Issue Date: 01/16/08 1 60851 

NRC INSPECTION MANUAL NMSS/SFST

INSPECTION PROCEDURE 60851 

DESIGN CONTROL OF ISFSI COMPONENTS 

PROGRAM APPLICABILITY: 2690 

60851-01 INSPECTION OBJECTIVES 

01.01 To determine whether the design control program described in a licensee’s or 

certificate of compliance (CoC) holder=s quality assurance program (QAP) is effectively 

implemented. 

01.02 To determine whether design changes implemented by the licensee or CoC holder 

have been properly evaluated for their impact on the functionality of dry cask storage 

system (DCSS) components used in an independent spent fuel storage installation (ISFSI). 

01.03 To determine whether these design changes have been evaluated to ensure that 

the change does not: 

 a. Require a change to the conditions in the license or the CoC; 

 b. Require prior U.S. Nuclear Regulatory Commission (NRC) approval; 

 c. Create a significant increase in occupational exposure; or 

 d. Have a significant unreviewed environmental impact. 

60851-02 INSPECTION REQUIREMENTS 

02.01 Determine whether the licensee’s or CoC holder=s QAP implementing procedures 

are in place and used effectively. 

02.02 Determine whether: 

 a. A method exists to ensure that design changes initiated by the vendor or CoC 

holder are communicated to the licensee; 

 b. The licensee was notified of the design changes in a timely manner to minimize 

production or operations impacts; and 

 c. The licensee has reviewed and/or approved these design changes that were 

approved by the vendor or CoC holder. 
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02.03 Determine whether any nonconforming conditions, which were resolved by design 

changes, have been reviewed and approved by the licensee or CoC holder (if authorized 

by the CoC). 

02.04 Determine whether all nonconforming conditions identified before completion of 

fabrication were appropriately resolved before the DCSS components affected were 

released to the licensee. 

02.05 Determine whether the licensee, vendor, and fabricator personnel have established 

an effective method for tracking, evaluating, and dispositioning changes or modifications to 

the DCSS component design. 

02.06 For selected design changes, determine whether the applicable documentation is 

complete and accurate, including relevant 10 CFR 50.59 or 72.48 evaluations. 

60851-03 INSPECTION GUIDANCE 

03.01 Definitions.

 a. Participants. The terms Alicensee,@ Avendor,@ ACoC holder,@ Afabricator,@ Ageneral 

licensee,@ and Asite-specific licensee@ are terms the inspectors will commonly 

encounter while reviewing ISFSI activities. Refer to Inspection Manual Chapter 

(IMC) 2690, AInspection Program for Dry Storage of Spent Reactor Fuel at 

Independent Spent Fuel Storage Installations,@ Section 03, for definitions of these 

terms. 

 b. Safety Classification. ISFSI systems, structures, and components (SSCs) are 

classified as either Aimportant to safety@ or Anot important to safety@ by the ISFSI 

designer. 

 If Aimportant to safety,@ the SSC will typically either: 

 1. Maintain the functions or conditions (i.e., confinement, criticality, shielding, 

and heat removal) necessary to store spent fuel safely; 

 2. Prevent significant damage to the spent fuel container (DCSS) during 

handling and storage; or 

 3. Provide reasonable assurance that spent fuel can be received, handled, 

packaged, stored, and retrieved without undue risk to public health and 

safety. 

 If an SSC does not perform any of the preceding functions, it may be classified as 

Anot important to safety.@

03.02 General Guidance.

 a. Additional Assistance. The inspectors may obtain additional assistance for both 
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technical and design questions from the cognizant Spent Fuel Storage and 

Transportation (SFST) project manager (PM). For questions involving ISFSI 

operations and how the ISFSI design can affect overall site operations, contact the 

SFST PM who may request Nuclear Reactor Regulation (NRR) assistance if 

needed. Note that additional guidance for review of ISFSI storage pad designs is 

located in Appendix A of inspection procedure (IP) 60856, AReview of 10 CFR 

72.212(b) Evaluations.@

 b. ISFSI SSCs Safety Classification. Before performing an inspection of ISFSI SSCs, 

the inspectors should review the licensee=s design basis documents to determine 

whether the licensee has applied an appropriate safety classification to a particular 

SSC. Note that site-specific variations in ISFSI designs may affect the safety 

classification of some SSCs. 

 c. ISFSI SSCs Not Important to Safety. For this class of SSCs, the licensee=s use of 

generally accepted commercial-grade standards, practices, and materials in 

design, fabrication, and construction activities is acceptable. However, these SSCs 

must still conform to the design requirements described in the safety analysis report 

(SAR) and supporting engineering documents. 

 d. Design Changes. Each DCSS design has been approved by the NRC through the 

licensing process, for a site-specific license, or the 10 CFR Part 72, Subpart L, 

process for a general license. All changes to the design described in the SAR must 

be approved by the licensee or CoC holder. Approval authority for changes can be 

difficult for the inspectors to determine. In such cases, the inspectors can find 

additional guidance in IMC 2690, Section 05.09. 

 e. Component Functionality. Functionality is the ability of a component to meet its 

design requirements. Some components may have multiple design requirements 

and several functions. These requirements and functions are defined in the SAR, 

safety evaluation report (SER), and, as applicable, the CoC or the site-specific 

license and technical specifications (TS) for the DCSS. For example, the cask 

support basket that separates the individual fuel bundles serves several functions: 

structural integrity, criticality control, heat transfer, and radiation shielding. 

