Text

Amendment No. 3 to Materials License No. Snm-2512 for the Idaho Spent Fuel Facility Independent Spent Fuel Storage Installation
	ML24332A158
Person / Time
Site:	07200025
Issue date:	06/06/2017
From:	John Mckirgan; Office of Nuclear Material Safety and Safeguards
To:	Provencher R; Office of Nuclear Material Safety and Safeguards
Shared Package
ML24332A156	List: ML24332A157; ML24332A158; ML24332A159;
References
	L25149, CLN250091
	Download: ML24332A158 (1)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, O.C. 20555-0001 Mr. Richard Provencher, Manager Department of Energy Idaho Operations Office 1955 Fremont Avenue Idaho Falls. Idaho 83415 June 6, 2017

SUBJECT:

AMENDMENT NO. 3 TO MATERIALS LICENSE NO. SNM-2512 FOR THE IDAHO SPENT FUEL FACILITY INDEPENDENT SPENT FUEL STORAGE INSTALLATION

Dear Mr. Provencher:

By letter dated September 8, 2016, the Department of Energy (DOE) requested an amendment to Special Nuclear Materials License No. 2512 for the Idaho Spent Fuel Facility Independent Spent Fuel Storage Installation. In its application, the applicant requested to change the licensee delegation of authority in the license, technical specifications, and final safety analysis report. These documents currently delegate authority under the license to the Manager, DOE Idaho Operations Office. The amendment replaces this reference with the Deputy Manager, Idaho Cleanup Project in each of the documents.

Based on our review of your application, the NRC staff has determined that there is reasonable assurance that: (i) the activities authorized by the amended license can be conducted without endangering the health and safety of the public, and (ii) these activities will be conducted in compliance with the applicable regulations. NRC staff has further determined that the issuance of the amendment will not be inimical to the common defense and security. In addition, the staff determined that issuance of Amendment No. 3 meets the criteria for a categorical exclusion in 1 O CFR 51.22(c)(11 ). Therefore, the staff will not prepare an environmental assessment or environmental impact statement.

The NRC has approved the requested amendment. The amended license supersedes Special Nuclear Materials License No. SNM-2512, Amendment No. 2, dated September 18, 2015.

Revised Technical Specifications and the staff's Safety Evaluation Report are also enclosed.

Changes made to the enclosed license and Technical Specification pages are indicated by vertical lines in the right margin. In accordance with 1 O CFR 72.46, the NRC will publish a Notice of Issuance of the amended license in the Federal Register.

In accordance with 1 O CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the publicly available records component of the NRC's Agencywide Documents Access and Management System (ADAMS). ADAMS is accessible from the NRC Website at http://www.nrc.gov/reading-rm/adams.html.

R. Provencher 2

If you have any questions regarding this matter, you may contact me at (301) 415-5722, or Mr.

Jose Cuadrado of my staff at (301) 415-0606.

Docket No.: 72-25 CAC No.: L25149

Enclosures:

1. Materials License No. SNM-2512 Amendment No. 3

2. Revised Technical Specifications

3. Safety Evaluation Report cc: Service List Jo McKirgan, Chief Sp t Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards

cc:

Mr. Richard B. Provencher Manager U. S. Department of Energy 1955 Fremont Avenue Idaho Falls, ID 83415 Mr. Steven Ahrendts Acting DOE-ID NRG Licensing Manager U.S. Department of Energy Idaho Operations Office 1955 Fremont Ave., MS-1222 Idaho Falls, ID 83415 Mr. Scott Ferrara FSVfrMl-2 Facility Director U.S. Department of Energy Idaho Operations Office 1955 Fremont Ave., MS-1222 Idaho Falls, ID 83415 Mr. Jack Zimmerman Deputy Manager for Idaho Cleanup Project U.S. Department of Energy 1955 Fremont Avenue Idaho Falls, ID 83415 Mr. David Bland Program Manager for NRG Licensed Facilities Spectra Tech Inc.

1955 Fremont Ave.

Idaho Falls, ID 83401 Mr. Robert Milazzo Business Manager for NRG Licensed Facilities Spectra Tech Inc.

1955 Fremont Ave.

Idaho Falls, ID 83401 Mr. Dennis Faulk U.S. EPA Region 10 Hanford/INL Project Office U.S. Environmental Protection Agency 309 Bradley Boulevard, Suite 115 Richland, WA 99352 The Honorable Blaine Edmo Chairman, Fort Hall Business Council Shoshone-Bannock Tribes P. 0. Box 306 Fort Hall, ID 83203 Ms. Talia Martin Director, Tribal DOE Program Shoshone-Bannock Tribes P.O. Box 306 Fort Hall, ID 83203 Snake River Alliance Beatrice Brailsford Nuclear Program Director PO Box 1731 Boise, ID 83701 Ms. Susan Burke I NL Oversight Coordinator DEQ State Office 1410 N. Hilton Boise, ID 83706 Mr. John Tanner Coalition 21 2175 Tasman Ave Idaho Falls, ID 83404 Chairman INL Committee Idaho Falls Chamber of Commerce P.O. Box 50498 Idaho Falls, ID 83405-0498 Mr. Chuck Broscious Environmental Defense Institute P.O. Box 220 Troy, ID 83871-0220 Mr. Bruce LaRule State of Idaho INL Oversight Program 900 N. Skyline Drive, Suite C Idaho Falls, l 0 83402

Mr. Herb Bohrer Chair, Citizens Advisory Board clo Ms. Jordan Davies North Wind 1425 Higham Street Idaho Falls, ID 83402 Chairman INL EM Site Specific Advisory Board clo Lori MacNamara North Wind Group 1425 Higham St.

Idaho Falls, ID 83402 NRC Liaison State of Idaho I NL Oversight Program 900 N. Skyline Drive, Suite C Idaho Falls. ID 83402

DEPARTMENT OF ENERGY DOCKET NO. 72-25 IDAHO SPENT FUEL FACILITY MATERIALS LICENSE NO. SNM-2512

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The amendment application dated September 8, 2016, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 1 O CFR Chapter I;*

B.

The Idaho Spent Fuel Facility Independent Spent Fuel Storage Installation will continue to operate in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance that (i) the activities authorized by this amendment can be conducted without endangering public health and safety, and (ii) such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to public health and safety; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by the enclosed changes to Materials License No.

SNM-2512, indicated by margin notations.

3.

This license amendment is effective as of the date of its issuance.

Enclosure:

Amended License Date of Issuance: 6/6/17 F.OR JHE U.S. NUCLEAR REGULATORY COMMISSION hnMc~a7.~

pent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards

NRC FORM 588 (10-2000) 10 CFR 72 U. S. NUCLEAR REGULATORY COMMISSION PAGE 1

OF _g_ 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 wilh 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 ii 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.

Licensee

1.

Department of Energy

2.

U. S. Department of Energy Idaho Operations Office 1955 Fremont Avenue

6.

Byproduct, Source, and/or Special Nuclear Material A. Spent nuclear fuel elements from the Peach Bottom Unit 1 reactor and various TAIGA reactors, reflector modules and rods from the Shippingport reactor, and associated radioactive materials and components related to their receipt, transfer and storage.

3.

License No.

SNM-2512 Amendment No.

3

4.

5.

Expiration Date Docket or Reference No.

7. Chemical or Physical Form A. Spent fuel elements from the Peach Bottom Unit 1 reactor, as UC and ThC. TAIGA spent fuel elements as uranium*

zirconium hydride alloy with aluminum or stainless steel clad. Shippingport reflector modules and rods as Th02 with zircaloy-4 clad.

November 30, 2024 72-25

8.

