ML20246E848
| ML20246E848 | |
| Person / Time | |
|---|---|
| Issue date: | 05/02/1989 |
| From: | Amenta J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| To: | |
| References | |
| NUDOCS 8905120040 | |
| Download: ML20246E848 (14) | |
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i U.S. Nuclear Regulatory Commission 3 1 5 0_
W. R. Person 301.
492-3764 10 CFR 72, Licensing Requirements for the Storage of Spent Fuel in an Independent Spent Fuel Storage Installation (ISFSI) 42 2201(o)
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OMB SUPPORTING STATEMENT LICENSING REQUIREMENTS FOR THE INDEPENDENT STORAGE OF SPENT NUCLEAR FUEL AND HIGH-LEVEL RADIOACTIVE WASTE Proposed Amendments to 10 CFR Part 72 to Permit Storage of Spent Nuclear Fuel in NRC-Approved Casks at Nuclear Power Reactor Sites Justification It is anticipated that power reactor licensees will have a major need for additional spent fuel storage capacity at reactor sites starting in the early j
1990s.
The Nuclear Waste Policy Act of 1982 (NWPA) recognizes this need for additional capacity at nuclear power reactor sites.
In Section 218(a) the NWPA directs the Department of Energy (00E) to establish a demonstration program, in cooperation with the private sector, for the dry storage of spent fuel at reactor sites with_the objective of establishing one or more technologies that the Commission may approve for use at civilian nuclear power reactor sites without the need, to the maximum extent practicable, for additional site-specific approvals.
In Section 133 the NWPA directs that the Commission shall establish, by rule, procedures for the licensing of any technology approved by the Commission under Section 218(a). The recently revised regulations in 10 Part 72 made effective on October 19, 1988 do not permit licensing the storage of spent fuel without extensive site reviews.
Need for and Practical Utility of the Information Collection Under the proposed rule power reactor licensees would be allowed to store spent fuel in NRC-approved casks at reactor sites under a general license.
These licensees would not be required to submit license applications or related documents, such as safety analysis reports.
However, they would have to maintain records showing compliance with the conditions of the rule for inspection by the Commission.
The proposed rule would permit referencing and
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7 modification of documents, plans, and programs previously submitted by the licensee and approved by the NRC.
The Commission will rely on its inspection and enforcement authority to ensure compliance with its regulations.
The proposed rule would also set forth procedures and criteria for obtaining NRC approval of spent fuel storage cask designs.
A record would be initiated, by spent fuel storage cask vendors, for each cask fabricated.
The record would contain the cask Certificate of Compliance number, the cask model number, the cask identification number, the date that the cask was fabricated, and certification that the cask was designed, fabricated, and tested under an NRC accepted quality assurance program.
This record would be forwarded to the cask user, i.e., reactor licensees, who would maintain the record. The user would enter such information as maintenance j
(e.g., replacement of pressure gauges), upgrading of components (e.g.,
replacement of bolts or gaskets with different materials), defects, and damage resulting from accidents in the historical cask record.
If a cask is sold, leased, or otherwise transferred the historical cask record would be transferred and maintained by the new user.
The final cask user would retain the historical cask record for 3 years af ter the cask is decommissioned.
Approval of a cask design is limited to 20 years.
After that period the design would have to be reapproved.
The cask vendor would be expected to submit the application for reapproval, however, cask users or their representatives could also apply.
I Information concerning reporting and recordkeeping requirements, by specific section number in the proposed rule, follows:
Section 72.212(b)(1)(1) specifies that the general licensee notify the Commission at least 90 days before the first storage of spent fuel under the general license.
Since the Commission will rely on its inspection and enforcement authority to ensure compliance with its regulations, it needs a record of licensees storing spent fuel under the general license.
Section 72.212(b)(1)(ii) specifies that a general licensee register use of each cask with the Commission no later than 30 days after using the cask to store 2
n spent fuel. Registration of cask use is needed by the NRC staff to obtain information on the use of spent fuel storage casks in order to establish and maintain an independent historical record for each cask.
