Contamination controls mentioned above minimize the possibility that storage modules will have radioactive contamination above the specified release limits established by the NRC. For purposes of the cost estimate, ISP has assumed that parts of some of the storage modules will require decontamination. The initial characterization survey and sampling of each storage module will determine the nature and location of any contamination. The interior area of a storage module is approximately 455 square feet. 100% of Page 3-4 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN this area will be surveyed in the initial characterization survey. Three concrete core samples will be retrieved and analyzed from each module. The cost estimate assumes that the maximum portion of a storage module that would require decontamination is 20%. Decontamination activities would include scabbling contaminated concrete or bead-blasting steel. Waste generated (scabbled concrete, steel scale, misc. tools and filters, and PPE) will be packed into drums for transportation by truck to the adjacent Waste Control Specialists LAW disposal cell.

Storage Pads: The storage pads will be used to support the storage modules. It is not anticipated that these concrete pads will become contaminated due to the canister controls.

ISP has assumed that 20% of the storage pad areas have levels of contamination above allowable release limits. The total storage pad area is 125,000 square feet, 25,000 square feet of this area is assumed to be contaminated. Decontamination activities would include scabbling of concrete. Waste generated will be packed into drums for transportation by truck to the adjacent Waste Control Specialists LAW disposal cell.

Cask Handling Building: The Cask Handling Building is an operational feature and not a storage system. The building will be surveyed during unloading and loading operations through the life of the facility. Any contamination discovered will be located and removed during the operational life of the building and not as part of the decommissioning.

Salvage: The cost estimate does not take credit for any salvage value that might be realized from the sale of potential assets during or after decommissioning.

3.2 Adjusting The Cost Estimate The Decommissioning Cost Estimate will be updated at a minimum every three years. The update will capture the current price of goods and services and make any adjustments necessary for inflation. The update also provides an opportunity to account for the effect any facility modifications would have on the cost estimate. In addition, experience operating this new facility will provide additional input and verification of key assumptions of the original Decommissioning Cost Estimate.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN 3.3 Decommissioning Cost Estimate The Decommissioning Cost Estimate is provided in Tables 3-2 through 3-18.

Table 3-2, Number and Dimensions of Facility Components Area: Storage Modules Level of Contamination: Up to 20% of internal surface area, light Component Number of Dimensions of Total Components Components Dimensions (ft2) (ft2)

Glove Boxes 0 - -

Fume Hoods 0 - -

Lab Benches 0 - -

Sinks 0 - -

Drains 0 - -

Floors 0 - -

Walls 0 - -

Ceilings 0 - -

Ventilation/Ductwork 0 - -

Hot Cells 0 - -

Equipment/Materials 0 - -

Soil Plots 0 - -

Storage Tanks 0 - -

Storage Areas 0 - -

Radwaste Areas 0 - -

Scrap Recovery Areas 0 - -

Maintenance Shop 0 - -

Equipment Decontamination Areas 0 - -

Utilities/Piping 0 - -

Other: Storage Modules 450 455 204,750 Page 3-6 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-3, Number and Dimensions of Facility Components Area: Storage Pad Level of Contamination: Up to 20% of surface area, light Component Number of Dimensions of Total Components Components Dimensions (ft2) (ft2)

Glove Boxes 0 - -

Fume Hoods 0 - -

Lab Benches 0 - -

Sinks 0 - -

Drains 0 - -

Floors 0 - -

Walls 0 - -

Ceilings 0 - -

Ventilation/Ductwork 0 - -

Hot Cells 0 - -

Equipment/Materials 0 - -

Soil Plots 0 - -

Storage Tanks 0 - -

Storage Areas 0 - -

Radwaste Areas 0 - -

Scrap Recovery Areas 0 - -

Maintenance Shop 0 - -

Equipment Decontamination Areas 0 - -

Utilities/Piping 0 - -

Other: Storage Pad Type 1 1 30,175 30,175 Other: Storage Pad Type 2 15 6,144 92,160 Page 3-7 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-4, Number and Dimensions of Facility Components Area: Cask Handling Building Level of Contamination: None Component Number of Dimensions of Total Components Components Dimensions Glove Boxes 0 - -

Fume Hoods 0 - -

Lab Benches 0 - -

Sinks 0 - -

Drains 0 - -

Floors 1 150x 150 22,500 ft2 Walls 4 150 x 65 9,000 ft2 Ceilings 1 150 x 150 22,500 ft2 Ventilation/Ductwork 0 - -

