ML20125D388

Task Action Plan A-28: Increase in Spent Fuel Pool Storage Capacity, Revision 1

ML20125D388
Person / Time
Issue date:	10/19/1977
From:	Blond J Office of Nuclear Reactor Regulation
To:
Shared Package
ML20125D386	List: ML20125D383 ML20125D388
References
REF-GTECI-A-28, REF-GTECI-SF, TASK-A-28, TASK-OR NUDOCS 8001140264
Download: ML20125D388 (17)

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' CATEGORY A TECHNICAL ACTIVITY NO. A-28 APPROVEDBYTASC,197/

OCTOBER 19, TITLE: Increase in Spent Fuel Pool Storage Capacity LEAD RESPONSIBILITY: Division of Operating Reactors LEAD ASSISTANT DIRECTOR: Darrell G. Eisenhut, Assistant Director for Operational Technology, DDR TASL MANAGER:

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1. Problem Description With the present "no-reprocessing" posture throughout the nuclear power industry, a considerable increase in onsite spent fuel storage will be required in order to permit continued operation of many nuclear powe plants. On September 16, 1975, its intent to prepare a generic environmental impact statement on hand-ling and storage of light water power reactor spent fuel (GEIS) and also identified 'ive factors to be .pplied in licensing decisions in the interim. The Commission concluded that licensing activities should

• proceed on a " case-by-case" basis and, pending the outcome of the GEIS, rulemaking proceedings on more definitive standards and criteria would be instituted on or about the time of issuance of the draft GEIS by the NRC staff. I To achieve the Commission's stated objective, we must review the GEIS to detemine what, if any, change to the rules and procedures under  ;

which NRR licenses power reactors are required. Whi~ie such an effort

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i is underway, NRR must be prepared to continue to review and conclude on the many spent fuel pool expansion raQuests expected in the near future. Consistent with and in support of these objectives, we must l develop uniform guidelines and procedures for licensees and the staff l alike. ,

2. Plan for Problem Resolution l l To achieve the aforementiorted ,0,bjectives two concurrent task plansn have s Task 1, "0'ivel;pm;nt of + Standard Review Planfa^

beendeveloped.'efforReviewof,Incr, ease.in Regulatory Guid f SRP and nee-enttions Capacity" fee-a R.G

?provides for W : 4 0cfhm2 P ofbased upon an OT b draft form). This draft BTP is a compendium of insights gained by M DOR in The their "cgg;y-cise" reviews of spent fuel pool capacit deve. p -t of these documentsFould serve to ensure c creases.

the uniformity of reviews for the sixty-five operating plants and for' Q '; l plants under licensing alike, as well as to inform 74K--

applic 1 informational needs. For additional details see Attachment 1.

Out:;rc vi ibia a;ti-/ 4ty 9:y require : r:er:1ucti;n of cxisting S Ts I result Of thh effe-t; to det erin i' they re:;cire :henges :s :

' TASC CCffENTS INCORPORATED, OCTOBER 23,19/7 8 ""

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2-Tast II, " Policy Development" provides a mechanism for the develop-ment of infomation to detemine the necessity for changes to existing GEIS.

NRR licensing criteria based on the conclusions of basis for determining the need for rulemaking and the development For additional of proposed rules if they are found to be required.

details see Attachment 2.

This A Critical Path Milestone-Sumary is presented as Attachment 3.

sumary identifies the relationship of each task and key milestones in the individual tasks to the overall effort.

3. NRR Technical Organizations Involved Qu ne a

a. Lead responsibility for Task I, "D6elcpment of -a- Standard Review ide$or Review of Increase in Spent Fuel

,, .. (e vsto)diahand Regulatory GuPool Storage Capeaty" will reside with the Task M: n Plant Systems Branch of DOR. A significant support effort will Additional assistance will be required by the EB and EEB of DOR.The total estimated p0R/ Task be required from DSS /DSE/DPM.

Manager effort,.is estimated to be Man-weeks, 2dInan-weeks for e DSS /DSE and # man-weeks for DPM. Detailed work assignments and manpower estimates are provided in Attachment 4 will

b. Lead responsibility for Task II, " Policy Development,"

reside with the Task Manager with assistance from DPM, DOR, and OELD. The estimated effort for the Noselected DPM attempt has beenand madeDDR individuals will be 9 man-weeks each. Detailed work assignments to estimate the OELD manpower effort.

and manpower estimates are provided in Attachment 4.

