General License Considerations for Spent Fuel Storage in an Independent Spent Fuel Storage Installation at a Reactor Site
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The licensing process and concept of operation for independent spent fuel storage installations (ISFSIs) in the United States have evolved over time. Early considerations were based upon the safe storage of spent fuel in an existing reactor's spent fuel pool. In 1980, 10 CFR Part 72 was initially developed with the idea of a wet storage environment for spent fuel (e.g., GE-Morris facility). As dry cask storage technology evolved, consideration expanded to include storage of spent fuel in casks on a storage pad on a reactor site. This would continue to allow spent fuel to be discharged from the spent fuel pool to enhance operational flexibility by ensuring the spent fuel pool could handle a full core discharge during an outage. The Nuclear Waste Policy Act mandated that the use of dry cask storage technologies be permitted under a general license; therefore, in 1990, 10 CFR Part 72 was modified to incorporate these provisions. The attributes of general licensing for an independent spent fuel storage installation are as follows:
- General licensing provisions specified in 10 CFR Part 72, Subpart K;
- Limited to 10 CFR Part 50 reactor licensees;
- Effective without filing an application or issuance of licensing document;
- Not transferrable unless the 10 CFR Part 50 reactor license is transferred;
- Authorized for use of only NRC-certified casks;
- Reactor licensee is responsible for assuring generically-approved cask design and site requirements are compatible; and
- Relies on extending reactor licensee experience, qualifications, and programs to ISFSI activities.
This document provides an overview of the 10 CFR Part 72, Subpart K, general licensing process. The information contained in this document is a summary of the various areas a 10 CFR Part 72 general licensee is required to evaluate or consider when planning an ISFSI at a reactor site. The staff is providing this summary to assist potential licensees in understanding the overall scope of the project rather than to provide detailed guidance. A general licensee would typically evaluate their dry spent fuel storage needs against the technical specifications of the approved cask designs, conduct any necessary supporting analyses, and present their plans to NRC before starting the dry storage process. The time required to make the cask selection, perform preliminary analyses, and brief NRC are not reflected in this document. Licensees will find that some programs, plans, and processes will need to be developed to support the ISFSI. However, the information presented here reflects the intent that existing 10 CFR Part 50 reactor programs should be evaluated and used, to the extent possible, to support general licensing of an ISFSI.
The information contained in this document is not a substitute for NRC regulations and compliance is not required. The approaches and/or methods described in this paper are provided for information only. As a result, the list of areas for review may not be all-inclusive. The information is organized around the major steps in the overall process and is not meant to suggest an order in which actions must be completed. This document is focused on the actions to be taken by a 10 CFR Part 72 general licensee. As a result of this approach, this document does not reflect the NRC resources required to review licensee evaluations and assessments. NRC oversight activities should also be factored into a licensees' schedule for completing the overall process.
Effort Required by General Licensees
The decision to store dry spent fuel in an NRC-approved cask is the first step in a process that can typically take up to three years. While some of the tasks shown below can be completed concurrently, potential licensees should not underestimate the time required to complete the scope of the work. The level of effort has been estimated at approximately 200 staff-months, as shown in the following figure:
General Licensing Process Details
The major steps listed below correspond to the general licensing process outlined in NUREG-1571, "Information Handbook on Independent Spent Fuel Storage Installations."
- Begin general licensing process
Notify appropriate NRC regional office of the intent to store fuel in an approved cask under the general licensing provisions of 10 CFR Part 72 and present any special considerations or potential issues.
- Prepare analyses to address regulatory requirements
- 10 CFR 72.212 Evaluations
- Select pad site - Evaluate site characteristics against the cask design criteria contained in the cask Safety Analysis Report (SAR) and NRC Safety Evaluation Report (SER) and Certificate of Compliance to ensure that the approved cask is compatible with the selected site particularly in the following areas:
- Tornado missiles
- Earthquake intensity
- Cask transfer route
- Off-site dose limits
- Design pad and associated components or systems
- Prepare environmental assessment to demonstrate compliance with the requirements of 10 CFR 72.104
- Evaluate and modify existing programs, plans, and processes to support the ISFSI. Document the changes made and incorporate them, as needed, into the SAR.