Hot Cells 0 - -

Equipment/Materials 0 - -

Soil Plots 0 - -

Storage Tanks 0 - -

Storage Areas 1 50 x 50 2,500 ft2 Radwaste Areas 0 - -

Scrap Recovery Areas 0 - -

Maintenance Shop 0 - -

Equipment Decontamination Areas 0 - -

Utilities/Piping 1 - -

Other: Rail 1 150 150 Other: Overhead Cranes 2 75 150 Page 3-8 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-5, Planning and Preparation (Workdays)

Labor Category Activity Health Radiation RT Engineer Project Administrative Physicist Technician Supervisor Manager Assistant (RT)

Preparation of 125 0 0 50 14 25 Documentation for Regulatory Agencies Submittal of 0 0 0 0 10 10 Decommissioning Plan to NRC When required by 10 CFR 72.54(g)

Procurement of 1 0 0 1 1 1 Special Equipment Characterization 37 74 19 0 15 19 of Radiological Condition of the Facility (including sampling soil, concrete)

Administrative 15 0 0 15 5 30 Fees (procurement fees for third party contractor, legal fees, local permits, utilities, financial assurance fees, and NRC staff review of these items TOTALS 178 74 19 66 45 85 Page 3-9 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-6, Decontamination or Dismantling of Radioactive Facility Components (Workdays)

Number of workdays, by specific labor category, which will be required to complete decontamination and/or dismantling activities for each facility component.

Area: Storage Modules Level of Contamination: Up to 20% of surface area, light Component Decon. Laborer Foreman Method Laborer Glove Boxes - 0 0 Fume Hoods - 0 0 Lab Benches - 0 0 Sinks - 0 0 Drains - 0 0 Floors - 0 0 Walls - 0 0 Ceilings - 0 0 Ventilation/Ductwork - 0 0 Hot Cells - 0 0 Equipment/Materials - 0 0 Soil Plots - 0 0 Storage Tanks - 0 0 Storage Areas - 0 0 Radwaste Areas - 0 0 Scrap Recovery Areas - 0 0 Maintenance Shop - 0 0 Equipment Decontamination - 0 0 Areas Utilities/Piping - 0 0 Other: Storage Module Scabbling 505 101 TOTALS 505 101 Page 3-10 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-7, Decontamination or Dismantling of Radioactive Facility Components (Workdays)

Number of workdays, by specific labor category, which will be required to complete decontamination and/or dismantling activities for each facility component.

Area: Storage Pads Level of Contamination: Up to 20% of surface area, light Component Decon. Laborer Foreman Method Laborer Glove Boxes - 0 0 Fume Hoods - 0 0 Lab Benches - 0 0 Sinks - 0 0 Drains - 0 0 Floors - 0 0 Walls - 0 0 Ceilings - 0 0 Ventilation/Ductwork - 0 0 Hot Cells - 0 0 Equipment/Materials - 0 0 Soil Plots - 0 0 Storage Tanks - 0 0 Storage Areas - 0 0 Radwaste Areas - 0 0 Scrap Recovery Areas - 0 0 Maintenance Shop - 0 0 Equipment Decontamination - 0 0 Areas Utilities/Piping - 0 0 Other: Storage Pad Type 1 Scabbling 80 16 Other: Storage Pad Type 2 Scabbling 230 46 TOTALS 310 62 Page 3-11 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-8, Decontamination or Dismantling of Radioactive Facility Components (Workdays)

Number of workdays, by specific labor category, which will be required to complete decontamination and/or dismantling activities for each facility component.

Area: Cask Handling Building Level of Contamination: None Component Decon. Laborer Foreman Method Laborer Glove Boxes - 0 0 Fume Hoods - 0 0 Lab Benches - 0 0 Sinks - 0 0 Drains - 0 0 Floors - 0 0 Walls - 0 0 Ceilings - 0 0 Ventilation/Ductwork - 0 0 Hot Cells - 0 0 Equipment/Materials - 0 0 Soil Plots - 0 0 Storage Tanks - 0 0 Storage Areas - 0 0 Radwaste Areas - 0 0 Scrap Recovery Areas - 0 0 Maintenance Shop - 0 0 Equipment Decontamination - 0 0 Areas Utilities/Piping - 0 0 Other: Rail - 0 0 TOTALS 0 0 Page 3-12 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-9, Restoration of Contaminated Areas on Facility Grounds (Workdays)

Estimate the number of workdays, by specific labor category, required to restore contaminated areas on facility grounds.

