ML20147E736

Dry Cask Storage Action Plan Update

ML20147E736
Person / Time
Issue date:	01/31/1997
From:	NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
Shared Package
ML20147E733	List: ML20147E728 ML20147E736
References
NUDOCS 9703190002
Download: ML20147E736 (25)

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! DRY CASK STORAGE ACTION PLAN UPDATE I i

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January 1997 i

d 9703190002 970130 PDR ORG NOMA PDR

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TABLE OF CONTENTS i

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SUMMARY

OF PROGRESS . . . . . . . . . . . . . . . . . . ........................ 1 STATUS

SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES . . . . . . . . 4 TECHNICAL NEAR-TERM ACTIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . .4

, Heavy Load / Crane Control . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

Cask Trunnions . . . . . . . . . . . . . . . . . . . . . . . . . . . . .............. 4

Hyd rostatic Testing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 i

Seismic Requirements for Spent Fuel Storage Pads . . . . . . . . . . . . . . . . 5

TECHNICAL LONG-TERM ISSUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 C a s k Weep i ng . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

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Cask Loading and Unloading . . . . . . ........................... 6 '

Offloading Capability . . . . . . . . . . . . . . . . . . . . . . ...... .. . . ... 7 l , Failed Fuel Storage . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Safeguards Concerns . . . . . . . . . . . . . . ........ . .......... .. 8 ,

j COM M U N I C ATI O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 i Internal Communications -Internal . .. .... ... ............... 9 i j internal Communications - Staff Training . . . . . . . . . . . . . . . . . . . . . . . . 10 External Communications - Industry Interface . . . . . . . . . . . . . . . . . . . . 11 i External Communications - Public Responsiveness . . . . . . . . . . . . . . . . . 12  !

! PROCEDURAL ISSUES . . . . . . . . . . . .. .............. ........ 13

[- Change Processes . . . . . ...... .. ........................ 13 l Part 72 Reporting Requirements ...... ............... .. .... 13 Inspections of Site Activities . . . . . . . . . . ...................... 14 )

Vend or inspection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 l Cask Design and SAR Differences . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 i NEW ISSUES RELATED TO DRY CASK STORAGE , , . . . . . . . . . . . . . . . . . . 15 MOVEMENT OF CASKS PRIOR TO SECURING OF LID . . . . . . . . . . . 16 )

INSPECTION OF ISFSI SUPPORT FUNCTIONS AT REACTOR SITES

.......................... ............................. 16 AP P E N D I X A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-0

SUMMARY

OF ORIGINAL DRY CASK ACTION PLAN ISSUES . . . . . . . . . . . . . . . A-1 TECHNICAL NEAR-TERM ACTIONS . . . . . . . . . . . . . . . . . . . . . .. . . . . A- 1 HEAVY-LOAD CONTROL / CRANE ISSUES . . . . . . . . . . . . . . . . . . . . . . A-1 CASK TR U N NION S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 HYDROSTATIC TESTING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-1 SEISMIC REQUIREMENTS FOR SPENT FUEL STORAGE PADS . . . . A-2 TECHNICAL LONG-TERM ACTIONS . . . . . . . . . . . . . . . . . . .. . . . . A-2 C A S K WE E P I N G . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-2 l 1

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CASK LOADING AND UNLOADING .............. ...........A2

} OFF LOADING CAPABILITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3 l FAI LE D F U E L STORAG E . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3 i SAFEG UARDS CONCERNS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3 C OM M U N I CATI O N S . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-3 INTERNAL COMMUNICATIONS - COORDINATION . . . . . . . . . . . . . A-3 INTERNAL COMMUNICATIONS - STAFF TRAINING . . . . . . . . . . . . . A-4 EXTERNAL COMMUNICATIONS -INDUSTRY INTERFACE . . . . . . . . A-4 EXTERNAL COMMUNICATIONS - PUBLIC RESPONSIVENESS . . . . . A-4

