ML20236X476
| ML20236X476 | |
| Person / Time | |
|---|---|
| Issue date: | 05/28/1997 |
| From: | Au M NRC |
| To: | Persinko A, Young F NRC |
| Shared Package | |
| ML20236W816 | List:
|
| References | |
| FRN-63FR31364, RULE-PR-72 AF80-1-034, AF80-1-34, NUDOCS 9808100038 | |
| Download: ML20236X476 (14) | |
Text
_ _ _ ________ ______
p.FBo-I y ~g From: Markley Au
( ) To: WND1.WNP7.FIY, WND1.WNP7.AXP1 l
'As' Date: 5/28/97 10:42am j
Subject:
Part 72 Proposed Rule Misc. Items -- Reg. Analysis for Item 7 of
) Plan Attached is a draft regulatory analysis to revise Section 72.140(d) concerning permanent retention of QA records.
From the licensing view point, we need to discuss the benefits for retaining QA records. Please advise what the benefits of assuring that QA records are for permanently maintained.
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Rulemakina Plan '
Miscellaneous Chances to Part 72 and Amendment to Part 40 to Remove Natural or Deoleted Uranium Used in Storaae Cask Shieldina from Part 40 Licensina Requirements I. Reaulatory Issue The Commission's licensing requirements for the independent storage of spent nuclear fuel and high-level radioactive waste are specified in 10 CFR Part 72. Experience in applying Part 72 has indicated that it is not adequate in some respects and that certain additions and clarifications to the rule are necessary. By memorandum dated May 9.
1996, the Spent Fuel Project Office. NMSS, proposed several changes to Part 72 together with a list of 18 miscellaneous items. In response to this request. RES initiated six rulemaking actions that were approved by the EDO. Five of the rulemaking actions are discussed in other rulemaking plans. This rulemaking plan addresses a group of miscellaneous items which would correct several inconsistencies and provide clarification to certain sections of Part 72. This rulemaking O would also remove the use of natural or depleted uranium in storage
. . (f casks from the licensing requirements of 10 CFR Part 40. This would be an extension of the shipping container exemption in 6 40.13(c)(6).
II. Prooosed Chanaes Item 1 - Requirement for Submittal of Dry Cask Storage Effluent Report
-- (t 72.44)
Reaulatory Issue Current regulations in 6 72.44(d)(3). " License Conditions." require submittal of a dry cask storage effluent report to the appropriate NRC regional office within the first 60 days of each year. Section 50.36a(a)(2). " Technical specifications on effluents from nuclear power reactors." requires that a similar report be submitted to the Commission once each year specifying liquid and gaseous effluents from reactor operations, i
The proposed revision would permit reactor licensees to submit their dry cask storage effluent report to the NRC once each year at the same time as the effluent report from reactor operations.
l Preliminary Reculatory Analysis
{_
l ( 1. Draft Rule Lanouace Section 72.44(d)(3) would be revised as follows (new language is underlined):
"An annual report be submitted to the U.S. Nuclear Reculatory l
Commission. A RN Document Control Desk. Washinoton. DC 20555. with a cooy to the appro)riate regional office s)ecified in appendix A of Part 73 of this clapter, with a copy to tic Director. Office of Sclear Material Safety and Safeguards. U.S. Sclear Regulatory Cc=iction, W:chington. DC 20555. within 50 day after January 1. Of each year.
l specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents during the i
previous 12 months of operation and such other information as may be l required by the Commission to estimate maximum potential radiation dose l commitment to the public resulting from effluent releases. On the basis l of this report and any additional information the Commission may obtain from the licensee or others, the Commission may from time to time l- require the licensee to take such action as the Commission deems a)propriate. KtiMbetWspn]5Gbmis5fonlogtepohts))MstibeMQ6hgR
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- 2. Imoact on the Licensees l l
l Reactor licensees will obtain a small benefit since both annual reports 1 l ,
may be submitted at the same time to the NRC.
1 sO Item 2 - Requirement for making initial and written reports (il 72.4 and 72.216)
Reaulatory Issue
'An administrative change needs to be made to 6 72.4 to provide that, except where otherwise specified, all communications and reports be addressed to NRC's Document Control Desk rather than to the Director.