4. Technical Assistance Reovirements

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a. ForTaskI.,"DevelcrentofaStandtedReviewPlanlandRegula-tory Guidefor Review of Increase in Spent Fuel Pool Storage Capacity" no assistance is anticipated.

b. For Task 11. " Policy Development," Brookhaven National Lab may be requested to perfom a technical study of licensing alterna-l tives identified by the staff. The need for this assistance

. will be determined pending the NRR staff review of the draft GEIS.

Potentially this effort could involve development of alternative criteria to detemine the acceptable degree of spent fuel pool expansion at each site. The cost of the contractor

• effort is estimated to be approximately $10,000.

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,3 S. Interactions witn Outside Oroanizations

a. For Task 1. " Development of a Standard Review Plan and Regulatory Guide for Review of increase in Spent Fuel Storage j Capacity," no interaction with outside organizations is anticipated.

b. For Tas) 11, " Policy Development," no interaction is anticipated l witt outside orgerizations.

6. Assistance Requirements from Other NRC Offices l

l The Office of Nuclear Material Safety and Safeguards, Division of I Fuel Cycle and Material Safety, Fuel Reprocessing and Recycle Branch j has requested that they continue to be informed of progress and l developments by ONRR in the review of spent fuel pool storage )

capacity. NRP will review and coment on the draft GEIS which has I beer. prepared by Nv.55. In addition, we anticipate that, for Task II, "Pclicy Development" 0 ELD participation will be required. OSD will be requested 10 develop rules, stemming f rom the findings of the GEIS, for NRR if they are found to be required.

7. Schedule for Probler Resciution .

l A detailed Critical Path Milestone Summary is p. resented for each task in their respective attachments. A Critical Path Milestone - Summary l

is presented as. Attachment 3. This summary identifies the relation-ship of each tesl and the key milestones in the individual tasks to the overall effort.

E. Peter.tial Problems - . . . .W m t r/M gg%

" ReviewPlanjandReguia-

a. For Test 1 tory Guided, o& eve' e t of + Standardr Review of Increase in j Capacity" no problems are anticipated,

b. For Task 11, " Policy Development," the proposed schedule is very tight (20-weeks) which introduces the uncertainties of meeting it. OELD has indicated that a drawn out schedule would be unacceDtable and that we should be in a position to promulgate proposed rules, if any, within sixty days of publication of the draft GEIS.

The task may also be impacted by evolving administration plar.s for the Department of Energy regarding spent fuel storage.

i 90017095 Attachments:

1. Test 1 - Detailed Su-cary

2. Task )) - Detailed Sumary i

3. Critical Path Milestones - Summary.

4. Manpower Estimates

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ATTACHMENT 1 i

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TASK I - DETAILED

SUMMARY

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TASK I Qe w - - h o 75/0a4 we DECO *D:7 0F A STANDARD REVIEW PLAN 1AND REGULATORY GUID OF INCREASE IN SPENT FUEL P0OL STORAGE CAPACITY BASIS FOR TASK An increased demand for onsite storage of spent fuel assemblies has prompted licensees to propose the Similar use of proposals high density canstorage racks in reasonably existing spent fuel storage pools.

be anticipated to be submitted by applicants for operating licenses.

The review of these proposals and of the acceptance criteria which have been applied to these proposabiad&tes that to provide sufficient -

consistency of staff reviews, ag'tandard review glan-Ef 2hrd f=t-should be developed. Experience to date indicate that there is sufficient similarity among the proposals that much of the review can be " standardized."

TASK PLAN DOR /0T, Engineering Branch, has developed a draft 6TP entitled, " Pro-pesed Position for Review and Acceptance of Spent Fuel Storage and Handling Applications" which describes the staff review, acceptance g criteria, and development of findings for the EnvH onmental Impact The insights gained by DDR

• Appraisal and the Safety Evaluation Report.

in their " case by-case" reviews are reflected in this document. Due io the imediate industry need for guidance as to the staff's information requirements for approval of spent fuel pool modifications the draft BTP should be finalizeg',, reviewed by RRRC, and promulgated to the licensees '

e n t- Plan ^and ' transmittal of prior to the M M crecommendationsfor24egul,0fTStandardReview atory Guideato OSD. The d?/W!ph nt of + 4 .

