ML20040G240

Reg Guide 3.50, Guidance on Preparing License Application to Store Spent Fuel in Independent Spent Fuel Storage Installation

ML20040G240
Person / Time
Issue date:	01/31/1982
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
References
TASK-FP-907-4, TASK-OS REGGD-03.050, REGGD-3.050, NUDOCS 8202120033
Download: ML20040G240 (8)

Text

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U.S. NUCLEAR REGULATORY COMMISSION January 1982 f

M@/ OFFICE OF NUCLEAR RE GU DE

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REGULATORY GUIDE 3.50 (Task FP_907 4) _

GUIDANCE ON PREPARING A LICENSE APPLICATION TO STORE SPENT FUEL IN AN INDEPENDENT SPENT FUEL STORAGE INSTALLATION INTRODUCTION 170 - Fees for Facilities and hiaterials Licenses and other Regulatory Services under the Atomic Energy Act Subpart B, " License Application, Form, and Contents,"

of 1954, as Amended.

j of 10 CFR Part 72, " Licensing Requiremsnts for the i

Storage of Spent Fuel in an Independent Spent Fuel Part 72 provides for a single licensing procedure. The Storage Installation," specifies the information to be smooth functioning of this one-step licensing proced. ire covered in an application for a license to store spent fuelin requires that the license application be essentially complete an independent spent fuel storage ins dlation (ISFSI).

in its initial submission. A license under this part will be llowever, Part 72 does not specify the format to be followed issued before the start of construction of any physical in the license application. This regulatory guide suggests a facilitier involved. Under this procedure, the final design format acceptable to the NKC staff for submitting the details of those ISFSI components, systems,and structures information specified in Part 72 for a license application to that are important to safety must be available for review store spent fuelin an ISFSt.

and evaluation. Part 72 also requires that a site evaluation be provided to ensure that the natural characteristics of the Other regulations applicable to the licensing of spent site and its environs are sufficiently known and have been fuel storage in an ISFSIarein the following parts of Title 10, factored into the engineering design of the installation. The f} " Energy,"of the Code of Federa' Regulations:

document in which this information is presented is a Saft ty

(

)

Analysis Report (SAR).

U 2-Rules of Practice fw Domestic Licensing Proceedings 8-Interpretations Although an applicant may plan to contract with anott er 9-Public Records organization for the design, construction, and possibly the 11 - Criteria and Procedures for Determining Eligibility operation of the proposed ISFSI, a licensee under Part 72 for Access to or Control over Special Nuclear cannot delegate to a contractor the responsibility for Material meeting all applicable regulatory requirements. This means 19 - Notices, Instructions and Reports to Workers; that the applicant must make a commitment that, as the Inspections licensee, it will have an adequate staff to ensure that 20 - Standards for Protection against Radiation regulatory requirements are met at each stage of the proposed 21 - P oorting of Defects and Noncompliance project. If the applicant plans to contract with another 25 -

i Authorization for Licensee Personnel organization for the operation of the proposed ISFSI, the 51 -

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.ng and Regulatory Policy and Procedures contractual arrangements must be described in the licente fo. Lavironmental Protection application. Any subsequent changes in such contractual 73 - Physical Protection of Plants and Materials arrangements may require an amendment to the license.

75 - Safeguards on Nuclear Material-implementation of US/IAEA Agreement This guide represents a standard format that is acceptab'e 95 - Security Facility Approval and Safeguarding of to the NRC staff for the license application. Conformance National Security Information and Restricted Data with this guide, however,is not mandatory. License applica-150 - Exemptions and Continued Regulatory Authority tions with different formats will be acceptable to the staff in Agreement States and in Offshore Waters under if they provide an adequate basis for the findings required Section 274 for the issuance of a license, llowever, because it may te 8202120033 820131 PDR REGGD 03.050 R PDR USNHC HEGULATORY GUIDES Comments should be sent to the Secretary of the Commisslor, U.S.

Nuclear Regulatory Commission, Washington, D.C. 20555 Regulatory Guides are issued to describe and make avalf able to the Attention Docketing and Service Branch, public methods acceptable to the N RC staff of implementing specific parts of the Crwnmission's regulations, to delineate tech.

