ML20236W975
Text
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erd At May 9, 1996 gg/
MEMORANDUM TO: David L. Morrison, Director Office of Huclear Regulatory Research FROM: Carl J. Paperiello, Director ORIGINAL SIGNED BY Office of Nuclear Material Safety JOHN T. GREEVES for...
and Safeguards
SUBJECT:
USER NEED FOR REVISING 10 CFR PART 72
.10 CFR Part 72 contains the Commission's regulations for licensing independent
- storage of spent nuclear fuel and high level radioactive waste. Experience in applying Part 72 as more applicants are proposing to construct independent spent fuel storage installations (ISFSIs) and requesting NRC approval has shown that the existing Part 72 is inadequate in some respects. Addit'aons and clarifications to the rule are therefore necessary and are described in the attachments.
NMSS requests assistance from RES to revise 10 CFR Part 72 to address the concerns described in the attachments. The proposed changes to Part 72 have been grouped into seven categories (Attachment 1). A list of miscellaneous detailed changes is also provided (Attachment 2) as a supplement to the seven categories of changes. A proposed schedule is included in Attachment 1.
The NMSS Project Manager for this matter is Drew Persinko of the Spent Fuel
. Project Office (SFP0). He can be reached at 415-8528.
Attachments: As stated 1 Distribution: -
SFP0 r/f NRC F/C NMSS r/f b
l 00cument Name: A:\ RULE 3.PLA \ Backup: G:\ RULE 3.PLA l 0FC 5 SFP0 SFP0 SFP0 NM55 MS5ff NAK DPersinko:lat EEaston WDTravers JTG M NJPaNrMo DATE 05/08/96 05/08/96 05/08/96 IN 05/ i 96
/
C= COPY E = COVER & ENCLOSURE W= NO COPY OFFICIAL RECORD COPY 9008076033 980804 PDR PR 72 63FR31364 PDR
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CATEGORIES OF CHANGES TO PART 72 AND SCHEDULE i Technical / Administrative Issuel 1
- 1. Clarification of Specific and General Licensee Responsibilities '
Part 72 contains requirements for obtaining both. site-specific and general licenses for an ISFSI. It has not always been clear (to
)
licensees) from the wording of Part 72 which requirements are applicable to general versus site specific licensees.
- 2. Expansion of Scope to include Additional Parties The scope of Part 72 applies primarily to general or site-specific licensees. There are no or few specific requirements for other s;rties involved with safety related functions, such as certificate hcluers, I cask fabricators, vendors, designers, etc. As such the Commission has not been able to issue notices of violations to these parties to ensure that their safety related functions are properly conducted. ;
- 3. Use of Casks approved under Subpart K by Specific Licensees /
Construction of Casks Before Receiving a Certificate of Compliance Under Part 72, the analysis of a storage cask design intended for use under a specific license for an off-site ISFSI, is subject to hearing rights, including technical review and challenge. This leads to a duplication of staff effort in instances where a prospective specific licensee proposes to use a storage cask design previously approved, by rulemaking, under Part 72, Subparts X and L.
Part 72 discusses issuing Certificates of Compliance provided that certain requirements in Part 72 are met. The regulation, however, does not address when cask construction may begin relative to the issuance of a Certificate of Compliance.
- 4. Greater than Class C Low-level Waste Decommissioning activities at nuclear power plants are anticipated to generate relatively small volumes of low-level wastes which exceed the concentration limits in 10 CFR 61.55. These wastes are referred to a
" greater than Class C" low-level wastes (GTCC LLW), and are generally unacceptable for near-surface disposal. There are currently no disposal options for GTCC LLW, and utilities must store these materials pending development of a disposal facility. Such storage is anticipated to be necessary because the U.S. Department of Energy (the Federal Agency with
, the responsibility for developing a national GTCC LLW disposal strategy) has placed a low priority on developing a GTCC LLW disposal facility, and one will not likely be developed prior to a high-level waste i
1 repository.