- Quality assurance (QA) program
- Notify Director, NRC/NMSS of intent to apply 10 CFR Part 50 QA program to ISFSI activities
- Revise 10 CFR Part 50, Appendix B, QA program to include Part 72 activities
- Procurement process
- Establish vendor audit program
- Determine records retention requirements
- Welding program
- Develop cask weld processes
- Qualify weld procedures
- Train and qualify welders and weld inspectors
- Inspection program
Develop inspections procedures for
- heavy load lift devices
- helium leak detection
- miscellaneous equipment
- non-destructive examination
- cask components
- fabrication activities
- completed cask
- flammable gas detection during loading activities
- coatings, paint, plating, metal spray, etc. (if used)
- Surveillance and maintenance programs
- Develop routine inspection and maintenance procedures
- daily visual vent inspection
- daily temperature monitoring
- Develop long term inspection and maintenance procedures
- annual cask system inspection
- 5-year cask system inspection
- other miscellaneous areas as needed
- Health physics and dose assessment
- Assess the consequences of cask drops
- Complete an ISFSI dose assessment
- Complete a dry fuel operations radiological dose assessment
- Evaluate the need for temporary shielding
- Identify changes needed to overall site program
- Modify neutron dosimeter calibration to reflect spent fuel neutron spectrum
- Fuel inspection
- Define criteria for fuel selection using bounding conditions in the design basis document of the dry storage system
- Establish requirements and criteria for fuel inspection
- Define criteria for selecting position of fuel in cask
- Develop loading procedures
- Characterize each assembly
- Physical security
Identify the impacts of ISFSI operation on the overall site to ensure no decrease in the protection of vital equipment
- Emergency plan
Assess the impacts of ISFSI operation to ensure no decrease in overall effectiveness of the plan
- Training programs
- Compare ISFSI-related skills to existing performance-based training programs to identify new skills for which training must be developed and presented
- Ensure that trainee population includes all personnel with ISFSI-related responsibilities
- Conduct training on the full range of ISFSI-related activities
- emergency response
- Water management and chemistry program
- Evaluate pool cooling system
- Evaluate chemistry requirements during transfer of fuel
- Evaluate pool water level changes due to off-load to canisters
- Evaluate and modify plant and support facilities, as needed, to support activities related to the construction, pretesting, and operation of the ISFSI including the following:
- Plant facilities
- Determine heavy load design, installation, and test requirements in accordance with NUREG-0554, NUREG-0612, ANSI N14.6, and ANSI 1330 Series
- Assess adequacy of the size of the containment opening
- Assess adequacy of the size of the work platform
- Assess power requirements in containment
- Evaluate capabilities of transfer-cask grapple
- Assess adequacy of road bed from reactor building to ISFSI
- Assess instrument capabilities to determine if existing equipment can be calibrated and used within the specified accuracy
- Training facilities
- Assess the space requirements to train personnel on ISFSI-related skills
- Assess existing equipment to ensure it is adequate to support training of ISFSI personnel
- Plant systems
- Ventilation system
- Vacuum drying system
- Backfill gas system
- 10 CFR 50.59 Evaluation
- Evaluate the impacts of the spent fuel storage activities and program changes resulting from the addition of the ISFSI on the reactor activities
- Consider revision of the 10 CFR 50.59 procedure to include ISFSI issues
- 10 CFR 72.48 Evaluation
- Assess engineering tasks and procedures developed to support system implementation to ensure that design changes do not create unreviewed safety questions
- Evaluate the need to amend the reactor design control process (10 CFR 50.59) to reflect the ISFSI design control process
- Provide for notification to operations when criteria when critical lifts are in progress so that contingency plans are ready to be initiated, if necessary
- Monitor fabrication of ISFSI components and auxiliary equipment
- Develop oversight controls
- Perform periodic audits and surveillances
- Material tolerances
- Chemical expiration dates
- Concrete aggregate and pour control, and testing
- Neutron absorbing materials (e.g., resins)