Section 72.212(b)(2) specifies that the general licensee perform written evaluations showing that conditions specified in the cask Certificate of l
Compliance are met. This review is necessary to show that storage of spent fuel is in accordance with the Certificate of Compliance. This record would be made available for inspection by the Commission and must be retained as long as spent fuel is stored under the general license.
Section 72.212(b)(3) specifies that the general licensee review the safety l
analysis report (SAR) referenced in the cask's Certificate of Compliance and the related safety evaluation report to determine that the licensee's site parameters are enveloped by the cask design capability. A copy of the SAR would be obtained from the cask vendor.
The results would be documented under 972.212(b)(2), but there would be no submittal to the NRC. This review is l
necessary to show that storage of spent fuel is in accordance with the Certificate of Compliance.
Section 72.212(b)(7) specifies that the general licensee maintain a copy of the Certificate of Compliance and documents referenced in the certificate for each cask used for storage of spent fuel. The cask is an item that is important to safety and compliance with conditions in the cask certificate is necessary under proposed 972.212(b)(2).
It is the responsibility of users to ensure that casks are used as prescribed, thus, copies of these documents are necessary.
Section 72.212(b)(8) specifies that the historical cask record provided by cask vendors be maintained by the licensee.
This record will be initiated under proposed 672.234(d). This information will be used by hRC to confirm ccmpliance with the Certificate of Compliance.
The last user of the cask would retain the record for 3 years after the cask is decommissioned, which would allow time for final inspection by NRC.
Section 72.212(b)(9) specifies that a general licensee conduct activities related to storage of spent fuel under the general license in accordance with 3
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f written procedures. Activities related to spent fuel storage will be inspected by NRC to ensure compliance with the Commission's regulations. Written j
procedures, which will be approved under a formal safety system, will be part of these inspections.
These procedures will be retained and used by the licensee, although they may be revised and updated periodically, until spent fuel is no longer stored under the general license.
Section 72.216(a) specifies that cask users must report defects with safety significance discovered in any spent fuel storage cask and any instance in which there is significant reduction in the effectiveness of a cask's confinement system during use.
Reports would be submitted under proposed
$50.72(b)(2)(vii).
This information is necessary to inform NRC of potential hazards to public health and safety that could result from defects in cask confinement systems or accidents involving casks.
Section 72.216(b) specifies that a written report, concerning items reported under 672.216(a), would be required to be submitted within 30 days.
The written report is needed so that the staff can determine whether or not there are any generic safety implications.
The NRC allows 30 days for the written report so that the licensee can review and analyze the event and present NRC with a clear and complete history.
Section 72.218(c) specifies that a copy of the notice required by 10 CFR 550.54(bb) and a copy of the application for license termination under $50.82 be submitted to the Administrator of the appropriate NRC regional office.
Under SEO.54(bb) a power reactor licensee must notify the Commission, no later than 5 years before the reactor license is due to expire, concerning how the irradiated fuel at the reactor site will be managed. Under $50.82 any reactor licensee may submit an application for termination of the reactor operating license. The staff will review the information in these submittals to ensure that spent fuel stored under the general license is included in these plans and will be managed in a safe manner.
Reporting requirements under SS50.54 and 50.82 are approved under OMB number 3150-0011.
Section 72.230(a)and (b) specify that an application be submitted to obtain approval of spent fuel storage cask designs.
It also specifies that a safety 4
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analysis report (SAR) must be included with the application.
The information in the SAR will be reviewed by the NRC staff to determine whether or not there j
is reasonable assurance that use of these casks will provide adequate protection for public health and safety.
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Section 72.232(c) specifies that the cask vendor notify the Commission at least 45 days before starting to fabricate casks under a Certificate of Compliance.
This notice would be used to arrange for inspection of initial cask fabrications. A quality assurance program (QA) will be established by the cask vendor to ensure that casks are designed, fabricated, tested, repaired, and used in accordance with applicable quality assurance measures. Cask fabrication and QA implementation will be subject to inspection by the NRC staff.
