**NRC INSPECTION MANUAL** NMSS/SFST

INSPECTION PROCEDURE 60854

PREOPERATIONAL TESTING OF AN INDEPENDENT

SPENT FUEL STORAGE INSTALLATION

PROGRAM APPLICABILITY: 2515 and 2690

60854-01 INSPECTION OBJECTIVE

01.01 Determine by direct observation and independent evaluation
whether:

a\. The licensee has developed, implemented, and evaluated
preoperational testing activities to safely load spent fuel from the
spent fuel pool (SFP) into a dry cask storage system (DCSS) and to
transfer the loaded DCSS to the independent spent fuel storage
installation (ISFSI).

b\. The licensee has developed, implemented, and evaluated a
preoperational test program in order to safely retrieve spent fuel from
an ISFSI and transfer it to either the SFP or a separate cask or
canister.

c\. The licensee has fulfilled all test acceptance criteria and all
identified deficiencies are resolved before receipt of fuel at the
ISFSI; and

d\. The licensee has made changes to appropriate plant programs and
procedures to support operation of the ISFSI.

01.02 Determine that the activities in Section 01.01 are accomplished in
accordance with the commitments and requirements contained in the Safety
Analysis Report (SAR), NRC's Safety Evaluation Report (SER), Certificate
of Compliance (CoC) for the DCSS design being used under a general
license or the license and technical specifications (TS) for an ISFSI
operated under a specific license, the licensee's Quality Assurance (QA)
program, and 10 CFR Part 72.

01.03 Independently assess, at the completion of the preoperational
testing program, the licensee's readiness to load spent fuel into the
ISFSI or retrieve spent fuel from the ISFSI.

60854-02 INSPECTION REQUIREMENTS

02.01 Before any on-site activity, review the SAR, SER, CoC, and, if
applicable, the specific license and TS for the DCSS being used. The
review should also include relevant Bulletins, Information Notices, or
10 CFR Part 21 reports issued related to ISFSI activities or the
specific cask design. Prior to the on-site visit, the Agency-Wide
Documents Access and Management System (ADAMS) should be searched for
any ISFSI related documents or reports that are relevant to the
inspection or that identify issues that should be added to the
inspection. The ADAMS search should go back to the date of the last
inspection.

As the following documents are typically available only at the site, at
the start of the inspection, review any evaluations required by 10 CFR
72.212(b) for general licensed ISFSIs, and any 10 CFR 50.59 and 10 CFR
72.48 evaluations for both general and specific licensed ISFSIs, as
these documents may contain assumptions regarding ISFSI operations.
(NOTE: these evaluations may have been previously inspected through the
use of Inspection Procedures (IPs) 60856 and 60857)

02.02 Verify that the preoperational test procedures for DCSS loading,
unloading, and transfer activities and their acceptance criteria meet
the commitments and requirements specified in the DCSS SAR, SER, CoC, 10
CFR Part 72, the site-specific license and TS as applicable, any related
10 CFR 50.59 and 72.48 evaluations, and 10 CFR 72.212(b) evaluations for
general licensed ISFSIs.

02.03 Verify that preoperational test procedures, for the activities
listed below, have been prepared, reviewed, and initially approved in
accordance with the licensee's administrative programs. Determine if the
licensee has completed a verification and validation of the procedures.
If the licensee has used multiple procedures, then verify that
sufficient overlap has been maintained to ensure all required critical
activities, such as those listed below, will be performed.

a\. For transferring spent fuel from the SFP to the ISFSI:

1\. Moving the empty cask or canister into the SFP area.

2\. Placing the cask or canister in the SFP.

3\. Verification of selected fuel and movement of fuel from SFP into the
cask or canister.

4\. Documenting the parameters and characteristics of spent fuel placed
in the cask or canister per the license or CoC.

5\. Lifting the cask or canister from the SFP.

6\. Sealing the cask or canister.

7\. Evacuating water from the cask or canister and vacuum drying.

8\. Gas backfilling the cask or canister and decontaminating.

9\. Transferring the loaded cask or canister to the transport vehicle.

10\. Transporting the cask or canister to the ISFSI.