The guides are issued in the following ten broad divisions:

/

n6 Ques used by the staff in evaluating specific problems or postu.

/

lated accidents or to provid3 guidance to applicants. Regulatory

1. Power Reactors

6. Products j Guides are nol substitutes for regulations, and compliance with

2. Research and Test Peactors

7. Transportation r

them is not required. Methods and solutions dif ferent from those set

3. Fuels and Materials Facilities

8. Occupational Health r

M/ out in the guides will be acceptable if they provide a basis for the

4. Environraental and Siting

9. Antitrust and Financial Review findings requisite to the issuance or continuance of a permit or

5. Materials and Plant Protection 10. Gerieral license by the Commission.

Copies of issued guides may be purchased at the current Government This guide was issued after considerathn of comments received from Printing Of fice price. A subscription service for future guides in spe.

the public. Comments and suggestions for improvements in these cific divisions is available through the Government Printing Office.

guides are encouraged at all times, and guides will be revised. as information on the subscription service and current GPO prices may appropriate, to accommodate comments and to reflect new informa.

be obtained by writing the U.S. Nuclear Regulatory Commission, tion or experience.

Washington, D.C. 20555, Attention: Putilications Sales Manager.

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more difficult to locate needed information, the staff Physical Specifications review time may be longer, and there is a greater likehhood that the staff may regard the license application as incomplete.

1. Paper size: 8% x 11 inches As experience is gained in the licensing of spent fuel

2. Paper stock and ink: Suitable quality in substance, storage, the Commission's requirements for information paper color, and ink density for handling and reproduction needed in its review of 1pplications for licenses to store by microfilming or image-copying equipment.

tpent fuel in an ISFSI may change. Revisions of the Commis-sion's needs for information in connection with such

3. Paper margins: A margin of no less than I inch licensing actions will be conveyed to the industry and the should be maintained on the top, bottom, and binding side public by (1) amendments to N RC regulations,(2) revisions of all pages.

to this regulatory guide, (3) issuance of new or revised regulatory guides, and (4) direct communications, as

4. Printing:

needed, with an applicant by the NRC staff,

a. Composition: Text should be single or 1% spaced.

Since the preparation of a license application pursuant to Part 72 will be a new experience, prospective applicants

b. Type face and style: Suitable for microfilming or are encouraged to meet with representatives of the Division image copying equipment.

of Fuel Cycle and Material Safety of the Office of Nuclear Material Safety and Safeguards during the development of a

c. Reproduction: Either mechanical or photographic.

license application to resche any problems that may arise.

Text should be printed on both sides of the paper with the An early resolution of potential problems is beneficial to all image printed head to head, concerned with the licensing process.

S. Ilinding: Pages should be punched for a standard Contents of the License Application 3-hole loose-leaf binder.

The license application is the basic document that must

6. Chapter and page numbering: Each requirement of address each of the requirements of Part 72 and must be the regulation addressed should be shown as a separate complete in itself. Ilowever, the following subjects should chapter with the same number as the chapter given in this be covered in separate reports that are identified as enclosures guide, e.g., Chapter 8, " Operator Training." Pages should be to the license application, and the contents of each report numbered sequentially in each chapter, e.g.,8-1, 8-2, etc.

shculd be summarized in a brief statement in the license Do not number the entire document sequentially, application:

Procedures for Updating or Revising Pages

1. Safety Analysis Report

2. Decommissioning Plan All pages submitted to update, revise, or add to the

3. Emergency Plan license application should show the date of change and a

4. Environmental Report change or amendment number. He changed or revised

5. Quality Assurance Program portion of each page should be higidighted by a " change

6. Physical Security Plan indicator" mark consisting of a bold vertical line drawn in

7. Safeguards Contingency Plan the margin opposite the binding side.

8. Personnel Training Program

9. Proposed License Conditions, including Technical Referenced Materials Specifications

10. Design for Physical Security Caution should be used in references to information previously filed with the AEC or NRC. Such references Format and Style must be pertinent to the subject discussed, must contain current information, and must be readily obtainable or l

The applicant should strive forclear, concise presentation extractable from the referenced documents. It may be more of the information prosided in the application. The applica-efficient in some cases to repeat in a license application tion should be w~itten in plain English and should be previously furnished information.

understandable to an educated lay person.

