ML25113A153

IP 60851 Design Control of ISFSI Components

ML25113A153
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Issue date:	05/27/2025
From:	Tomeka Terry NRC/NMSS/DFM/IOB
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CN 25-013
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Issue Date: 05/27/25 1

60851 NRC INSPECTION MANUAL NMSS/DFM INSPECTION PROCEDURE 60851 DESIGN CONTROL OF ISFSI COMPONENTS Effective Date: May 27, 2025 PROGRAM APPLICABILITY: IMC 2690 60851-01 INSPECTION OBJECTIVES 01.01 To determine whether the design control program described in a licensees or certificate of compliance (CoC) holders quality assurance program (QAP) is effectively implemented.

01.02 To determine whether design changes implemented by the licensee or CoC holder have been properly evaluated for their impact on the functionality of dry cask storage system (DCSS) components used in an independent spent fuel storage installation (ISFSI).

01.03 To determine whether these design changes have been evaluated to ensure that the change does not:

a. require a change to the conditions in the license or the CoC;

b. require prior U.S. Nuclear Regulatory Commission (NRC) approval;

c. create a significant increase in occupational exposure; or

d. have a significant unreviewed environmental impact.

60851-02 INSPECTION REQUIREMENTS 02.01 Determine whether the licensees or CoC holders QAP implementing procedures are in place and used effectively.

02.02 Determine whether

a. A method exists to ensure that design changes initiated by the vendor or CoC holder are communicated to the licensee;

b. The licensee was notified of the design changes in a timely manner to minimize production or operations impacts; and

c. The licensee has reviewed and/or approved these design changes that were approved by the vendor or CoC holder.

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60851 02.03 Determine whether any nonconforming conditions, which were resolved by design changes, have been reviewed and approved by the licensee or CoC holder (if authorized by the CoC).

02.04 Determine whether all nonconforming conditions identified before completion of fabrication were appropriately resolved before the DCSS components affected were released to the licensee.

02.05 Determine whether the licensee, vendor, and fabricator personnel have established an effective method for tracking, evaluating, and dispositioning changes or modifications to the DCSS component design.

02.06 For selected design changes, determine whether the applicable documentation is complete and accurate, including relevant 10 CFR 50.59 or 72.48 evaluations.

60851-03 INSPECTION GUIDANCE 03.01 Definitions

a. Participants. The terms licensee, vendor, CoC holder, fabricator, general licensee, and site-specific licensee are terms the inspectors will commonly encounter while reviewing ISFSI activities. Refer to Inspection Manual Chapter (IMC) 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations, Section 03, for definitions of these terms.

b. Safety Classification. ISFSI systems, structures, and components (SSCs) are classified as either important to safety or not important to safety by the ISFSI designer.

If important to safety, the SSC will typically either:

1. maintain the functions or conditions (i.e., confinement, criticality, shielding, and heat removal) necessary to store spent fuel safely;

2. prevent significant damage to the spent fuel container (DCSS) during handling and storage; or

3. provide reasonable assurance that spent fuel can be received, handled, packaged, stored, and retrieved without undue risk to public health and safety.

If an SSC does not perform any of the preceding functions, it may be classified as not important to safety.

03.02 General Guidance

a. Additional Assistance. The inspectors may obtain additional assistance for both technical and design questions from the cognizant Spent Fuel Storage and Transportation (SFST) project manager (PM). For questions involving ISFSI operations and how the ISFSI design can affect overall site operations, contact the SFST PM who may request the Office of Nuclear Reactor Regulation (NRR) assistance if needed. Note that additional guidance for review of ISFSI storage pad designs is located in Appendix A of Inspection Procedure (IP) 60856, Review of 10 CFR 72.212(b) Evaluations.

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60851

b. ISFSI SSCs Safety Classification. Before performing an inspection of ISFSI SSCs, the inspectors should review the licensees design basis documents to determine whether the licensee has applied an appropriate safety classification to a particular SSC. Note that site-specific variations in ISFSI designs may affect the safety classification of some SSCs.

c. ISFSI SSCs Not Important to Safety. For this class of SSCs, the licensees use of generally accepted commercial-grade standards, practices, and materials in design, fabrication, and construction activities is acceptable. However, these SSCs must still conform to the design requirements described in the safety analysis report (SAR) and supporting engineering documents.

d. Design Changes. Each DCSS design has been approved by the NRC through the licensing process, for a site-specific license, or the 10 CFR Part 72, Subpart L, process for a general license. All changes to the design described in the SAR must be approved by the licensee or CoC holder. Approval authority for changes can be difficult for the inspectors to determine. In such cases, the inspectors can find additional guidance in IMC 2690, Section 05.09.

e. Component Functionality. Functionality is the ability of a component to meet its design requirements. Some components may have multiple design requirements and several functions. These requirements and functions are defined in the SAR, safety evaluation report (SER), and, as applicable, the CoC or the site-specific license and technical specifications (TS) for the DCSS. For example, the cask support basket that separates the individual fuel bundles serves several functions: structural integrity, criticality control, heat transfer, and radiation shielding. Assistance in identifying the function(s) of a given component may be obtained from SFST.

f.