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P R OC E D U RAl lS S U ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . A-4 CHANGE PROCESSES ...................................A-4 PART 72 REPORTING REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . A-5  ;

INSPECTION OF SITE ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . A-5 i VENDOR INSPECTION . . . . . . . . . . . . . . . . . . . . ...... . . . . A-5 CASK DESIGN AND SAR DIFFERENCES . . . . . . . . . . . . . . . . . . . . A-5 t ,

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SUMMARY

OF PROGRESS i

t The Dry Cask Storage Action Plan was developed by staff from the Regions, NMSS, j and NRR in an effort to improve agency performance and to increase the NRC's effectiveness in regulating Independent Spent Fuel Storage Installations. The plan j identified major issues and problems related to design, fabrication, construction and i pre-operational test activities associated with the storage of spent fuel in dry casks.

The action plan had two basic goals:

8 l 1. To resolve identified problems and to address anticipated licensing and j inspection issues on a programmatic level for dry cask storage.

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To develop and maintain more efficient communications both within the 2.

l NRC, and with industry and to foster greater communications on dry cask j storage issues among industry organizations.

It should be emphasized that this action plan was developed to identify programmatic

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weaknesses in how our offices approached the review, licensing and inspection of dry cask storage activities. For identified deficiencies, program developments and

revisions, such as creation of dry cask storage inspection procedures and standard

review plans, were implemented to provide guidance to the staff on the oversight of dry j cask storage activities. From time to time, issues related to a specific cask design or  !

[ utility will arise. This action plan will not address such detailed issues, rather, the l programmatic enhancements implemented as a result of this action plan will be used to address new or plant specific issues.

This is the second update since the plan was originally issued on July 28,1995.

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! Since January 1996, all but one of the Technical Near-Term Actions, one of the  ;

{ Technical Long-Term Actions, and one of the proceduralissues identified in the original i _ plan have been closed. The remaining near-term item involved the suitability and l adequacy of cranes at power plants used to handle dry cask components. Resolution i of this item is being pursued throughout the nuclear power plant industry through the

! . issuance of NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, Over i Fuel in the Reactor Core or Over Safety-Related Equipment," on April 11,1996. This item is under NRR purview and is projected to be completed in December 1997. The remaining long-term item involves the storage of failed fuel or fuel otherwise susceptible to cladding structural failures. This issue is being addressed through guidance contained in the Standard Review Plan for Dry Cask Storage Systems (NUREG 1536) and as part of a dry cask design certification application. A draft of NUREG 1536 was issued for public comment in February 1996. The revised NUREG 1536 will be published in January 1997 and completion of review of the certification application is projected by December 1997. The remaining proceduralissue involved clarification of 1

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l the method for approving changes to cask SARs under the provisions of 10 CFR 72.48.

, While NRC expectations have been communicated to the industry and cask vendors

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through issuance of generic communications and many public meetings, NRC is preparing a new inspection procedure for oversight of changes to cask designs made

under the provisions of 10 CFR 72.48. Issuance of this new NRC inspection procedure i is targeted during the summer of 1997. Development of the 72.48 inspection procedure will be coordinated with ongoing efforts to enhance guidance regarding the 50.59 l change process for reactors.

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! Since January 1996, additional training sessions on Independent Spent Fuel Storage i Installations (ISFSis), including regulatory requirements, design criteria, and licensing

methods were held both in NRC Headquarters and Region I to provide training to NRR, NMSS, and Regional staff. Similar training sessions were held in Regions lil and IV in i 1995, and a session in Region ll is planned. Feedback from trainees has been very i positive. Conference calls are periodically held with NRR, NMSS and Region staff to j update the staff on items of interest, including recent inspection findings, affecting dry

cask storage. Time sensitive idormation is electronically distributed to designated staff.

i The Spent Fuel Project Office conducted a full day workshop on spent fuel storage and

transportation issues on May 17,1996. Topics included an overview of the dry cask l l storage licensing process, regulatory requirements, industry experience with dry cask

storage and transportation, and NRC expectations for cask vendors, component ,

i fabricators and utilities. Speakers from NMSS, NRR, NEl and representatives from utilities that have implemented dry cask storage at their sites spoke before an audience  :