Section 72.234(d)(1) specifies that a cask vendor establish a record for each essk. The record must include the NRC Certificate of Compliance number; the cask model number; the cask identification number; the date that cask fabrication was started; the date that cask fabrication was completed; certification that the cask was designed, fabricated, and tested under a quality assurance program accepted by the NRC; certification that the cask was inspected for cracks, pinholes, uncontrolled voids, or other defects that could significantly reduce its confinement effectiveness; and the name and address of the cask user. The vendor would have to provide the original record to the cask user and maintain a composite record for all casks shipped to users.
Section 72.234(d)(3) specifies that (1) the original of each cask record established under 672.234(d)(1)besuppliedtothecaskuser,(2)acomposite record uf all casks be kept by the vendor for the life of the cask, and (3) the composite record be sent to the Commission if the vendor permanently ceases production under a Certificate of Compliance. The original record should be supplied to the cask user so that the historical cask record can be properly maintained by the user. A composite record should be made available to the NRC for inspection to ensure that a complete historical record of all casks is available. The composite record should be sent to the Commission if the vendor stops producing a particular cask model or goes out of business to ensure continuity of cask records for safety purposes.
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Section 72.234(f) specifies that cask vendors establish procedures and tests appropriate for use of the cask.
A copy of these procedures and tests would be provided to cask users, which will assist them in development of procedures for use of the cask.
The cask vendor would develop a set of procedures and tests and retain the set for as long as the cask design is active for submittal of a copy to each cask user.
The NRC will not receive a copy of these procedures and tests.
Section 72.236(k) specifies that casks be conspicuously and durably marked.
This is necessary to identify casks as containers for spent fuel and enable cask users to establish material control and inventory records.
The tag would be expected to last for the life of the cask.
Section 72.240(b) specifies that an applicant for cask design reapproval submit an application at least 3 years before the cask certificate is due to expire.
The application must be accompanied by a SAR showing that the cask will continue to provide adequate confinement of radioactive material.
The information in the SAR would be reviewed by tha NRC staff to determine whether or not there is reasonable assurance that the type of cask will continue to l
provide adequate protection for public health and safety. The 3 year interval will ensure that a new Certificate of Compliance can be issued for the cask before the existing certificate expires.
A conforming amendment will be added to $50.72(b)(2)(vii) specifying that a general licensee report, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, instances in which a significant defect in a cask's systems or components important to safety is discovered, or instances in which there is a significant reduction in a spent fuel storage cask's confinement system.
Use of Improved Information Management Technology Submittals that would be required by this proposed rule are not easily adopted to information systems network processing.
Safety analysis reports (SAR) for spent fuel storage cask design approvals are best handled on an 6
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individual case basis.
The format and content of the SAR, which has been set forth in Regulatory Guide 3.61, is sim'ar for each submittal but individual designs are not readily adaptable to this type of processing.
Efforts to Avoid Duplication Information required in notices, applications, reports, or records, concerning the storage of spent fuel under the general license or approval of spent fuel storage cask designs, is only available from applicants and licensees. This information collection does not duplicate other Federal information collection requirements.
Use of Similar Information Section 72.18, Elimination of repetition, of 10 CFR Part 72, " Licensing Requirements for the Storage of Spent Fuel in an Independent Storage Installation" specifically allows applicants and licensees to avoid repetition in filing submittals by incorporating information by reference to documents previously filed and accepted by the Commission. The proposed rule, in 1
applicable parts, allows reference to and modification of existing reactor operation plans and programs to meet requirements of Part 72.
i Effort to Reduce Small Business Burden The Commission has determined that affected entities are not small businesses, as those terms are used in the Regulatory Flexibility Act and defined in the Small Business Administration's regulations at 13 CFR Part 121.
l Consequences of Less Frequent Collection 1
Notification that a reactor licensee is storing spent fuel under the general license is required only once during the reactor operating lifetime.
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Since the Commission will rely on its inspection and enforcement autho ensure compliance with its regulations, notification by the licensee is necessary.
