Regulatory Guide 3.53

Applicability of Existing Regulatory Guides to the Design and Operation of an Independent Spent Fuel Storage Installation

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U.S. NUCL; REGULATORY

COMMISSION`'

July 1982!) REGULATORY

GUIDE OFFICE OF NUCLEAR REGULATORY

RESEARCH REGULATORY

GUIDE 3.63 (Task CE 0374)APPLICABILITY

OF EXISTING REGULATORY

GUIDES TO THE DESIGN AND OPERATION OF AN INDEPENDENT

SPENT FUEL STORAGE INSTALLATION

A. INTRODUCTION

The storage of spent fuel in an independent spent fuel storage installation (ISFSI) pending its ultimate disposal Is a new step in the nuclear fuel cycle that is licensed pursuant to 10 CFR Part 72, "Licensing Requirements for the Storage of Spent Fuel in an Independent Spent Fuel Storage Installation." The conventional method for such storage is in water basins embedded in the ground with their water surface approximately at grade level. Other methods using dry storage are also being considered.

These methods may include air-cooled canyons or vaults, under-ground caissons or dry wells, or surface-storage casks or silos. Applicants may determine that other regulatory guides contain useful information for particular situations.

Potential use of other guides may be discussed with the NRC staff.This regulatory guide identifies existing regulatory guides that may be applicable in whole or in part to the design and operation of an ISFSI. Since the different modes of storage vary widely in design, the guides cited will obviously not all be applicable to all design technologies.

Also, as a general rule, the technologies and operating conditions involved in the receipt and storage of aged spent fuel (i.e., spent fuel that has undergone at least 1 year of decay since removal from a reactor core) are not only much less complex and dynamic than those of production and utilization facilities (i.e., reactor and reprocessing facilities), but they are also less complex and dynamic than the tech-nologies and conditions involved in the receipt and storage of spent fuel in reactor basins designed to receive spent fuel directly from a reactor core after a decay of a few days or less. The referenced guides are useful not only because the methods of design and operation cited have been examined by the NRC staff and found to be appropriate as a means of meeting the requirements of NRC regulations, but also because these guides are familiar to licensees and applicants.

Thus, while the guides inay exceed the requirements of Part 72 in some cases (in particular, those guides written with reference to power reactors), they can be of benefit to applicants and licensees who already have experience with the solutions endorsed in them and who may wish to apply familiar solutions rather than develop alternative solutions less certain of being acceptable to the NRC staff.

B. DISCUSSION

Existing regulatory guides were examined for their potential applicability to the design and operation of an ISFSI that may use either a wet or dry mode of storage.The specific revision of each guide that may be appli-cable, in whole or In part, is listed In the tables of this guide. This guide will be updated as referenced guides are revised.The user and staff must exercise discretion in using all of the detailed information ssociated with each regulatory position cited, e.g., not all appendices and examples con-tained in the cited guides are applicable to an ISFSI. If the guidance in a guide written specifically for an ISFSI differs from that in a guide developed for another facility, (e.g., a Division I guide), the guidance in the guide specific to an ISFSI should be followed.C. REGULATORY

POSITION Tables 1, 2, and 3 list existing regulatory guides that may be applicable to an ISFSI. Table I identifies guides applicable to ISFSI design and Table 2 identifies guides applicable to ISFSI operation.

Table 3 identifies guides that are specific to an ISFSI. The guides are listed in the tables by number, title, and revision under general subjects that are arranged alphabetically.

Relevant regulatory positions in each guide are identified and briefly described.

In Tables 1 and 2, the portions of the NRC regulations addressed by the regulatory positions are also identified and other pertinent information is provide

d. USNRC REGULATORY

GUIDES Regulatory Guides are issued to describe and make available to the public methods acceptable to the NRC taff of Implementing specific parts f the Commission's regulations, to delineate tech-niques used by the staff In evaluating specific problems or postu-lated ccloents or to provide guidance to applicants Regulatory

~ Guides are nof substitutes for regulations, and compliance with-; them Is not required.

Methods and solutions different from those set out In the guides will be acceptable I they Povide basis for the findings requisite to the issuance or continuance of a permit or license by the Commission.

This guide was Issued after consideration of comments received from the Public. Comments and suggestions for Improvements in these guides are encouraged at all times, and guides will be revised, as appropriate, to accommodate comments and to reflect new Informa-tion or experience.