, of over 300. Attendees included NRC staff from both Hes%uarters and the Regions, l utility staff, members of the press and public, representatives from other Federal

! agencies and representatives from several states.

l The Spent Fuel Project Office issued and updated the ISFSI inspection procedures in l February and May of 1996, respectively. These inspection procedures provide i

guidance to NRC inspectors regarding the oversight of dry cask storage systems and i facilities. In addition, the draft " Standard Review Plan for Dry Cask Storage Systems (NUREG 1536)" and draft " Standard Review Plan for Spent Fuel Dry Storage Facilities j (NUREG 1567)" were published for public comment in February and October 1996, j respectively. These guidance documents discuss the review process for cask system i design and spent fuel storage facilities. Although these documents are for use by NRC

, staff, they are publicly available and should help to clarify NRC's expectations in these j areas. Spent Fuel Project Office staff are currently reviewing comments on NUREG j 1536 and anticipate publication of the final Standard Review Plan for Dry Cask Storage

Systems during the first calendar quarter of 1997. The public comment period for

NUREG 1567 closes in March 1997.

s A table summarizing the status of the action plan items is enclosed.

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A number of new issues have been identified by the staff that are related to dry cask storage. These issues are office specific and are tracked within the responsible office using current tracking vehicles, such as the NRR Monthly Action Plan Status and the NMSS Operating Plan; however, they are summarized below for completeness.

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STATUS SulttARY OF DRY CASK STORAGE ACTION PLAN ISSUES TECHNICAL NEAR-TERM ACTIONS Issue Descriotion Lead Status Closure Method Office Heavy Load / Crane Control NRR Open Bulletin 96-02 issued on April 11. 1996, requesting information from Concerns regarding the adequacy of crane utilities planning to move heavy loads over safety related equipment qualifications. load path evaulations, during operation. Progress on this issue _is being tracked by a licensee procedures, and load drop newly developed NRR Heavy Loads Action Plan with completion analyses for heavy loads, such as dry currently expected by December 1997.

storage casks.

Cask Trunnions NMSS Complete' All cask vendors requested to revise their design documents (SARs)

Cask trunnion design and test requirements to explicitly identify the trunnion design and test requirements for not clearly defined in cask design their designs in spring of 1995. This was completed in 1995.

documents, causing confusion during Standard Review Plans state that NRC reviewers should verify inspection process. definition of such design and test criteria in the certification application prior to approval.

Hydrostatic Testino NMSS Complete All cask vendors requested to revise their design documents (SARs)

Hydrostatic test requirements for newly to explicitly identify the hydrostatic test pressure for their fabricated canisters not clearly defined designs in the spring of 1995. This was completed in 1995.

in design documents causing confusion Standard Review Plans state that NRC reviewers should verify during inspection process. definition of these test parameters in the license application prior to design approval.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued TECHNICAL NEAR-TERM ACTIONS Seismic Recuirements for Soent Fuel NMSS Complete Information Notice 95-28. " Emplacement of Support Pads for Spent Storace Pads Fuel Dry Storage Installations at Reactor Sites. was issued on Some licenseer did not accurately June 5. 1995. This issue was also discussed with the NEI Dry Cask implement the seismic analysis Storage Working Group throughout 1995 and 1996 and at the full day requiremer.i.s for spent fuel storage pads. public " Spent Fuel Storage and Transportation Workshop ~ held on May Utilities stated that NRC expectations 17. 1996. NRC inspection procedures were revised in May of 1996 to were unclear. provide NRC inspectors with guidance on the Agency's expectations for the construction of dry cask storage support pads. In addition.

NRC is pursuing clarification of the seismic requirement for ISFSI support pads through rulemaking. This item is closed.