Assistance in identifying the function(s) of a given component may be obtained 

from SFST. 

 f. Document Review. Before any onsite inspection activity, for each DCSS in use, 

review (as applicable) the: 

 1. SAR and corresponding NRC SER; 

 2. CoC; 

 3. Site-specific license and TS; and 

 4. 10 CFR 72.48 evaluations performed since the last update to the DCSS SAR. 

 SARs and SERs describing DCSS components have been written for each type of 
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approved DCSS. Information on operational commitments for a particular DCSS 

may also be found in the CoC or the site-specific license and TS. As DCSS 

designs vary, be careful to review the appropriate documentation. The inspectors 

can obtain copies of these documents from the appropriate regional division or 

cognizant SFST PM. 

03.03 Specific Guidance.

(Note: The following inspection activities should be performed at the ISFSI location; 

however, document reviews may be performed elsewhere as conditions require.) 

a. Inspection Requirement 02.01. The licensee’s or CoC holder=s QAP should have 

been previously reviewed and approved by the NRC. Verify that design control and 

related activities (e.g., document control, special processes, or resolution of 

nonconforming conditions) are conducted under an approved QAP. Review 

completed audits and fabrication records, interview selected personnel, and/or 

review procedures. Review any related licensee quality assurance (QA) audits or 

SFST inspections regarding DCSS design changes and determine whether 

corrective actions for the audit or inspection findings have been effectively 

implemented. 

b. Inspection Requirement 02.02. If the licensee has imposed requirements on the 

vendor or CoC holder to notify it of any design changes initiated by the vendor or 

CoC holder, determine whether the vendor or CoC holder is complying with these 

requirements. Review QA audits of the vendor=s or CoC holder=s activities in this 

area. 

c. Inspection Requirement 02.03. No specific guidance. 

d. Inspection Requirement 02.04. Determine whether there is a process in place 

under the QAP to keep track of design changes. Assess the adequacy of design 

interface activities, communications, evaluations and safety screenings, and 

documentation of changes. 

e. Inspection Requirement 02.05. Determine, through review of records, inspection of 

equipment and components, and/or interviews with selected personnel, whether the 

licensee or CoC holder has performed design changes and modifications. Evaluate 

the quality and timeliness of such documentation. Assess the thoroughness of 

documentation and the independence of reviews, particularly for those design 

changes that resolve nonconformances and field change requests. Check that 

evaluations contain a discussion of the effect on component functionality. The 

inspectors can find information on component functionality in the SAR, SER, CoC, 

or, as applicable, the site-specific license and TS. 

 Determine the adequacy of the timing of design change reviews. Ideally the 

licensee or CoC holder should complete the reviews before the component is 

fabricated. However, if the licensee elects to proceed with fabrication Aat risk,@

verify that the licensee does not use the DCSS until all design changes have been 

evaluated and appropriately dispositioned. 
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f. Inspection Requirement 02.06. Design-basis accidents, such as a DCSS tipover or 

a drop from a maximum specified height, are addressed in the SAR; however, the 

inspectors may obtain assistance from the cognizant SFST PM in determining 

whether a change requires NRC approval for a particular DCSS design. 

60851-04 INSPECTION RESOURCES 

To prepare for these inspections each inspector should spend approximately 32 hours on 

in-office review. Inspection activities will require approximately 40 hours, each, by three 

inspectors. Inspections may take place at the licensee’s or CoC holder=s facilities. 

Documentation is estimated to require 32 hours for each inspector. SFST vendor 

inspection staff is expected to have the lead in inspecting CoC holders, and any associated 

vendors or fabricators, with assistance from regional inspection staff. Regional inspection 

staff is expected to have the lead in inspecting licensees, with assistance from SFST. 

60851-05 REFERENCES 

NUREG-1536, AStandard Review Plan for Dry Cask Storage Systems,@ January 1997. 

NUREG-1567, AStandard Review Plan for Spent Fuel Dry Storage Facilities,@ March 2000. 

NUREG/CR-6407, “Classification of Transportation Packaging and Dry Spent Fuel Storage 

System Components According to Importance to Safety,” February 1996. 

NRC Information Notice 95-29, AOversight of Design and Fabrication Activities for Metal 

Components Used in Spent Fuel Dry Storage Systems,@ June 7, 1995. 

NRC Inspection Manual Chapter 2690, AInspection Program for Dry Storage of Spent 

Reactor Fuel at Independent Spent Fuel Storage Installations,@ May 3, 2007. 

NRC Inspection Procedure 60856, AReview of 10 CFR 72.212(b) Evaluations,@ November 

1999. 

10 CFR 50.59, AChanges, tests, and experiments.@

10 CFR 72.48, AChanges, tests, and experiments.@

END 
Issue Date: 01/16/08 Att1-1 

ATTACHMENT 1 

Revision History for IP 60851

Commitment Tracking Number 

Issue Date Description of Change Training Needed Training Completion Date Co

Ac

N/A 01/16/08 CN 08-003 

This document has been revised to change SFPO to SFST and some minor editorial changes. No other changes were proposed by 10/17/2007.

No N/A N/A