l Attachment 1
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- . 5. Geological and Seismological Characteristics 10 CFR Part 72.102 specifies the geological and seismological siting factors for spent fuel storage facilities. Among the options available to licensees for satisfying this provision, is to utilize the criteria and level of determinations required by Appendix A of 10 CFR Part 100, for siting of Part 50 facilities. Because these evaluations have already been performed for all operating facilities, Part 50 licensees are expected to rely on this provision. Amendments to Appendix A to 10 CFR Part 100 are being developed that may have an impact on 10 CFR Part 72 licensees. The revision to Part 72 will accommodate the revised Appendix A to 10 CFR Part 100 and will identify an appropriate level of earthquake, in terms of probability of exceeAp,cet for which an ISFSI must be designed. The current regulations specffy a design earthquake for an ISFSI of no less than the SSE.for western sites and eastern sites with known seismicity; eastern sites"(excluding sites of known seismicity) are permitted to use .25g or the SSE.
. Clarifying changes to 10 CFR 72.212(b) are also needed to clearly communicate that licensees uring-the general license provisions may need
. to do additional analyses to assure that casks are not placed in an i, unanalyzed condition. For example, a dynamic loading analysis for an '
ISFSI pad may be appropriate to assure that a cask is not placed in an unanalyzed condition as a result of using the reactor site safe-shutdown earthquake (SSE). .
. 6. Adoption of Part 20 Dosimetry Methodology 10 CFR Part 72.104 establishes dose limits, to a real individual, from effluent and direct radiation from an ISFSI or MRS at 25 arem to the whole body, 75 mrem to the thyroid, and 25 mrem to any other organ.
10 CFR 72.106 limits the dose resulting from a design basis accident, to a hypothetical individual at the controlled area boundary, to 5 rem to the whole body or to any other organ. Both of these dose limits are inconsistent with the methodology used by 10 CFR part 20 and the President's Federal Radiation Protection Guidance on Occupational Exposure, which generally adopt the philosophy and methodology of the International Commission on Radiological Protection (ICRP) 1 d
recommendations in ICRP 26 and ICRP 30. The current Part 72 uses the dosimetry methodology of ICRP 2 (and the old Part 20).
- 7. Part 72 Issues Involving other Parts of Title 10
- a. Exempt natural or depleted uranium metal used in storage cask shielding from Part 40 general license currently, any person using a spent fuel storege cask that comprises a natural or depleted uranium shield would be subject to the general license provisions under Part 40 for possession of the uranium. These materials, depleted uranium in particular, are in abundant supply, and are used elsewhere in shielding applications. NRC already exempts the use of these materials as shielding in shipping containers, subject to i
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l certain conditions, from the general license provisions of Part 40. We anticipate that designers will want to employ these materials as shielding in future storage cask designs, and we have no objection to that use. The current general license, however, may impede the use of l j
these materials for storage casks, possibly leading to multiple requests for exceptions from the general license requirement.
- b. Submittal of dry cask storage effluent report does not coincide with Part 50 annual reactor effluent report submittal.
Currently, Part 72 licensees submit a report within the first 60 days each year specifying the effluents released from spent fuel storage operations during the previous 12 months. Since the storage casks are sealed in nost cases, the report is a simple statement that there were no effluent releases during the reporting period. The report should be retained, however, in light of future dry cask transfer operations.
Reactor licensees are also required to submit a report to NRC once each year, but not necessarily with the first 60 days, that specifies the effluents from reactor operations. A provision should be made to allow the submittal of the storage effluent report simultaneously with the ;
more substantial reactor effluent report. !
Reculatory Aeolication:
- 1. Clarification of Specific and . General Licensee Responsibilities Staff has received several inquiries from prospective applicants requesting an interpretation of the applicability of certain Part 72 provisions to general licensees under Subpart K. An example is the July 28, 1995 letter from Davis-Besse, in which Toledo Edison questioned the applicability of 672.82(e) (and other regulations in Part 72) to general licensees. OGC has since interpreted that these provisions are applicable to general licensees. Clarification of which regulations are I applicable to site-specific and general licensees is needed to reduce the uncertainty for potential licensees, and lessen the need for legal interpretations by NRC legal staff.
- 2. Expansion of Scope to include Additional Parties ,
Because there kre no or few spicific requirements in Part 72 for parties other than licensees, the Comission has been unable to issue notices of violation to other parties involved in ISFSI safety related functions.