TECHNICAL LONG-TERM ISSUES Issue Descriotion Lead Status Closure Method Office

' Cask Weeoino NMSS Complete Discussions with utilities and health physics professionals led the Casks that are submerged in spent fuel staff to conclude that this problem is not a safety significant pools over long periods of time exhibit issue. Casks are typically not left in the spent fuel pool for recurrent surface contamination following extended periods of time. Many casks are either polished or a removal from the pool. coating is applied to alleviate the weeping phenomenon. NEI agreed to monitor this issue and to develop a plan to address this issue should it recur with any frequency. This item is complete.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued TECHNICAL LONG-TERM ISSUES Cask L0adina and Unloadina NRR Complete

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in 1995 NRC contacted NEI and affected utilities to determine the Cask loading and unloading procedures have status and scope of loading and unloading procedures. While there been found to be of variable quality and were no irrinediate safety concerns. NRC expectations regarding the j scrpe. Some unloading procedures were scope and content of such procedures were unclear. Although general simplistic and did not contain sufficient guidance regarding such procedures was incorporated into the detail to permit unloading without standard review plan for the review of dry cask storage systems, procedure revision. Utilities stated that inspection procedures providing specific guidance on the scope and NRC expectations in this area were content of loading and unloading procedures were issued in February unclear. 1996. In early 1996. NMSS and NRR staff conducted a survey of utilities operating dry cask storage facilities to assess the status of existing loading and unloading procedures against the NRC inspection proceduros. No safety significant findings affecting the safety of the public were identified. NRC expectations in this area were restated during the full day " Spent Fuel Storage and Transportation Workshop held in May of 1996. Regarding future ISFSI facilities. NRC staff will inspect all loading and unloading procedures for dry cask storage as part of the pre-operational inspection of all dry cask storage facilities. This item is complete.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued TECHNICAL LONG-TERM ISSUES l 0ffloadina Caoability NMSS Complete Determination of methods by which utilities can meet the Some licensees who are planning to retrievability requirement of 10 CFR 72 does not fall within the permanently shut down their reactors may regulatory purview of the NRC. The Department of Energy is legally choose to use dry cask storage facilities , responsible for taking title to commercial spent fuel, effective in to store their entire spent fuel 1 1998. The method and means by which DOE will accomplish this has inventory. thereby permitting not been determined; however, the NRC is monitoring DOE activities decommissioning of their 10 CFR 50 reactor in this area. In addition an application for a dry transfer system.

facilities. Part 72 currently requires which would provide a means for unloading loaded casks without a that licensees maintain the capability for spent fuel pool was recently submitted by EPRI for NRC review. It retrievability of stored spent fuel, even is possible that a programmatic resolution for offloading if no spent fuel pool exists. NRC capabilities for plants pursuing decommissioning may be reached expectations in this area are not clear. before the problem arises. In addition, plants pursuing decommissioning must identify how they will disposition their spent.

fuel inventory as part of their site decomissioning plan which are reviewed by the NRC prior to utility implementation. As such.

resolution of this issue will be addressed on a case by case basis as needed. This item is complete.

Failed Fuel Storace NMSS Open This subject has been discussed with DOE. utilities and NEI. The Guidelines for the storage of failed fuel Standard Review Plan for Dry Cask Storage Systems states that the ior fuel otherwise susceptible to clad application define the type and properties of the spent fuel or failure do not exist. other radioactive materials proposed for storage in a given cask system. Applicants seeking to store spent fuel which is damaged or

, otherwise susceptible to clad failure will be required to

! demonstrate that the materials will not compromise the assumptions made in the design analysis. NRC is currently reviewing an application for the storage of fuel with degraded cladding. Upon completion of the staff's review of this application. this item will be closed. This item remains open.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued TECHNICAL LONG-TERM ISSUES Safeauards Concerns NMSS Complete NRC staff completed its analysis of the concerns in December 1995.