11\. Placing the cask or canister in the ISFSI.

b\. For retrieving spent fuel from a loaded DCSS in the ISFSI and
returning it to the SFP:

1\. Retrieving of the cask or canister from the ISFSI.

2\. Transporting the cask or canister from the ISFSI to the reactor or
fuel building.

3\. Sampling the cover gas for indications of fuel damage such as
radioactivity or air inleakage, and directing operator response if the
sample indicates fuel damage.

4\. Venting of the cover gas and backfilling of the cask or canister
with water.

5\. Unsealing the cask or canister for access.

6\. Transferring the cask or canister to the SFP.

7\. Transporting the fuel from the cask or canister to the SFP.

8\. Removing the cask or canister from the SFP and decontaminating.

9\. Storing or disposing of the cask or canister.

c\. For inspection guidance on retrieving spent fuel from a loaded DCSS
in the ISFSI and performing a dry transfer to a different DCSS
component, contact Nuclear Material Safety and Safeguards/Spent Fuel
Storage and Transportation (NMSS/SFST) for assistance.

02.04 Verify, through interviews and reviews of selected records, that
licensee personnel conducting preoperational test activities have a
clear understanding of their duties and responsibilities, and that:

a\. Personnel have been trained and certified per the licensee's
approved training program.

b\. A pre-job briefing has been performed for all affected staff.

c\. Oversight and command and control responsibilities have been clearly
established, including notification requirements.

d\. Specific radiological hazards are identified and controls
implemented.

02.05 Verify that equipment used during preoperational test activities
has been tested and/or evaluated for its impact on plant structures,
systems and components before performance of the preoperational tests.

02.06 Determine by review of selected licensee procedures, that
responsibilities for specific activities relating to the ISFSI (i.e.,
design, component fabrication, construction, preoperational testing,
operations, maintenance, and surveillance testing) have been defined and
the licensee has integrated responsibilities for these activities into
the appropriate plant programs listed below. Verify that these
procedures fulfill the commitments and requirements specified in the
SAR, SER, CoC, 10 CFR Part 72, the site-specific license and TS as
applicable, any related 10 CFR 50.59 and 72.48 evaluations, and 10 CFR
72.212(b) evaluations for general licensed ISFSIs.

a\. Plant Operations;

b\. Radwaste Storage and Handling;

c\. Control of Heavy Loads;

d\. Radiation Protection;

e\. Security and Safeguards;

f\. Emergency Preparedness;

g\. Maintenance;

h\. Surveillance;

i\. Fire Protection;

j\. Training;

k\. Environmental Monitoring;

l\. QA Activities; and

m\. Administrative Procedures.

02.07 Evaluate the effectiveness of the licensee's management oversight
and QA assessments of preoperational testing activities.

02.08 Evaluate the effectiveness of the licensee's plans and
preparations for controlling radiological activities, by reviewing
documents and interviewing individuals. Evaluate the effectiveness of
radiological controls and monitoring and the effectiveness of security
controls during preoperational testing.

02.09 If the procedures used by the licensee during the dry run have not
received final approval yet, then re-perform the reviews described in
Section 02.03 after the licensee has issued the procedures for use.
Similarly, prior to ISFSI operation, ensure that any plant programs and
procedures reviewed in Section 02.06 that were not yet finalized have
been, any outstanding issues related to them have been resolved, and the
programs and procedures have received the appropriate reviews and
approval.

02.10 By direct observation and evaluation of selected activities, such
as those listed in Section 02.03.a, independently assess whether the
licensee has adequately demonstrated its readiness to safely transfer
spent fuel from the SFP to the ISFSI.

02.11 By direct observation and evaluation of selected activities, such
as those listed in Section 02.03.b, independently assess whether the
licensee has adequately demonstrated its readiness to safely retrieve
spent fuel from the ISFSI and transfer it to the SFP or to another DCSS
component.

60854-03 INSPECTION GUIDANCE

03.01 [General Guidance]{.underline}.

For the purposes of this procedure, the term "licensee" may refer to a
specific license holder (10 CFR 72.16) or a reactor licensee using a
general license (10 CFR 72.210).