Activity Laborer Foreman Laborer Backfill and Restore Site 0 0 TOTALS 0 0 Note: Once contaminated areas have been decontaminated and/or dismantled (Table 3-6), no restoration on facility grounds will be required.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-10, Final Radiation Survey (Workdays)

Estimate the number of workdays, by specific labor category, required to conduct a final radiation survey.

Labor Category Activity Health Radiation RT Engineer Project Administrative Physicist Technician Supervisor Manager Assistant (RT)

Final 1125 2813 1125 50 536 281 Status Survey Final 75 0 0 0 14 75 Report Preparation and Submittal TOTALS 1200 2813 1125 50 550 356 Page 3-14 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-11, Site Stabilization and Long-Term Surveillance (Workdays)

Estimate the number of workdays, by specific labor category, required to complete site stabilization and long-term surveillance activities.

Labor Category Activity Health Radiation RT Engineer Project Administrative Physicist Technician Supervisor Manager Assistant (RT)

Not 0 0 0 0 0 0 Applicable TOTALS 0 0 0 0 0 0 Page 3-15 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-12 Total Workdays by Labor Category Estimate the number of workdays, by specific labor category, required to conduct a final radiation survey.

Labor Category Radiation Administrative RT Supervisor Task Health Engineer Project Foreman Physicist Technician (RT) Manager Assistant Laborer Laborer Planning and Preparation (TOTALS 178 74 19 66 45 85 0 0 from Table 3-5)

Decontamination or Dismantling of 0 0 0 0 0 0 815 163 Radioactive Facility Components (Sum of TOTALS from all copies of Table 3-7)

Packaging, Shipping, and Disposal 8 24 24 0 8 24 0 0 of Radioactive Wastes

Restoration of Contaminated Areas 0 0 0 0 0 0 0 0 on Facility Grounds (TOTALS from Table 3-9)

Final Radiation Survey (TOTALS 1200 2813 1125 50 550 356 0 0 from Table 3-10)

Site Stabilization and Long-Term 0 0 0 0 0 0 0 0 Surveillance (TOTALS from Table 3-11)

Note:

Labor workdays in this category are estimated for Radiation monitoring and Administrative actions during this activity. Labor for actual work is included in Table 3-15.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-13, Worker Unit Cost Schedule Estimate labor costs (including salary, fringe benefits, and corporate overhead). Include all appropriate labor categories, including Supervisor, Foreman, Craftsman, Technician, Health Physicist, Laborer, Clerical, and others as needed.

Labor Category Radiation Administrative RT Supervisor Labor Cost Component Health Engineer Project Foreman Physicist Technician (RT) Manager Assistant Laborer Laborer Salary & Fringe 208,000 166,400 187,200 208,000 416,000 83,200 99,840 124,800

($/year)*

Overhead Rate 25 25 25 25 25 25 25 25

(%)

Total Cost Per 260,000 208,000 234,000 260,000 520,000 104,000 124,800 156,000 Year Total Cost Per 1,000 800 900 1000 2,000 400 480 600 Workday**

Notes:

Source: Waste Control Specialists Wage Rate Range 2015

- Based on 260 workdays per year and an 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months work day Page 3-17 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-14, Total Labor Costs by Major Decommissioning Task Multiply the estimated workdays for each specific labor category (from Table 3-12) by the total cost per workday for the corresponding labor category (from Table 3-13), and enter the results in the tale below. Then, add across all labor categories to determine the total labor costs for each major decommissioning task.