Office of Nuclear Material Safety and Safeguards. At present, three regulations govern the submission of written reports under Part 72: i (1) 6 72.75. (2) H 72.216(b) and (3) 5 50.72(b)(2)(v11) (which is referenced in 6 72.216(a)). Under 6 72.75 a report is sent to the Document Control Desk: however, the two other paragraphs direct that the report be sent as instructed in 5 72.4 which specifies that reports be addressed to the Director, Office of Nuclear Material Safety and Safeguards. To achieve consistency in the NRC addressee for Part 72 reports, s 72.4 is being revised to instruct that reports be sent to the Document Control Desk. Directing licensing correspondence to the NRC's Document Control Desk will ensure proper docketing and i distribution.
Also, 6 72.216(c) is being changed to correct an error. The present t
regulation references 65 72.75(a)(2) and (3). The reference should be 1
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to il 72.751bl(2) and (3).
Preliminary Reaulatory Analysis
- 1. Draft Rule lanauace Section 72.216(c) would be revised and corrected as follows: (new
-language is underlined)
"The general licensee shall make. .. . , except for the events cpecified by is 72.75fa-)1b_l(2) and (3) for which the initial reports will be made under paragraph (a) of this section."
Section 72.4 would be revised as follows:
"Except where otherwise specified, all communications and reports....should be addressed to the Director. Office of Nuc' car Materia' cr.d Safeguart. U.S. . Nuclear Regulatory Commission ATTN:
Document Control Desk. Washington, DC 20555-0001."
- 2. Imoact on Licensees Correcting the error and the administrative change requiring the submittal of reports to NRC headquarters would not increase the j regulatory burden on licensees.
p Item 3 -- Modify El 72.1 and 72.2 to include spent fuel storage cask and delete superseded information Reaulatory Issue The purpose (5 72.1) and scope (5 72.2)-sections of Part 72 were not modified when the Commission amended Part 72 in 1990 to include a l process for providing a general license to a reactor licensee to store l
spent fuel in an independent spent fuel storage installation (ISFSI) at power reactor sites (Subpart K) and for the approval of spent fuel storage casks (Subpart L). Although the language in these sections may-be read to include the general license provisions of subpart K. it does not reference the approval process for spent fuel storage casks in Subpart L. This rulemaking will make the purpose and scope sections more complete by specifically referencing the Subpart L cask approval process. This rulemaking will also delete information in the purpose and scope sections regarding the Federal interim storage program since
.the timeframe for its implementation has expired (61 FR 35935, July 9.
1996).
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Preliminary Reaulatory Analysis '
- 1. Draft Rule Lanauaae Section 72.1 would be revised as follows: (new language is underlined)
"The regulations in this part establish requirements, procedures, and criteria for the issuance of licenses to receive, transfer, and possess power reactor spent fuel and other radioactive materials associated with spent fuel storage in an independent spent fuel storage installation (ISFSI) and the terms and conditions under .nich the Commission will issue such licenses. . including licence: to the U.S. Ocpartment of Energy (DOE) for the provision of not more than 1900 metris ton: 05 spent fuel capacity at facilitics not owned by the Federel Ccycrnment on January 7.1983 for the Federal interim storage ^rogram under Subtitle B Interim Storage Program of the Nuclear W:ste P$licy .^.ct of 1982 (NWP,^J . The regulations in this part also establish requirements, procedures, and criteria for the issuance of licenses to DOE to receive, transfer, package, and possess power reactor spent fuel, high-level radioactive waste, and other radioactive materials associated with the spent fuel and high-level radioactive waste storage, in a monitored retrievable storage installation (MRS). Furthermore. the reaulatiens in this cart also establish requirements. orocedures and criteria for the !
issuance of Certificates of Comoliance aoorovina soent fuel storaae casks."
Section 72.2 would be revised as follows: (new language is underlined)
Delete 9 72.2(e) -- superseded information regardin the Federal interim storage program. The existing 5 72.2(f) wi 1 become new 9 72.2(e).
Add a new paragraph (f) --
"(f) Certificates of Comoliance aoorovina the use of soent fuel storace casks shall be issued in accordance with the requirements of this cart as stated in s 72.236."