Maximum Amount That licensee May Possess at Any One Time Under This License A. 2.95 metric tons of heavy metal (MTHM) for the Peach Bottom Unit i spent fuel elements; i 8.95 MTHM for the Shippingport reflector modules and rods; 0.32 MTHM for the TAIGA spent fuel elements.

9.

Authorized Use: The material identified in 6.A. and 7.A. above is authorized for receipt, possession, storage and transfer in the Idaho Spent Fuel Facility, as described in the Idaho Spent Fuel Facility Safety Analysis Report dated November 19, 2001, as revised or supplemented on November 8, 2002, and on March 28 and November 14, 2003, and as further supplemented and amended in accordance with 10 CFR 72.70 and 10 CFR 72.48.

10.

Authorized Place of Use: The licensed material is to be received, possessed, transferred and stored at the Idaho Spent Fuel Facility, located at the Idaho National Engineering and Environmental Laboratory in Butte County, Idaho.

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. The Appendix contains Technical Specifications related to environmental protection to satisfy the requirements of 1 O CFR 72.44(d)(2).

12.

The licensee shall follow the physical protection plan entitled, "Idaho Spent Fuel Facility Physical Protection Plan," dated November 19, 2001, as revised November 10, 2003, and the Safeguards Contingency Plan and the Security Training and Qualification Plan incorporated therein, and as they may be further amended under the provisions of 10 CFR 72.44(e) and 10 CFR 72. i 86.

NRC FORM 58BA U. S. NUCLEAR REGULATORY COMMISSION PAGE 2

OF 2

(Hl*2000)

License No.

I Amendment N;.

10 CFA 72 LICENSE FOR INDEPENDENT STORAGE OF SPENT NUCLEAR SNM*2512 FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Docket or Reference No.

SUPPLEMENTARY SHEET 72*25

13.

The licensee shall follow the Idaho Spent Fuel Facility Emergency Plan dated November 19, 2001, as revised or supplemented on March 28 and November 14, 2003, and as further supplemented and revised in accordance with 10 CFR 72.44(f).

PAGES

14.

Pursuant to 10 CFR 72. 7, the licensee is hereby exempted from the provisions of 10 CFR 72.30(c) regarding decommissioning financial assurance requirements, and from the provisions of 1 O CFR 72.102(f)(1) regarding the seismic design criteria of 1 O CFR Part 100, Appendix A. The exemption to 1 O CFR 72.30(c) allows the licensee to demonstrate financial assurance for decommissioning of the ISF Facility based on the U.S. Department of Energy's Statement of Intent to obtain required decommissioning funds when needed. The exemption to 1 O CFR 72.102(f){1) allows the licensee to use a Probabilisitic Seismic Hazards Analysis methodology to calculate the design earthquake values to be used in the facility design.

15.

The licensee shall maintain a current Statement of Intent from the U.S. Department of Energy in which the Department commits to make a timely request for the necessary funds from the United States Congress for the decommissioning of the ISF Facility, based on decommissioning cost estimates throughout the entire term of the license. The licensee shall promptly notify NRC, in writing, of any changes to the current contract with DOE for the ISF Facility (Contract No. DE-AC07-00ID13729) that would significantly impact the decommissioning cost estimates.

The licensee shall provide to NRC an updated estimate of the operations, maintenance, security and decommissioning costs at a minimum of every 5 years; or in a timely manner whenever these costs are significantly impacted (such as a change in storage capacity, imposition of additional security requirements, etc.).

16.

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

Date of Issuance: 6/6/17

Attachment:

Appendix - Technical Specifications FOR THE U.S. NUCLEAR REGULATORY COMMISSION n McKirgan1 Chief ent Fuel Licensing Branch Division of Spent Fuel Management Office of Nuclear Material Safety and Safeguards Washington, DC 20555

APPENDIX TECHNICAL SPECIFICATIONS FOR THE IDAHO SPENT FUEL FACILITY Docket No. 72-25 Materials License No. SNM-2512

Technical Specifications Table of Contents 1.0 USE AND APPLICATION.............................................................................................................. 1 1.1 Definitions................................................................................................................................ l 1.2 Logical Connectors................................................................................................................... 3 1.3 Co1npletion Times.................................................................................................................... 5 1.4 Frequency................................................................................................................................. 8 2.0 APPROVED CONTENTS............................................................................................................... 11 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY....................................... 13 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY........................................................ 14 3.1 Canister Integ1ity...................................................................................................................... 15 3.1. l Canister Integrity........................................................................................................... 15 3.2 STORAGE TUBE Integrity..................................................................................................... 17 3.2.1 STORAGE TUBE Pressure and Interseal Leak Rate.................................................... 17 3.2.2 Storage Vault Heat Removal System............................................................................ 20 3.3 Criticality Control Program...................................................................................................... 22 3.3.1 Fuel Packaging Area Limits.......................................................................................... 22 3.3.2 Criticality Monitoring System....................................................................................... 24 3.4 Fuel Packaging Area Confinement Boundary.......................................................................... 26 3.4. l Heating, Ventilation, Air Conditioning (HY AC) System............................................. 26 4.0 DESIGN FEATURES...................................................................................................................... 28 4.1 Design Features Significant to Safety............ :.......................................................................... 28 4.1.1 Criticality Control......................................................................................................... 28 4.1.2 Materials....................................................................................................................... 28 4.2 Codes and Standards................................................................................................................ 29 4.2. l Alternatives to Design Codes, Standards, and C1iteria................................................. 29 4.2.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria..................... 29 4.3 SPENT NUCLEAR FUEL Handling Equipment..................................................................... 30 4.3.1 ISF Facility Cranes and Trolleys................................................................................... 30 4.3.2 Lifting Devices.............................................................................................................. 30 4.3.3 Peach Bottom Transfer Casks....................................................................................... 30 5.0 ADMINISTRATIVE CONTROLS.................................................................................................. 33 5.1 Responsibility........................................................................................................................... 33 5.2 Organization............................................................................................................................. 34 5.2. l Onsite and Offsite Organizations.................................................................................. 34 5.3 ISF Facility Staff Qualifications............................................................................................... 35 5.4 Procedures................................................................................................................................ 36 5.5 Programs................................................................................................................................... 37 5.5. l Technical Specifications Bases Control Program.......................................................... 37 5.5.2 Radioactive Effluent Control Program.......................................................................... 38 5.5.3 Fuel Handling Program................................................................................................'. 39 5.5.4 Fire Protection Program................................................................................................ 40 5.5.5 Radiation Protection Program....................................................................................... 41 5.5.6 Essential Program Control Program.............................................................................. 43 Idaho Spent Fuel Facility

1.0 USE AND APPLICATION I. I Definitions Definitions I. I

N 0 TE - ----- --:-------------- ---- --------------------

The defined terms of this sectio11 appear in capitalized Lype and are applicable throughout these ISF Facility Technical Specifications and Bases.

ACTIONS CANISTER HANDLING CHANNEL CHECK Definition ACTIONS shall be rhal part of a Specification that prescribes Required Actions to be taken under the designated Conditions within the specified Completion Times.

CANISTER HANDLJNG exists when SPENT NUCLEAR FUEL is contained in an ISF CANISTER that has passed its leak rate acceptance test and is not within a STORAGE TUBE that has passed its interseal leak rale acceptance tesl.

A CHANNEL CHECK is the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indicf}tion and Status Lo other indications and status de1ived from independent instrument channels measuling the same parameter.

CHANNEL FUNCTIONAL TEST A CHANNEL FUNCTIONAL TEST is the injection of a simulated or actual signal into the channel as close to the sensor as practicable to verify OPERABILITY, including required alarms, interlocks, dispfoy, and trip functions.