Requirements and commitments related to preoperational testing may be
found in the various licensing basis documents such as the SAR, SER,
CoC, and, if applicable, the specific license and TS for the DCSS being
used. Additional requirements and commitments may also be located in
evaluations required by 10 CFR 72.212(b) for general licensed ISFSIs,
and in any 10 CFR 50.59 and 10 CFR 72.48 evaluations for both general
and specific licensed ISFSIs. In the event that preoperational test
methods and/or acceptance criteria do not coincide with those specified
in these documents, the inspectors are encouraged to contact NMSS/SFST
in order to obtain technical assistance. The inspectors should directly
observe any dry runs required by the specific license or CoC. While it
is preferable for the dry run to replicate the actual evolution, the use
of mockups and overlapping procedures is acceptable. The dry run should
accomplish the following overall goals:

a\. Demonstrate the functionality of all equipment.

b\. Test and refine the procedures used for loading and unloading
activities.

c\. Train and rehearse licensee personnel before actual movement of
spent fuel.

If the licensee intends to use a different model or type of DCSS, for
which a preoperational test program has not been completed, then
applicable portions of IP 60855 and this procedure may be revisited.

03.02 [Specific Guidance]{.underline}.

a\. [Inspection Requirement 02.01]{.underline}. SARs and SERs describing
commitments regarding preoperational testing have been written for each
type of approved DCSS. DCSS designs vary widely and care must be taken
to review the correct documentation. Copies may be obtained from the
Division of Reactor Safety or NMSS/SFST. In some cases, requirements and
commitments for preoperational testing may be located in Section 9 of
the SAR. While the SER can document or clarify commitments made by the
licensee or vendor, it does not serve as an independent basis for
enforcement actions.

b\. [Inspection Requirement 02.02]{.underline}. If possible, review the
licensee's approved preoperational test procedures for DCSS loading,
unloading, and transfer activities before conducting the on-site
inspection. Although test criteria are discussed in the DCSS SAR, SER,
CoC, and, if applicable, the specific license and TS, there may be
differences between the licensee's test procedure and the test criteria
because of different interpretations of construction Code requirements.
Such issues should be brought to the attention of the Nuclear Reactor
Regulation (NRR) project manager (PM) and NMSS/SFST as soon as they are
identified, for timely resolution.

c\. [Inspection Requirement 02.03]{.underline}. A licensee may use the
preoperational test program to validate through trial use the proposed
operating procedures. Consequently, the procedures may not have received
a final approval before the inspectors' review. In that case, the
inspectors should ensure that the licensee has performed an initial
review, which may include the plant operations review committee (or
similar entity), and that performance of these "draft" procedures is
subsumed under the overall ISFSI preoperational testing process.
However, this overall process and associated documents should have been
reviewed and approved by the licensee's administrative processes. The
list of activities contained in Section 02.03 should be viewed as
typical, but not all inclusive. Further, not all tasks are equally
significant; for example, activities that affect containment boundaries,
seal integrity, or long-term heat removal capabilities have greater
potential safety impact and warrant a higher level of attention by the
inspectors.

Responsibilities should be clearly defined. Instructions should be
provided if licensee personnel cannot perform the steps as written and
stop-work criteria and contingency plans should be established to place
the DCSS in a safe configuration. Determine if the licensee has
established guidelines for how long a cask or canister may remain
suspended in mid-air from a crane and has identified any required
compensatory measures. Dry runs of cask or canister movements should
simulate the maximum expected weight, including water, as closely as
possible. Hold and inspection points should be clearly identified.
Procedures should also state whom to notify if an abnormal or emergency
condition arises and what criteria must be met to resume activity.
Alternatively, the licensee's problem identification and corrective
action systems may be referenced for those actions. Particular attention
should be paid to procedures for venting and sampling loaded DCSSs,
recognizing and responding to damaged fuel, and refilling the loaded
cask or canister with water, as problems have been observed in these
areas. Problem areas can include radiation exposure when sampling the
container or steam flashing and pressure control difficulties while
backfilling the cask or canister with water. Guidance for operator
actions and radiological controls in response to damaged fuel should be
included. As a minimum, the unloading procedure should contain steps to
identify the presence of fuel damage in excess of that assumed by the
procedure and direct initial operator response to this event.
Supplemental guidance on inspecting licensee procedures can be found in
IP 42700.

