ML20198K269

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Forwards Update to NMSS Policy & Procedures Ltr 2-3, B.1.B,which Replaces Existing Guidance.Update Being Issued to Provide Clarification on Several Issues,Including Differences Between Independent ISFSI & site-specific
ML20198K269
Person / Time
Issue date: 10/16/1997
From: Linehan J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To:
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
NUDOCS 9710230246
Download: ML20198K269 (16)


Text

e er 16, 1997 l MEMORANDUM TO: All NMSS Employees l

  • FROM: John J. Lineh:n, Director Program Management, Policy Development and Analysis Staff Office of Nuclear Material Safety and Safeguards

SUBJECT:

UPDATED NMSS POLICY AND PROCEDURES LETTER 2-3, ATTACHM6NT B.1.B Attached is an update to NMSS Policy and Procedures Letter (P&PL) 2 3, Attachment B.1.8, which replaccs the existing guidance. This update will remas in effect until the next permanent revision of P&PL 2 3 is issued. P&PL 2-3, Attachment B.1.B. contains guidance for reporting Regulatory information Tracking System (RITS) Information for activities associated with inspections, technical reviews, and licensing of spent fuel storage systems that are licensed under 10 CFR Part 72 and spent fuel transportation systems that are licensed under Part 71.

This update is being issued to provide clarification on several issues, including differences between Independent Spent Fuel Storage installation (ISFSI) general and site-specific licensees, providing new guidance on away from reactor ISFSis, and ensuring consistency with the spent fuelinspection program (Inspection Manual Chapter 2690). PMDA has reviewed and coordinated these changes with the Spent Fuel Project Office, NMSS, and License Fee and Accounts Receivable Branch, Office of the Controller.

Because staff RITS time expenditures are the basis for receiving funds from the Nuclear Waste Fund, from reimbursable agreements, and calculating license and inspection fee bills sent to licensees, it is essential that time be reported promptly and accurately, if you have any question or need assistance, please contact Mary Rogers, PMDA at 415 7813 or e-mail (MLR) or Phil Brochman, SFPO at 415-859 or e-mail (PGB).

Attachment:

Updated P&PL 2-3, Attachment B.1.B cc: Deputy Regional Administrators ,

R. Zimmerman, NRR

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NRC f/c NMSS r/f NMSS Dir/r/f SFPO r/f PMDA r/f PUBLIC W. Reckley, NRR F. Gillespie, NRR M. Rogers, NMSS M. Messler, OC C. Anderson, RI W. Gloerson, Rll R. Landsman, Rlli J. Evrerett, RIV 9 b( p) 6.p 6 Proofed By: EDS Concunence Division: NMSS Date: 10/10/97 See previous h,c~{

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FY98 REVIEW PROCESS FOR INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS (ISFSI)

Charge to Charge to Charge to TAC # Inspection Mission Report # Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE General License ISFSIs Desian evaluation nhase:

-A licensee holding a Part 72 general license may . /

make changes via the 72.48 process to spent fuel storage casks listed in 72.212, if the licensee determines that prior NRC approval is not required, inspection of the licensee's 72.48 evaluations will be cnarged to that licensee using the 72-docket number associated with the general license.

If the licensee determines that NRC prior /

a> proval is required for the proposed changes, tle licensee must request that the Certificate of Compliance (CoC) holder submit an application to amend the CoC to the NRC. The COC is amended by rulemaking. Staff activities during rulemaking which involve reviewing changes to the dry cask storage system's (DCSS) design:

3reparing, reviewing, or revising the NRC Safety Evaluation Resort (SER): revising the CoC: and addressing pu)lic comments will be charged to the CoC holder using the 72-docket number associated with the. certified cask design.

Inspections of the CoC holder or fabricator /

which are related to the issuance of the CoC will be charged to the CoC applicant using the 72-docket number associated with the certified l cask design.

-Issue Date: 10/16/97 -1 Attachment B.1.B

Charge to Charge to Charge to TAC # Inspection Mission Report # Direct RITS#

DESCRIPTION OF ACT WITY FULL COST FULL COST NONFEE Activities involving rulemaking to revise a CoC. /

which have been requested by the CoC holder in support of a general licensee, will be charged to the CoC holder using the 72-docket number associated with the certified cask design.

