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PNL-6739
UC-812

Licensing of Spent Fuel Dry Storage
and Consolidated Rod Storage:
A Review of Issues and Experiences
February 1990

Prepared for the U.S. Department of Energy
under Contract DE-AC06-76RLO 1830
Pacific Northwest Laboratory
Operated for the U.S. Department of Energy
by Battelle Memorial Institute

DISCLAIMER
This report was prepared as an account of work sponsored by an agency of
the United States Government. Neither the United States Government nor
any agency thereof, nor Battelle Memorial Institute, nor any of their employees, makes ~ny warrmty, expressed or implied, or usurnes my lepl

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manufacturer, or otherwise, does not necessarily constitute or 1mply its endorsement, recommendation, or favoring by the United States Government
of any agency thereof, or Battelle Memorial Institute. The views and opinions
of authors expressed herein do not necessarily state or reflect those of the
United States Government or any agency thereof.

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3 3679 00056 371 0





LICENSING OF SPENT FUEL DRY STORAGE
AND CONSOLIDATED ROD STORAGE:
A REVIEW OF ISSUES AND EXPERIENCES

W. J. Bailey

February 1990

Prepared for

the U.S. Department of Energy
under Contract DE-AC06-76RLO 1830

Pacific Northwest Laboratory
Richland, Washington 99352



PNL-6739
UC-812





••

'





ABSTRACT





:

The results of this study, performed by Pacific Northwest Laboratory
(PNL) and sponsored by the U.S. Department of Energy (DOE), respond to the
nuclear industry's recommendation that a report be prepared that collects and
describes the licensing issues (and their resolutions) that confront a new
applicant requesting approval from the U.S. Nuclear Regulatory Commission
(NRC) for dry storage of spent fuel or for large-scale storage of consolidated spent fuel rods in pools. The issues are identified in comments,
questions, and requests from the NRC during its review of applicants' submittals. Included in the report are discussions of I) the IS topical reports
on cask and module designs for dry storage of spent fuel that have been
submitted to the NRC, 2) the three license applications for dry storage of
spent fuel at independent spent fuel storage installations (ISFSis) that have
been submitted to the NRC, and 3) the three applications (one of which was
later withdrawn) for large-scale storage of consolidated fuel rods in
existing spent fuel storage pools at reactors that were submitted to the NRC.
For each of the applications submitted, examples of some of the issues {and
suggestions for their resolutions) are described. The issues and their
resolutions are also covered in detail in an example in each of the three
subject areas: I) the application for the CASTOR V/2I dry spent fuel storage
cask, 1) the application for the ISFSI for dry storage of spent fuel at
Surry, and 3) the application for full-scale wet storage of consolidated
spent fuel at Millstone-2.
The conclusions in the report include examples of major issues that
applicants have encountered. Recommendations for future applicants to follow
are listed .


iii



f

••

!



SUMMARY




The new applicant is faced with numerous licensing issues when applying
for approval from the U.S. Nuclear Regulatory Commission (NRC) to place spent
light-water (LWR) fuel in dry storage casks or modules at independent spent
fuel storage installations (ISFS!s) or for large-scale storage of consolidated spent LWR fuel rods in pools. The issues are identified in comments,
questions, and requests from the NRC during its review of the applicants'
submittals. Many of those issues have been addressed in earlier licensing
reviews by the NRC but are documented in diverse places. The nuclear
industry recommended that a report be issued that collects and describes
major licensing issues and their resolutions. In response to that
recommendation, a study was performed under the Commercial Spent Fuel Management (CSFM) Program, which is sponsored by the U.S. Department of Energy
(DOE) and managed by Pacific Northwest Laboratory (PNL), with the objective
of preparing such a report.
The results of the study are presented in this report. Discussed in the
report are the 18 applications that have been submitted to the NRC for
approval of dry storage casks or modules, the three applications that have
been submitted for dry storage of spent fuel in at-reactor ISFSis, and the
three applications (one of which was later withdrawn) for large-scale storage
of consolidated fuel rods in existing spent fuel storage pools at reactors.
For each of the applications submitted, examples of some of the issues (and
suggestions for their resolution) are provided. The issues and their resolutions are described in more detail for one example in each of the three subject areas: I) the application for the CASTOR V/21 dry storage cask
(Project M-37), 2) the application for an !SFSI for dry storage of spent fuel
at Surry (Docket No. 72-2), and 3) the application for full-scale wet storage
of consolidated spent fuel at Millstone-2 (Docket No. 50-336). Comments on
each of the three subject areas are presented below .