Labor Category Task Radiation RT Administrati Health Engineer Project Foreman Laborer Technician Physicist (RT) Supervisor Manager ve Assistant Laborer Total Labor Cost Planning and

$178K $59.2K $17.1K $66K $90K $34K 0 0 $444.3K Preparation Decontamination or Dismantling of Radioactive 0 0 0 0 0 0 $391.2K 97.8K $489K Facility Components Packaging, Shipping, and Disposal of $8K $19.2K $21.6K 0 16K $9.6K 0 0 $74.4K Radioactive Wastes*

Restoration of Contaminated 0 0 0 0 0 0 0 0 0 Areas on Facility Grounds Final Radiation

$1,200K $2,250K $1,013K $50K $1,100K $142.4K 0 0 $5,755.4K Survey Site Stabilization and Long-Term 0 0 0 0 0 0 0 0 0 Surveillance Note:* Labor in this Table is for Radiation monitoring and Administrative actions during this activity. Labor for Packaging waste is included in the Decontamination or Dismantling or Radioactive facility Components Task. Labor for actual work is included in Table 3-15.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-15, Packaging, Shipping, and Disposal of Radioactive Wastes (a) Packing Material Costs Estimate the types and volumes of waste expected to be generated, along with the number and types of containers required for packaging the waste. Multiply the number of containers required by the unit cost per container.

Waste Type Volume Number of Type of Container Unit Cost Total 3

(m ) Containers of Packaging Container Costs DAW 3.7 19 55 Gallon Steel $263.00 $4,997 Drum Misc Tools, 3.7 19 55 Gallon Steel $263.00 $4,997 Equipment Drum Soil Like 39 197 55 Gallon Steel $263.00 $51,811 (Scabbled Drum Concrete, etc.)

TOTAL 46.4 235 - - $61,805 (b) Shipping Costs Estimate the number of truckloads of waste to be shipped. Multiply shipping costs per mile (including truckload costs, surcharges, and overweight charges) by the total distance shipped.

Waste Type Number Unit Cost Surcharge Overweight Distance Total of ($/mile/ ($/mile) ** Charges Shipped Shipping Loads truckload) * ($/mile) ** (miles) Costs 55 Gallon 3 $929.99 $0 $0 4 $11,160 Drums (Low Activity)

TOTAL 3 - - - - $11,160 Notes:

Mileage cost derived from daily equipment and crew costs assuming one truckload per day. Cost based on RS Means 2015 Construction Data.

- Transport is short distance on private property. No Surcharge or Overweight changes are applicable.

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN (c) Waste Disposal Costs Estimate the volume of waste to be disposed. Multiply the volume of waste disposed by the unit disposal cost (including any volume-based surcharges). Add any surcharges that are based on the number of containers of waste.

Waste Type Disposal Unit Cost Surcharges Total Disposal Volume (m3) ($/m3) ($/m3 or Costs

$/container) 55 Gallon Drums 46.4 $529.72 $0 $24,579 (Low Activity)

TOTAL 46.4 $529.72 - $24,579 Disposal Cost based on Waste Control Specialists Low Activity Waste Landfill Rates Table 3-16, Equipment/Supply Costs (Excluding Containers)

Estimate the quantity of equipment and supplies required for decommissioning and multiply that quantity by the appropriate unit costs.

Equipment/Supplies Quantity Unit Cost Total Equipment/Supply Cost HEPA Vacuum 1 $80,000 $80,000 HEPA Filters 3 $906.61 $2,720 Rough Filters 9 $271.26 $2,441 Vacuum Hose 12 $272.00 $3,264 Vac Scabbler 6 $25,000 $150,000 Vac Floor Shaver 1 $65,000 $65,000 Scabbler Bits 8 $502.37 $4,019 Shaver Blades 6 $10,753 $64,518 Side Shaver Blades 4 $4,840.80 $19,363 PPE 1 $6,500 $6,500 TOTAL - - $397,825 Page 3-20 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-17, Laboratory Costs If applicable, estimate costs for analyses to be performed by an independent third-party laboratory.

Activity Total Costs Core Sampling $361,600 Soil Sampling $29,600 Testing and Analysis (includes Transport) $524,208 TOTAL $915,408 Table 3-18, Miscellaneous Costs Estimate any other applicable costs.