While there are no hearings under CoC rulemakings, any public meetings that may occur at a location near the site of the proposed ISFS1 and whic's are directly related to the /

certified cask design to be used there should be charged to that licensee using the 72 docket number associated with the general license.

-If the licensee determines that an amendment +- /

the co located Part 50 license is required. '

licensee must subinit an ap)lication for NRC review. Staff review of t11s application will be charged to the licensee using the 50 docket number associated with the reactor license, inspection of licensee activities in support of /

an a> plication to amend the Part 50 license will )

be clarged to the licensee using the 50-docket number associated with the reactor license.

4 Issue Date: 10/16/97 2 Attachment B.I.B

~,

4 Charge to Charge to Charge to TAC # Inspection Mission Report # Direct  ;

RITS#

DESCRIPTIOil 0F ACTIVITY FULL COST FULL COST NONFEE

~

[MinqPhasetibrication. Construction. and Preooerationd inspection activities associcted with observing /

on site fabricatio1, construction, and preoperationa' '4 scing at*/"ies, including r eviewing 72. m(b) evaluatic.u. revicaing 72.48 r.ai..'tions, reviewing spent tue' !oading and unloaf ny r ocedures, and reviewilig preoperatiunal testing (including Observing the c'ry run) will be charged to that licensee using 4 the 7E-docket number associated with the general license. Note: The inspection report of these a Mivities is issued against the licensee.

Inspection activities associated with reviewing /

the li;ensee's 50.59 evaluations and changes to prograrra which support operation of the ISFSI will be charged to the licensee using the 50-docket number associated with the reactor license. Examples of support programs include:

radiation ;;rotection, security, emergency preparedness, training, and quality assurance.

Inspection activities. which are focused on the /

impact of the ISFSI on the safety of tho reactor, will be charged to the licensee using the 50-docket number associated with the reactor license.

Inspection activities, which are focused on the /

im]act of the reactor on the sa9ty of the ISFSI. w111 be cnarged to that licensee using the '/2-docket number associated with the general s license.

J Issue Date: 10/16/97 3 Attachment ~8.1.B

.j

Charge,to Charge to Charge to TL Inspection Mission Report # Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE Doerations Phase Inspection of licensee activities, involving /

observing loading cr unloading spent fuel: .

reviewing 72.48 evaluations: and observing )

surveillance monitoring of loaded ISFSIs, maintenance, modifications, and training activities will be charged to that licensee '

using the 72-docket number associated with the 1 general license.

i Inspectinn of licensee activities, involving /

operation of the spent fuel pool and associated

- equipment, movetent of spent fuel, operation of reactor /fu>' 1dling building systems, and cha~ '

ms v.hich support operation of tb i . radiation protection, security, s

e preparedness), will be charged to t . see using the 50-docket number lat iated with the reactor license.

Inspection of licensee activities, involving /

review of annual reports of 72.48 evaluations and 72.70 annual updates of the SAR. will be charged to that licensee using the 72-docket number associated with the general license.

Inspection activities, wnich are focused on the / l impact of the ISFSI on the safety of the reactor, will be charged to the licensee using the 50-d3cket number assorlated the reactor license. I

, Inspection activities which are focused on the /

im]act of the reactor on the safety of the IS SI. will be charged to that licensee using the 72-docket number associated the general license.

t Issue Date: 10/16/97 4 Attachment T.1.B ,

J

~

Charge to Charge to Charge to TAC # Inspection Mission Report # 01 rect RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE Staff effort on reviewing ISFSI activities under /

572.218. which is associated with termination of the reactor license, will be charged to that licensee using the 72-docket number associated ,

with the general license.

  • Note: SFP0 establishes a 72-docket number for a general licensee when the NRC is informed that the licensee plans to use a DCSS approved under Subpart K. A " license" number will ',e entered into the LTS database after the general licensee notifies NRC that spent fuel has been loaded into the ISFSI per 72.212(b)(1)(11).

Sitc Specific Licensed ISFSI located at a Power Reactor Site L1:ensina. Fabrication. Construction. and Preooerational Testina Phases Staff effort on reviewing and approving an /

application for a site-specific ISFSI license will be charged to the applicant using the 72-docket number associated with the site-specific license.