When performing Section 02.01, make note of any operational commitments
contained in documents (e.g., the SAR, SER, CoC, and, if applicable, the
specific license and TS for the DCSS being used and any 10 CFR 50.59, 10
CFR 72.48 and 10 CFR 72.212(b) evaluations) that should be captured in
the ISFSI operating procedures and verify that they have been
incorporated in the applicable procedures.

d\. [Inspection Requirement 02.04]{.underline}. Inspectors may choose to
review training records, training curricula, and available training aids
to support staff interviews. Workers should be able to readily discuss
their responsibilities and demonstrate an understanding of the critical
knowledge and skills required to perform their assigned tasks.
Supplemental guidance on inspecting training can be found in IP 41500.
For a specific license, additional requirements are contained in 10 CFR
72.192 and the cask CoC.

Pre-job briefings should be thorough and discuss hold and inspection
points, expected radiological hazards and controls, and worker actions
if an unexpected response is encountered during preoperational testing.
Continuance of testing during shift turnovers should be addressed.
Delineation of responsibilities should be clear to all licensee staff
performing preoperational test activities.

e\. [Inspection Requirement 02.05]{.underline}. Operation of an ISFSI,
whether under a specific or general license, requires a licensee to
assess the ISFSI's affects on all aspects of plant operations. This
evaluation is performed under 10 CFR 50.59. Inspection of these safety
evaluations may be done through a review of selected 10 CFR 50.59 and
72.48 evaluations. Inspection guidance for inspecting 10 CFR 50.59
evaluations may be found in IP 71111.02 and in IP 60857 for 10 CFR 72.48
evaluations.

Special attention should be paid to testing and inspecting cranes and
rigging and lifting equipment, to verify that they can support the
anticipated loads, without compromising the licensing basis margins of
safety and are compatible with the DCSS components. This should also
include reviews of heavy load paths, crane single failure issues, and
maximum DCSS weight versus crane capacity limits. Any impact on
transient radiation sources (such as high integrity containers in the
load path) should be evaluated by the licensee. See the references for
supplemental information.

The inspectors should directly observe that sufficient space in the SFP
and in laydown areas has been prepared and set aside to conduct both
preoperational testing and the operational transfer and transport of
DCSS components. Reinforcement of the roadway from the fuel or reactor
buildings to the ISFSI site should also be considered.

f\. [Inspection Requirement 02.06]{.underline}. Additional guidance for
the review of licensee procedures may be found in IP 42700. Procedures
should have been formally reviewed and approved consistent with the
licensee's administrative programs, including any reviews required by
the plant operations review committee (or similar entity). When
performing Section 02.01, make note of any operational commitments
contained in documents (e.g., the SAR, SER, CoC, and, if applicable, the
specific license and TS for the DCSS being used and any 10 CFR 72.48 and
10 CFR 72.212(b) evaluations) that should be captured in the ISFSI
operating procedures and verify that they have been incorporated in the
applicable procedures.

The CoC or site-specific license and TS typically include requirements
that the Zircaloy cladding of spent fuel loaded into the DCSS contain no
known or suspected gross cladding failures. A licensee should establish
written procedures to address this issue. These procedures should define
the inspection process and specific acceptance criteria.

Supplemental guidance may also be found in the inspection procedures
used for evaluating these program areas in the Inspection Manual Chapter
(IMC) 2515 program. Supplemental guidance on the quality classification
of DCSS components may be found in the references. Further questions
should be referred to NMSS/SFST for assistance.

1\. Procedures should include normal, abnormal, and emergency
conditions. They may include guidance on contingency plans for placing
the DCSS in a safe configuration during an emergency or abnormal
condition.

2\. No specific guidance.

3\. For control of heavy loads, the program should be examined closely
to determine whether the licensee has properly evaluated, through the
use of 10 CFR 50.59, the impact of lifting loaded DCSSs against the
operating reactor facility. Areas where problems have arisen include
heavy load pathways, single-failure-proof cranes, and loaded casks or
canisters exceeding crane capacity limits. Supplemental guidance may be
found in the references.

4\. Requirements for radiation protection program activities may be
found in 10 CFR 72.104, 72.106, 72.126, and 72.212, in addition to 10
CFR Part 20.