- 2. Imoact on Licensees There is no impact on licensees in making the purpose and scope sections of Part 72 comprehensive since no regulatory requirements are being changed.
l
- Item 4 Requirement for capability for continuous monitoring for confinement storage systems (5 72.122(h)(4))
Reaulatory Issue I
under current regulations, 6 72.122(h)(4) requires the capability for 1 continuous monitoring of storage confinement systems. The meaning of 4
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" continuous" is open to different interpretations and does not differentiate between monitoring requirements for wet and dry storage of spent fuel. Wet storage requires active heat removal systems that involve a monitoring which is " continuous" in the sense of uninterrupted. On the other hand, because of the passive nature of dry storage, active heat removal systems are not needed and monitoring can be less frequent. This rulemaking would clarify that the frequency of monitoring can be different for wet and dry storage systems.
Preliminary Reculatory Analysis
- 1. Draft Rule Lanausge Section 72.122(h)(4) would be revised as follows: (new language is underlined) {
" Storage confinement systems must have the capability for continuous monitoring in a manner such that the licensee will be able to determine when corrective action needs to be taken to maintain safe storage conditions. For dry storace. Deriodic monitorina is sufficient orovided that oeriodic monitorina is consistent with the cask desian requirements. The monitorina Deriod shall be based upon the cask desian requirements."
- 2. Imoact on Licensees
( This revision is to clarify monitoring requirements for dry spent fuel storage and would not change the burden for licensees.
Item 5 - Requirement S cifying Instrument and Control Systems for Monitoring Dry Spent Fue Storage is Not Appropriate (5 72.122(1)). f Reaulatory Issue Section 72.122(-i) requires that instrumentation and control systems be 3rovided to monitor systems important to safety and does not distinguish Jetween wet and dry storage systems. For wet storage, systems are required to monitor and control heat removal. For dry storage, passive heat removal is used and a control system is not required. This rulemaking will clarify that control systems are not needed for dry storage systems.
Preliminary Reaulatory Analysis
- 1. Draft Rule Lanauaae Section 72.122(i) would be revised as follows: (new language is
, underlined) l l "(i) Instrumentation and control systems. Instrumentation and control i systems for wet soent fuel storace must be provided to monitor systems l
f
) 5
that are important to safety over anticipated ranges for normal operation and off-normal operation. Those instruments and control
\ systems that must remain operational under accident conditions must be identified in the Safety Analysis Report.
Instrumentation systems for dry scent fuel storaae casks must be orovided in accordance with cask desian requirements to monitor.
)
conditions that are imoortant to safety over anticipated ranaes for normal conditions and off-normal conditions. Systems that are reauired under accident conditions must be identified in the Safety Analysis Reoort."
- 2. Imoact on the Licensees There would not be any change in regulatory burden for licensees in clarifying dry fuel storage monitoring requirements.
Item 6 - Clarify Requirement for Dry Spent Fuel Storage Cask on Methods of Criticality Control (5 72.124(b))
Reaulatory Issue Section 72.124(b) requires specific methods for criticality control, including the requirement that where solid neutron absorbing materials are used, the design shall provide for positive means to verify their continued efficacy. This requirement is appropriate for wet s)ent fuel storage systems but not for cry spent fuel storage systems. T1e dry O. s)ent fuel storage casks are sealed and it is not practical to penetrate t1e integrity of the cask to make the measurements for verifying the efficacy of neutron absorbing materials. Moreover, the potentially corrosive environment under wet storage conditions is not present in dry storage systems since an inert environment is maintained. This rulemaking will clarify that positive means for verifying the continued efficacy of solid neutron absorbing materials are not required for dry storage systems.
Preliminary Reaulatory Analysis
- 1. Draft Rule Lanauaae Section 72.124(b) would be revised as follows: (new language is underlined)
" Methods of criticality contro'i. When practicable the design of an l ISFSI or MRS must be based on favorable geometry. )ermanently fixed neutron absorbing materials (poisons), or both. W1ere solid neutron absorbing materials are used. the design shall provide for positive means of verifying their continued efficacy. For dry soent fuel storaae systems. the continued efficacy may be confirmed by demonstration before use and an analysis showina that significant degradation of the neutron absorbina materials cannot occur over the life of the facility.