Inspection activii.ies associated with verifying /

the applicant's implementation of commitments made in the SAR or with observing fabrication, construction, and preoperational testing activities will be charged to the applicant

-using the 72-docket number associated with the site-specific license. These activities include reviewing 72.48 evaluations, reviewing spent fuel loading and unloading procedures, and reviewing preoperational testing (including o'oserving the dry run;.

Issue Date: 10/16/97 5 Attachment B.1.B

Charge to Charge to Charge to TAC # Inspection Mission Report #- Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE If the licensee determines that 'an amendme t to /

the co located Part 50 license is required, the licensee must submit an apalication for NRC review, Staff review of t11s application will be charged to the licensee using the 50-docket number associated with the reactor license.

Inspection of activities associated with /

reviewing the licensee's 50.59 evaluations and with implementing changes to programs which support operation of the ISFSI will be charged to the licensee using the 50-docket number associated with the reactor license. Examples of support programs include: radiation protection, security. emergency preparedness.

training, and quality assurance.

Staff effort on reviewing changes to licensee /

programs, for which the licensee has determined that a reduction in effectiveness will occur and i which support operation of the ISFSI will be charged to the licensee using the 50-docket number associated with the reactor license.

1 Inspection activities, which are focused on the /- "

impact of the ISFSI on the safety of tM reactor, will be charged to the licensee using the 50 docket number associated with the reactor license.

Inspection activities, which are focused on the l

/  !

tmaact of the reactor on the safety of the IS SI, will be charged to the licensee using the ,

72-docket number associated with the site-specific license.

Issue Date: 10/16/97 6 Attachment B.1.B i

O Charge to Charge to Charge to TAC # Inspection Mission

  • Report # Direct RITS#-

DESCRIPTION OF ACTIVITY FutL COST FULL COST NONFEE Inspection of fabricator activities, which are /

focused on the DCSSs being built for a particular licensee and for which an inspection report will be issued against the licensee, will be charged to that licensee using the 72-docket number associated with the site-specific license, Inspection of fabricator activities, which are /

not associated with a particular licensee and for which an inspection report will be issued against the fabricator or vendor, will be charged to mission direct support.

Staff effort on license hearings will be charged as follows:

. For uncontested hearings, staff effort /

will be charged to the applicant under the 72-docket number associated with the site-specific license.

. For contested hearings, staff effort will /

be charced as mission direct effort in support of the ISFSI program area.

Staff effort associated with attendance at /

public meetings for an application for a site-specific license will be charged to the applicant using the 72-docket number associated with the site-specific license.

l 00erations Phase Inspection of licensee activities, involving /

operation of the spent fuel pool and associated equipment, movement of spent fuel, and operation of reactor / fuel handling building systems. will be charged to the licensee using the 50-docket number associated with the reactor license.

Issue Date: 10/16/97 7 Autachment B.1.B

__ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . - - - . - - - - - - - - ---___.---a

l Charge to Charge to Charge to TAC # Inspection Mission.

Report # Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE

' Inspection o/ licensee activities. involving /

observing loading or unloading spent fuel:

reviewing 72.48 evaluations: and observing surveillance monitoring of loaded ISFSIs.

maintenance, modifications, and training '

activities' will be charged to the licensee using the 72-docket number associated with the-site-specific license.

-Staff effort on reviewing applications to amend, /

terminate. or renew the-license will be charged to the licensee.using the72-docket number associated with the site-specific license.

Inspection of licensee activities, involving /

review of annual reports of 72.48 evaluations ,

and 72.70 annual updates of the SAR'. will be charged to the licensee using the 72-docket number associated with the site-specific license.

Inspection of licensee changes to the physical /

security or emergency preparedness plans will be charged to the licensee using the 50-docket number associated with the reactor license.

Staff effort on reviewing proposed changes to /

the physical security or emergency preparedness plans which decrease their effectiveness or of any proposed changes to the quality assurance plan, will be charged to the licensee using the 50 docket number associated with the reactor license.

Inspection activities. which are focused on the /

impact of the ISFSI.on the safety of the reactor. will be charged to the-licensee using the 50-docket number associated the reactor license.

