Standard Review Plan for 

Renewal of Spent Fuel 

Dry Cask Storage System 

Licenses and Certificates of 

Compliance 

Final Report 

Office of Nuclear Material Safety and Safeguards 

NUREG-1927
Standard Review Plan for 

Renewal of Spent Fuel 

Dry Cask Storage System 

Licenses and Certificates of 

Compliance 

Final Report 

Manuscript Completed: March 2011 

Date Published: March 2011 

Office of Nuclear Material Safety and Safeguards 

NUREG-1927 
ii 
iii 

ABSTRACT 

This Standard Review Plan is intended for use by the U.S. Nuclear Regulatory Commission 

(NRC) reviewer. It provides guidance for the safety review of license (specific or general) and 

certificate of compliance (CoC) renewal applications submitted by licensees and holders of 

CoCs for dry cask storage systems (DCSSs), respectively, as codified in Title 10 of the Code of 

Federal Regulations (10 CFR) Part 72, “Licensing Requirements for the Independent Storage of 

Spent Nuclear Fuel and High-Level Radioactive Waste, and Reactor-Related Greater Than 

Class C Waste.” A license authorizes a licensee to store spent fuel in an NRC-approved DCSS 

at a site under the requirements of 10 CFR Part 72. To renew a specific license, an applicant 

must submit a license renewal application at least 2 years before the expiration of the license in 

accordance with the requirements of 10 CFR 72.42(b). To renew a general license, the general 

licensee or the CoC holder must submit a renewal application at least 30 days before the 

expiration of the associated CoC in accordance with the requirements of 10 CFR 72.240(b). 

The NRC may renew a specific license or a general license for a term not to exceed 40 years, in 

accordance with 10 CFR 72.42(a) or 10 CFR 72.212(a)(3), respectively. 

The NRC may revise and update this Standard Review Plan to clarify the content, correct 

errors, or incorporate modifications approved by the Division of Spent Fuel Storage and 

Transportation. Comments, suggestions for improvement, and notices of errors or omissions 

should be sent to the Director, Division of Spent Fuel Storage and Transportation, U.S. Nuclear 

Regulatory Commission, Washington, DC 20555-0001. 

Paperwork Reduction Act Statement 

This NUREG contains information collection requirements that are subject to the Paperwork 

Reduction Act of 1995 (44 U.S.C. 3501 et seq.). The Office of Management and Budget (OMB) 

approved these information collections under OMB control number 3150-0132. 

Public Protection Notification 

The NRC may not conduct or sponsor, and a person is not required to respond to, a request for 

information or an information collection requirement unless the requesting document displays a 

currently valid OMB control number. 

 
iv 

 
v 

CONTENTS 

ABSTRACT ............................................................................................................................ iii 

ABBREVIATIONS ................................................................................................................. vii 

DEFINITIONS ........................................................................................................................ix 

INTRODUCTION ................................................................................................................... 1 

1. GENERAL INFORMATION REVIEW .......................................................................... 5 

1.1 Review Objective ............................................................................................ 5 

1.2 Areas of Review ............................................................................................. 5 

1.3 Regulatory Requirements ............................................................................... 5 

1.4 Review Guidance ........................................................................................... 6 

1.4.1 Specific Licensee/Certificate of Compliance Holder Information ........ 6 

1.4.2 Specific Financial Information ............................................................. 6 

1.4.3 Specific Environmental Report ........................................................... 6 

1.4.4 Application Content ............................................................................. 7 

1.5 Evaluation Findings ........................................................................................ 8 

2. SCOPING EVALUATION ........................................................................................... 9 

2.1 Review Objective ............................................................................................ 9 

2.2 Areas of Review ............................................................................................. 9 

2.3 Regulatory Requirements ............................................................................... 9 

2.4 Review Guidance ......................................................................................... 10 

2.4.1 Scoping Process ............................................................................... 10 

2.4.2 Structures, Systems and Components Within the Scope of License 

Renewal ............................................................................................ 12 

2.4.3 Structures, Systems, and Components Not Within the Scope of 

 License Renewal .............................................................................. 13 

2.5 Evaluation Findings ...................................................................................... 13 

3. AGING MANAGEMENT REVIEW ............................................................................ 15 

3.1 Review Objective .......................................................................................... 15 

3.2 Areas of Review ........................................................................................... 15 

3.3 Regulatory Requirements ............................................................................. 18 

3.4 Materials, Service Environment, Aging Effects, and Aging .......................... 19 

Management Activities ................................................................................. 19 