Standard Review Plah10r'the NRR staff and

• Regulatory Guidebl44 (nformation reoviremenisjbased ongh,is BTP would serve to ensure the [ %p

]g uniformity of reviews for operating olants and plants not yet licensed for operation alike. n ,:11 :: thTnform applicants and licensees, in infonnation needs.

advance of preogr The first public:gion of applications, as to the staff'sm of a Stan should be titled " Interim" to reflect that it will be reevaluated sub-sequent Spent Fuel ."

to completion of Task A-36, i.e., " Control of Heavy Load l which result from this generic task, i.e., Task A-36, will be factored -

into a revised version of the Standard Review Plan 48nd Regulatory Guidet.G.

Consequently, we can promulgate our findings from the generic effort, -

i.e.. Task A-36,in a consistent and orderly fashion while still providing the best guidance available to the staff, licensees and applicants in the interim.

NRR_ Technical Oreanizations involved f

After finalization of the draft paper a value/ impact statement will be s- prepared for RRRC by the EB and Task Manager.

It is estimated that this i

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2-effort will require four nweeks with approximately one-man week each

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- of consultation by EEB and PSB. Following the issuance of the finalized and approved BTP the lead responsibility for this task will be transferred from the EB of DDR to the Plant Systems Branch of DOR and the Task Manager.

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The development of the first draft of thelStandard Review Plan (SRP),,is estimated to require about 4%#e man-weeks total for EB, PSB, and EEB DPP e,a, of 00R. Review and comment by DSS (MEB, Mat 1. EB, SEB, CS , ASB)

DSE ( AB, ETSB), and DOR on the first draft should require about M weeks per branch. , Incorporation of comments by PSB and the Task Manager should require .tMr man-weeks with approximately one man-week of consul-tation each by EEB and EB. The review of the final draft by management and resolution of coments is estimatg, to d be tko* man-weeks for PSB and the Task Manager "with approximately t OM man-week each of consultation by EB and EEB.

At this stage about'dM man-week per branch should be allo-cated by involved DSS /DSE branches for consultation.

The completion of Task A-36, " Control of Heavy Loads At thisNear timpSpent we will Fuel" will be a decision point for this task, i.e., Task I.

determine what, if any, modifications are required to the SRPX*a' rid ^to the

- pr;pc;cd RG to reflect the results of Task A-36. In the event that further action is,rjauired, the PSB and the Task Manager would re -

mom 9 theRG to be sentThe toinvolved OSD DSS,withDOR, dffman-weekf each for 'EEB and DPM and DSE branches reovired for thejr coments. The should require o d man-week for each branch to review these changes.

incorporation of comments by PSB and the Task Manager and the preparation of a value/ impact statement for RRRC should require JEFman-weeks with The review approximately 3de man week each of consultation by EEB and EB.

of the final draf t by management and the resolution of comments is estimated to be two man-weeks for PSB and the Task Manager with approx-imately man-week each of consultation by EEB and EB.

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DDR/ Task Manager effor#tefor this task is about 4t man-Detailed weeks, .26 man-weeks for DSS /DSE and theet Man-weeks for DPM.

manpower estimates are provided in Attachment 4.

Technical Assistance Requirements None anticipated Interactions with Outside Oreanizations None anticipated 90017098

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Assistance Requirements from Other NRC Offices s

l The Office of Nuclear Material Safety and Safeguards Division of Fuel I

' Cycle and Material Safety, Fuel Reprocessing and Recycle Branch has 1

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requested that they continue to be informed of progress and developments by ONRR in the review of spent fuel pool storage capacity.

Schedule for Problem Resolution We anticipate that eighteen weeks after RRRC approval of the Branch Technical Position, an interim Standard Review Plan'}s3Uld be available for use by the staff. We estimatewe that ten weeks after RRRC approval will have developed the information c' Regulatoryto Guide  ? A4-the-i of the Branch Technical Pos_Mgignecessary request 050 d. .. .

valu:tien of cui: ting SPo; may be r.ece:sary somplction Of the test.  ?

to deterninc if eny :Pe ;e ere aecessary to ther For additional details see the Critical Path Milestones in the attached Figure.

Potential Problems None anticipated.

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TASK I DF#ELOPMEttY OF STANDARD REVIEW PLAT (JAND REGULATORY GUIDE q FOR REVIEW OF INCREASE IN SPENT FUEL POOL STORAGE CAPACITY iG (November 18,1977) (December 30,1977) (February 24,1978)

(October 21. 1977) Final Publication incorporation Publication Branch Dra f t - of Changes to of Final Standard Draft - of SRP t%

Position Reg. Guide and Reg. Guide Complete Review SRP boa.+ and SRP SRP for RRRC Plan (SRP)

Review

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A4 wks A2 wks l A4 wks l l ,

l l l l Decision Point- Coments  ; j Coments on Infonnation l on Changes l Requirements to Completion of Draft from l Task A-36 to Reg. Guldp

- DSS, DSE, OSD for d _ op- l and SRP l DOR, DPM men jt a Reg.  ;

5 (December 21, Gurde .