Instead the Comission has been forced to issue notices of non-compliance. This is because the requirements on other parties come from ,
a contract agreement with a licensee rather than from a direct l regulation. The inability to issue notices of violation to these other ,
l parties could reduce the effectiveness of NRC's inspection and '
enforcement programs in assuring compliance with the Commission's regulations and safety goals.
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- 3. Use of Casks approved under Subpart K by Specific Licensees /
Construction of Casks Before Receiving a Certificate of Compliance Staff anticipates that NRC may receive several applications for specific licenses for off-site ISFSIs that will propose using storage casks previously approved in Subpart K of Part 72. Under current regulation, the adequacy of the design of these previously approved storage casks could be at issue (particularly during the hearing process) in each specific license application. This would result in staff having to expend considerable resources in repeatedly re-examining and defending technical issues already resolved during the public rulemaking process.
The staff has received exemption requests to allow construction of storage casks to begin before a Certificate of Compliance is issued (Sierra Nuclear). The staff issued such an exemption on April 26, 1994 provided that the casks were constructed under an approved quality assurance program among other conditions. The staff's position is that construction of casks may begin before a certificate of compliance is issued provided that construction is performed under an NRC approved quality assurance program and that the applicant bear all risks I associated with early construction.
- 4. Greater than Class C Low-Level Waste 10 CFR Part 72 lacks the regulatory language to allow possession or storage of GTCC LLW, under a site-specific license, pending the availability of a disposal facility for these materials. Licensees which use the general license provisions of 10 CFR Part 72 may possess and store these materials because of the requirement to maintain their j site-specific license. Amending Part 72 to allow GTCC LLW storage would
- facilitate transition from a general license to a specific license, for those licensees that wish to make such a change, and could therefore result in considerable cost savings. However, staff considers this expansion of scope to have a negligible effect on public and occupational health and safety or the environment.
- 5. Geological and Seismological Characteristics - 10 CFR 72.102 The changes to the geological and seismological siting characteristics in Appendix A to 10 CFR Part 10,0 should be evaluated to <ietermine any impact on 10 CFR Part 72 licensees. The need for a conforming change, or alternative siting provisions specific to Part 72, could then be .
assessed. l
- 6. Adoption of Part 20 Dosimetry Methodology l
, The modification of the 10 CFR 72.104 and 671.106 dosimetry methodology, j to reflect the effective dose equivalent (EDE) methodology of 10 CFR '
Part 20, will result in a consistent level of protection of public health and safety, but will reduce burden, confusion, and uncertainties I resulting from duplicative efforts necessary to comply with two different methodologies (i.e., ICRP 2 and ICRP 26), in the applicable
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. .o NARC regulations. Under the ICRP 26 dosimetry methodology, stochastic doses to organs are implicitly considered and separate limits for organs are unnecessary. The changes will make 55/2.104 and 72.106 consistent with other Comission regulations, including 10 CFR Parts 20 and 60.
However, the change to EDE methodology for 10 CFR 72.104 will make that section inconsistent with the current requirements of 40 CFR Part 190, which still uses ICRP 2 methodology.
- 7. Part 72 Issues Involving other Parts of Title 10
- a. Exempt natural or depleted uranium metal used in storage cask shielding from Part 40 general license Part 40.25(a) issues a general license to receive possess use, or transfer depleted uranium contained in industrial products or devices.
Under paragraph 40.13(c)(6), an exemption from Part 40 is granted for natural or depleted uranium metal used as shielding in a shipping container, provided the uranium is marked and encased in mild steel or j i
equally fire resistant metal. As written, this exemption does not apply 1 to spent foal storage casks. I
- b. Submittal of dry cask storage effluent report does not coincide with Part 50 annual reactor effluent report submittal.
Part 72.44(d)(3) requires licensees to submit a report to the ,
appropriate regional office within the first 60 days each year '
specifying the quantity of each of the principal radionuclides released to the environment in liquid and in gaseous effluents from spent fuel storage operations during the previous 12 months. Reactor operators are {
required under Part 50.36a(a)(2) to submit a similar report to the Document Control Desk once each year specifying effluents from reactor operations.
Product:
- 1. Clarification of Specific and General Licensee Responsibilities NMSS proposes that Part 72 be amended to clarify the applicability of its previsions:to general and site-specific licensees.