8804290116

80411 N- ISS SUBJ .--- ~102 DCD.Comments should be ent to the Secretary of the Commission.

U.S. Nuclear Regulatory Commission Washington D.C. 20555.Attentiong Dockting and Service ranch.The guides are ssued In the following ten broad divisions:

1. Power Reactors 6. Products 2. Research and Test Reactors

7. Transportation

3. Fuels and MaterIals Fcilities

8. Occupational Health 4. Environmental and Siting 9. Antitrust and Financial Review 5. Materials and Plant Protection

10. General Copies of Issued guides may be purchased at the current Government Printing Office price. A subscription service for future guides In spe-cific divisions Is available through the Government Printing Office.information on the subscription service and current OPO prices may be obtained by writing the U.S. Nuclear Regulatory Commission.

Washington, D.C. 20555. Attention:

Publications Sales Manager.

V , .Table I DESIGN Subject Regulatory Guide Regulatory Position Portions of 10 CFR Addressed Accident Analysis 1.25, Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handl-ing and Storage Facility for Boiling and Pressurized Water Reactors (Safety Guide 25).2 3.b-Atmospheric diffusion assumptions

-External whole-body approximations assumptions

72.65(a), 72.74(d)72.65(a), 72.74(d)1.91, Revision , Evaluations of Explosions Postulated To Occur on Transportation Routes Near Nuclear Power Plants 2 2 3-Explosive transport-Explosive transport-Explosive transport 7x.63, 72.7f(c)72.63, 72.72(c)72.63, 72.72(c)(1.145, Atmosphen'S

Dispersion Models for Potential Accidenytonsequence Assess-ments at Nucleaf Power Plants 1.2 1.3 1.4 2 3 4 Control Room-Chemical Release 1.78, Assumptions for Evaluating the Habitability of a Nuclear Power Plant Control Room During a Postulated Hazardous Chemical Release I 2 3 4 5.a 6 11 12-Distances for X/Q-X/Q at the controlled area-X/Q at EPZ-Maximum sector X/Q values-5% overall site XJ1 value-Selection of X/Q-Stored chemicals-Transported chemicals-Onsite chemicals-Toxicity limits-Accident concentration

-Dilution factor* Removal systems-Natural phenomena and chemical release-Emergency procedures In applying this guide to an ISFSI, substitute the terms"controlled area" as defined in § 72.3(h) and "ISFSI-emergency planning zone (ISFSI-EPZ)" as defined in§ 72.3(n) respectively for the terms "exclusion area" and "low population zone (LPZ)" wherever they appear.72.65(a), 72.74(d)72.65(a), 72.74(d)72.65(a), 72.74(d)72.65(a), 72.74(d)72.65(a), 72.74(d)72.65(a), 72.74(d)72.61(b), 72.72(j)72.61 (b), 72.72(j)72.6 1(b), 72.72(j)-72.72(j)72.61(b), 72.72(j)72.61(b), 72.72(j)72.72(j)72.61(b), 72.720)As 72.1 (a)(1 l)

Table 1 (Continued)

DESIGN Subject Criticality Safety Regulatory Guide 3.41, RevisioA 1, Validation of Calculational Methods for Nuclear Criticality Safety Regulatory Position Portions of 10 CFR Addressed 72.73(a)All-Endorsement of ANSI N16.9-1975 Floods 1.59, Revision 2, Design Basis Floods for Nuclear Power Plants I 2.a 2.c 3 4-Flood conditions

-Hardened protection alternative-warning time-Hardened protection alternative-less severe flood conditions

-Unanticipated changes-Data utilization

72.33(cX4), 72.61(c), 72.62, 72.72(bX2), 72.72(b)(4)

72.33(cX4).