Chapter 1. GENER AL AND FINANCIAL INFORMATION Abbreviations should be consistent throughout the l

license application and its enclosures. Any abbreviations, The license application shov!d addrest the requirements symbols, or special terms unique to the proposed activity or of 72.14 of 10 CFR Part 72 regarding details on the not in general use should be defined when they first appear, identity of an applicant. If the applicant is other than the owner or planned operator of the proposed ISFSI, details A title page identifying key individuals responsible for of the working and contractual arrangements between all l

the preparation of the license application and the oath parties involved should be set forth. Any information on required under paragraph 72.11(b) should be included. A such matters considered as proprietary information by the table of contents should also be included.

applicant should be identified and submitted under separate 3.50-2

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cover. The procedures in 10 CFR 2.790(b) should be basin),its design capacity, any unique features incorporated

followed, in its design, and its mode of operation is adequate for the m

license application document.

If the proposed ISFSIis to be built on the site of another y

licensed activity or facility such as a nuclear power plant, The SAR required for an ISFSI differs from the SARs details of the working arrangements and responsibilities of for some other nuclear facilities in that the initial SAR is the ticensecsinvolved should be stated. Limilarly,if unlicensed expected to be complete and comparable in scope and ativities are carried out at the proposed site,any potential detail to the final SAR for facilities licensed under 10 CFR interactions between the proposed ISFSI and these other Part 50. Section 72.15 identifies.he minimum information site activities should be explained, that is required to be included in the SAR. Although 72.50 provides for the subsequent updating of the SAR, Paragraph 72.14(e) specifically addresses the required such changes during the design and construction phases of financial information that must be submitted with the the project are expected to be of minor importance. Any of application. If the applicant is a government agency or a these changes deemed significant by the staff may cause regulated utility, the assumption is made that the applicant delay in the granting of the final clearance to receive spent is financially qualified for a license under Part 72. If the

fuel, applicant is a corporation organized for the speci'ic purpose of owning and operating the proposed ISFSI, details of its Guidance on the preparation of the SAR for an ISFSI of organizational structure, including the responsibilities ofits the conventional water-basin type is contained in Regulatory members to meet the financial requirements of the preposed Guide 3.44," Standard Format and Content for the Safety ISFSI throughout its proposed operating life and ultimate Analysis Report for an Independent Spent Fuel Storage decommissioning, must be stated. This requirement is Installation (Water-Basin Type)." For the dry storage applicable even if the proposed ISFSIis to be owned and ISFSI, guidance on the preparation of the SAR is contained operated by a consortium of utilities.

in Regulatory Guide 3.48," Standard Format and Content for the Safety Analysis Report for an Independent Spent Chapter 2. TECHNICAL QUALIFICATIONS Fuel Storage Installation (Dry Storage)."

Paragraph 72.31(a)(4)and { 72.17 require a finding bythe Chapter 4. CONFORMITY TO GENER AL DESIGN staff that the applicant is qualified by training and experience CRITERIA to construct and operate an ISFSL

[N Subpart F of 10 CFR Part 72 contains the general design i

I Although spent fuel storage in an ISFSI is generally criteria for an ISFSI. The subject of conformity to the considered a relatively low-risk operation compared to general design criteria is covered in detail in the SAR. It is some other types of nuclear activities,the design,construc-sufficient that the license application contain a summary tion, and operation of an ISFSI require certain skills and an discussion of each criterion and reference where more understanding of the requirements involved to ensure that detailed information on a specific subject can be found in the objective of a relatively low-risk operation is achieved in the SAR.