- 2. Expansion of Scope to include Additional Parties -
NMSS proposes that the scope of Part 72 be expanded to include parties i
other than licensees with safety related functions. This should be accomplished by amending Part 72 to include specific regulations i describing the required functions of certificate holders, cask fabricators, designers and vendors, etc.
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3.
Use of Casks' approved under Subpart X by Specific t.icensees /
Construction of Casks Before Receiving a Certificate of Compliance NMSS proposes that Part 72 be amended to allow applicants for specific licensees to use cask designs previously approved under Subpart K, without having as part of to submit the specific a :;eparate license safety analysis for 6he cask design application.
cask would not.then be subject to technical re-review during theThe des licensing review and hearing process.
l l NMSS proposes that Part 72 be revised to allow for initiation of storage l
cask construction provided that certain conditions are met by the applicant.
4.
Greater than Class C Low-Level Waste A petition for rulemaking has been submitted to NRC requesting the expansion of the scope of 10 CFR Part 72 to include GTCC LLW. HMSS proposes that rulemaking issues in this this petitionplan.
be considered together with the remaining l_ 5.
Geological and Seismological Characteristics - 10 CFR 72.102 10 CFR Part 72.102 will be analyzed to determine:
j conforming amendments to changes to 10 CFR Part 100 Appendix A, or (1) the need for i l
l (2) the need to develop independent seismic siting criteria for storage systems. I l 10 CFR 72.212(b)(3), will be clarified to state that L
5572.102(c), (d), and (f) apply to general licensees and to clearly communicate that a cask must not be place in an unana,lyzed condition. A requirement will be included for a dynamic loading analysis for an ISFSI pad, if appropriate, to assure that a cask is not placed in an l
unanalyzed condition as a result of using the reactor site SSE.
10 (notCFR 72.212(b)(2) load). will' be corrected to reference the " static
- load the'*statis'
- 6. Adoption of Part 20 Dosimetry Methodology Modification of the 25 mres to the whole body, 75 arem to the thyroid, and 25 mrem to any other organ limits, to reflect the part 20 system of dose limits, will result in a dose limit of 15 ares TEDE in 572.104.
This ve}ee is egesistent with other commission actions (see, for exampig NistES 1496, Vol.1).
Modif teetten of the 5 rem dose limit, to reflect the part 20 system of dose limits, results in a family of dose limits:
res); the sum of the deep dose equivalent and the comitted dosea TEDE of 0.05 S equivalent to any individual organ or tissue (other than the lens of the eye) of 0.5 Sv (50 res); an eye dose equivalent of 0.15 Sv (15 res); and a shallow dose equivalent to skin of 0.5 Sv (50 ren) in 172.106. These values are also consistent with the limits for Category I design basis
! events which are being proposed (60 FR 15180) for the geologic repository operations area (a facility anticipated to be very similar to ISFSI and MRS facilities) under 10 CFR Part 60.
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- 7. Part 75 ssues Involving other Parts of Title 10
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- a. Egt natural or depleted uranium metal used in storage cask shielding from Part 40 general license.
NHSS requests that Part 40 be revised to expand the current exemption j for encased depleted uranium use as shielding in shipping containers to l include use a shielding in spent fuel storage casks.
- b. Submittal of dry cask storage effluent report does not coincide with Part 50 annual reactor effluent report submittal.
NMSS requests that Part 72 be revised so that licensees may be submit i the storage effluent report in unison with the reactor effluent report, j l
Schedule:
Draft rule issued for coment 12/31/96 Coment period ends 2/28/97 ,
Issue final rule 9/30/97 Priority: *
)
High Priority, Category I .
. General Coments:
Revising Part 72 to better comunicate the Comission's requirements for designing and constructing ISFSIs is critical as an increase in the number of applicants are expected in the future.
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' MISCEtt.ANE005 DETAILED QB E ES TO PART 72 7
A list of detailed changes to Part 72 is provided below. They are provided to supplement the seven categories of changes contained in Attachment I and complete the scope of revisions to Part 72.
! 1. Clearly state the applicability of Section 100.23 to a f5tS or other l facility.