72.61(c), 72.62, 72.72(bX2), 72.72(bX4)

72.33(cX4), 72.61(c), 72.62, 72.72(bX2), 72.72(bX4)

72.33(cX4), 72.61(c), 72.62, 72.72(bX2), 72.72(b)(4)

72.33(c)(4), 72.61(c), 72.62, 72.72(bX2), 72.72(bX4)

(w w Flood Protection

1.102, Revision 1, Flood Protection for Nuclear Power Plants 2 2 3-Types of protection

-Shutdown specifications

-Vulnerability of safety-related equipment 72.72(b)X2)

72.72(b)(2)

72.72(b)X2)

Physical Hydraulic Models 1.125, Revision 1, Physical Models for Design and Operation of Hydraulic Struc-tures and Systems for Nuclear Power Plants 2 2 3-Model preconstruction submittals

-Early staff discussions

-Documentation

-Comparison of data and model-Design changes 72.15(aX3), 72.33(cX4), 72.61(c), 72.62 72.1 5(aX3), 72.33(cX4), 72.61(c), 72.62 72.15(a)(3), 72.33(cX4), 72.61(c), 72.62 72.15(aX3), 72.33(cX4), 72.61(c), 72.62, 72.72(bX3)

72.1 S(aX3), 72.33(cX4), 72.61(c), 72.62, 72.72(bX3)

72.15(aX3), 72.33(cX4), 72.61(c), 72.62, 72.72(bX3)

4 5 6 -Report contents r .I Table I (Continued)

DESIGN Subject Regulatory Guide Regulatory Position Portons of 10 CFR Addressed Quality Assutance-Design and Constructon

1.28, Revision 2, Quality Assurance Program Requirements (Design and Construction)

General-Endorsement of ANSI N45.2-1977

4 4 72.15(a)(14), 72.72(a), 72.80 72.15(aX14), 7.72(a), 72.80 Quality Auurance-Terms

1.7, Quality Assurance Terms and Detinitions Second Paragraph

-Procurement documents 72.80 (Radiological Protection- ALARA 8.8, Revision 3, Information Relevant to i!nsuring that Occupational Radiation Expo-sures at Nuclear Power Stations Wm Be As Low As h Reasonably Achievable W Lab 1Ld 2.a 2.b( 1)2.b(2)2.b(4)2.b(5)2.b(6)2.b(7)2.b(8)2.b(9)2.b(I0)2.c 2.d(l)2.d(2)* Review of designs and equipment-Access control of radiation areas-Shielding for senice personnel* Temporary shieldft and distance-Streaming and scattering

-Streaming-Reduction of exposure from pipes-Expeditious design features-Laydown space-Removal of equipment-Drains* Process instrumentation and controls-Control of airborne con-taminants (air flow)-Ventilation systems In applying this guide to an ISFSI, substitute the term"ISFSI" for the tenns "LWR" and "nuclear power station" wherever they appear. Dis-regard references to the nuclear steam supply vendor.20.1(c), 72.15(a)(5), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.IS(a)(S), 72.74(a)20.1(c), 72.15(a)(5), 72.74(a)20. 1(c), 72. I5(aX5), 72.74(a)20.1(c), 72.1S(a)(5), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.15(a)(5), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.15(aX5), 72.74(a)20.1(c), 72.1S(a)(S), 72.74(a)20.1(c), 72.15(a)(S), 72.74(a), 72.74(c), 72.74(d)20.1(c), 72.1 5(aXS), 72.1 5(aXI 2), 72.74(a)72.74(d)I I

Table (Continued)

DESIGN Subject Regulatory Guide Regulatory Position Portions of 10 dFR Addresed 2.d(3)2.f 2.g 2.h(1)2.h(2)2.h(3)2h(4)2.h(5)2Jh(6)2.h(7)2i(l)w%A 2i(2)2Ji(3)2i(4)2i(5)2i(7)2.i(8)2i(9)2(10)2.i(11)2i(12)2.i(3)21(14)2i.(15)3.a 3.b(1)3.b(3)3.c 4.-Auxiliary ventilation systems-Isolation and decontamination

-Radiation monitoring systems* Reduction of accumulation

-Need for maintenance

-Pipe bends* Pipe surfaces-Pipe tees* Slurry piping-Sparging* Radiation-damage-resistant materials-Stainless steel piping .* Pipe routing* Filters-Servicing valves-Valve selection-Pumps-Sedimentation

-Spare pipe connections

-Station design,.-Component removal-Working environment

-Lamp replacement

-Emergency lighting-Radiation protection program preparation and planning-Health physics technicians