Submittal of information on particular spent fuel storage cask use which is necessary for maintaining Commission records, would most likely be required once during the spent fuel storage period.
Consultation Outside NRC Comments from the public and industry will be sought on the proposed ru Confidentiality of Information None, except proprietary or safeguards information.
Sensitive Questions None.
Estimated Annualized Burden to the Federal Government N,!!SSS Contractor
$200,000 Staff hours 1,000 NR,R Contractor
$10,000 o
Staff hours 120 f'
The above estimate is for NRC resource requirements, which at $60 l
l hour totals $277,200.
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1 Estimate of Compliance Burden
. Reporting Requirements i
Burden Section
' Number of Annual Staff Hours Total Annual (ProposedRule)
Responses
- perSubmittal' Burden (hrs.)
72.212(b)(1)(1) 4 1
4 72.212(b)(1)(ii) 4 10 40 72.216(a) 1 4
4 72.216(b) 1 40 40 (Responses to 972.16 are contingency provisions; no response is anticipated.
However, burden is estimated for one submittal per year).
72.218(c) 4 4
16 (Reportrequiredunderil50.54and50.82, which are approved under.0MB number 3150-0011, once per reactor lifetime. Above estimate is for a copy of these reports to be sent to l
theappropHateTegionalAdministrator).
i 72.230(a)and(b) 1 1,200 1,200 l
l (Primarily for safety analysis report required L
for storage cask design approval, including approval of designs certified for transportation.
Estimated 10 different cask designs. Averaged over a 10 year period.).
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(
o Burden Section Number of Annual
~ Staff Hours Total Annual (ProposedRule)
Responses'*
per Submittal Burden (hrs.)
72.232(c) 1 2
2 72.234(d)(1) and (3) 60 8
480 (Cask historical record.
Record originated by cask vendor and sent to cask user.
Cask user to retain and update as required for life of cask. Estimate that a total of about 600 casks will be used over a 10 year period.
Burden averaged over 10 year period. A composite record of all casks would be sent to the Comission, if a vendor stopped production of-a cask model).
72.234(f) 1
'190 190 (Written procedures for cask use; averaged over 10 year period).
72.236(k) 60 1
60 (Installcaskidentificationtags).
72.240(b) i 600 300 (Reapprovalofcaskdesign;- 10 vendors; reapproval required every 20 years).
50.72(b)(2)(vil)
(Burdenunder72.216(a)).
TotalAnnualReportingBurden(hours)=2,336
- NOTE:
Includes submittals by spent fuel storage cask vendors as well as reactor licensees.
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t Estimate of Compliance Burden Recordkeeping Requirements Number of Number of Total Record Section Records hours per Annual Retention
-(Proposed Rule)
Annually Record Hours Period 72.212(b)(2) and (3) 4 6
24 3 years (Thesetwoevaluationsaretoshow after compliance with the Certificate of initial Compliance. Totalburdenshown).
storage.
72.212(b)(6) 4 8
32 Until general license is terminated.
72.212(b)(7) 1 8
8 Until (Certificate of Compliance and related general records maintained. Once for each cask license modelused).
is terminated.
72.212(b)(8) 60 4
240 3 years (Estimated total number of casks is 600; after averaged over a 10 year period).
cask is deconjm-.
Missioned.
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a.
r 72.212(b)(9) 4 32 128 Life of (Writtenprocedures;burdenestimate.
general includesupdating).
license 72.234(f) 4 24 96 Life (Procedures written once per cask design and of cask-one copy sent to each user).
design.
72.234(d)(3) 60 2
120 Life of (Estimatedtotalnumberofcasksis600; cask.
averaged ' over 10 year' period).
Number of Records =
137 Total Recordkeeping Burden = 648 hours0.0075 days <br />0.18 hours <br />0.00107 weeks <br />2.46564e-4 months <br /> Total Burden = 2,984 hours0.0114 days <br />0.273 hours <br />0.00163 weeks <br />3.74412e-4 months <br />.
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