v

ISSUES IN APPLICATIONS FOR APPROVAL OF DRY SPENT FUEL STORAGE CASK AND
MODULE DESIGNS
In reviewing the applications for approval of dry spent fuel storage
casks or modules, the NRC has raised a number of issues. Allowance for
burnup credit remains an open issue. The NRC is concerned that, during the
typical process of loading and/or unloading spent fuel into a cask or canister in the spent fuel storage pool, there is the potential for introducing
nonborated water, which would result in undermoderation because of reduced
water density. The NRC has major concern with components (e.g., cask bodies
and fuel baskets) that are proposed to be made of nonspecification materials.
Such materials must be adequately characterized if they are to be approved by
the NRC. Storage of spent fuel in air-filled casks or modules has not been
accepted yet by the NRC. However, the NRC Staff does not reject the contention that continued research on this subject may subsequently result in
allowance of air as a cover gas for dry storage of spent LWR fuel. A major
issue with one application was the criticality design of the fuel basket,
which relied on the insertion of a "poison spider" assembly of rods into a
fue 1 assemb 1y. The NRC questioned whether this approach can satisfy the
design criteria of 10 CFR Part 72 for at-reactor site storage, at least in
the context of a nonsite-specific topical report. The discovery of cracks in
the borated stainless steel fuel basket (Project M-37) was of great interest
to the NRC. The cracks were caused by constrained thermal expansion. The
problem was solved by incorporating a simple design modification that
involved eliminating fabrication stitch welds on the first few feet of either
end of the basket. An issue with one application (Project M-44) was the use
of scale models of the cask in the drop testing program. There is a need for
thorough editing of applications. With at least four of the applications,
the NRC commented that there appeared to be errors, inconsistencies, and
omissions. In some applications, reduced drawings were too small to be
legible.
A recent article indicates that the NRC is proposing a rule change that
would permit LWR licensees to store spent fuel in NRC-approved dry storage
casks (free-standing metal and concrete type) under a general license that
would not require additional site-specific reviews by the NRC. So far, four
vi





:



metal dry storage casks that have been approved by the NRC would come under
the general license coverage. The four are CASTOR V/21 (Project M-37), MC-10
(Project M-41), NAC-S/T (Project M-40), and NAC-C28 S/T (Project M-51).
ISSUES IN APPLICATIONS FOR DRY STORAGE OF SPENT FUEL IN AT-REACTOR ISFS!s



A number of issues were involved with these applications. One issue
raised by the NRC centered on the question of whether, and to what extent,
the spent fuel storage canisters to be used at the ISFS!s will be compatible
with the transportation casks ultimately chosen by DOE to transport spent
nuclear fuel temporarily stored at reactor sites to permanent repositories.
One applicant indicated, given the fact that DOE's design effort for its cask
fleet is in its early stages, that no meaningful compatibility review can be
conducted at this time. With one application, the NRC stated that the associated Environmental Report did not fully comply with 10 CFR 72. There is a
need to show that an ISFSI at a reactor site operates independently {as
defined in 10 CFR Part 72) from the reactor. An array of casks/modules needs
to be considered in the application .



ISSUES IN APPLICATIONS FOR LARGE-SCALE STORAGE OF CONSOLIDATED FUEL IN
EXISTING POOLS AT REACTORS



'

The NRC raised a number of issues with these applications. With one
application (Maine Yankee), an issue involved the need for a procedure for
controlling the temperature of the pool water so it does not exceed a
specified limit. With two applications (Maine Yankee and Milestone-2), an
issue involved controlling/justifying the decay time of the spent fuel. With
one application (Maine Yankee), the NRC indicated that the applicant was to
avoid lifting a spent fuel shipping cask over the pool until a cask drop
analysis was submitted by the licensee and approved by the NRC. Applicants
were requested by the NRC to provide a complete description of the consolidation process and an associated safety analysis. Generally, in completing an
application, there is a need to eliminate inconsistencies and the potential
for unnecessary confusion and incorrect perceptions. With one application
(Millstone-2), the NRC raised an issue over the lack of discussion of a
testing program involving the spent fuel rack system and the use of the
vii


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