5\. Security and safeguards inspections are conducted under IP 81001.

6\. No specific guidance.

7\. No specific guidance.

8\. Surveillance requirements may be found in the CoC or site-specific
license and TS.

9\. The fire protection program should consider the impact of transient
combustible loading on the ISFSI (e.g., fuel oil for multiple cranes).

10\. For training programs, a systems-based approach should be used that
identifies required knowledge and skills, provides the training, and
examines the individual to ensure he/she understands the training. For a
site-specific license, additional requirements are specified in 10 CFR
72.192. Supplemental guidance may also be found in IP 41500.

11\. No specific guidance.

12\. Supplemental guidance may be found in applicable IMC 2515 IPs.

13\. No specific guidance.

g\. [Inspection Requirement 02.07]{.underline}. Inspectors should review
QA audit and surveillance plans and interview auditors to assess the QA
department's plans for evaluating the preoperational testing. Hold
points should be clearly marked in preoperational test procedures.
Completed audits and surveillances should be reviewed after the testing
to assess their depth and thoroughness. Inspectors may supplement these
activities with reviews of completed audits of ISFSI construction and
fabrication activities.

Corrective actions for identified deficiencies should be completed in a
timely manner and dispositioned in accordance with the licensee's
programs. Corrective actions should be resolved before the
preoperational testing program is completed.

h\. [Inspection Requirement 02.08]{.underline}. Verify that the licensee
has implemented the site radiological protection program for activities
related to dry cask storage. Special consideration should include
contamination controls, minimizing workers time near the cask, use of
temporary shielding, such as during welding, pre-job briefings,
continuous coverage by radiation protection (RP) personnel, and special
considerations for neutron surveys and dosimetry. Verify that the
licensee has adequately addressed the change in the neutron energy
spectrum that will be encountered around the cask after the water has
been drained and has provided workers with personnel dosimeters and
alarming dosimeters that compensate for the higher neutron energy.
During preoperational testing and dry runs the inspectors should observe
the implementation of RP activities and the licensee's readiness to deal
with actual radiation hazards.

i\. [Inspection Requirement 02.09]{.underline}. The intent of this
section is not to re-perform procedure reviews accomplished by Sections
02.03 and 02.06, unless the licensee used the preoperational testing
program as a means of validating "draft" operating procedures during
performance of the dry run. In that case, the inspectors should review
the operating procedures after the licensee has incorporated any
comments and improvements and approved the procedures for use. See also
the guidance for Sections 03.02.c and f.

j\. [Inspection Requirement 02.10]{.underline}. No specific guidance.

k\. [Inspection Requirement 02.11]{.underline}. No specific guidance.

60854-04 INSPECTION RESOURCES

Generally, to prepare for these inspections each inspector should spend
approximately 16 hours for in-office review. Inspection activities will
require approximately 40 hours, each, by three inspectors. Documentation
is estimated to require 16 hours per inspector. It is expected that
regional inspection personnel will perform this procedure, with
assistance from NMSS and NRR staff, as requested. Actual budgeted
resources for each inspection will vary as defined in the individual IP
developed for each site.

60854-05 REFERENCES

ANSI/N14.6-1993, "For Radioactive Materials - Special Lifting Devices
for Shipping Containers Weighing 10,000 Pounds (4500 kg) or More."

NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants," July 1980.
Licensee implementation of this NUREG may vary and specific commitments
to this guidance are covered by responses to NRC Generic Letters 80-113
and 85‑11.

END

ATTACHMENT 1

[Revision History for IP 60854]{.underline}

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| Comm   | Issue  | Description of Change  | Tr  | Tra   | Comment     |
| itment | Date   |                        | ain | ining | Resolution  |
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| acking |        |                        | Nee | etion | Number      |
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| N/A    | 01     | This document has been |     |       |             |
|        | /16/08 | revised to change SFPO |     |       |             |
|        |        | to SFST and some minor |     |       |             |
|        | CN     | editorial changes. No  |     |       |             |
|        | 08-003 | other changes were     |     |       |             |
|        |        | proposed by            |     |       |             |
|        |        | 10/24/2007.            |     |       |             |
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