-Communications

• Postoperations

-Radiation protection facil-ities Instrumentation and equipment 20.1(c), 72$ 5(ax)()72.1 5(a)( 2), 72.74(a)72.74(c), 72.74(d).20.1(c), 72.1S(a)(S), 72.74(a), 72.74(b)20.1(c), 72.16(aXS), 72.74(b), 72.74(c)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.1S(a)(S), 72.74(a)20.1(c), 72.15(aX5), 72.74(a)20.1(c), 72.lS(aXS), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.1S(aXS), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.15(a)(5), 72.74(a)20.1(c), 72.15(aX5), 72.74(a)20.1(c), 72.15(a)(5), 72.74(a)20.1(c), 72.1S(aX5), 72.74(a)20.1(c), 72.1S(aXS), 72.74(a)20.1(c), 72.1S(aX5), 72.74(a)20.1(c), 72.15(aX5), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.IS(aXS), 72.74(a)'20.1(c), 72.lS(aXS), 72.74(a) -20.1(c), 72.15(aXS), 72.74(a) (20.1(c), 72.15(aXS), 72.74(a)20.1(c), 72.1S(aXS), 72.74(a)20.1(c), 72.33(c)(5)

20.1(c), 72.33(c)(S)

20.1(c), 72.33(cX5)

20.1(c), 72.33(cXS)

20.1(c), 72.33(c)(S), 72.74 I.

Table I (Continued)

DESIGN Subject Regulator Guide Regulatory Position Seismic 1.29, Revision 3, Seismic Design Classification Portions of 10 CFR Addressed In applying this guide to an ISFSI, substitute the term"ISFSI Design Earthquake (ISFSI-DE)" (or the "Safe Shutdown Earthquake (SSE)" wherever it appears.72.72(b)(2)

I .d 1.6 I.i I.j L.k 11 1.n L.p 1.q 2 3-All sections listed for posi-tion I describe applicable activities to be included 72.72(bl(2)

-72.72(b)X2)

72.72(b)X2)

72.72(b)X2), 72.72(i)72.72(b)X2)

72.720)72.75(a)72.72(b)X2)

72.72(b)X2)

W'A W-Non-safety-related components

-Defined boundaries

72.72(bX2)

1.6o, Revision 1, Design Response Spectra for Seismic Design of Nuclear Power Plants In applying this guide to an ISFSI, substitute the term"ISFSI Design Earthquake (ISFSI-DE)" for the term"Safe Shutdown Earthquake (SSE)" wherever it appears.The term "Operating Basis Earthquake (OBE)" is not applicable to an SFSI.72.66(a)(2), 72.66(a)(6), 72.66(b)72.66(aX2), 72.66(a)(6), 72.66(b)In applying this guide to an ISFSI, substitute the term"ISFSI Design Earthquake (ISFSI-DE)" for the term 2 2-Horizontal component* Vertical component 1.61, Damping Values for Seismic Design of Nuclear Power Plants To C .7 Table I (Continued)

DESIGN Subfeet Regulatory Guide Regulatory Position Portiots of 10 CF1 Addressed 2 2 3-Modal damping values* High damping values-Combined stress"Safe Shutdown Earthquake (SSE)' wherever t appears.The term "Operating Basis Earthquake (OBD)" is not applicable to an ISFSI.72.66(aX2), 72.66(aX6), 72.66(b)72.66(aX2), 72.66(a)(6), 72.66(b)72.66(aX2), 72.66(aX6), 72.66(b)w Af-J1*1.92, Revision 1. Combining Modal Responses and Spatial Components In Seismic Response Analysis 1.122, Revision 1, Development of Floor Design Response Spectra for Seismic Design of Floor-Supported Equipment or Components I 2-Combination of effects-Combining of modal responses l-Directional analysis 72.66(aX2), 72.66(sX6), 72.66(b)72.66(aX2), 72.66(a)(6), 72.66(b)72.66(aX2), 72.66(a)(6), 72.66(b)72.66(aX2), 72.66(aX6), 72.66(b)72.66(aX2), 72.66(a)(6), 72.66(b)2-Uncertainties

3-Response spectrum Site Investigations- Foundstions

1.132, Revision 1, Site Investigations for Foundations of Nuclear Power Plants This guide applies to all types of ISFSI designs (§ 72.66).If massive structures or foundations are required by the specific design (i.e., water basin, vault, canyon, support hot cell), this guide would provide applicable guidance for the site investigation.