Tp 2. Include a definition of certificate or certificate holder in 72.3 4 3.- Consider whether to include cert.ificate holder in the employee protection provision, section 71.10. 7 79 4. Certificate holder should be added to the completeness and accuracy of 4 information provision in section 72.11. , g ,
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% D p .- Certificate holder provision should in section be added to the deliberate misconduct 72.12.
TD 6. Subpart G, Quality Assurance, is presently made applicable to 4 certificate holders via footnote 2; consider including certificate holder wherever licensee is used. i
- 7. Add provision to sections 72.1 and 72.2 to indicate that this part also governs approval of spent fuel storage casks.
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8.- In 72.70, clarify who is responsible for maintaining SARs, particul'arly SARs written by vendors.
- 9. Clarify who can make changes to the designs under 72.48. Currently, it is only permitted by the licensees, however, condition 9 of the Vectra SER/SAR gave persission to the vendor.
- 10. Section 72.122(h)(4), clarify " capability for continuous monitoring in a manner..." so that monitoring is consistent with the threat to public l health and safety.
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- 11. Clarify section 7t.122(1), I&C systems may not be appropriate for passive storage cask designs.
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- 12. Clart h section 72.122(1) to redefine retrievability for the MPC to allow he definition to mean retrievability of the canister only. This 7 .
would allow for the possible degradation of the cladding with the assumption that the canister would be handled in a dedicated facility.
- 13. Section 72.124(b), clarify "where solid neutron absorbing materials are used, the design shall provide for positive means to verify their continued efficacy." This is included in the regulation to address Attachment 2 I
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i Boraflex in spent fuel rack designs and'may not be appropriate or practical for sealed casks using borated aluminum or borated stainless {
steels. 1 I
+ 14. Part 72.216 is inconsistent with 72.74 and 72.75: reporting requirements !
l for site-specific license are different than for general license - they should be the same. {
+ 15. Section 72.216(c) should refer to 72.75(b)(2)(3) - there is no 72.75(a)(2)(3).
, 16. Clarify 72.140(d) ,: that previously approved Appendix B to Part 50 may be applied except sor XVII, Quality Assurance Records.
1 <-- *i7. Revise Parts 72.74 and 72.75 to remove inconsistent reporting
\ requirements.
\ 18. In Part 72.75(2), refer to 50.73 for format and content.
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1 Minor Amendments to 10 CFR Part 72 and Related Sections Reoulatory issues Current regulations in several Sections of 10 CFR Part 72 have inconsistent, inappropriate, and unclear regulatory requirements which also involve other Parts af the regulations. l Curren,1 Rule Requirements Correct Four inconsistencies:
1 NRC regu!ations in 5 72.44, " License conditirins" requires submittal of a dry cask storage effluent report to the regional office within the first 60 days of each year. This requirenwnt is not consistent with 5 50.36, " Technical specifications" which requires a similar trprt be submitted to the Document Control Desk once each year specifying offluent frorn reactor operations.
- 2. NRC regulations in 5 72.216. " Reports"is inconsistent with il 72.74 and 72.75 concerning reporting requirements for site specific license are different than for general license under 5 50.72 "Immediate notification requirements for operating nuclear power reactors."
- 3. NRC regulations i 72.216(c)" Reports" indicates 72.75(a)(2H3) which is incorrect. '
- 4. NRC regulations il 72.74 and 72.75 specify inconsistent reporting requirements.
- 5. NRC regulations il 72.1 and 72.2 require licensees to submit a report within the first 60 days each year concerning ,
effluents released from spent fuel storage operations. Reactor licensees are also required to submit a report to NRC once each year, but not necessarily within the first 60 days, that specifies the effluents from reactor operations.
Clarification of Five Sections
- 1. NRC regulations in Section 72.122(hW4) specifies capability for continuous monito.ing so that the keensee is able to determine when corrective action needs to be taken to ensure safe storage conditions. The monitoring needs to be con /* ant with regulatory requirements,teprEls thiest to public health and safety. bu .e A o . + . e
- 2. NRC regulations in Section 72.122(i) specifies operationalinstrumentation and control systems to monitor systems that are important to safety. The requirement for operating reactors I & C systems is not appropriate for passive spent fuel storage cask designs.