Safeguards concerns have repeatedly been Final conclusions supported the initial assessment that current raised by members of the public. protection levels are adequate. This item is complete.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued COMMUNICATIONS Issue Descriotion Lead Status Closure Method Office i Internal Communications - Internal Both Complete Individuals serving as official points of contact for dry cask in some cases, communications among NRC storage issues have been identified in NMSS. NRR and all 4 Regions.

offices were incomplete or ineffective. NMSS and NRR staff communicate daily and periodic conference calls Some examples of NRC offices not informing are held with the Regions. Time sensitive information is shared each other of planned inspection electronically with all affected parties. Concurrence and activities, issuance of inspection distribution requirements for related correspondence have been reports. status of technical review defined and implemented. Training of affected staff was accomplished activities and receipt of intervenor in 1996 and included the full day Spent Fuel Storage and communications in a timely manner were Transportation Workshop. NMSS has developed a master inspection noted. schedule and monthly status summaries of licensing case work to compile a list of projected dry cask storage activities. NRR has developed a monthly report to track the status of its actions on dry.

cask storage. All these documents are shared between offices. No significant. concerns regarding coordination among NRC organizations have been identified during the last 12 months. This item is complete.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued COMMUNICATIONS Internal Communications - Staff Trainino NMSS Complete Training sessions regarding the regulatory requirements and Many NRC staff had not previously worked licensing mechanisms for dry cask storage systems were held both in on dry cask storage and were unfamiliar Headquarters and the Regional offices. Since the inception of the  ;

with the associated regulatory Dry Cask Storage Action Plan, two standard review plans and 5 requirements, inspection activities and inspection procedures have been published to provide review and the licensing process. General inspection guidance to the staff as well as a description of the information on design bases, regulatory design basos for cask system components. Videos of the full day r requirements and inspection findings were Spent Fuel Storage and Transportation Workshop as well as the May not provided to NRC staff in a timely 30. 1996. Comission briefing on spent fuel storage have been made manner. available to hPr staff for training purposes. NUREG 1571. "NRC Handbook on Independent Spent Fuel Storage Installations (ISFSIs) was provided to affected staff as they were assigned to dry cask storage oversight activities and is currently being printed in i quantity for broader distribution to staff. This item is complete. '

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued COMMUNICATIONS External Communications - Industry Complete NMSS Administrative Letter 95-04 was issued _on November 1. 1995 to Interface inform the industry of the responsibilities of NRR and NMSS Past communications with licensee have not pertaining to oversight and regulation of dry cask storage always been effective or timely. In some activities. Periodic meetings with NEI and the industry, including cases. NRC became involved after licensee the full day Spent Fuel Storage and Transportation Workshop, have and vendor decisions, based on erroneous been conducted over the past 2 years. Kickoff meetings are held interpretations of NRC requirements. had among NMSS. NRR and utility staff for these utilities considering been made thereby causing disputes and implementation of dry cask storage facilities to clarify NRC delays. expectations. NMSS Project Managers have been assigned for each cask system and affected utilities are routinely contacted to determine the status of any dry cask storage activities. NRC staff have issued 2 Generic Letters and 3 Information Notices informing industry of developments in the dry cask storage area and continue to periodically meet with NEI and affected utilities. This item is complete.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued COMMUNICATIONS External Communications - Public NRR Closed NRR has the responsibility for answering queries from individuals Resoonsiveness external to the NRC. Two NRR individuals have been specifically Membars of Congress and the public have assigned to respond t such inquiries in a timely manner. While the expressed concern regarding licensee plans number of inquiries has not decreased, the timeliness of response and NRC regulatory activities related to has improved. All incoming correspondence is monitored using dry cask storage. existing tracking mechanisms, including 2.206 petitions. Most documents related to dry cask storage are placed in the PDRs and staff has sought public comment on draft NRC guidance documents, including the inspection procedures and standard review plans. All meetings with cask vendors and affected utilities are open to the public and are properly noticed. Industry press have attended such meetings and discussed them in the trade press which is also available to the public. Continued interactions with the public are handled through established NRC processes. This item is complete.