I 2 2 3-General site investigation

-Boring logs-Ground-water investigations

72.61(a), 72.66(a)(4)

72.61(a), 72.66(aX4)

72.61(a), 72.66(a)(4)

r Table 1 (Continued)

DZESIGN Suet Regulator Guide Regulatory Position 4 S 6 7-Procedures

-Spacing and depth-Sampling-Retention of records and samples Site Investlgations- soils 1.138, Laboratory Inwestigations of Soils for Engineering Analysis and Design of Nuclear Power Plants I 2-Requirements for testing program-Handling and storage of samples-Selection and preparation of specimens-Criteria for testing procedures

-Documentation

3 4 S w th Y Portlon of 10 CFR Addressed 72.61(a), 72.66(aX4)

72.61(a), 72.66(a)(4)

72.61(a), 72.66(a)(4)

72.61(a), 72.66(aX4)

72.61(a), 72.66(aX4)

72.61(a), 72.66(a(4)

72.61(a), 72.66(aX4)

72.61(a), 72.66(aX4)

72.61(a), 72.66(aX4)

72.1 S(aX3), 72.33(c)(4), 72.74(a)72.80 72.80 72.1 5(aX3), 72.3 3(cX4), 72.74(a)72.1 5(a)(3), 72.33(c)(4), 72.74(a)72.1 S(aX3), 7 2.33(c)(4), 72.74(a)72.1 S(aX3), 72.3 3(cX4), 72.74(a)72.1 5(aX3), 72.33(cX4), 72.74(a)72.1 S(aX3), 7 2.33(cX4), 72.74(a)(Structures.-Concrete Shields 1.69, Concrete Radiation Shields for Nuclear Power Plants General 1 2 3 4 5 6 7 8-Endorsement of ANSI-N101.6-1972 Testing-Diesel Generator 1.108, Revision 1, Periodic Testingof Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants 3 2 3-General design* Testing-Records and reports 72.72(f, 72.72(k)72.72(k)Reports are not submitted pursuant to Regulatory Guide 1.16. 72.72(k)

40 to Table 1 ContInued)

DESIGN Subject Regulatory Guide Regulator Position Testing-Protective

1.22, Periodic Testing of Protection System Actuation Functions (Safety Guide 22)Porton of 10 CFR Addresed In applying this guide to an ISFSI, substitute the expres-sion "lSFSI receiving and stor-age operations" for the expres-sion "reactor operation" wher-ever it appears.72.72(f)72.72(f)72.72(f)72.61(c), 72.62 72.61(c), 72.62 2 2 4-Testing requirements

-Testing methods-Untested equipment-Design basis tornado b Len conseis tive design basis tornado (Tornado 1.76, Design Basis Tornado for Nuclear Power Plants 1 2 W b t41 Waste Management Systems 1.143, Revision 1, Design Guidance for Radioactive Waste Management Systems,.Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants This guide does not refer to the spent fuel storage systems such as the basin, cask, vault, etc., but only applies to the systems that ae used to collect, store, control, or process waste that is generated during the ISFSI operation.

Liquid Waste System 1.1.1

• Design and test requrements

1.1.3 -Seismic criteria 1.1.4

• Seismic criteria 1.2 -Tank design 72.72(a)72.72(b)(1), 72.72(bX2)

72.72(b)(1), 72.72(bX2)

72.75 I

I Table I (Continued)

DESIGN Subject Regulatory Guide Regulatory Position Porthr of 10 CFR Addressed Solid Waste System 3.1.1 e Design and test requirements

3.1.3 -Seismic criteria 3.1.4 v Seismic criteria 4.1 -ALARA 4.4 -Hydrostatic testing 4.5 -Testing 5.2 -Buildings housing radwaste systems 5.3 -Optional shielding 7i.72(a)72.72(b)(1).