Cost Item Total Cost Security $341,000 Insurance $100,000 TOTAL $441,000 Page 3-21 Revision 3

INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN Table 3-19, Total Decommissioning Costs Task/Component Cost Percentage Planning and Preparation $444,300 4.4%

(From Table 3-14)

Decontamination and/or Dismantling of Radioactive Facility $489,000 4.8%

Components (From Table 3-14)

Packaging, Shipping, and Disposal of Radioactive Wastes $74,400 0.7%

(From Table 3-14)

Restoration of Contaminated Areas on Facility Grounds $0 0%

(from Table 3-14)

Final Radiation Survey $5,755,400 57.0%

(From Table 3-14)

Site Stabilization and Long-Term Surveillance $0 0%

(From Table 3-14)

Packing Materials Costs $61,805 0.6%

(TOTAL From Table 3-15(a))

Shipping Costs $11,160 0.1%

(TOTAL From Table 3-15(b))

Waste Disposal Costs $24,579 0.2%

(TOTAL From Table 3-15(c))

Equipment/Supply Costs $397,825 3.9%

(TOTAL from Table 3-16 Laboratory Costs $915,408 9.1%

(TOTAL From Table 3-17)

Miscellaneous Costs $441,000 4.4%

(TOTAL From Table 3-18)

Contractor Overhead and Profit $1,500,000 14.8%

SUBTOTAL $10,114,877 100.0%

25% Contingency $2,528,719 25.0%

TOTAL DECOMMISSIONING COST ESTIMATE $12,643,596 125.0%

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INTERIM STORAGE PARTNERS LLC LA APPENDIX D DECOMMISSIONING FUNDING PLAN CHAPTER 4 REFERENCES

1. 10 CFR 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.

2. 10 CFR 20, Standards for Protection Against Radiation.

3. NUREG-1757, Consolidated Decommissioning Guidance.

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v t e Letter Sequence Request
CAC:001028, (Approved, Closed) EPID:L-2017-NEW-0002, Interim Storage Partners, LLC - Submittal of License Application Revision 2, and Request to Restart Review of Application for Approval of the WCS Cisf (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, Request, ... further results\|Request]] Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance, Acceptance Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement, Supplement Administration Withholding Request Acceptance Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting, Meeting Questions 25 August 2021 20 February 2020 6 March 2020 31 March 2020 31 March 2020 10 April 2020 28 May 2020 28 May 2020 4 August 2020 31 August 2020 30 September 2020 28 September 2020 6 October 2020 20 November 2020 10 December 2020 16 December 2020 14 January 2021 14 January 2021 22 January 2021 23 March 2021 23 March 2021 3 March 2021 20 May 2021 15 June 2021 30 August 2021 28 October 2021 28 October 2021 18 October 2021 3 November 2021 21 December 2021 21 December 2021 8 December 2021 8 December 2021 20 January 2022 20 January 2022 6 May 2022 23 March 2022 31 March 2022 1 July 2022 31 October 2022 31 October 2022 8 December 2022 4 January 2023 6 March 2023 6 March 2023 25 July 2023 25 July 2023 20 June 2023 4 October 2023 4 October 2023 28 August 2023 ... further results Answers 31 March 2020 5 June 2020 10 July 2020 11 September 2020 11 November 2020 27 January 2021 9 February 2021 19 November 2021 30 November 2021 25 February 2022 7 June 2022 11 July 2022 13 July 2022 29 July 2022 31 August 2022 31 August 2022 9 September 2022 3 October 2022 3 October 2022 1 December 2022 21 December 2022 6 January 2023 27 January 2023 17 March 2023 8 May 2023 30 June 2023 Results Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, Approval, ... further results\|Approval]] Other: L-23-005, Independent Spent Fuel Storage Installation License Renewal Application, Revision 1 (Cac/Epid No. 001028/L-2022-RNW-0007), ML19276D398, ML20014E677, ML20049A082, ML20065N277, ML20065N278, ML20065N280, ML20065N281, ML20065N285, ML20071F156, ML20076D696, ML20094G482, ML20099A180, ML20104C015, ML20104C016, ML20104C018, ML20104C019, ML20105A135, ML20105A136, ML20105A137, ML20105A138, ML20105A139, ML20105A173, ML20111A240, ML20115E377, ML20121A272, ML20136A049, ML20136A050, ML20136A051, ML20150A300, ML20150A335, ML20150A421, ML20155K741, ML20155K742, ML20155K743, ML20155K744, ML20160A040, ML20161A088, ML20163A702, ML20163A703, ML20163A704, ML20181A211, ML20181A212, ML20192A328, ML20192A329, ML20212L768, ML20212L769, ML20212L878, ML20223A036, ML20224A287... further results
MONTHYEAR2019-04-23 [Table View]

ML20237F470

Text

Subject:

Reference:

Enclosures:

1.4 DESCRIPTION

10.2 BACKGROUND

SUMMARY

4.2 BACKGROUND

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