1977) re so,. b.g '

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SUMMARY

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• TASK II 1

l POLICY DEVELOPMENT BASIS FOR TASK On September 16, 1975 the Commission announced (40 F.R. 42801) its intent to prepare 'a generic environmental impact statement (GEIS) In on this handling and storage of spent light water power reactor fuel.  ;

notice, the Commission also announced its conclusion that it would not  ;

be in the public interest to defer licensing actions intended to amelio-rate a possible shortage of spent fuel storage capacityThe pending comple-Commission tion of the generic environmental impact statement.

provided "five factors" to be applied, weighed, and considered within the staff's statements or appraisals in reaching licensing determina-tions. Consequently, in the last two years the staff has proceeded on l a case-by-case basis in the review of these licensing actions.

The Commission stated in part, that upon completion of the d: aft GEIS, rulemaking proceedings on more definitive standards and criteria would be instituted on or about the time of issuance of the draft GEIS.

Possible amendments This task is to to 10 CFR 51.20(e) develop would the technical also be considered information and legal at this. time.

documentation for NRR to support this action with respect to expansion

• of spent fuel storage at reactor facilities. We also viish to assure that the r"les applicable to reactor facilities are developed consistent Con- with and in conjunction with rules for non-reactor storage facilities.

sequently, close coordination with NMSS in this regard will be required.

TASK PLAN The thrust of this plan is to review the draft GEIS and detemine what, if any, techM cal. and legal changes to the rules and procedures under which NRR licenses power reactors are required to implement the findings of the draft GEIS. This will require a parallel legal and technical review effort. The results of this effort will be a Summary Staff Report documenting the NRR staff's review of the draft GEIS and a presentation of conclusions and recommendations OSD will be forrequested rulemaking toproceedings, develop if necessary, for reactor facilities. The results of this task effort proposed rules if they are necessary.

may provide input to Task I " Development of a Standard Review Plan and Regulatory Guide for Review of Increase in Spent Fuel Pool Storage Capacity", in the event that policy issues are identified which lead to technical requirements, either in terms of information required from licensees or staff technical criteria.

NRR TECHNICAL ORGANIZATIONS INVOLVED

' The lead responsibility for this task should reside with the Task Manager.

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Upon receipt of the draft GEIS for NRR review in August 1977, a review of the draft GEIS should consnence by the Task Manager and appropriate 90017102 e

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The objective of this initial representatives from each NRR office.

effort would be to develop NRR comments on the GEIS for transmittal to

' NMSS, to develop a series of relevant questions for OELDif to as consider a

in their review, and to develop a work plan for a contractor No attempt result of the NRR review this is found to be necessary.

has yet been made to estimate NRR manpower required for the draft GEIS.

technical bases for various licensing alternatives identified by the NRR staff. Potentially this effort could involva development of alterna-tive criteria to determine the acceptable degree of spent fuel po expansion at each site.

time for the Task Manager and require about 3 man-weeks ea and 00R (EEB) support.

Lab.

The estimated cost of the contractor effort is $10,000.

The contractor effort, if necessary, and the OELD support effort It is would begin upon publication of the draft GEIS for public commen GEIS that the NRR staff is considering the following:

1. Issuance of an interim Regulatory Guide and Standard Review Plan for Increases in Spent Fuel Storage Capacity at Nuclear Power Reactors.

2.

The development of definitive criteria to implement the draft GEIS findings in the licensing process for increases in reactor spent fuel storage capacity.

Upon NRR receipt of the draft reports from OELD r J

the Director of NRR would review and comment.abo the Task Manager.

It is anticipated that a coordinated effort between NMSS and NRR will assure that NRR implements, as necessary, the findings of the GEIS, and that NMSS appropriately reflects the experience gained to date by This NRR in its review of spent fuel pool modifications at reactors.

will assure that the findings presented in the GEIS will reflect NRR experience and future plans.

Upon receipt of the final contractor report and final O prepare a draf t Staff Report on definitive criteria to implement theAt this tim draft GEIS findings in the licensing process.

requested to develop rules for NRR if they are found to be necessary,

/. This effort will be full time for the Task Manager and 2 man-weeks A management review of each s for selected DPM and 00R (EEB) staff members.

the draft will follow.