72.72(b)(2)

72.72(b)(1), 72.72(bX2)

72.75 72.75 72.75 72.72(b)(1), 72.72(b)(2)

72.72(b)(1), 72.72(b)(2)

(%wf wf CD II C t)

I Table 2 OPERATIONS

Subject Regulatory Guide Regulatory Position Portions of 10 CFR Addressed Atmospheric Releases 4.16,Measuring, Evaluating, and Reporting Radioactivity in Releases of Radioactive Materials in Liquid and Airborne Effluents from Nuclear Fuel Processing and Fabrica-tion Plants Examples in this guide are not applicable to an ISFSI.Environmental reports for an ISFSI should be submitted on an annual basis rather than semiannually as stated In posi-tion 5.1.72.74(c)72.74(c)72.74(c)72.74(c)1 2 3 4 S* Methods of sampling analysis-Sampling program-Analysis of samples-Precision and accuracy of results-Reporting of results 72.33(dX3)

.tA Atmospheric Transport 1.11"1) Revision 1, Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light.Water-Cooled Reactors I* Atmospheric transport and diffusion models-Source configuration

2 3-Removal mechanisms

4 Meteorological data for models 72.33(dX3), 72.61(e).72.65(a), 72.74(d)72.33(d)(3), 72.61(e), 72.65(a), 72.74(d)72.33(dX3), 72.61(e), 72.65(a), 72.74(d)72.33(dX3), 72.61(e), 72.65(a), 72.74(d)72.15(a)(13), 72.33(dX3), 72.61(e), 72.65(a), 72.74(d)72.15(aX13), 72.33(dX3), 72.61(e), 72.65(a), 72.74(d)Aqnati Dispersion

1.113, Revision 1, Estimating Aquatic Disper-sion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Imple.menting Appendix I I-Transport and water-use models-Selection of models 2 Dose Assessment

1.1 IUY, Revision 1, Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I.1 3 4-Doses from liquid effluent pathways-Doses from airborne particulates

-Integrated doses to population

72.33(d)(3), 72.61(e), 72.65(a), 72.74(d)72.33(dX3), 72.61(e), 72.6S(a), 72.74(d)72.33(dX3), 72.61(e), 72.65(a), 72.74(d)f Table 2 (Continued)

OPERATIONS

Subject Effluent Monitoring Tleguhar Guide Regulatory Position 1.21, Revision l, Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Mate-dals in Liquid and Gaseous Effluents from Light-Water-Cooled Nudear Power Plants'.ft le)2 3 4 S 6 7 8 9 l .a I I.b I .c 12.b 12.c Location of monitoring

• Type of monitoring

-Gross radioactivity measurements

-Measurements of specific radionuclides

-Representative samples-Composite samples* Time between collection and analysis-Corrections for decay-Errors in measurement

-Quality controls-Calibrations

-Significant figures-Numerical values Portion of 10 CFR Addressed For an ISPSI that is co-located at a reactor site, as opposed to an ISFSI at a separate site, the monitoring requirements may be reduced. Monitoring may be needed at the fuel receiving and storage areas on a continuous basis only when spent fuel is being handled. Otherwise, periodic measurements may suffice, particularly for possible sealed storage modes.72.74(c)(1), 72.74(d)72.33(d), 72.74(c)(1), 72.74(d)72.33(d), 72.74(cX 1), 72.74(d)72.33(d), 72.74(c)(1), 72.74(d)72.33(d), 12.74(c)(1)

72.33(d), 72.74(c)(1)

72.33(d), 72.74(c)(1)

72.33(d), 72.74(c)( 1)72.33(d), 72.74(d)72.80(b)72.74(d)72.33(d), 72.74(d)72.33(d), 72.74(d)(Environmental Monitoring The preoperational monitoring period as stated in regulatory position I should be reduced from 2 years to I year.72.33(d)(2), 72.67 72.33(dX2), 72.67 72.33(dX2), 72.67 4.1, Revision 1, Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants 1 2.a 2.b-Preoperational program* Sample media-Sample frequency R4 Table 2 (Continued)

OPERATIONS

Regui!Wry Guie Regatory Position Portions of 10 CR Addressed 2.d 2.e 3-Analysis-Quality control-Detection capabilities

72.33(dX2)

72.33(d)l2), 72.80 72.33(dX2), 72.67 Envi"omental Monrtovins-TLD

4.13, Revision 1, Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry:

Environmental Applications General I 2 3 4 5-Endorsement of ANSI N545-1979 Quality Asmnce-Environmental I Monitoring

'4 I..)4.15, Revision 1, Quality Assurance for Radio-logical Monitoring Programs (Normal Opera-tions)-Effluent Streams and the Environment