. Issue Date: 10/16/97 8 Attachment B.1.B

Charge to Charge to Charge to TAC # Inspection Mission Report # Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE I Inspection activities, which are focused on the /

impact of the reactor on the safety of the ISFSI will be charged to the licensee using the 72-docket number associated the site-specific license.

  • Note: SFP0 establishes a 72-docket number for a site-specific licensee when an application is submitted to the NRC. A license numbar will be entered into the LTS database when the license 5 is issued.

Site Specific Licensed ISFSI located Away From Any Power Reactor Site (AFR ISFSI)

Licensina. Fabrication. Construction. and Preonerational Testina Phases Staff effort on reviewing and approving an /

applicat">n for a site-specific AFR ISFSI license will be charged to the applicant using the 72-docket number associated with the site-specific license.

Staff effort on license hearings will be charged as'follows:

. For uncontested hearings, staff effort /

will be charged to the applicant under the 72-docket number associated with the site-specific license.

  • For contested hearings, staff effort will /

be charged as mission direct effort in support of the ISFSI program area.

Issue Date: 1o/16/97 9 Attachment B.1.B

e 1 i

Charge to Charge to Charge to .!

TAC # Inspection Mission Report # Direct RITS#

DESCRIPTION OF ACTIVITY l ~

FULL COST FULL COST NONFEE l

L Staff effort on attendance at public meetings /

for an ap)lication for a site-specific license will be clarged to the applicant using the 72-docket number associated with the site-specific licerise.

Inspection of fabricator activities, which are /

focused on the DCSSs being built for a particular licensee and for which an inspection report is issued against the licensee, will be charged to that licensee using the 72-docket i

number associated with the site-specific license.

I- Inspection of fabricator-activities, which are /

not associated with a particular licensee and for which an inspection report will be issued against the fabricator or vendor, will be charged to mission direct support, Inspection activities tssociated with verifying /

the applicant's implementation of commitments made in the SAR or with ub*erving fabrication, construction, and preoperational testing activities will be charged to the applicant using the 72-docket number associated with the site-specific license. These activities include reviewing 72.48 evaluations, reviewing spent fuel loading and unloading procedures, and reviewing preoperational testing (including observing the dry run).

Inspection of an applicant's implementation of /

programs which support operation of the AFR ISFSI will be charged to the ap]lica1t using the

.72-docket number associated wit 1 the site-specific license. Examples of suppc t_ programs include: radiation protection, security, emergency preparedness, training, and quality assurance.

Issue Date: 1o/16/97 10 attachment B.1.B A

l 0

" Charge to Charge to Charge to TAC # Inspection- Mission Report #- Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE Ooerations Phase Inspection of licensee activities, involving /

review of annual reports of 72.48 evaluatie s and 72.70 annual updates of the SAR. will be charged to the licensee using the 72-docket number associated with the site-specific license.

Inspection of licensee activities, involving /

observing loading or unloading spent fuel; reviewing 72.48 evaluations: and observing surveillance monitoring of loaded ISFSIs, maintenance, modifications. transportation, and training activities, will be charged to the licensee using the 72-docket number associated with- the site-specific license.

Inspection of licensee changes to the physical /

4_ security or emergency preparedness plans will be charged to the licensee using the 72-docket number associated with the site-specific license.

Staff effort on reviewing proposed changes to /

the physical security or emergency preparedness plans which decrease their effectivenen or of-any proposed changes to the quality assurance plan, will be charged to the licensee using the 72-docket number associated with the site-specific license.

Staff effort on reviewing applications to amend, /

terminate, or-renew the license will be charged to the licensee using the 72-docket number associated with the site-specific license. j Issue Date: 10/16/97 11 Attachment B.1.B

e.

Charge to Charge to Charge to TAC # Inspection Mission <

Report # Direct RITSP DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE

-- Note: SFP0 establishes a 72-docket number for-the site specific licensee when an application is submitted-to the NRC. A license number will

' be entered-into the LTS database when the license is issued.