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l- 2. Imoact on the Licensees There would be no impact on licensees trom this clarification of requirements for dry spent fuel storage systems.
Item 7 - Clarify Requirements in i 72.140(d) concerning previously Commission approved quality assurance program conforming to Appendix B of 10 CFR Part 50 j
Reaulatory Issue Section 72.174 specifies that quality assurance (0A) records shall be maintained by or under the control of the licensee until the Commission l terminates the license. However, 6 72.140(d) allows a holder of a Part 50 license to use its approved Part 50. Appendix B, OA program in
, place of the Part 72 0A requirements including the requirement for QA records. Appendix B allows the licensee to determine what records will
( be considered permanent records, using Regulatory Guide 1.28. Thus.
Part 50 licensees utilizing an Appendix B OA program could choose not to l make permanent all records generated in support of Part 72 activities.
This rulemaking will ' require such licensees to follow the Part 72 requirement to maintain 0A records until termination of the license.
Preliminary Reaulatory Analysis
- 1. Draft Rule Lanauaae Section 72.140(d) would be revised by adding the following sentence at the end of the first sentence: (new language is underlined)
"(d) Previously approved programs. A Commission-approved quality )
- assurance program which satisfies the applicable criteria of Appendix B to Part 50 of this chapter and which is established, maintained, and executed with regard to an ISFSI will be accepted as satisfying the i requirements of paragraph (b) of this section exceot that a licensee utilizina an ADoendix B ouality assurance oroaram must also meet the requirement of 6 72.174. Prior to first use. . . . . date of Commission 4 approval."
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- 2. Imoact on licenses I
- All Part 72 licensees, including those who have adopted an A)pendix B OA l program, currently maintain the OA records which are prescri)ed in i 72.174 as permanent records. However the maintenance of 0A records beyond those required under Appendix B is voluntary on the part of licensees who have adopted an Appendix B QA program. Since there is no assurance that these additional records would continue to be maintained in the future, NRC's regulatory analysis policy prescribes that for base case cost-benefit calculations. it is appropriate to give no credit for those voluntary actions, and to view this as an incremental burden of the proposed regulatory action. The staff estimates that the 20-year 7
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I present worth cost to a reactor licensee to maintain all permanent O records is on the order of $100.000 per licensee. This assumes an Q average one-time cost of $40,000 for a vault or cabinet, an annual labor cost of $6000 to maintain the records, and an annual storage fee of
$500. The present worth of the annual costs is based on a 7 percent .
real discount rate over a 20-year period which corresponds to the life I of the license. Based on discussion with NRC staff directly involved in oversight of 6 72.174 requirements. it is estimated that the permanent Independent Spent Fuel Storage Installation (ISFSI) records represent no more than 5 percent of the total permanent records required to be maintained by a reactor licensee. Thus, it is estimated that the 20-year incremental burden resulting from this rule change is on the I order of $5000 per licensee. This figure is equally applicable to both reactor and non-reactor licensees storing spent fuel. Given that there are about 40 licensees currently relying on the Appendix B OA program in lieu of 5 72.142. the incremental burden for the affected licensee population is approximately $200.000.
Alternatively, for sensitivity analysis purposes, it is useful to recognize that this new regulatory requirement is currently being met under existing licensee practices, anc in terms of real dollar outlay there is no change in burden associated with this regulatory action.
This presumes however, that, absent this proposed change, those i licensees utilizing an Appendix B QA program would continue to make permanent all records generated in support of Part 72 activities.
,p Item 8 - Remove natural or depleted uranium metal used in storage cask Q shielding from Part 40 licensing requirements Reculatory Issue The use of natural or depleted uranium in shipping casks is not subject to the Part 40 licensing requirements for source material under 140.13(c)(6). However, unlike for shi ping casks. current licensing requirements do apply to natural and de leted uranium used in spent fuel '
storage casks. Currently, natural or d pleted uranium is not used in the design of storage casks but it is anticipated that designers may want to use thi.s material in future cask designs. The purpose of this rulemaking is to make the use of natural and depleted uranium available for storage casks under s 40.13(c)(6) without subjecting that use to the licensing requirements of Part 40.