ISF CANISTER The ISF CANISTER is the sealed SPENT NUCLEAR FUEL container that consists of a cylindlical shell with welded upper und lower closure heads. The ISF CANISTER provides for the canning of consolidated fuel rods or unconsolidared assemblies to meet the requirements of I 0 CFR 72. I 22(h)( I). The !SF CANISTER also provides the primary confinement for the stored SPENT NUCLEAR FUEL.

(continued) ldaJ10 Spent Fuel Facility

1.1 Definitions {continued)

LOADING OPERATIONS OPERABLE/OPERABILITY RECEIPT OPERATIONS SPENT NUCLEAR FUEL STORAGE OPERATIONS STORAGE TUBE Idaho Spent Fuel Facil.ity Definitions I. I LOADING OPERATIONS include activities associated with packaging SPENT NUCLEAR FUEL into ISF canisters. LOADING OPERATIONS exist whenever SPENT NUCLEAR FUEL is present in a transfer cask without a restrained closure lid (i.e., either the transfer cask closure lid bolts are not fully tensioned or the cask adapter remote release lid restraints are not folly engaged);

SPENT NUCLEAR FUEL is in the Pue! Packaging Area; or SPENT NUCLEAR FUEL is.in an ISF CANISTER that has not completed its leak rate acceptance test.

A system, component, or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified safety function(s) and when all necessary attendant instrnmentation, control,

normal or emergency electrical power, and other auxiliary equipment required for the system, component, or device to perform its specified impo11ant to safety funclion(s) are also capable of perf arming rheir related support functions.

RECEIPT OPERATIONS include all activities associated with handling SPENT NUCLEAR FUEL while it is contained in a transfer cask with a restrained closure lid (i.e., either the transfer cask lid closure bolts are fully tensioned or the cask adapter remote release lid restraints are fully engaged).

SPENT NUCLEAR FUEL means fuel that has been withdrawn from a nuclear reactor following in*ac.Jiation, has undergone at least one year's decay since being used as a source of energy in a power reactor and has not been chemically separated into its constilllents eleme1lls by reprocessing. SPENT NUCLEAR FUEL includes the special nuclear matetial, byproduct material, source material, and other radioactive materials associated with fuel assemblies.

STORAGE OPERATIONS exist when an ISF CANISTER is contained within a STORAGE TUBE that has passed its interseal leak rate acceptance test.

The STORAGE TUBE is the sealed ISF CANISTER container, which consists of a cylindrical shell, shield plug, and a bolted closure plate.

The STORAGE TUBE provides the secondary confinement boundary for the stored radioactive materials.

2

1.0 USE AND APPLICATION 1.2 Logical Connectors PURPOSE BACKGROUND Idaho Spent Fuel Facility Logical Connectors 1.2 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 may appear in TS are AND and OR. The physical arrangement of these connectors constitutes logical conventions with specific meanings.

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 indentations 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 Completion Time, Surveillance, or Frequency.

3

1.2 Logical Connectors (continued)

EXAMPLES The following examples illustrate the use of logical connectors.

EXAMPLE 1.2-1 ACTIONS CONDITION REQUIRED ACTION A. LCO not met A.1 Verify....

AND A.2 Restore...

Logical Connectors 1.2 COMPLETION TIME In this example the logical connector AND is used to indicate that when in Condition A, both required Actions A.l, and A.2 must be completed.

EXAMPLE 1.2-2 ACTIONS CONDITION A. LCO not met REQUIRED ACTION A.1 OR Stop....

A.2.1 Verify...

AND A.2.2. l Reduce...

OR A.2.2.2 Perform...

OR A.3 Remove...

COMPLETION TIME This example represents a more complicated use of logical connectors. Required Actions A. l, 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. l or A.2.2.2. The indented position of the logical connector OR indicates that A.2.2. l and A.2.2.2 are alternative choices, only one of which must be performed.

Idaho Spent Fuel Facility 4

1.0 USE AND APPLICATION 1.3 Completion Times PURPOSE BACKGROUND DESCRIPTION Idaho Spent Fuel Facility Completion Times 1.3 The purpose of this section is to establish the Completion Time convention and to provide guidance for its use.

Limiting Conditions for Operation (LCOs) specify the lowest functional capability or pe1formance levels of equipment required for safe operation of the facility. The ACTIONS associated with an LCO state Conditions that typically desctibe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s).

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 ente1ing 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.

(continued) 5

1.3 Completion Times (continued)

Completion Times 1.3 EXAMPLES The following examples illustrate the use of Completion Times with differnnt types of Conditions und changing Conditions..

EXAMPLE 1.3-1 ACTIONS CONDITION REQUIRED ACTTON COMPLETION TiME B. Required Action and B.J Per form Action 8. 1 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion AND Ti mes not met B.2 Pe1form Action 8.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Condition B has two Required Actions. Each Required Action has its own separate Completion Time. Each Completion Time is referenced lo the time that Condition B is entered.

The Required Actions or Condition B are to complete action B. J 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. I 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 aclion 8. I ls 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 8.2 is 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

EXAMPLE J.3-2 ACTIONS CONDlTlON REQUIRED ACTION COMPLETlON TIME A. One system not within A. l Restore system 10 7 days limits.

within limit B. Required Action and B. I Complete action B. I 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion Time not met.

AND B.2 Complete action B.2 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a system is determined to not meet the LCO, Condition A is entered. If lhe system is not restored within 7 days, Condition Bis also entered and the Completion Time clocks for Required Actions B. I and B.2 ~ta.ii. If the system is restored after Condition B is entered, Conditions A and Bare exited, and therefore, the Required Actions of Condition B may be terminated.

Idaho Spent Fuel Facility 6

1.3 Completion Times (continued)

EXAMPLE 1.3-3 Completion Times 1.3

N 0 TE ----------------------------------------------

Separate Condition entry is allowed for each component.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.l Restore compliance 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months with LCO.

B. Required Action and B.l Complete action B. l 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion AND Time not met.

B.2 Complete action B.2 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 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 stmts. If subsequent components me 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 COMPLETION TIME Idaho Spent Fuel Facility When "Immediately" is used as a Completion Time, the Required Action should be pursued without delay and in a controlled manner.

7

1.0 USE AND APPLICATION 1.4 Frequency PURPOSE DESCRIPTION Idaho Spent Fuel Facility Frequency 1.4 The purpose of this section is to define the proper use and application of Frequency requirements.

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 coITect application of the specified Frequency is necessary for compliance with the SR.

The "specified Frequency" is refened to throughout this section and each of the Specifications of Section 3.0, Surveillance Requirement (SR) Applicability. The "specified Frequency" consists of the requirements of the Frequency column of each SR as well as ce1tain Notes in the Surveillance column that modify pe1formance 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 pe1formed 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 pe1formed.

With a SR satisfied, SR 3.0.4 imposes no restriction.

(continued) 8

J.4 Frequency (continued)

Frequency l.4 EXAMPLES The following examples illusLrate the various ways 1ha1 Frequencies are specified.

EXAMPLE 1.4-1 SURVEILLANCE REQUIREMENTS SURVElLLANCE 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 mosl often encountered in the Techni<.:aJ Specifications (TS). The Frequency specifies an interval ( 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) duting which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the ubsequent 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 lime interval to J.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continue

at all time, even when the SR is not required to be met per SR 3.0. l (such as when a variable is outside specified limits, or the facility is outside the Applicability of the LCO). ff the interval pccified by SR 3.0.2 is exceeded while che facility is in a condition specified in the Applicability of the LCO, the LCO is nor 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)

Idaho Spenl Fuel Facility 9

1.4 Frequency (continued)

EXAMPLE 1.4-2 SURVEILLANCE REQUIREMENTS SURVEILLANCE Ve1ify flow is within limits.