Document Review. Before any onsite inspection activity, for each DCSS in use, review (as applicable) the:

1. SAR and corresponding NRC SER;

2. CoC;

3. site-specific license and TS; and

4. 10 CFR 72.48 evaluations performed since the last update to the DCSS SAR.

SARs and SERs describing DCSS components have been written for each type of approved DCSS. Information on operational commitments for a particular DCSS may also be found in the CoC or the site-specific license and TS. As DCSS designs vary, be careful to review the appropriate documentation. The inspectors can obtain copies of these documents from the appropriate regional division or cognizant SFST PM.

If the inspector has questions or concerns that require additional technical or regulatory support, additional guidance can be found in IMC 2690, for obtaining additional support from headquarters.

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60851 03.03 Specific Guidance (Note: The following inspection activities should be performed at the ISFSI location; however, document reviews may be performed elsewhere as conditions require.)

a. Inspection Requirement 02.01. The licensees or CoC holders QAP should have been previously reviewed and approved by the NRC. Verify that design control and related activities (e.g., document control, special processes, or resolution of nonconforming conditions) are conducted under an approved QAP. Review completed audits and fabrication records, interview selected personnel, and/or review procedures. Review any related licensee quality assurance (QA) audits or SFST inspections regarding DCSS design changes and determine whether corrective actions for the audit or inspection findings have been effectively implemented.

b. Inspection Requirement 02.02. If the licensee has imposed requirements on the vendor or CoC holder to notify it of any design changes initiated by the vendor or CoC holder, determine whether the vendor or CoC holder is complying with these requirements.

Review QA audits of the vendors or CoC holders activities in this area.

c. Inspection Requirement 02.03. No specific guidance.

d. Inspection Requirement 02.04. Determine whether there is a process in place under the QAP to keep track of design changes. Assess the adequacy of design interface activities, communications, evaluations and safety screenings, and documentation of changes.

e. Inspection Requirement 02.05. Determine, through review of records, inspection of equipment and components, and/or interviews with selected personnel, whether the licensee or CoC holder has performed design changes and modifications. Evaluate the quality and timeliness of such documentation. Assess the thoroughness of documentation and the independence of reviews, particularly for those design changes that resolve nonconformances and field change requests. Check that evaluations contain a discussion of the effect on component functionality. The inspectors can find information on component functionality in the SAR, SER, CoC, or, as applicable, the site-specific license and TS.

Determine the adequacy of the timing of design change reviews. Ideally the licensee or CoC holder should complete the reviews before the component is fabricated. However, if the licensee elects to proceed with fabrication at risk, verify that the licensee does not use the DCSS until all design changes have been evaluated and appropriately dispositioned.

f.

Inspection Requirement 02.06. Design-basis accidents, such as a DCSS tipover or a drop from a maximum specified height, are addressed in the SAR; however, the inspectors may obtain assistance from the cognizant SFST PM in determining whether a change requires NRC approval for a particular DCSS design.

60851-04 INSPECTION RESOURCES To prepare for these inspections each inspector should spend approximately 32 +/- 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> on in-office review. Inspection activities will require approximately 40 +/- 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, each, by three

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60851 inspectors. Inspections may take place at the licensees or CoC holders facilities.

Documentation is estimated to require 32 +/- 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> for each inspector. SFST vendor inspection staff is expected to have the lead in inspecting CoC holders, and any associated vendors or fabricators, with assistance from regional inspection staff. Regional inspection staff is expected to have the lead in inspecting licensees, with assistance from SFST.

60851-05 REFERENCES 10 CFR 50.59, Changes, tests, and experiments 10 CFR 72.48, Changes, tests, and experiments NRC Information Notice 95-29, Oversight of Design and Fabrication Activities for Metal Components Used in Spent Fuel Dry Storage Systems, June 7, 1995 IMC 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations, May 3, 2007 IP 60856, Review of 10 CFR 72.212(b) Evaluations, November 1999 NUREG/CR-6407, Classification of Transportation Packaging and Dry Spent Fuel Storage System Components According to Importance to Safety, February 1996 NUREG-1536, Standard Review Plan for Dry Cask Storage Systems, January 1997 NUREG-1567, Standard Review Plan for Spent Fuel Dry Storage Facilities, March 2000 END

Issue Date: 05/27/25 Att1-1 60851 : Revision History for IP 60851 Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Number (Pre-Decisional Non-Public Information)

N/A ML073090589 01/16/08 CN 08-003 This document has been revised to change SFPO to SFST and some minor editorial changes. No other changes were proposed by 10/17/2007.

N/A N/A ML25113A153 05/27/25 CN 25-013 Revised to incorporate resource estimate ranges and include additional assistance guidance.

N/A N/A