Preliminary Reaulatory Analysis L 1. Draft Rule Lanavaae i l Section 40.13(c)(6) would be revised as follows (new language is '
underlined):
"(c) Any person is exempt from the regulation in this part and from the requirements for a license set forth in Section 62 of the Act to the f 8
(
extent that such person receives, possess, uses, or transfers:
O . .(6) Natural or depleted uranium metal used as shielding constituting
)
part of any shipping container or scent fuel storaae cask: Provided.
That:
(i) The shipping container or soent fuel storace cask is conspicuously and legibly impressed with the legend " CAUTION - RADIOACTIVE SHIELDING - l URANIUM": and"
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- 2. Imoact on the Licensees This revision is intended to eliminate the need for licensees to obtain specific authority for use of natural or depleted uranium in spent fuel storage casks. This would provide burden relief for both licensees and the staff since requests for exemptions or applications for a Part 40 license would not be necessary.
Item 9 - Reporting Requirements for Specific Events and Conditions --
5 72.75 Reaulatory Issue Section 72.75 contains reporting requirements for specific events and conditions, including the requirement in 5 72.75(d)(2) for a follow-up written report for certain types of emergency and non-emergency notifications. Section 72.75(d)(2) also contains a brief description of
.p the type of information to be included in the required report. Staff's Q experience has been that this brief description has not been sufficient to elicit sufficient information for the staff to complete its review of a report. necessitating follow-up contacts with the licensee to secure additional information. Many requirements for the content of reports appropriate for reporting Independent Spent Fuel Storage Installation (ISFSI) or Monitored Retrievable Storage (MRS) events and conditions are found in 5 50.73(b) which staff has used as guidance. The proposed rulemaking would place appropriate 5 50.73(b) requirements in 5 72.75(d)(2) and thereby clearly inform licensees of the information necessary for the staff's review of a report.
Preliminary Reaulatory Analysis
.1. Draft Rule Lanauaae
.Section 72.75(d)(2) would be revised as follows: (new ianguage is underlined) i Delete il 72.75(d)(2)(1) (ii), (iii), (iv). (v), and (vi).
l "(2) Written report. Each licensee who makes an initial report required l by paragra)h (a) or (b) of this section shall submit a written follow-up i
report wit 11n 30 days of the initial re) ort. Written reports prepared pursuant to other regulations may be su)mitted to fulfill this
requirement if the reports contain all of the necessary information and O
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the appropriate distribution is made. These written reports must be sent to t1e U.S. Nuclear Regulatory Commission. Document Control Desk.
Washington DC 20555-0001. with a copy to the appropriate NRC Regional Office listed in Appendix D of 10 CFR Part 20. These reports must include the following:
(1) A brief abstract describino the ma.ior occurrences durina the event.
includina all component or system failures that contributed to the event and significant corrective action taken or olanned to orevent recurrence.
(2)(i) A clear. soecific. narrative description of what occurred so that knowledgeable readers conversant with the desian of ISFSI or MRS. but not fam'iliar with the details of a carticular facility. can understand the comolete event.
(ii) The narrative description must include the follov:ina soecific information as aoorooriate for the carticular event:
(A) ISFSI or MRS operatina conditions before the event.
(B) Status of structures. comoonents. or systems that were inocerable at the start of the event and that contributed to the event.
(C) Dates and aooroximate times of occurrences.
(D) The cause of each comoonent or system failure or oersonnel error. if known.
(E) The failure mode. mechanism. and effect of each failed comoonent. if Q
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or failures of comoonents with multiDie functions. include a list of systems or secondary functions that were also affected.
O (G) For failure that rendered a train of a safety system inocerable. an estimate of the elaosed time from the discovery of the failure until the train was returned to service (acolies to wet sDent fuel systems storaae only).
(H) The method of discovery of each comoonent or system failure or !
orocedural error. )
LI)(1) Ooerator actions that affected the course of the event. includina operator errors. orocedural deficiencies. or both. that contributed to the event.