FREQUENCY Frequency 1.4 Once within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months p1ior 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 pe1formed, the Surveillance must be performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months plior to staiting 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 pe1formances 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 pe1formed, the measurement of both intervals stops.

New intervals stait upon prepaifog to restart the specified activity.

Idaho Spent Fuel Facility 10

Approved Contents 2.0 2.0 APPROVED CONTENTS 2.1 The ISF Facility shall be limited to the receipt, packaging, and storage of the following SPENT NUCLEAR FUEL:

Peach Bottom fuel elements with characteristics as described in Table 2-1, Shippingport fuel rods with characteristics as described in Table 2-2, and TRIGA fuel elements with characteristics as described in Table 2-3.

Table 2-1.

Spent Fuel Limits - Peach Bottom Fuel Characteristic Limit Cladding Graphite Maximum Fuel Enrichment 16 w/o uranium enriched to 93.15%

23su Maximum Decay Heat per ISF CANISTER 33 w Fuel Design High-temperature gas-cooled with graphite moderation Maximum Bumup 900 EFPD Table 2-2.

Spent Fuel Limits -Shippingport L WBR Fuel Characteristic Limit Cladding Zircaloy-4 Maximum Fuel Enrichment Not applicable Maximum Decay Heat per ISF CANISTER lOW Fuel Design L WBR Th02 Type IV N reflector Maximum Burnup 30,000 EFPH (continued)

Idaho Spent Fuel Facility 11

2.0 APPROVED CONTENTS (continued)

Table 2-3.

Approved Contents 2.0 Spent Fuel Limits - Training Research Isotope Production General Atomics (TRIGA)

Fuel Characteristic Limit Cladding Aluminum or Stainless Steel Maximum Enrichment 9 w/o uranium emiched to 20%

23su Maximum Decay Heat per ISF CANISTER 36W 2.2 The decay heat load of the ISF Facility storage vaults shall not exceed the limits shown in Table 2-4.

Vault l Vault 2 Idaho Spent Fuel Facility STORAGE TUBE Heat Load (Watts) 40 120 40 120 Table 2-4 ISF Facility Heat Load Limits Number of STORAGE TUBES 76 26 132 12 Total 12 Heat Load Vault Heat (Watts)

Load (Watts) 3040 6160 3120 5280 6720 1440 12880

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.l LCO 3.0.2 LCO 3.0.3 LCO 3.0.4 LCO 3.0.5 LCOs shall be met dming specified conditions in the Applicability, except as provided in LCO 3.0.2.

Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Actions(s) is not required, unless otherwise stated.

Not applicable to an ISFSI.

When an LCO is not met, entry into a specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in specified conditions in the Applicability that are required to comply with ACTIONS.

Equipment removed from service or 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.

Idaho Spent Fuel Facility 13

SR Applicability 3.0 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.l SR 3.0.2 SR 3.0.3 SR 3.0.4 SRs shall be met during specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a SR, whether such failure is experienced dming the pe1formance of the Surveillance or between pe1formances of the Surveillance, shall be failure to meet the LCO. Failure to pe1form 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 pe1formed on inoperable equipment or vmiables outside specified limits.

The specified Frequency for each SR is met if the Surveillance is pe1formed within 1.25 times the interval specified in the Frequency, 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 pe1formance.

Exceptions to this Specification are stated in the individual Specifications.

If it is discovered that a surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 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 pe1formed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

When the Surveillance is pe1formed within the delay period and the Surveillance is not met, the LCO must immediately be declm*ed not met, and the applicable Condition(s) must be entered.

Entry into a specified condition in the Applicability of an LCO shall not be made unless the LCO's SRs 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 or that are related to unloading of a STORAGE TUBE.

Idaho Spent Fuel Facility 14

3.1 Canister Integrity 3.1.1 Canister lmegrity LCO 3. 1. l APPLICABILITY:

Canister Integrity 3.1.I The ISF CANISTER helium leak rate shall be :::; I o*~ std cm3/sec at a pressure of 19-21 psia at 80-100°F.

CANISTER HANDUNG, STORAGE OPERA TTONS ACTIONS:

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

Separate Condition entry is allowed for each !SF Canister.

CONDITION A. LCO not met.

Idaho Spent Fuel Facility REQUIRED ACTION COMPLETJON TIME A.1 Establish ISF CANISTER Prior to CANISTER pressure and fi ll helium HANDLING leak rate within limits.

(continued) 15

SURVEILLANCE REQUIREMENTS SURVEILLANCE Canister Integrity 3.1.J FREQUENCY SR 3.1. l.

Verify ISF CANISTER fill Once prior to CANISTER HANDLING.

pressure and helium leak rate is within limits.

Idaho Spent Fuel Facility 16

STORAGE TUBE Pressure and Interseal Leak Rate 3.2. 1 3.2 STORAGE TUBE Integrity 3.2. l STORAGE TUBE Pressure and Interseal Leak Rate LCO 3.2. l The STORAGE TUBE interseal leak rate shall be ::: 10*4 std cm3/sec at a pressure within the limits of Figmc 3.2-l.

APPLICABILITY:

STORAGE OPERA TJONS ACTIONS:

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

Separate Condition entry is allowed for each STORAGE TUBE containing an ISF CANISTER.

CONDITION A. LCO not met.

Idaho Spent Fuel Facility REQUIRED ACTION A. l Restore STORAGE TUBE pressure and intcrscal leak rate within limits.

17 COMPLETION TIME 30 days (continued)

STORAGE TUBE Pressure and lnterseal Leak Rate 3.2.1 3.2 STORAGE TUBE Integrity 23.0

<U ! 22.0

~ 21.0

l IJ)

IJ)

~

c..

w al 1-w CJ

<I:

0::

0 I-m 20.0 - -

18.0 17.0 16.0 -

15.0 14.0 Figure 3.2-1 STORAGE TUBE Helium Fill Pressure Limits

~----

Minimum Helium Fill Pressure 40 30 20 10 -5 0

5 10 15 20 25 30 35 40 45 50 55 60 65 70 75 80 85 90 95 100 105 Environmental Ambient Temperature (deg F)

(continued)

Idaho Spent Fuel Facility 18

STORAGE TUBE Pressure and Jnterseal Leak Rate 3.2. l SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.2.1.1 Verify STORAGE TUBE pressure and interseal leak rate within specified limits.

SR 3.2.1.2 Verify STORAGE TUBE pressure and interseal leak rate within specified limits.

Idaho Spent Fuel Facility 19 FREQUENCY Prior to commencing STORAGE OPERATIONS for the STORAGE TUBE being tested.

Annually for I occupied STORAGE TUBE from each storage vault.

Storage Vault Heat Removal System 3.2.2 3.2 STORAGE TUBE Integrity 3.2.2 Storage Vault Heat Removal System LCO 3.2.2 The Storage Vault Heat Removal System for each occupied STORAGE TUBE shall be OPERABLE.

APPLICABILITY:

STORAGE OPERATIONS ACTIONS:

N 0 TE------------------------------------------------

Separate Condition entry is allowed for each STORAGE TUBE containing an ISF CANISTER.

CONDITION REQUIRED ACTION COMPLETION TIME A. LCO not met.

A.I Restore Storage Vault 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Heat Removal System to OPERABLE status.

B. Required Action and B.I Transfer the ISF 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months associated Completion CANISTER to an Time not met.

unaffected STORAGE TUBE.

(continued)

Idaho Spent Fuel Facility 20

SURVEILLANCE REQUIREMENTS SURVEILLANCE Storage Vault Heat Removal System 3.2.2 FREQUENCY SR 3.2.2.