practice. The license application should contain a commit-ment that the applicant will staff the project with an Chapter 5. OPERATING PROCEDURES; ADMINIS-adequate cadre of personnel possessing the required skills TRATIVE AND MANAGEMENT CONTROLS throughout all phases of the project. This element of the license application is in addition to the discussion of the Paragraph 72.31(a)(5) requires a finding by the staff that conduct of operations covered in Chapter 9 of the SAR.

the applicant's proposed operating procedures to protect health and to minimize danger to life or property are The licensee is responsible for the execution of the adequate. Essential to these operating procedures are the proposed project as described in the license application.

applicant's proposed administrative and management This means that, even though much of the actual work controls. Guidance on this subject is availablein ANSI N299-involved during the site selection, design, procurement, con-1976, " Administrative and Managerial Control for the struction, and even the operating phases of the project may Operation of Nuclear Fuel Reprocessing Plants."* Although be performed by a contractor, the licensee must have a staff ANSI N299-1976 is designed for the much more complex that is knowledgeable in all aspects of the project. If such a operating requirements of a fuel reprocessing plant, the staff does not actually exist, the applicant should describe basic principles set forth for administrative and managerial the staffing plans in sufficient detail to support the finding controls are considered applicable to the operation of an required by paragraph 72.31(a)(4).

ISFSI. Paragraph 72.15(a)(8) identifies the information that is to be included in the SAR.

Chapter 3. TECHNICAL INFORMATION; SAFETY ANALYSIS REPORT If the proposed ISFSI is to be operated by the owner, a relatively brief explanation of I aw the requirements of ps As required by @ 72.15, the technical information is ANSI N299-1976 will be met may be adequate. Ilowever,if

) presented in the SAR, which should be submitted as an (d enclosure to the license application. A summary statement

. copies may be obtained from the American National Standards identifying the type of installation proposed (e.g., a water Institute,Inc.,143o Broadway, New York, N.Y.10o18.

3.50-3 l

the proposed ISFSI is to ha operated by a contractor, con-Section 72.51 identifies the inventory and record require-

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siderable detail will be required on the working arrangements ments for spent fuel stored at an ISFSI. Because of the i

between the parties involved. Particular attention should be uncertainty as to the ultimate disposition of spent fuel placed on the description of the administration of the stored in an ISFSI, the records on the identity of each fuel independent Review and Audit Program that is identi-assembly should be complete. As a minimum, these records fled in ANSI N299-1976.

should cover:

Chapter 6. QU ALITY ASSURANCE PROGRAM

a. Fuel manufacturer,

b. Date of manufacture, The quality assurance program required by 72.80

c. Reactor exposure history, must be submitted as an enclosure to the application and is

d. Burnup, briefly discussed in Chapter 11 of the SAR. It is sufficient

e. Pertinent observations on discharge and during that the license application contain a commitment that storage at the reactor, transfer to the ISFSI, and the quality assurance program described is (or will be) storage in the ISFSI.

understood by all involved in its execution and that the program will be implemented, as applicable, for all phases if storage of consolidated fuel rods is being considered, of the project, including any activities important to safety special requirements concerning inventory and recordkeep-that have been carried out prior to submission of tne license ing for stored fuel pins should be described.

application.

Chapter 9. PHYSICAL PROTECTION This program should cover the engineering aspects of the site investigation, facility design, procurement, shop fabrica-Subpart II, " Physical Protection," of 10 CFR Part 72 tion, onsite construction, preoperational testing, conduct of requires that a physical security plan ( 72.81), a design for operations, and ultimate decommissioning. De emphasis of physical protection (Q 72.82), and a safeguards contingency this program should be on those activities and items that plan ( 72.83) be submitted. Smce the details of the are identified as being important to safety. De planned provisions for physical protection are withheld from public quality assurance effort should be commensurate with the disclosure, this subject should be covered in separate importance to safety of such identified activities and items.

reports. He license application should contain only a reference to the identity of the reports and when they were Chapter 7. OPER ATOR TRAINING submitted.