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A final Staff Report will be written by the selected DPM and DOR staff members and the Task Manager and will include pro, ed rules developed by OSD if they are required. This effort will be full time forDELD the Task will be Manager and require 2 man-weeks each for DPM and DDR (EEB).

requested to review and approve the final Staff Report and proposed rules if they are necessary.

The total anticipated manpower for this effort is 9 man-weeks each for 00R and DPM selected personnel with a full time effort by the Task Manager. No attempt has been made to estimate the DELD effort. De-tailed manpower estimates are provided in Attachment 4.

TECHNICAL ASSISTANCE REQUIREMENTS Brookhaven National Lab may be requested to provide assistance in the development of technical basis for licensing alternatives.

INTERACTION WITH OUTSIDE ORGANIZATIONS None anticipated.

ASSISTANCE REQUIREMENTS FROM OTHER NRC OFFICES The Office of Nuclear Material Safety and Safeguards, Division of  !

Fuel Cycle and Material Safety, Fuel Reprocessing and Recyr.le Branch J has requested that they be included in the review process for the generic NRR effort on Increase in Spent Fuel Pool Storage Capacity. i It is anticipated that a coordinated effort between NMSS and NRR will assure that NRR implements, as necessary, the findings of the GEIS, l and that NMSS appropriately reflects the experience gained to date by NRR in its review of spent fuel pool modifications at reactors. This will assure that the findings presented in the GEIS will appropriately reflect NRR experience and future plans.

OELD effor! will be required as described in the section of this task entitled, *NRR Technical Organizations Involved."

OSD will be requested to assist in the development of rules for NRR if they are found to be required.

SCHEDULE FOR PROBLEM RESOLUTION The estimated time from the beginning of the contractor and OELD review effort of the dratt GEIS to the publication of proposed rules and a -

Summary Staff Report is about 20 weeks. For additional details see the attached CPM.

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POTENTIAL PROBLEMS f

s The proposed schedule is very tight which introduces the uncertainties of meeting it. OELD indicated that a drawn out schedule is unacceptable.

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- and we should be Nomulgating our proposed rules ideally within .

sixty days of publicatior of.the draft GEIS.

The task may also be impacted by evolving administration plans for the Department of.Eneroy regarding spent fuel storaae.

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TASK II 7-P0llCY DEVELOPMENT August 31, 1977 November 11, 1977 0 --- 0 Drsft GEIS Draft GEIS Received Issued for for Comnent by Public NRR Coment 0 33 ,gs 33 ,g3 g 33 ,g3 g 34 ,g3 g-A4 wks l  :

• l l l  ! FinaIReport Draft Staff  ; Final Report Start Draft Report  ; w/reconnended Prepare Con- By Report-on l tr ctor Requi- -Contractor Received  : definitive criteria

-Contractor  ; -Eontractor sition 8 Detailed Effort

-0 ELD criterie to l ifork Plan and -0 ELD Effort -0 ELD implement

Proposed rules Review GEIS for (December 9, 1977) ;; (January 70,1978) DGEIS findin9s  ; for coment MMSS in licensing l

(March 31, 1978) process l (February 10,1971)

Mgt. Review Comments from NRR to (March 3, 1978) 4 -0 ELD o -Contractor o

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ATTACHMENT 3 CRITICAL PATH MILESTONES -

SUMMARY

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CRITICAL PATH MILESTONE -

SUMMARY

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Task I - Lyvehpawmt of Standard Review Planjand Regulatory Guide 10 Branch Position Complete Publication of for RRRC Review Interim SRP w o ww (October 21, 1977) (rchniary 24. 1978)

Infonnation to OSD Publication of Final for d4Y@t of RG Decision Point RG & SRP woauw (December 30,1977) 0 0- 0 - - - - - - - -C 0

Completion of A16 wks Task A-36 Task II - Policy Development .

Contractor Effort Proposed rules for connent Availability of GEIS Begin -

Final Staff Report

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RESPON5tBluYY FOR CHANGE We SOMEOULE TASK NO: _b-M h~MG D @ Task Mgr. Q DSE 6s==ry >=um GENERtc TASK- N

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IMPACT DATA (Prepared by MIPC) omens j

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OMIPC AUDIT AND COMMENT cMesa. us. om.ac DATE:

COMPLETE: DeRsGTDR. WED. OM6PC DATE: .-

RECOMMENDED FOR APPROVAL: *

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APPROVED /Dt1 APPROVED: CMM AMAM.T A&C e

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