Visually inspect all inlet air 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months vents, outlet air vents, and occupied STORAGE TUBE annular outlets for blockage.

Idaho Spent Fuel Facility 2 1

3.3 Criticality Control Program 3.3.1 Fuel Packaging Area Limits Fuel Packaging Area Limits 3.3.J LCO 3.3.1 Only one SPENT NUCLEAR FUEL type (i.e., Peach Bottom, Shippingport, or TRIGA) shall be present within the Fuel Packaging Area.

APPLICABILITY:

RECEIPT OPERATIONS, LOADING OPERATIONS ACTIONS:

CONDITION A. LCO not met.

Jdaho Spent Fuel Facility REQUIRED ACTION A. I Suspend LOADING OPERA TIO NS.

ANO A.2 AND A.3 22 Perform an evaluation and develop a recovery plan to restore Fuel Packaging Area such that it contains only one SPENT NUCLEAR FUEL type.

Restore Fuel Packaging Area such that only one SPENT NUCLEAR FUEL type is present COMPLETION TIME Immediately 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 90 days (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.3.1.1 Verify SPENT NUCLEAR FUEL type in transfer cask.

SR 3.3.J.2 Verify SPENT NUCLEAR FUEL type in Fuel Packaging Area Idaho Spent Fuel Facility 23 Fuel Packaging Area Limits 3.3. 1 FREQUENCY Prior to transferring transfer cask loaded with SPENT NUCLEAR FUEL into Transfer Tunnel Once during visual inspection of first fuel package unloaded from each transfer cask.

3.3 Criticality Control Program 3.3.2 Criticality Monitoring System Cri1icality Monitoring System 3.3.2 LCO 3.3.2 The criticality monitoring system shall be OPERABLE.

APPLTCABlLITY:

LOADING OPERA TlONS wi1h SPENT NUCLEAR FUEL in the Fuel Packaging Area.

ACTIONS:

CONDITION A. LCO not met.

Jdaho Spent Fuel Facility REQUJRED ACTION A. I Suspend LOADING OPERATIONS.

AND A.2 Restore criticality monitoring sys1em co operable status.

24 COMPLETION TJME Immediately Prior to resuming fuel movement.

(con1inued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.3.2. 1 Pe1form a CHANNEL CHECK of criticality monitoring system.

SR 3.3.2.2 Perform a CHANNEL FUNCTIONAL TEST of criticality monitoring system.

Idaho Spent Fuel Facilily 25 Criticality Monitoring Sysccm 3.3.2 FREQUENCY Within I hour prior to commencing LOADING OPERATIONS in the Fuel Packaging Area and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter.

Once, wirhin 7 days prior Lo initial LOADING OPBRATlONS in the Fuel Packaging Area and every 12 months thereafter.

3.4 Fuel Packaging Area Confinement Boundary 3.4. I Heating, V entilation, Air Conditioning (HY AC) System LCO 3.4. l HY AC System shall be OPERABLE.

APP LI CAB ILJTY:

LOADING OPERATIONS ACTIONS:

CONDlTTON A. LCO not met.

REQUIRED ACTION A. I Suspend SPENT NUCLEAR FUEL movement.

A.2 Verify all supply fans deenergized A.3 Ensure confinement penetration boundaries closed.

HVACSystem 3.4. 1 COMPLETION TIME Immediately Immediately I hour A.4 Commence air monitoring. Within I hour of ldnho Spent Fuel Facility 26 HVAC system declared INOPERABLE and every 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter.

(continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR.3.4.1.1 Verify 1 Transfer Area exhaust fan running.

HVAC System 3.4.1 FREQUENCY Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months prior to commencing LOADING OPERATIONS.

AND Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months during LOADING OPERATIONS.

SR 3.4.1.2 Verify HVAC primary exhaust Within I hour prior to commencing HEPA filter differential LOADING OPERA TIO NS.

pressure is >0 in w.g. and < 4 in w.g.

SR 3.4.1.3 Verify the following Fuel Packaging Area access po11 conditions:

Idaho Spent Fuel Facility Cask p011 plug in place OR Transfer cask positioned beneath cask port and associated seal inflated AND Canister port plug in place OR Canister cask positioned beneath canister port and associated seal inflated.

AND Waste p011 plugs in place OR SPENT NUCLEAR FUEL in designated storage locations in Fuel Packaging Area.

27 AND Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months dming LOADING OPERATIONS.

Within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months p1ior to commencing LOADING OPERA TIO NS with SPENT NUCLEAR FUEL in the Fuel Packaging Area.

AND Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months when SPENT NUCLEAR FUEL is in the Fuel Packaging Area.

4.0 DESIGN FEATURES

4. l Design Features Significant to Safety 4.1.1 Criticality Control Design Features Significant co Safety 4.1 ISF CANISTER loading shall not exceed the following limits:

SPENT NUCLEAR FUEL Maximum Loading per ISF CANISTER Peach Bottom I 0 elements TRIG A l 08 clements Shippingpott LWBR l reflector module or 127 loose rods 4.1.2 Materials I. Confinement boundary materials The STORAGE TUBE and lid shall be constructed of carbon sceel to form a pressure vessel.

The lSF CANISTER and lid shall be constructed of stainless steel to form a pressure vessel.

2. Confinemenl boundary seals During STORAGE OPERA TJONS, SPENT NUCLEAR FUEL shall be confined in a welded ISF CANISTER within a bolted STORAGE TUBE employing redundant ring seals.

Idaho Spent Fuel Facility 28

4.0 DESIGN FEATURES 4.2 Codes and Standards Codes and Standards 4.2 The following are the governing codes for the ISF Facility storage component design:

Storage Component Applicable Codes Editions I Application Imp01tant to Safety Years Design Fabrication STORAGE TUBE ASME Boiler and Pressure Vessel Code 1998 with (B&PVC),Section II 2000 addenda ASME B&PVC, Section Ill, Division I, Yes Yes Subsection NCA, NC, and Appendix F ASME B&PVC,Section V ASME B&PVC,Section IX ISF CANISTER ASME B&PVC,Section II 1998 with 2000 ASME B&PVC,Section III, Division I, addenda Subsections NCA, NB, Appendix F Yes Yes ASME B&PVC,Section V ASME B&PVC,Section IX ISF Basket ASME B&PVC,Section II, 1998 with No. In 2000 accordance ASME B&PVC,Section III, Division 1, addenda Yes with ISF Subsections NCA, NF, NG, & Appendix F Quality Program Plan 4.2.1 Alternatives to Design Codes, Standards, and Criteria No alternatives to the codes listed in 4.2 above have been used in the design of the ISF Facility.

4.2.2 Construction/Fabrication Alternatives to Codes, Standards, and Criteria Proposed alternatives to the codes listed in 4.2 above may be used when authorized by the Director of the Office of Nuclear Material Safety and Safeguards or designee. The request for such alternatives should demonstrate that:

I. The proposed alternatives would provide an acceptable level of quality and safety, or

2. Compliance with the specified requirements of the codes listed in 4.2 above would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

Requests for alternatives shall be submitted in accordance with 10 CFR 72.4.

Idaho Spent Fuel Facility 29

4.0 DESIGN FEATURES 4.3 SPENT NUCLEAR FUEL Handling Equipment 4.3.1 ISF Facility Cranes and Trolleys SPENT NUCLEAR FUEL Handling Equipment 4.3 The components classified to be important to safety of the Cask Receipt Crane, the Fuel Handling Machine, the Canister Handling Machine, the Cask Trolley, and the Canister Trolley shall meet the requirements of NUREG-0554, "Single Failure Proof Cranes for Nuclear Power Plants", and NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants". These are considered supplemental requirements to the base code, Crane Manufactures Association of America Specification #70 (CMAA 70).