ISFSI operators are not required to be licensed. Ilowever, Interim guidance regarding the proposed design for they must have a level of qualifications and training in physicai security and the format and content of the physical subjects and operating procedures applicable to the opera-security plan can be obtained from the Director, Division of tion of an ISFSI comparable to the requirements of 10 CFR Safeguards, Office of Nuclear Material Safety and Safe-Part 55 on spent fuel pool operation for licensed operators guards, U.S. Nuclear Regulatory Commisswn, Washington, of a reprocessing plant or nuclear power plant. Appropriate D.C. 20555.

documentation of training activities and certifications of proficiency should be included in the ISFSI records.

Guidance for the safeguards contingency plan is contained Subpart 1, " Training and Certification of ISFS! Personnel,"

in Regulatory Guide 5.55, " Standard Format and Content of 10 CFR Part 72 require-that a training program be of Safeguards Contingency Plans for Fuel Cycle Facilities."

established and that the personnel training program document be included as an enclosure to the license application. A Chapter 10. DECOMMISSIONING PLAN brief summary of the program should be included in the application.

Section 72.18 requires the submission of a decommis-sioning plan as part of the license application. A brief in addition to ;he specific operating requirements of the description of the decommissioning plan is included in planned facility, the training program should also coves the Section 9.6 of the SAR. He heense application need nuclear engineering principles involved in the safe handling contain only a brief summary statement, enough to identify and storage of spent fuel and the regulations, regulatory what will be involved and the basis for the estimated costs guides, and national standards applicable to ISFS! operations.

of decommissioning.

Guidance on the content of the required training program is available from the Fuel and Spent Fuel Ucensing Branch, llowever, the financial provisions for carrying out the Division of Fuel Cycle and Material Safety, Office of decommissioning plan at the end of useful life of the Nuclear Material Safety and Safeguards, U.S. Nuclear Regu-proposed ISFSI are not necessarily addressed in the SAR latory Commission, Washington, D.C. 20555.

and must be covered in either the license application or the decommissioning plan.

Chapter 8. INVENTORY AND RECORDS REQUIREMENTS Chapter 11. EMERGENCY PLAN A description of the inventory and records system for Section 72.19 requires that an m ergency plan be the stored fuel should beincluded in the license application, provided as part of the license applicston. The plan must 3.50-4 d

include the information listed in Section IV. " Content of should be taken to ensure that such references are clear and i

Emergency Plans," of Appendix E to 10 CFR Part 50.

explicit,

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Proposed license conditions should address such subjects Chapter 12. ENVIRONMENTAL REPORT as:

Section 72.20 requires that an environmental report be

1. Administrative and management organization; proce-provided as part of the license application. Guidance on the dures and controls, including review and approval activities; format and content of an environmental report for an and auditing and reporting requirements, in particular, the ISFSI may be found in 10 CFR Part $1, "Ucensing and subject of interfaces between thelicensee and its contractors Regulatory Policy and Procedures for Environmental should be covered.

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Protection."

2. Verification of design features that are important to safety, in particular, those quality assurance activities that

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In the interests of keeping the size of this report within confirm that design and construction are being carried out

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reasonable bounds and its structure and language keyed to in accordance with plans,e.g., inspection hold points,should the general public, it is recommended that s prospective be covered.

applicant confer with the NRC staff to obtain definitive guidance on the scope and content of this report.

3. Test procedures throughout the life of the project.

Such subjects as conditions applicable to site evaluation, p

component testing during design and construction, preopera-Chapter 13. PROPOSED LICENSE CONDITIONS tional testing prior to startup, and conditions applicabie i

to tests that may be desirable after the commencement of Ucense conditions proposed by an applicant constitute a operations should be covered, commitment by the applicant to take the actions specified therein. Because a license issued pursuant to Part 72 is

4. Functional and operating limits of monitoringinstru-issued prior to the commencement of construction, license ments and limiting control settings, conditions cover the entire proposed life of the ISFSI, from site selection through the subsequent phases of de,ign,

5. Umiting conditions of operation. The functional construction, operation, and ultimate decommissioning, capabilities or performance levels of equipment and systems f)'

that are important to safety should be addressed. The Ucense conditions can be considered in tr a broad subject includes setpoint limits on monitoring instruments

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categories; (1) administrative and management organization and any controls that may need to be imposed on personnel and controls and (2) technical specifications. Those addressing access to any part of the installation.

administrative and management subjects should be covered in the Ucense application; those addressing technical subjects

6. Surveillance requirements. Such items as the periodic can be covered very briefly in the license application with inspection of cranes and, for water pools, water purity and appropriate references to Chapter 10 of the SAR. Care evidence of corrosion should be covered.

