ML24324A064
| ML24324A064 | |
| Person / Time | |
|---|---|
| Site: | 07200009 |
| Issue date: | 11/14/2024 |
| From: | US Dept of Energy, Idaho Operations Office |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24324A062 | List: |
| References | |
| CLN250095 | |
| Download: ML24324A064 (1) | |
Text
License Amendment Request
1.0 DESCRIPTION
This submittal is a request to amend Special Nuclear Materials (SNM) license SNM-2504 for the Fort St. Vrain (FSV) Independent Spent Fuel Storage Installation (ISFSI).
The proposed changes would revise the SNM license and applicable technical specifications (TSs) to modify the title of the designated DOE licensee position with the authority to serve as the Secretary of Energys authorized representative in accordance with NRC regulations at 10 CFR 72.16(b). These SNM license currently assigns designated licensee authority under the license to the Deputy Manager, Idaho Cleanup Project. The amendment removes this designation and assigns the Manager for the Idaho Cleanup Project (ICP) as the designated authority and authorized representative in all matters regarding the license. Additional related editorial changes are proposed change references to Department of Energy (DOE) Idaho (DOE-ID) to DOE ICP. Also, proposed changes would make clerical corrections to Limiting Conditions for Operation (LCO) 3.3.1 and TS 5.5.2.6 language to reflect changes approved in Amendment 10 but were inadvertently omitted from Amendment 11. Finally, a reference correction for 5.5.1.d and a punctuation correction for 5.5.2.5 are proposed, as well as a change to 5.4.1 to update a title for the Idaho National Laboratory.
2.0 PROPOSED CHANGE
S The following changes to the FSV ISFSI license and TSs are proposed:
- Revise License Condition 9 with the date of submittal of this License Amendment Request.
- Revise License Condition 14 to replace DOE-ID with Department of Energy (DOE) Idaho Cleanup Project (ICP).
- Revise TS LCO 3.3.1, section A.1.1, A.1.2.1, A.1.2.2, and A.2 to correct a clerical error that occurred for the required action completion times when the license was amended for Amendment 11. The changes to the required action completion times were approved under License Amendment 10 but were inadvertently omitted from Amendment 11.
- Revise TS 5.1.1 to delete Deputy, Idaho Cleanup Project, the parentheses around ICP, and Office of Environmental Management (DOE-ID), and insert the so that it states The Manager for the ICP is responsible.
- Revise TS 5.2.1.2 to delete Department executive and replace with Manager for the ICP, and to replace delegated with designated.
- Revise TS 5.4.1 to delete Engineering and Environmental.
- Revise TS 5.5.1.d to correct the reference from 10 CFR 72.48(b)(2) to 10 CFR 72.48(d)(2).
- Revise TS 5.5.2.5 to correct punctuation from don=t to dont.
- Revise TS 5.5.2.6 to refer to 10 CFR 72.70(c)(6), as it incorrectly refers to 10 CFR 72.70(b). This was a clerical error that occurred when the license was amended to Amendment 11. This change was originally approved in License Amendment 10 but was inadvertently omitted from Amendment 11.
- Revise TS 5.5.2.7 to insert ICP after DOE.
- Revise TS 5.6.1 to delete Deputy and insert the prior to ICP so that it states, Manager for the ICP.
In summary, the proposed changes revise the SNM license to modify the title of the licensee designation of authority to be the Manager for the ICP, correct changes originally approved in License Amendment 10 but inadvertently omitted from Amendment 11, and correct references and other errors. A red-line markup of the license and TSs is attached containing the proposed changes.
As a result of the proposed changes, associated changes to the Technical Specification Bases will be required. Changes will be made in accordance with TS 5.5.1 and reported to the NRC in accordance with 10 CFR 72.48(d)(2) upon approval of the license amendment.
Additionally, as a result of these proposed changes, changes will be necessary to the FSV ISFSI FSAR Chapters 9 and 11 to incorporate the conforming changes. Changes will be made in accordance with 10 CFR 72.70, Safety Analysis Report Updating, upon approval of the license amendment.
3.0 BACKGROUND
This license amendment request replaces the Deputy Manager, ICP with the Manager for the ICP. This change identifies the most senior DOE Office of Environmental Management official located at the DOE ICP office as the designated Licensee. The Secretary of Energy has designated as her authorized representative the Manager for the ICP to be the DOE-responsible official for the DOE ICP NRC facilities managed by the Office of Environmental Management. The designation will be effective upon approval of this License Amendment Request.
Additionally, a clerical error was identified in Amendment 11 of the license that changes originally made to the license for Amendment 10 were inadvertently omitted from Amendment 11. This amendment request incorporates the previously approved changes that were inadvertently omitted.
This request also replaces references to DOE-ID with DOE ICP more clearly referencing the DOE organization managed by the Office of Environmental Management. Editorial corrections are requested to an incorrect reference and a punctuation error. Also, an update to a title for the Idaho National Laboratory was included. Some formatting and technical editing changes were also included throughout.
4.0 TECHNICAL ANALYSIS
All of the proposed changes are administrative in nature. The proposed change to update the title of the Licensee responsible official aligns the license with the DOE ICP
organization and the most senior DOE ICP Environmental Management official as designated by the Secretary of Energy. Other editorial changes to regulation references and LCO-required action completion times are clerical corrections.
5.0 REGULATORY ANALYSIS
The proposed changes are administrative in nature, and do not affect or change licensed operations nor the type and amount of material licensed for storage at the site. The proposed changes do not affect the ability of the FSV ISFSI of meeting the regulatory requirements of 10 CFR Part 72.
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
6.0 ENVIRONMENTAL CONSIDERATION
The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements, (ii) changes to recordkeeping, reporting, or administrative procedures or requirements, or (iii) changes the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
7.0 REFERENCES
None.
8.0 AGING MANAGEMENT The proposed changes addressed in this license amendment request are editorial in nature and have no effect on any aging management review or aging management activity.
9.0 ATTACHMENTS None.
10.0 ENCLOSURES Proposed changes to license conditions and TS (marked-up version) are provided with this License Amendment Request.