Other exceptions to CMAA 70 are tabulated below.

4.3.2 Lifting Devices All lifting devices used to raise or lower SPENT NUCLEAR FUEL shall be designed in accordance with ANSI N 14.6 - 1993, "Special Lifting Devices for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More".

Other exceptions to ANSI Nl4.6 are tabulated below.

4.3.3 Peach Bottom Transfer Casks The original design standard for the Peach Bottom transfer cask was 10 CFR 71. The original fab1ication crite1ia were contained in a set of detailed drawings and construction specifications prepared by Battelle Mem01ial Institute (BMI) and furnished to the cask fabricator. The BMI SAR for the Peach Bottom transfer casks contains six specifications and procedures that are referenced on the drawings. One of these six specifications and procedures cited ASME Section VIII Unfired Pressure Vessels 1962 Edition and Section IX Welding Qualification 1962 Edition for the welding of austenitic stainless steel and clad stainless steel by the Metallic Arc Process and the TIG process. ASTM is cited for base metals and filler metals within this same procedure.

The assembly basis was the set of detailed drawings and construction specifications.

The exceptions to Codes and Standards for the existing transfer casks are tabulated in Appendix A Table A4. 7-4 to the Safety Analysis Report.

Idaho Spent Fuel Facility 30

4.0 DESIGN FEATURES SPENT NUCLEAR FUEL Handling Equipment 4.3 Exceptions to Codes and Standards System, Structure, or Component: Cask Receipt Crane, Cask Trolley, Canister Trolley, Fuel Handling Machine, Canister Handling Machine Reference Code or Exception, Justification &

Standard Code or Standard Requirement Section/ Article Compensatory Measures Crane Manufacturers Various NUREG-0554 and NUREG-0612 Association of have been invoked and take America Specification precedence over CMAA 70

70 (CMAA 70) where applicable. NUREG-0554 and NUREG-0612 contain additional guidance provided by the NRC with respect to cranes.

Crane Manufacturers Section 3.2 Welding, 3.2. l All Welding is in accordance with Association of welding and designs and A WS D 1.1 "Structural Welding America Specification procedures shall conform to the Code - Steel". NUREG-0554

70 (CMAA 70) current issue of A WS D 14.1, cites use of portions of A WS "Specification for Welding Dl.l.

Industrial and Mill Cranes" Crane Manufacturers Section l. 7 Design Stresses, l. 7.1 Lifting devices that are load Association of

... All other load carrying paits carrying paits are designed, America Specification shall be designed so that the fab1icated, tested, and inspected

70 (CMAA 70) calculated static stress in the in accordance with ANSI Nl4.6 material, based on rated crane in lieu of the CMAA 70 criteria.

capacity, shall not exceed 20 NUREG-0612 defines the use of percent of the published average ANS Nl4.6 for special lifting ultimate strength of the material.

devices. ANSI Nl4.6 requires a safety factor on ultimate strength of the material of 5 on non-clitical loads and l 0 on c1itical loads that do not have redundant load paths.

Idaho Spent Fuel Facility 31

4.0 DESIGN FEATURES SPENT NUCLEAR FUEL Handling Equipment 4.3 Exceptions to Codes and Standards (Cont.)

System, Structure, or Component: Cask Receipt Crane, Cask Trolley, Canister Trolley, Fuel Handling Machine, Canister Handling Machine (Cont.)

Crane Manufacturers Section 1.4 Runway,... The Anchor bolts are in accordance Association of runway rails should be standard with AISC, Manual of Steel America Specification rail sections or any other Construction, 9th Edition.

70 (CMAA 70) commercial rolled sections with CMAA 70 does not provide an equivalent specifications of a explicit code or standard. The proper size for the crane to be NRC recognizes the use of AISC installed and must be provided for structural anchor bolts.

with proper rail splices and hold-down fasteners.

System, Structure, or Component: Special Lifting Devices used with the Fuel Handling Machine Reference Code or Exception, Justification &

Standard Code or Standard Requirement Section/ Article Compensatory Measures ANSI N 14.6 - 1993 Sections 4.3.5 Positive means of A friction grip device is used to attachment to the fuel under load handle Peach Bottom Core 2, in all handling positions and 7.1 b instrumented TRIGA, and L WBR Single failure proof design loose rod fuels. The handling features on the Peach Bottom Core 2 fuel element have been removed and the other two fuels do not contain specific handling features. The fuel handling operations in question will occur within the FPA confinement banier, and the fuels will be packaged and stored in a manner consistent with NRC requirements for failed fuel.

Under these conditions, dropping a fuel element will not result in unacceptable dose consequences during handling or storage.

Therefore, these exceptions are considered acceptable.

Idaho Spent Fuel Facility 32

5.0 ADMINISTRATIVE CONTROLS

5. 1 Responsibilily Responsi bi Ii ty 5.J The ISF Facility Director shnll be responsible for overall facility operation and shall delegate in writing the succession to this responsibility during his absence.

The ISF Facility Director or his dcsigncc shall approve, prior to implementation, each proposed change, test, or experiment to structures, systems, or components that are impo11ant to safety as defined in I 0 CFR 72.3.

Idaho Spent Fuel Facility 33

5.0 ADMINISTRA TfVE CONTROLS 5.2 Organization 5.2.1 Onsite and Offsite Organizations Organization 5.2 Onsite and offsite organizations shall be established for facility operation and corporate management, respectively. The onsite and offsite organizations shall include the positions for activities affecting safety of the ISF Facility.

a)

Lines of authority, responsibility, and communication shall be defined and established throughout highest management levels, intermediate levels, and operating organization positions. These relationships shall be documented and updated, as approp1iate, in organizational charts, functional descriptions of depaitmental responsibilities and relationships, and job descriptions for key personnel positions, or in equivalent forms of documentation.

These requirements, including the plant-specific titles of those personnel fulfilling the responsibilities of the positions delineated in these Technical Specifications, shall be documented in the Safety Analysis Repo1t; b) The ISF Facility Director shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe operation and maintenance of the facility; c) The Deputy Manager for the Idaho Cleanup Project (ICP) shall have ultimate responsibility for overall facility nuclear safety and shall take any measures needed to ensure acceptable pe1formance of the staff in operating, maintaining, and providing technical support to the facility to ensure nucleai* safety; and d) The individuals who pe1form health physics functions, or pe1form quality assurance functions shall have sufficient organizational freedom to ensure their independence from operating pressures.

Idaho Spent Fuel Facility 34

5.0 ADMINISTRATIVE CONTROLS 5.3 ISF Facility Staff Qualifications

!Sf Facility Staff Qualifications 5.3 The ISP Facility Staff shall meet or exceed the minimum qualifications of ANSI 18. l -197 1 for comparable positions. The ISF Facility Operations Manager and ce1tified Operators shall be trained and certified in accordance with the ISF Operator Training Plan.

Idaho Spent Fuel Facility 35

5.0 ADMINISTRATIVE CONTROLS 5.4 Procedures Procedures 5.4 Written procedures shall be established, implemented, and maintained covering the following activities that are impo1tant to safety:

a) Administrative controls; b) Routine ISF Facility operations; c) Alarms and Annunciators; d) Emergency operations; e) Design control and facility change or modifkation; t) Control of surveillances and tests; g) Control of special processes; h) Maintenance; i) Health physics, including ALARA practices; j) Special nuclear material accountability; k) Quality assurance, inspection, and audits; I)

Physical security and safeguards; m) Records management; n) Repo1ting; and o) All programs specified in Specification 5.5.