- 3. NRC regulations under Section 72.124(b)" Methods for criticality control" specifies "Where solid neutron absorbing materials are used, the design shall providsgositive rneans to venty their continued efficacy." This requirement in the regulation is not applicable for spent fuel storage casks / -M P .edp<ub-j 4. NRC regulations under Section 72.140(d) concerning quality assuranca contain requirements include a quality assurance 5 l
program which satisfies criteria of appendix B to Part 50. This proposed change ad apply appropriate criteria of appendix B to Part i 50 e*eeptJar XVil, Quality Assurance Records.9 ev E P M La .
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- 5. NRC regulations Section 72.75. " Reporting requirements for specific events" should include reference to Section 50.73 for format and content.
Eremotion:
Current NRC regulations require any person using a spent fuel storage cask that comprises a natural or depleted uranium shield would be subject to the generallicense provisions under Part 40 for possession of the uranium. NRC dready exempts the use of these materials as shielding in shipping containers, subject to certain conditions, from the generallicense provision of Part 40.
7 Reoulatory Problem to be Resolved The rulemaking would update NRC regulations in 1572.44, 72.74,72.75,122,72.124,72.140, and 72.216 and related sections for I
consistency and clarify to reflect current practices.
Preliminary Reoulatory Analysis This rulemaking is of a clarifying nature, and imposes no new requirements on licensees for a holder of a certification of compliance issued pursuant to Part 72) or applicants. Therefore, thb rule change will have no impact on licensees and a Regulatory impact Analysis is not required These changes would amend to update and clarify existing 10 CFR Part 72 regulatory requirements. Only minimal NRC resources will be needed to make these changes.
0GCleoal Analgis.
000 has no objection la updating i 72.
Backfit Analysis t
l The NRC has determined that the backfit rule,10 CFR 50.109, does not apply to this Direct Final Rule, and therefore a backfit analysis is L not required. These arnendments do not involve any provisions that would imposa backfits as defined in CFR 50.109(aWI).
l' Aoreement State implementation Problems.
1 No problem from the proposed amendment have been identified that would adversely affect the Agreement States.
Supoortino Documents None required l
Resources N aded.
It is anticir led that 0.8 FTEs will be needed to complete this action.
l No contrar or support dollarr will be expended.
Lee ' affice Staff and Staff from Supportino Offices.
Project Manager: Mark Au, RES 3, g User office cognizant staff: L-b m uso, NMSS ADM: Michaelless OGC:
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Steerino Grouo!Workino Group.
A steering group will be used on this rulemaking. The steering group members are as f allows: TBD 4 I
r Enhanced Public Participation.
The rulemaking will use the FedWorld Bulletin Beard to notify the public that a Direct Final Rule has been issued. Comments can still be made during a specified comment period be the final rule become effective.
EDO or Commissic- tssuance.
i the proposed changes. This action does not constitute a s y. A Direct Final Rule is issued as final but still allows for a public comment period. If no signthc becomes final at the specified date. If a significant issue is raised, the Direct Final should minimize both firne and resources expended for this action. .
ss Schedule.
Approval by the E00 of the Rulemaking Plan to initiate Rulemaking I Rulemaking package for Office concurrence October 1996 Ruler.aking package to the ED0 November 1996 Direct Final Rule December 199 January 1996 l
PPR AfBo-t.
Frans khrkley Au h To: WND1.WNP7.AXP1
Subject:
Part 72 -- Rulemaking Plan --Misc. Items l Drew, l RE: Miscellaneous Item 18 of NMSS user need letter dated May 9, 1996 Proposed rule change requested including Section 50.73 for format and content in Section 72.75. Since Section 50.73 involves LERs for opera 4 ting reactors, please advise what parts of the content are desired for inclusion in Section 72.75. Identifywhatisdgiredintermsof format.
Thanks, f' Mark Au l
CC: PVN l
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From: Markley Au M66-I To:
Subject:
WND1.WNP7.AXP1 Part 72 Ruelmaking Plan Miscellaneous Items 6 g
Drew, W
Please provide basis requiring clarification of the Connission approved quality assurance program under Appendix B of Part 50 except for XVII, Quality Assurance Records. Where is the current requirement for QA records in Part 72 7
Will revision be required to ensure QA records are maintained by licensees ?
Mark Au-CC: PEN N,
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