ML24326A352
| ML24326A352 | |
| Person / Time | |
|---|---|
| Site: | Crane, 07200020  |
| Issue date: | 11/21/2024 |
| From: | US Dept of Energy, Idaho Operations Office |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML24326A350 | List: |
| References | |
| Download: ML24326A352 (1) | |
Text
License Amendment Request
1.0 DESCRIPTION
This submittal is a request to amend Special Nuclear Materials (SNM) license SNM-2508 for the Three Mile Island Unit 2 (TMI-2) Independent Spent Fuel Storage Installation (ISFSI).
The proposed changes would revise the SNM license 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). The 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 to change references to Department of Energy (DOE) Idaho Operations office (DOE-ID) to DOE ICP and correct spacing. An additional proposed change would revise the language in TS 5.5.1 regarding changes to the TS Bases Control Program.
2.0 PROPOSED CHANGE
S The following changes to the TMI-2 ISFSI license and TSs are proposed:
- Revise License Condition 11 to delete delegated, Deputy, Department of Energy, and delegation, and insert designated, for the, the (ICP) acronym, and designation so that it states The Secretary of Energy has designated the Manager for the Idaho Cleanup Project (ICP) as the Secretarys authorized representative in all matters regarding this license and future amendments thereto and informed the Commission of this designation in writing.
- Revise License Condition 11 with the date of submittal of this License Amendment Request.
- Revise License Condition 14, to replace DOE-ID with Department of Energy (DOE) ICP and insert ICP between DOE and contractor wherever it is called out in the condition so that it clearly specifies the DOE ICP contractor.
- Revise License Condition 15, to replace DOE-ID with DOE wherever it appears in the condition.
- Revise TS 5.1.1 to delete Deputy, Idaho Cleanup Project, the parentheses around ICP and (DOE-ID), and insert the so that it states The Manager for the ICP is responsible.
- Revise TS 5.2.1.2 to delete Deputy, Idaho Cleanup Project (DOE-ID), and delegated, and insert the ICP and designated so that it states The Manager for the ICP, as designated.
- Revise TS 5.4.1, 5.4.1.L, 5.4.1.N, and 5.4.2 to insert spaces as marked.
Additionally, revise TS 5.4.2 to replace DOE-ID with DOE Idaho Operations Office.
- Revise TS 5.5.1.b.2 to delete statement that changes may be made to the TS Bases without prior NRC approval provided that the changes do not involve a change to the SAR or Bases which involves an unreviewed safety question, a significant increase in occupational exposure, or a significant unreviewed environmental impact as defined in 10 CFR 72.48. Replace the deleted words with requires a license amendment according to the criteria of. This wording updates the TS to refer to the regulation and eliminates outdated language.
- Revise TS 5.5.2.7 to replace DOE-ID with DOE ICP.
- Revise TS 5.6.1 to delete DOE-ID in 2 locations and insert for the ICP after the word Manager so that it states Manager for the ICP or the TMI-2 Facility Director.
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, revise DOE-ID references to DOE ICP, and correct an outdated reference to an NRC regulation. A red-line markup of the license and TSs is attached containing the proposed changes.
No associated changes to the Technical Specification Bases are required as a result of the proposed changes.
As a result of these proposed changes, changes will be necessary to the TMI-2 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.
This request also replaces references to DOE-ID with DOE ICP more clearly referencing the DOE organization managed by the Office of Environmental Management.
Additionally, an outdated reference to NRC regulatory language is being updated so that the language of the TS more closely aligns with regulatory requirements.
Some technical editing and formatting changes are 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. Changes to regulation references and associated wording addressing use of the 72.48 review process for changes to the TS Bases aligns the wording in the TS with current NRC regulatory language.
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 TMI-2 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.