Idaho Spent Fuel Facility 36

5.0 ADMINISTRATIVE CONTROLS 5.5 Programs The following programs shall be established, implemented, and maintained.

5.5. l Technical Specifications Bases Control Program Programs 5.5 This program provides a means for processing changes to the Bases of these Technical Specifications.

a) Changes to the Bases of the Technical Specifications shall be made under appropriate administrative controls and reviews.

b) Changes to the Bases may be made without prior NRC approval provided the change would not:

l. require a change in the Technical Specifications incorporated in the license,

2.

meet the criteria provided in 10 CFR 72.48(c)(2),

3.

result in a significant increase in occupational exposure, or

4.

result in a significant unreviewed environmental impact.

c) The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the SAR d) Proposed changes that do not meet the c1iteria of 5.5.1. b above shall be reviewed and approved by the NRC p1ior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 72.48(d)(2).

Idaho Spent Fuel Facility 37

5.0 ADMINIS1'RATIYECONTROLS 5.5.2 Radioactive Efnuent Control Progrnm Programs 5.5 This program conlains the offsite dose calculation methodologies, radioactive effluent controls, and radiological monitoring aclivities. This program shall contain:

a) The methodologies and parameters used in cakulalion of offsite doses resulting from radioactive gaseous and liquid efnuents; b) The methodologies and parameters used in calculation of gaseou ~ und liquid effluent monitoting alarm and trip setpoints; c) The controls for mainmining rhe doses to members of the public from radioactive effluents as low as is reasonably achievable in accordance with 10 CFR 72. 104(b). These include:

I. Limitations on the functional capability of radioactive liquid and gaseous monitoring instrumentation including surveillru1ce test and setpoinc determination;

2. Monito1ing, sampling, and analysis of radioactive liquid and gaseous effluents in accordante wirh IO CPR 20.1302.

Changes to the program shall be documented and records of reviews performed shall be retained. This documentation shall contain:

a) Sufficient information to suppon the change together with the appropriate analyses or evaluations justifying the change(s), and b) A determination that the change will maintain the level of radioactive effluent control required by I 0 CFR 20. 1302 and I 0 CFR 72. I 04.

Idaho Spent Fuel Facility 38

5.0 ADMINISTRATIVE CONTROLS 5.5.3 Fuel Handling Program Programs 5.5 This program implements the ISF Safety Analysis Repo1t requirements for receipt, packaging, and storage of SPENT NUCLEAR FUEL. At a minimum, the program shall establish criteria that need to be verified to address ISF Facility Safety Analysis Report commitments and regulatory requirements for:

a) Transfer Cask and fuel acceptance criteria; b) Fuel Packaging Area limits to ensure restrictions on fuel types are not violated; c) Limiting operations of structures, systems, or components that are important to safety to certified operators qualified in accordance with the ISF Facility Operator Training Plan; d) Acceptance testing of the JSF CANISTER final closure welds; e) Helium inerting pressure and purity to assure col'l'osion control; t)

Leak testing to assure adequate JSF CANISTER and STORAGE TUBE integrity and consistency with the offsite dose analysis; and g) Configuring the Fuel Packaging Area for the fuel type being packaged.

The program shall include compensatory measures and appropriate completion times if program requirements are not mer.

Idaho Spent Fuel Facility 39

5.0 ADMINISTRATIVE CONTROLS 5.5.4 Fire Proteccion Program Programs 5.5 This program contains the fire protection policy for protection of structures, systems, and components important to safety at the'ISF Facility and the procedures, equipment, and personnel required to implement the program at the facility. At a minimum, the program shall contain:

a)

Organizational structure for fire protection responsibilities, including design, maintenance, surveillance, quality assurance of fire protection features, fire prevention activities, and fire fighting organization and training; b)

Fire Hazards Analysis describing the defense-in-depth approach for fire areas important to safety; c)

Implementing procedures for surveillance of fire protection equipment including identification of suitable compensatory measures for degraded or inoperable components; d)

Fire pre-plans for firefighting strategies; and e)

Administrative controls for housekeeping, control of combustibles, control of ignition sources (hot work), and fire notification.

Idaho Spent Fuel Facility 40

5.0 ADMINISTRATIVE CONTROLS 5.5.5 Radiation Protection Program Programs 5.5 This program contains the radiation protection policy for maintaining onsite and offsite personnel exposure as low as is reasonably achievable (ALARA). At a minimum, the program shall contain:

a)

Procedures and administrative controls to limit personnel exposure ALARA in accordance with l 0 CFR 20; b) Requirements for monitming the DOE transfer cask during RECEIPT and LOADING OPERA TIO NS to ensure that su1face dose rates are within analyzed values; c) A monitoring program to ensure the annual dose equivalent to any real individual located outside the ISF Facility controlled area does not exceed regulatory limits, (which is incorporated as pait of the environmental monitming program in the Radioactive Effluent Control Program of Specification 5.5.2);

d) Requirements for monitoling the DOE transfer cask during RECEIPT and LOADING OPERA TIO NS prior to and after unloading SPENT NUCLEAR FUEL to ensure that 0

removable surface contamination levels do not exceed 2200 dpm/100 cm-from beta and 0

gamma sources and 220 dpm/100 cm-from alpha sources; and e) Measures for controlling access to high radiation areas as defined by 10 CFR 20. These measures are alternative methods allowed by 10 CFR 20.1601 ( c) and ai*e further desctibed in Regulatory Position 2.4 of Regulatory Guide 8.38, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants.

Each area, accessible to individuals, in which radiation levels could result in an individual receiving a deep dose equivalent in excess ofO.l rem (100 mrem) in l hour at 30 centimeters from the radiation source or from any surface that the radiation penetrates shall be banicaded and conspicuously posted as a high radiation area, and entrance thereto should be controlled by requiting issuance of a radiation work permit (RWP) or equivalent.

Radiation Control Technicians or other individuals trained and qualified in radiation protection procedures or personnel continuously esco1ted by such individuals may be exempted from this R WP requirement while performing their assigned duties in high radiation areas where radiation doses could be received that are equal to or less 1.0 rem in l hour (measured at 30 centimeters from any source of radiation) provided they ai*e otherwise following plant radiation protection procedures, or a general radiation protection RWP, for entry into such high radiation areas.

Any individual or group of individuals permitted to enter such areas should be provided with or accompanied by one or more of the following:

Idaho Spent Fuel Facility 41

5.0 ADMINISTRATIVE CONTROLS Programs 5.5 A radiation monitoring device that continuously indicates the radiation dose rate in the area; A radiation monitoring device that continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rates in the area have been determined and personnel have been made knowledgeable of them; An individual qualified in radiation protection procedures with a radiation dose rate monito1ing device. This individual is responsible for providing positive radiation protection control over the activities within the area and should pe1form periodic radiation surveillance at the frequency specified in the radiation protection procedures or the applicable RWP.

In addition, areas that are accessible to personnel and that have radiation levels greater than 1.0 rem (but less than 500 rads at l meter) in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months at 30 cm from the radiation source, or from any smface penetrated by the radiation, should be provided with locked doors to prevent unauthorized entry, and the keys should be maintained under the administrative control of the shift supervisor on duty or health physics supervisor. Doors should remain locked except during periods of access by personnel under an approved R WP that specifies the dose rates in the immediate work areas and the maximum allowable stay time for individuals in that area. In lieu of a stay time specification on the RWP, direct or remote continuous surveillance (such as closed circuit TV cameras) may be made by personnel qualified in radiation protection procedures to provide positive exposure control over the activities being performed within the area.