1 2 4 S 6 7 8 9-Organization and responsibilities

-Personnel qualifications

• Records-Quality control In sampling-Quality control in analysis-Quality control for continuous monitoring systems-Review and analysis of data-Audits 72.33(d)(2), 72.74(c)(2)

72.33(dX2), 72.74(cX2)

72.33(d)(2), 72.74(c)(2)

72.33(dX2), 72.74(cX2)

72.33(dX2), 72.74(c)(2)

72.17 72.17 72.33(cXS), 72.80 72.33(c)(S), 72.80 72.33(c)(5), 72.80 72.33(cXS), 72.80 72.33(c)(S), 72.80 72.33(cXS), 72.80 (Radiological Protection-ALARA

8.8, Revision 3, Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable In applying this guide to an ISFSI, substitute the term"ISFSI" for the terms "LWR" and "nuclear power station" wherever they appear. Dis-regard references to the nuclear steam supply vendor.20.1(c), 7 2.3 3 (c)(S)20.1(c), 7 2.33(c)(S)20.1(c), 72.17 20.1(c), 72.17, 72.92 I l.b I.c-General-program goals* Establishment of program-Organization and personnel responsibilities

-Training and instruction r

Table 2 (Continued)

OPERATIONS

Subject Regulatory Guide Regulatory Position Portlons of 10 CFR Addressed 8.10, Revision -R, Operating Philosophy for Maintaining Occupational Radiation Expo-sumas As Low As Is Reasonably Achievable L.a-Management commitment I .b-Audits I c 1.d l.e l.f 2-Responsibilities

-Training-RSO authority-Procedure modifications

-Staff vigilance-Calibration frequency-Err6r limit-Documentation

20.1(c), 72.1 S(aX8), 72.17, 72.33(c)(S)

20.1(c), 72.1S(aX8), 72.33(c)(S)

20.1(c), 72.15saX8), 72.17, 72.33(bX4), 72.33(cXS), 72.92 19.12, 72.17(d), 72.33(bX4), 72.92 20.1(e), 72.15(a)(8), 72.33(c)(S)

20.1(c), 72.1 S(aX8), 72.33(c)(5)

20.1(c), 72.15(aX8), 72.33(c)3), 72.33(cXS)

20.103(aX3), 72.74(b)20.103(aX3), 72.74(b)20.103(a)(3), 72.74(b)(w Radiological Protection- Ar Sampling Instru-ments 8.25) Calibration and Error Limits of Air Sampling Instruments for Total Volume of Air Sampled 1 2 3 Radiological Protection- Boassay 8.9, Acceptable Concepts, Models, Equa-tions, and Assumptions for a Bioassay Program All-Assumption, models, concepts 20.108, 72.15(aI2)

20.108, 72.1 S(aX8)8.26, Applications of Bioassay for Fission and Activation Products All* Endorsement of ANSI N343-1978 Radiological Protection- Evacuation Signal 8.5, Revision 1, Criticality and Other Interior Evacuation Signals AU* Endorsement of ANSI/ANS N2.3-1979 72.74(b)Radiological Protection- Pocket Dosimeters

8.4, Direct-Reading and Indirect-Reading P6cket Dosimeters I-Testing 2 Rejection 20.202(a), 20.401, 72.15(aX5)

20.202(a), 20.401, 72.1 S(aXS)20.202(a), 20.401, 72.1 S(a(5)3-Mixed radiation fields ii ..

4 ho .,-Table 2 Continued)

OPERATIONS

Subjct Radiological Protection- Prenatal Exposure Regulary Guide Regulatory Position Portions of 10 CFR Addressed 19.12 19.12 8.13j Revision, 1, Instruction Concerning i natal Radiation Exposure 2 2-Instruction

-Reasons Radiological Protection- Respiratory Protection

8.1 5)Acceptable Programs for Respiratory Ptotection

1 2 3 4 5 6 7 8-Written policy-Equipment selection-Individual use of respirator

-* Requirements of program* Equipment approval-Unapproved equipment-Protection factors-Technical requirements

20.103 20.103 20.103 20.103 20.103 20.103 20.103 20.103-t Radiological Protecton- Symbol Safeguards-Alann Systems 8.1, Radiation Symbol 5.44, Revision 2, Perimeter Intrusion Alarm Systems General 20.203 2 2-Qualification