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SUMMARY

OF DRY CASK STORAGE ACTION PLAN ISSUES continued PROCEDURAL ISSUES Issue Descriotion Lead Status Closure Method Office Chanae Processes NMSS Open NMSS expectations for staff review of changes to cask designs was The method for approving changes to cask for Pt presented in staff training in August 1995. General guidance for SARs was not well understood. Some staff 72; NRR the review of cask design changes made under 10 CFR 72.48 were were unfamiliar with the practices and for Pt included in the dry cask storage inspection procedures issued in requirements for licensee documentation of 50 February 1996. However, more detailed guidance is in preparation proposed changes, including documentation and a new inspection procedure will be issued during the summer of of analyses supporting the change. 1997. Development of this new procedure will be coordinated with the ongoing NRR effort to enhance guidance related to 50.59 changes.

NRR has determined that plant modifications resulting from the implementation of a dry cask storage facility do not require separate guidance and may be evaluated under 10 CFR 50.59. NRR continues to evaluate its inspection guidance related to 50.59 changes.

Part 72 Reoortino Recuirements NMSS Closed On September 19. 1995, the NRC informed the industry that licensees Utilities have questioned whether they are are required to comply with the provisions of 10 CFR 72.82(e) This subject to the reporting requirements item is complete.

defined in 10 CFR 72.82(e) 13

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, i PROCEDURAL ISSUES t Insoections of Site Activities NMSS Complete- NMSS issued inspection procedures for the oversight of dry cask In some cases, inspections of site storage activities in February 1996. These procedures were updated I activities under Parts 50 and 72 are not in May 1996 and will be updated periodically in response to new  !

4 clearly defined. On-site inspections have concerns and issues. These procedures were reviewed by affected been conducted using either general inspection staff and include estimates of resources required to i inspection modules or site-specific conduct these inspections. This item is complete.  !

inspection plans. Inspection procedures j are needed for such inspections and l required resources should be identified. .

Vendor Insoection NMSS Complete The Transportation and Storage Safety Inspection Section has Inspections of vendors to ensure developed an inspection schedule for the oversight of dry cask consistency with dry cask design storage activities. Inspection schedules now consider delivery i requirements have been scheduled when dates for specific cask components and are coordinated with NRR and i components are near Lunpletion. This the Regions so that inspections are conducted earlier in the  ;

4 schedule made it difficult for fabricators fabrication process.* This item is complete,  !

to correct any identifieo deficiencies.

Cask Desian and SAR Differences NMSS Complete Draft Standard Review Plans have been published to discuss and Cask Safety Analysis Reports vary among clarify NRC expectations for the_ review of cast certification and l vendors in style and format. Cask designs license applications. These documents discuss the typical format  !

vary. and design features and related test and content for such applications. NRC expectations were discussed  ;

requirements differ from cask to cask. during the full day workshop held in May 1996 as well as in meetings  !

with cask vendors and utilities. NRC expectations remain as defined  ;

in the Standard Review Plan for Dry Cask Storage Systems published in February 1996. This item is complete.

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! NEW ISSUES RELATED TO DRY CASK STORAGE i

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i DECEMBER 1996 i

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e l New issues Related to Drv Cask Storage ISSUE: MOVEMENT OF CASKS PRIOR TO SECURING OF LID LEAD: NRR

! STATUS:. In the cask loading sequence, it may be possible to tip the cask such that fuel assemblies spill out of the cask onto the floor surface or into the pool if the cask lid is not secured prior to cask movement.

i NRR has subsumed this issue under the " Heavy Load Control and Crane issues Task

Action Plan" which is being reviewed and, once approved, will be available to the  ;

public. As part of the.NRC Bulletin 96-02, " Movement of Heavy Loads Over Spent Fuel, '

Over Fuel in the Reactor Core, or Over Safety-Related Equipment," review effort, NRR ,

3 issued requests for additional information to various utilities in December 1996 l 1

regarding the subject scenario Completion of the Heavy Load Control and Crane '

, Issues Task Action Plan is currently projected for December 1997.