Individual high radiation areas that are accessible to personnel, that could result in radiation doses greater than 0.01 Sv (1.0 rem) in 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , and that are within large areas where no enclosure exists to enable locking and where no enclosure can be reasonably constructed around the individual area should be barricaded and conspicuously posted. A flashing light should be activated as a warning device whenever the dose rate in such an area exceeds or is expected to exceed 1.0 rem in l hour at 30 cm from the radiation source or from any surface penetrated by the radiation.

The Radiation Protection Program will be reviewed annually for content and implementation.

Idaho Spent Fuel Facility 42

5.0 ADMINISTRATfVE CONTROLS 5.5.6 Essential Program Control Program Programs 5.5 I. This program provides a means for processing changes to the following essential programs.

u) Quality Assurance Program b) Radiological Environmental Monitoring Program c) Training Program

2. Changes to essential programs shull be made under appropriate administrative contmls and reviews.

3. The licensee may make changes 10 essential programs without prior NRC approval provided the changes do not involve eirher or the following:

a) A change in the Technical Specification incorporated in tile license: or b) A decrease in effectiveness.

4. The Essential Program Control Program shall con rain provisions ro ensure essential prograrns are maintained consistent with the regulati_ons.

5. Proposed changes to essential programs which do not meet the criteria of 5.5.6.3 above shall be reviewed and approved by NRC before implementation.

6. Changes lo essential programs implemented without prior NRC approval. shall be provided to the NRC on a frequency consistem w.ith I 0 CFR 72.70(c)(6).

7. DOE will review and approve all submittals to the NRC made pursuant to TS 5.5.6.

Idaho Spent Fuel Facility 43

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION REPORT IDAHO SPENT FUEL FACILITY INDEPl:NDENT SPENT FUEL STORAGE INSTALLATION MATERIALS LICENSE NO. SNM-2512 AMENDMENT NO. 3 1.0

SUMMARY

This safety evaluation report (SER) documents the review and evaluation of a license amendment request to SNM License No. 2512 for the Idaho Spent Fuel Facility (ISFF)

Independent Spent Fuel Storage Installation (ISFSI). By letter dated September 8, 2016, the Department of Energy (DOE) submitted a request to the NRC in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 72.56, to amend the licensee delegation of authority in the license, technical specifications(TS), and final safety analysis report (FSAR). These documents currently delegate authority under the license to the Manager, DOE Idaho Operations Office. The amendment replaces this reference with the Deputy Manager, Idaho Cleanup Project in each of the documents.

The NRC staff has reviewed the application, including the justifications for the requested changes. As discussed below, based on the staff's evaluation of the statements and representations in the application, the staff finds that the requested amendment to Special Nuclear Materials License No. SNM-2512 for the ISFF ISFSI meets the regulatory requirements of 10 CFR Part 72.

2.0 EVALUATION CRITERIA The staff conducted an evaluation of the changes requested by the applicant to ensure that they meet the applicable requirements of 10 CFR Part 72 and 1 O CFR Part 20. The staff used the guidance provided in NUREG-1567, "Standard Review Plan for Spent Fuel Dry Storage Facilities," to conduct the evaluation. The staff's evaluation focused on the changes to SNM-2512 requested in the application and did not reassess previously approved portions of the license, TS, the final safety analysis report (FSAR) or any changes to the FSAR made by DOE under the provisions of 10 CFR 72.48. The evaluation for each applicable review discipline is described below.

3.0 TECHNICAL SPECIFICATIONS EVALUATION In its amendment application, DOE requested to revise the licensee delegation of authority in the license, TS, and FSAR. These documents currently delegate authority under the license to the Manager, DOE Idaho Operations Office. The amendment request replaces this reference with the Deputy Manager, Idaho Cleanup Project in each of the documents. In its application, DOE stated that the Secretary of Energy has designated the Deputy Manager, DOE Idaho Cleanup Office to be the DOE responsible Official for the ISFF ISFSI. DOE states that this revised designation aligns the ISFF license, TS and FSAR with the DOE office that has programmatic responsibility for NRG-licensed operations at the ISFF ISFSI.

To implement the proposed delegation of authority changes, DOE requested to revise Sections 5.1, "Responsibility and Section 5.2, "Organization," of the ISFF ISFSI TS. In addition, DOE made conforming changes in Chapter 9, "Conduct of Operations, and Chapter 11, "Quality Assurance," of the ISFF ISFSI FSAR. The staff reviewed the proposed changes requested by the applicant and determined that they are administrative ln nature, and do not affect or change licensed operations nor the type and amount of material licensed for storage at the site. The staff finds that the proposed change in the licensee delegation does not affect the ability of the ISFF ISFSI of meeting the regulatory requirements of 1 O CFR Part 72.

4.0 REQUIREMENTS FOR NOTICING PROPOSED ACTION In accordance with 1 O CFR 72.16, a Notice of Docketing was published in the Federal Register on April 28, 2015 (80 FR 23610). During its acceptance review of the proposed amendment, staff determined that the proposed amendment did not present a genuine issue to public health and safety. Accordingly, pursuant to 10 CFR 72.46(b)(2), the staff has determined that the publication of a notice of proposed action and opportunity for hearing, or the publication of a notice of hearing, is not warranted and has taken immediate action on the proposed amendment. A Federal Register Notice of Issuance will be issued notifying the public of the action taken and of the right of interested persons to request a hearing on whether this action should be rescinded or modified.

5.0 ENVIRONMENTAL REVIEW The staff reviewed the proposed amendment request against the categorical exclusion criteria in 10 CFR 51.22(c)(11 ), and determined that the amendment request is administrative in nature.

Under 1 O CFR 51.22(c)(11 ), a categorical exclusion from the requirement to prepare an environmental impact statement for such a change is allowed provided the following conditions are satisfied: (i) there is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite, (ii) there is no significant increase in individual or cumulative occupational radiation exposure, (iii) there is no significant construction impact, and (iv) there Is no significant increase In the potential for or consequences from radiological accidents.

After evaluating the amendment request, staff has determined that the amendment: (i) would not produce a significant change in either the type or amount of effluents released to the environment because the amendment does not affect the design, fabrication, or operations of the facility, and consequently does not affect the type or amount of effluents released to the environment; that (ii) the amendment would not produce a significant increase in occupational radiation exposure because changes to these administrative programs do not affect the operations at the facility, nor the amounts of radioactive material authorized for storage at the facility, and consequently would not produce a significant increase in occupational radiation exposure; that (iii) the amendment would not have significant construction impacts because the amendment only impacts the process by which administrative programs are revised, does not involve construction, and consequently would not have significant construction impacts; and that (iv) the amendment would not produce a significant increase in the potential for or consequences from radiological accidents because the amendment does not decrease the capabilities of personnel to perform their duties or decrease DOE's control of the design, fabrication and operation of the facility, and consequently would not produce a significant increase in the potential for or consequences from radiological accidents. Consequently, staff finds that the amendment request meets the categorical exclusion criteria in 10 CFR 51.22(c)(11 ).

6.0 CONCLUSION

Based on its review of the proposed amendment, the staff has determined that there is reasonable assurance that: (i) the activities authorized by the amended license will be conducted without endangering the health and safety of the public, and (ii) these activities will be conducted in compliance with the applicable regulations. The staff has further determined that the issuance of the amendment will not be inimical to the common defense and security.

The staff approves Amendment No. 3 to Materials License No. SNM-2512 for the ISFF ISFSI.

Issued with Materials License No. SNM-2512, Amendment No. 3, dated:

6/6/17

ML24332A158

Text

SUBJECT:

Dear Mr. Provencher:

Enclosures:

Enclosure:

Attachment:

SUMMARY

6.0 CONCLUSION

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