(2) For each 3ersonnel error. the licensee shall discuss:
(1) Whether t 1e error was a coanitive error (e.a. failure to recoanize i the actual facility condition. failure to realize which systems should !
be functioning. failure to recoanize the true nature of the event) or a 1 Drocedural error:
(ii) Whether the error was contrary to an aDDroVed Drocedure. was a direct result of an error in an aooroved orocedure. or was associated j l with an activity or task that was not covered by an aporoved orocedure: l (iii) Any unusual characteristics of the work location (e.a. heat.
noise) that directly contributed to the error: and (iv) The tvDe of oersonnel involved (i.e. contractor oersonnel. !
utility-licensed ooerator. utility nonlicensed ooerator. Other utility l Dersonnel). l (J) Automatically and manually initiated safety system resoonses (wet soent fuel storace systems only).
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(K) The manufacturer and model number (or other identification) of each O comoonent that failed durina the event.
(L) The cuantities. and chemical and ohysical forms of the soent fuel or HLW involved.
L (3) An assessment of the safety conceauences and implications of the l event. This assessment must include the availability of other systems or comoonents that could have oerformed the same function as the comoonents and systems that failed durina the event.
(4) A description of any corrective actions olanned as a result of the event. includina those to reduce the probability of similar events occurrina in the future.
! (5) Reference to any orevious similar events at the same olant that are known to the licensee.
(6) The name and teleohone number of a oerson within the licensee's organization who is knowledgeable about the event and can orovide additional information concernina the event and the olant's l
characteristics."
- 2. Imoact on the Licensees Licensees currently submit follow-up reports for specific events and conditions in accordance with 5 72.75(d)(2). Upon review, the staff-often requests, via telephone calls and correspondence, that
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supplemental information be submitted to provide an adequate description
. of the event. The revised requirements in 9 72.75(d)(2) will provide l
clarification of what information is necessary in the initial submittal.
Thus, the revised reporting requirements are an increase in the licensee burden for preparation of the initial report. On balance, however, the total licensee burden under the revised requirements would be similar to l the current situation where the initial report is supplemented by l requests for additional information by the staff.
III. Common Elements for Items 1-Throuah 9 0GC Leoal Analysis.
OGC has no legal objection to this proposed rulemaking. Assuming that Item 8 is supported by the planned safety analysis report and 1 environmental assessment. 0GC does not anticipate any legal impediments !
to promulgation of the contemplated rule.
- Backfit Analysis. l t The NRC staff has determined that the backfit rule 9 72.62, does not _
apply to this Direct Final Rule, and therefore a backfit analysis is not l required.
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Aareement State Implementation Problems.
roposed amendment have been identified that would No adversely problems affectfrom the the kgreement States.
Sucoortina Documents.
It is antici]ated that an environmental assessment and Safety Analysis Report will 3e prepared in sup) ort of Item 8. Also, OMB clearance package will be prepared for tais rulemaking.
Resources Needed.
It is anticipated that 0.85 FTEs will be needed to complete this action.
No contractor support dollars will be expended. These resources are included in the current budget.
l Lead Office Staff and Staff from Sucoortina Offices.
Project Manager: Mark Au, RES User office cognizant staff: Francis Young NMSS Michael Lesar, ADM E. Neil Jensen, OGC l Steerina Grouo/Workina Grouo.
A steering group will not be used on this rulemaking.
Enhanced Public Participation.
The rulemaking will use the FedWorld Bulletin Board to notify the public that a Direct Final Rule has been issued. Comments can still be made during the 30-day comment period before the final rule becomes effective.
EDO or Commission Issuance.
'No significant comments are anticipated on this rulemaking, therefore, RES recommends that the EDO issue a " Direct Final Rule" for the proposed changes. This action does not constitute a significant question of policy, and falls within the ED0's authority. A Direct Final Rule is issued as final but still allows for a public comment period. If no significant issue is raised during this period, the rule becomes final at the specified date. If a significant issue is raised, the Direct Final Rule will revert to a proposed rule. This process should minimize both time and resources expended for this action.
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Schedule.
O The schedule is expressed in terms of time from approval of the rulemaking plan.
Rulemaking package for Office concurrence 4 months Rulemaking package to EDO 6 months Direct Final Rule published and OMB Clearance Package submitted to OMB 8 months l
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