1 ISSUE: INSPECTION OF ISFSI SUPPORT FUNCTIONS AT REACTOR SITES LEAD: NRR STATUS: Currently, inspection procedures for the oversight of utility activities that provide support for ISFSI operations do not exist in the reactor inspection program defined by Manual

' Chapter 2515, " Reactor Operations." NRR plans to develop inspection requirements related to ISFSI suppo'rt in the areas of Quality Assurance, Security, Radiation Protection and Emergency Preparedness with issuance projected by the end of calendar year 1997, 16

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j APPENDIX A-J i

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OF ORIGINAL DRY CASK ACTION PLAN ISSUES i

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SUMMARY

OF ORIGINAL DRY CASK ACTION PLAN ISSUES TECHNICAL NEAR-TERM ACTIONS ISSUE: HEAVY-LOAD CONTROUCRANE ISSUES This issue included the suitability and adequacy of crane qualifications at specific sites, possible inadequacies of generic qualification standards for crane components, appropriateness of paths traversed by cranes when handling casks (safe load paths), and adequacy of licensee procedures and load drop analyses.

Licensees have different plant configurations requiring site specific evaluations.

Interpretation and implernentation of existing requirements and commitments, including NUREG 0612 and licensee responses to Generic Letter 85-11, also varies slightly from site to site. The potential for inconsistent approaches is high.

4 LEAD: NRR with NMSS assistance ISSUE: CASK TRUNMIONS l

Requirements for the design and acceptance testing of trunnions and special lifting devices for casks were not well understood by affected NRC staff and licensees.

Althcugh each cask design met the requirements, testing requirements were not consistently documented from cask SAR to cask SAR. This caused confusion during pre-operational testing.

LEAD: NMSS ISSUE: HYDROSTATIC TESTING Requirements for hydrostatically testing the primary confinement for dry cask storage l systems were not specifically documented in SARs in that test pressures were not l explicitly identified in some cases. Also, vendors often did not explicitly state the cask maximum normal operating pressure from which the test pressure is derived.

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i j ISSUE: SEISMIC REQUIREMENTS FOR SPENT FUEL STORAGE PADS j Under the provisions of the Part 72 general license, licensees are required to verify that

" cask storage pads and areas have been designed to adequately support the casks" and "whether or not reactor site parameters...are enveloped by the cask design parameters."

One licensee attempted to perform a simple comparison of the reactor site earthquake spectra to the cask design bases without evaluating the spectra at the actual location of '

the ISFSI. Although subsequent analyses proved that the cask design values were bounding, the NRC determined that the requirements for analysis of the cask storage pad l location needed clarification.

} LEAD: NMSS with NRR assistance-l TECHNICAL LONG-TERM ACTIONS

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ISSUE

CASK WEEPING l Transfer casks submerged in spent fuel pools over a period of days are decontaminated l upon removal from the pool. Occasionally these casks exhibit recurrent surface i contamination a few days later. This phenomenon is attributed to contaminated water 2-becoming entrapped in the interstitial spaces of the metal and " weeping" out over time.

LEAD: NMSS l h ISSUE: CASK LOADING AND UNLOADING '

Recent experience has shown that some cask loading and unloading procedures have l been inadequate and of variable quality. Unloading procedures often are simplistic and

! may not include sufficient detail for actual use. Few procedures fully account for failed

. fuel, taking of additional air samples, cask disassembly and radiation protection

} requirements. Licensees inconsistently apply their procedure writing guidelines to i i documents governing these activities. Thus far, this issue has been dealt with on a site specific basis.

LEAD: NRR with NMSS assistance i

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I ISSUE: OFF LOADING CAPABILITY

! Some licensees planning to permanently shut down their reactors may choose to build an i

ISFSI in order to remove all fuel from the spent fuel pool. Part 72 requires that fuel stored in dry casks be retrievable. This means that plants that have decommissioned their spent fuel pools and operate an ISFSI must have a viable method for retrieving the fuel from the

casks for inspection, further processing or disposal. This requirement applies even if a spent fuel pool is not available; therefore, such licensees must provide an attemate method for retrieving their fuel. NRC expectations regarding retrievability of fuel should be j clarified and communicated to the industry.