- Evaluate design changes with cask designer for regulatory compliance and system operation
- Conduct pre-operational activities
- Conduct start-up testing
- Conduct functional tests
- Individual components
- Ancillary devices
- Verify engineering evaluations
- Evaluate component fit-up
- Compatibility of components
- Mating surfaces
- Conduct cask loading dry-run
- Validate procedures
- Conduct on-the-job training and qualification
- Demonstrate readiness of people, equipment, and procedures to safely move spent fuel to the storage pad
- Load cask
- Notify the NRC in accordance with 10 CFR 72.212(b)(1)(i) at least 90 days before beginning to load spent fuel into the first storage cask
- Select spent fuel assemblies
- Select assemblies based on established criteria
- Inspect fuel using established criteria
- Assign fuel to cask location based on established criteria
- Move fuel
- Use approved and validated procedures
- Use trained and job-qualified workers
- Register casks
- Register use of each cask with the NRC in accordance with 10 CFR 72.212(b)(1)(ii) no later than 30 days after loading
- 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities"
- 10 CFR Part 72, "Licensing Requirements for the Storage of Spent NuclearFuel and High-Level Radioactive Waste"
- Regulatory Guide 1.76, "Design Basis Tornado for Nuclear Power Plants"
- Regulatory Guide 3.48, "Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel Storage Installation (Dry Storage)"
- Regulatory Guide 3.50, "Guidance on Preparing a License Application to Store Spent Fuel in an Independent Spent Fuel Storage Installation"
- Regulatory Guide 3.53, "Applicability of Existing Regulatory Guides to the Design and Operations of an ISFSI"
- Regulatory Guide 3.54, "Spent Fuel Generation in an Independent Spent Fuel Storage Installation"
- Regulatory Guide 3.60, "Design of an Independent Spent Fuel Storage Installation (Dry Storage)"
- Regulatory Guide 3.61, "Standard Format and Content for a Topical Safety Analysis Report for a Spent Fuel Dry Storage Cask"
- Regulatory Guide 3.62, "Standard Format and Content for the Safety Analysis Report for On-Site Storage of Spent Fuel Storage Casks"
- Regulatory Guide 3.66, "Standard Format and Content of Financial Assurance Mechanisms Required for Decommissioning Under 10 CFR Parts 30, 40, 70, and 72"
- Regulatory Guide 4.2, "Preparation of Environmental Report for Nuclear Power Stations"
- NUREG-0554, "Single Failure-Proof Cranes"
- NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants"
- NUREG-1571, "Information Handbook on Independent Spent Fuel Storage Installations"
- NUREG-1526, "Standard Review Plan for Dry Cask Storage System"
- NUREG-1567, "Standard Review Plan for Spent Fuel Storage Facilities" (Draft)
- NUREG-1619, "Standard Review Plan for Physical Protection Plans for the Independent Storage of Spent Fuel and High-Level Radioactive Waste
- NUREG/CR-6314, "Quality Assurance Inspections for Shipping and Storage Containers"
- NUREG/CR-6407, "Quality Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety"
NRC Inspection Manual Chapter
- Manual Chapter 2690, "Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations"
NRC Inspection Procedures (IPs)
- IP 46051, Structural Concrete Procedure Review
- IP 46053, Structural Concrete Work Observation
- IP 46055, Structural Concrete Record Review
- IP 60851, Design Control of ISFSI Components
- IP 60852, ISFSI Component Fabrication by Outside Fabricators
- IP 60853, On-Site Fabrication of Components and Construction of an ISFSI
- IP 60854, Preoperational Testing of an ISFSI
- IP 60855, Operation of an ISFSI
- IP 60856, Review of 10 CFR 72.212(b) Evaluations
- IP 60857, Review of 10 CFR 72.48 Evaluations
|Location ||Person ||Number |
|Region I |
King of Prussia, PA
|Raymond Powell, Chief |
Decommissioning and Technical Support Branch
Division of Nuclear Materials Safety
|Region II |
|Shakur Walker, Chief |
Engineering Branch 3
Division of Reactor Safety
|Region III |
|Robert Orlikowski, Chief |
Materials Control, ISFSI and Decommissioning Branch
Division of Nuclear Materials Safety
|Region IV |
|Ray Kellar, Chief |
Repository and Spent Fuel Safety Branch
Division of Nuclear Materials Safety
|Mark Lombard, Director |
Spent Fuel Storage Management Division
Office of Nuclear Material Safety and Safeguards
The NRC welcomes comments on this guidance and questions on the general licensing process. Comments and questions can be e-mailed to John Goshen at John.Goshen@nrc.gov.
Page Last Reviewed/Updated Wednesday, July 08, 2020