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3.50-5

VALUE/ IMPACT STATEMENT O

1. ACTION

3. PROCEDURAL APPROACli 1.1 Pescription 3.1 Procedural Alternatives This guide is an updating of the material in Regulatory The following are potential hRC procedures that.nay be Guide 3.24 to correct omissions and ref'ect regulatory devel-used to disseminate the information contained in the guwe:

opments since Regulatory Guide 3.24 wasissued. Regulatory Guide 3.24 was withdraw n on February 27,1981 (46 FR 14507).

Regulation Regulatory guide 1.2 f ced

. Branch position paper

. NUREG-series report Dere is increasing interest in the nuclear community in the licensing requirements for the storage of spent fuelin an 3.2 Value/ Impact of Procedural Alternatives ISFSI. He guide is designed to assist prospective applicants by discussing in more detail specific requirements of Part 72 A regulation is not a suitable means of disseminating the for the license application.

explanatory type of information contained in the proposed guide. A NUREG-series report is also not a viable alternative 1.3 Value/ Impact because the proposed guide contains regulatory positions.

Only a regulatory guide or branch position paper are 1.3.1 NltC considered to be viable alternatives.

The further explanation of the content oflicense applica-Branch positions are sometimes presented for guidance tions covering the storage of spent fuelin an ISFSI will be of this sort, flowever, because of the limited distribution helpful to the licensing staff in their contacts with potential with2n NRC for concurrence, branch positions should be licensees and in the review of these applications when received, formalized by the issuance of a regulatory guide. In this particularly during the " mini-review" before docketing of case, no branch position has been prepared or is anticipated.

such applications.

3.3 Decision on Procedural Approach 1.3.2 Other Government Agencies A regulatory guide should be prepared.

The Tennessee Valley Authority has expressed interest in the storage of spent fuelin an 151451 and is now trying to

4. STATUTORY CONSIDERATIONS determine the applicable licensing requirements.

4.1 NRC Authority 1.3.3 Industry Authority for this guida is derived from the Atomic ne further explanation of the content oflicense applica-Energy Act of 1954,as amended,and the Energy Reorganiza-tions covering the storage of spent fuel in an ISFSI is tion Act of 1974, as amended, and implemented through thought to be particularly useful to the utilities, which deal the Commission's regulations, primarily with the NRC Office of Nuclear Reactor Regula-tion and which now will be dealing with the NRC Office of 4.2 Need for NEPA Assessment Nuclear Material Safety and Safeguards, which handles the licensing of spent fuel storage in an ISFSI and operates The action is not a major Fe.deral action as defined by somewhat differently.

10 CFR Sl(a)(10) and does not require an environmental impact statement.

1.3.4 Public There is a need to aid the public in becoming better

5. RELATIONSillPTO OTifER EXISTING OR PROPOSED informed on the various aspects of the licensing of spent fuel REGULATIONS OR POLICIES storage in an ISFSI. The guide will contribute to meeting this need.

The guide is one of a series of guides that will replace Regulatory Guide 3.24. Other guides in this series include

2. TECilNICAL APPROACil Regulatory Guide 3.44, " Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel The guide is nontechnical m its content.

Storage Installation (Water-Basin Type)"; Regulatory 3.50-6

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Guide 3.48, " Standard Format and Content for the Safety

6.

SUMMARY

AND CONCLUSIONS

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Analysis Report for an independent Spent Fuel Storage Installation (Dry Storage)"; and Regulatory Guide 3.49, The regulatory guide should be issued to meet a current j

" Design of an Independent Spent Fuel Storage Installation need in the written development of the regulatory bases for j

(Water-Basin Type)."

the licensing of spent fuel storage in an ISFSt.

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