LEAD: NMSS i

I ISSUE: FAILED FUEL STORAGE

! Guidelines for the storage of failed fuel or fuel otherwise susceptible to significant cladding j structural failures do not exist. Fuel stored in casks must remain in a coolable geometry 1 for both criticality and cask handling considerations.

j LEAD: NMSS i

ISSUE: SAFEGUARDS CONCERNS 1

Safeguards concerns have repeatedly been raised by members of the public.

, LEAD: NMSS COMMUNICATIONS lSSUE: INTERNAL COMMUNICATIONS - COORDINATION l

In some cases, communications among NRC offices were incomplete or ineffective.

Some examples of NRC offices not informing each other of planned inspection activities, E issuance of inspection reports, status of technical. review activities and receipt of i- intervenor communications in a timely manner were noted.

i LEAD: NRR and NMSS t

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ISSUE: INTERNAL COMMUNICATIONS - STAFF TRAINING Many assigned NRC staff had not previously wt.rked on dry cask storage and were unfamiliar with the associated regulatory requirements, inspection activities, and licensing process. Generalinformation regarding the design bases, regulatory requirements, inspection findings, and lessons learned from observation of licensee dry cask storage activities was not provided to NRC staff in an efficient manner.

LEAD: NMSS with NRR assistance ISSUE: EXTERNAL COMMUNICATIONS - INDUSTRY INTERFACE Past communications with licensees have not always been effective or timely. In some cases, NRC became involved after licensee and vendor decisions, based on erroneous interpretations of NRC requirements, had been made based thereby causing disputes and delays.

LEAD: NMSS ISSUE: EXTERNAL COMMUNICATIONS - PUBLIC RESPONSIVENESS 4

Members of both the public and Congress have expressed concern regarding recent licensee plans and NRC regulatory activities related to ISFSis. This has been exacerbated by confusion as to whether NRR or NMSS is responsible for answering inquiries from the public on ISFSI matters as well as by poor communications among NRC

staff.

LEAD: NRR with NMSS assistance PROCEDURAL ISSUES ISSUE: CHANGE PROCESSES I

The method for approving changes to cask SARs was not well understood. Some staff members were unfamiliar with the practices and requirements for licensee documentation of the analyses supporting changes to plant programs and procedures as well as cask

, design and fabrication methods.

LEAD: NMSS for Part 72; NRR for Part 50 A-4

i ISSUE: PART 72 REPORTING REQUIREMENTS Utilities have questioned whether they are subject to the reporting requirements delineated in sections of Part 72. A formal challenge regarding the applicability of 10 CFR 72.82(e) was received by the NRC on July 28,1995.

LEAD

NMSS, with assistance from OGC and NRR i

ISSUE: INSPECTION OF SITE ACTIVITIES in some cases, inspections of site activities under Parts 50 and 72 are not clearly defined.

On-site inspections have been conducted utilizing either existing general inspection modules or site-specific comprehensive inspection plans. An inspection program and i

pertinent procedures must be developed for oversight of ISFSis. Also, required resources i should be determined and incorporated into the resource allocation discussions for plants expecting to employ an ISFSI.

LEAD: NMSS for Part 72 issues; NRR for Part 50 issues; with support from the Regions ISSUE: VENDOR INSPECTION i

Inspections of vendors to ensure consistency with dry cask design requirements have l been scheduled when components are near completion. This schedule made it difficult i for the fabricator to correct any identified deficiencies. Inspections were primarily focused on the Quality Assurance Program.

i l LEAD: NMSS, with support from NRR and the Regions 1 1 1 i ISSUE: CASK DESIGN AND SAR DIFFERENCES Cask Safety Analysis Reports vary among vendors in style and format. Cask designs vary, and design features and related test requirements differ from cask to cask. In addition, the technical basis for cask designs are not consistently documeMed among the various cask SARs.

4 LEAD: NMSS i

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