Certificate of Compliance (CoC) Under Part 72 Issued for a Dry Cask Storage System (DCSS)

Staff effort on rulemaking for applications to /

amend. revise. supplement or renew a CoC will be charged to the CoC holder using the 72-docket number associated with certified cask design.

Staff effort on rulemaking for applications for /

a CoC under Part 72 will be charged to the CoC applicant using the 72-docket number associated with certified cask design. These efforts may include reviewing the DCSS design and SAR.

preparing and issuing the NRC SER. preparing the CoC. and responding to public comments on the proposed rulemaking.

Under rulemaking for a CoC application there are /

no related hearings; however. staff effort on attendance at public meetings associated with the rulemaking. that are located near the applicant, will be charged to the 72-docket number associated with the certified Cask E design.

Inspections of CoC holders or fabricators in /

support of rulemaking to approve, modify.

revise, or suspend the CoC will be charged to the CoC holder using the 72-docket number associated with certified cask design.

Issue Date: 10/16/97- 12- Attachment B.1.B-

Charge to Charge to Charge to TAC # Inspection Mission Report # Direct RITS#

DESCRIPTION OF ACTIVITY FULL COST FULL COST NONFEE Inspections of vendors or fabricators in support /

of the NRC vendor inspection program, and which are not associated with any particular ISFSI licensee, will be charged to the CoC holder using the 72-docket number associated with certified cask design.

  • Note: SFP0 establishes a 72-docket number for a CoC when the application is submitted. Once the CoC is issued. SFP0 will enter a " license" number into the LTS database.

Certificate of Compliance (CoC) Under Part 71 Issued for a DCSS l

Staff efforts on reviewing app.lications to /

approve, renew, or amend a CoC under Part 71 will be charged to the CoC applicant using the 71-docket number associated with the transportation package. This may include reviewing the transportation package (DCSS) design and SAR. preparing alid issuing the NRC SER. or preparing the CoC.

Inspections of vendors or fabricators in support /

of ap3roval, amendment, or revision of the CoC will 3e charged to the CoC applicant using the 71-docket number associated with transportation package.

  • Note: SFP0 establishes a 71-docket number for a CoC when the application is submitted.

Issue Date: 10/16/97 13 Attachment B.1.B

-r-1 Charge to Charge to_ Charge to  !

TACf Inspection dission Report # Direct RITS#

DESCRIPTION OF ACTIVITY FULL COSf FULL COST- NONFEE l'TopicalReportReview

, Staff efforts on reviewing applications to /

approve or amend a topical report under Part 72 will be charged to the applicant (vendor) using the 72-docket number associated with the topical report. These efforts may-include reviewing the

- design and SAR of the application (e.g., the design of a DCSS. ISFSI or dry transfer system) and preparing and issuing the hRC SER.

InsSections _of vendors or fabricators associated /

wit 1 the approbl _of the topical report w111 be charged to the applicant using the 72-docket number associated with the topical report.

  • Note: SFP0 establishes a 72-docket number for a topical report when the application is i; submi tted. ,

l _ Standardized Spent Fuel Storage Facilities

. l Staff efforts on reviewing applications to /

approve, revise, renew. or amend a standardized spent fuel storage facility will be charged to t1e applicant using the 72-docket _ nunber i i associated with the standardized spent fuel '

storage facility.

Inspections of standardized spent fuel storage / l facilities will be charged to the licensee using the 72-docket number associated with the standardized spent fuel __ storage facility license. -

  • Note: SFP0 establishes a 72-docket number for l

.a stendardized spent fuel storage facility when an-application is submitted.

' Issue Date: 10/16/97 _14 Attachment B.1.B 7

u_ ...

l' j GENERAL NOTES -

NOTE 1: Any correspondence related to an ISFSI should include V. Tharpe on cc:.

' Copies of all application requests. NRC approval letters and notification of initial loading, for general license ISFSis, should be sent to M. Rogers. NMSS:PMDA.

These copies will then be forwarded to M. Messier. OC:LFARB. for fee billing purposes. Please document the 72-docket or 71-docket number and TAC / Inspection report number on all corres)ondence. To establish a TAC nu:nber contact V. Tharpe for all 72-docket or 71-doccet related TACs.

End s

k 1'

I-10/16/97 Issue Date: 15 Attachment B.1.B

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