-Testing 72.81 72.81 Safeguards-Contingeney Plans 5.55, Standard Format and Content of Safe-guards Contingency Plans for Fuel Cycle Facilities All-Contingency plans 72.83 Safeguards-Entry/Exit Control 5.7, Revision 1, Entry/Exit Control for Protected Areas, Vital Areas, and Material Access Areas I 2 3 4-Protected Areas-Material Access Areas* Vital Areas-Emergency procedures

72.81 72.81 72.81 72.71(q), 72.81 Safeguards-ocks S.12, General Use of Locks in the Protection and Control of Facilities and Special Nuclear Materials 1 2 3 4* Combination locks-Combination padlocks-Key locks-Key padlocks 72.81 72.81 72.81 72.81 Table 2 (Continued)

OPERATIONS

Subject Reguiatoey Gulde Regulatory Position Portlons of 10 CFR Addressed 5 6 7 8* Electric locks-Pushbutton mechanical locks-Mechanical locks-Combinations

72.81 72.81 72.81 72.81 Safeguards-Security Force 5.20, Training, Equipping, and Qualifying of Guards and Watchmen 1 2 3 4-Preemployment screening-Training-Testing and requalification

-Equipment 72.81 72.81 72.81 72.81 5.43, Plant Security Force Duties 2 2-Oganization

• Duties 72.81 72.81 Safeguds-Trmngportatlon

5.57, Revision 1, Shipping and Receiving Control of Strategic Special Nuclear Material 1 2 3 4-Preshipment controls on waste* Overchecks

-Additional shipping controls-Receipts 72.81 72.81 72.54, 72.81 72.4, 72.81 Safeguardo-Viual Surveillance S 14, Revision 1, Use of Observation (Visual Surveillance)

Techniques in Material Access Areas I 2-Operational measures-Aids to effective surveillance

72.81 72.81 t q A A.-- X )

a I VALUE/IMPACT

STATEMENT 1. PROPOSED ACTION 1.4 Decision on Proposed Action 1.1 Description The storage of spent fuel in an independent spent fuel storage installation (ISFSI) is licensed under 10 CFR Part 72. For this type of installation, much of the material in existing regulatory guides Is applicable.

The proposed action would be the ssuance of a regulatory guide that would identify the guides that are applicable to SFSls and the extent of their applicability.-This guide is considered the most expeditious way to convey to the public, the industry, and the staff the appli-cability of existing guidance to licensing actions pursuant to Part 72.

2. TECHNICAL

APPROACH This guide addresses all technical subjects applicable to ISFSls on which there is existing guidance.1.2 Need Applications covering spent fuel storage in an ISFSI are expected to be received in increasing quantity during the next few years. The regulatory base applicable to SFSls is not comparable to that for nuclear reactors, therefore, the issuance of this guide is a major step toward meeting this deficiency.

1.3 Value/Impact Assessment

1.3.1 NRC The guidance provided by this guide is likely to expedite the NRC staff's evaluation of the applications.

1.3.2 Other Government Agencies

3. PROCEDURAL

APPROACH Among the procedural alternatives considered for making this guidance available, a regulatory guide was determined to be the most appropriate.

4. STATUTORY

CONSIDERATIONS

4.1 NRC Authority The NRC derives its statutory authority from the Atomic Energy Act of 1954, as amended, and the Energy Reorgani-zation Act of 1974, as amended, to provide guidance on acceptable means of meeting the requirements of its regulations.

None.4.2 Need for NEPA Assessment

1.3.3 Industry This guide will be of particular value to industry since there are no precedents specifically applicable to a license application under 10 CFR Part 72.1.3.4 Workers The principle of maintaining occupational exposures as low as is reasonably achievable (ALARA) Is covered in the proposed document.1.3.S Public This guide is designed primarily for the protection of the public and the environment.

The issuance of this guide is not a major action as defined in paragraph

15(a) of 10 CFR Part 5 1, hence, the action does not require an environmental impact statement.

S. RELATIONSHIP

TO OTHER EXISTING OR PROPOSED REGULATIONS

OR POLICIES This guide is one of a series of guides on the storage of spent fuel in an ISFSL 6. SUMMARY AND CONCLUSIONS

This guide is the most expeditious way of establishing part of the regulatory base required for the licensing of the storage of spent fuel in an ISFSI 3.53-18