 3.4.1 Identification of Materials and Environment ...................................... 19 

 3.4.2 Identification of Aging Effects ........................................................... 19 

 3.4.3 Aging Management Activity .............................................................. 19 

 3.4.4 Evaluation Findings .......................................................................... 20 

3.5 Time-Limited Aging Management Analysis Evaluation ................................ 22 

 3.5.1 Review Guidance .............................................................................. 22 

 3.5.2 Evaluation Findings .......................................................................... 23 

3.6 Aging Management Program ....................................................................... 23 

 3.6.1 Review Guidance .............................................................................. 23
vi 

 3.6.1.1 Aging Effects Subject to Aging Management ............ 24 

3.6.1.2 Prevention, Mitigation, Condition Monitoring, and 

Performance Monitoring Programs ........................... 24 

 3.6.1.3 Corrective Actions ..................................................... 25 

 3.6.1.4 Component-Specific Guidance ................................. 25 

 3.6.2 Evaluation Findings .......................................................................... 25 

3.7 Retrievability ................................................................................................. 26 

 3.7.1 Review Guidance .............................................................................. 26 

3.7.2 Evaluation Findings .......................................................................... 26 

 

APPENDIX A NONQUANTIFIABLE TERMS (NONMANDATORY) ........................A-1 

APPENDIX B EXAMPLE OF INDEPENDENT SPENT FUEL STORAGE 

INSTALLATION MATERIALS AND COMPONENTS ......................B-1 

APPENDIX C EXAMPLE OF AGING MANAGEMENT REVIEW RESULTS ......... C-1 

APPENDIX D AGING EFFECTS TABLE .............................................................. D-1 

APPENDIX E COMPONENT-SPECIFIC AGING MANAGEMENT ........................E-1 

LIST OF FIGURES

Figure A Chart of License Renewal Process ................................................................ 2 

Figure 2-1 Flowchart of Scoping Evaluation .................................................................. 11 

Figure 3-1 Flowchart of AMR Process ........................................................................... 16 

LIST OF TABLES 

Table 1-1 Relationship of Regulations and General Information Review ....................... 5 

Table 2-1 Relationship of Regulations and Scoping Review .......................................... 9 

Table 3-1 Relationship of Regulations and AMR .......................................................... 18 

Table A-1 Screening Criteria for Nonquantifiable Terms . ............................................A-3 

Table B-1 Example of Materials and Components of Cask System ............................B-3 

Table C-1 AMR Results for the HSM .......................................................................... C-3 

Table D-1 Aging Effects and Possible Mechanisms ................................................... D-3 
vii 

ABBREVIATIONS 

AMA Aging Management Activity 

AMP Aging Management Program 

AMR Aging Management Review 

ASME American Society of Mechanical Engineers 

ASTM American Society for Testing and Materials 

CC Criticality Control 

CFR Code of Federal Regulations

CoC Certificate of Compliance 

DCSS Dry Cask Storage System 

DSC Dry Storage Canister and/or Dry Shielded Canister 

ER Environmental Report 

F Fahrenheit 

FSAR Final Safety Analysis Report 

GTCC greater-than-Class-C 

HSM Horizontal Storage Module 

HT heat transfer 

ISFSI Independent Spent Fuel Storage Installation 

ISG Interim Staff Guidance 

ksi kilo-pounds per square inch 

N/A Not Applicable 

NRC U.S. Nuclear Regulatory Commission 

OMB Office of Management and Budget 

PB pressure boundary 

PM NRC Project Manager 
viii 

psig pounds per square inch, gauge 

PVC polyvinyl chloride 

RS radiation shielding 

SAR Safety Analysis Report 

SER Safety Evaluation Report 

SRP Standard Review Plan 

SS Structural Support 

SSC Structure, System, and Component 

SST Stainless Steel 

TLAA Time-Limited Aging Analysis 

UFSAR Updated Final Safety Analysis Report 
ix 

DEFINITIONS 

Accident condition: The extreme level of an event or condition, which has a specified 

resistance, limit of response, and requirement for a given level of continuing capability, which 

exceeds off-normal events or conditions. Accident conditions include both design-basis 

accidents and conditions caused by natural phenomena. 

Aging management activity (AMA): An application of either the aging management program 

(AMP) or time-limited aging analysis (TLAA) to provide reasonable assurance that the intended 

functions of structures, systems, and components (SSCs) of independent spent fuel storage 

installations (ISFSIs) are maintained during the license period of extended operation. 

Aging management program (AMP): A program conducted by the licensee or CoC holder for 

addressing aging effects that may include prevention, mitigation, condition monitoring, and 

performance monitoring. 

Aging management review (AMR): An assessment conducted by the licensee or CoC holder 

that addresses aging effects that could adversely affect the ability of SSCs to perform their 

intended important-to-safety functions during the license period of extended operation. 

Canister (in a dry cask storage system for spent nuclear fuel): A metal cylinder that is sealed at 

both ends and may be used to perform the function of confinement. Typically, a separate 

overpack or horizontal storage module (HSM) performs the radiological shielding and physical 

protection function. 

Cask (in a dry cask storage system for spent nuclear fuel): A passive stand-alone component 

that performs the functions of confinement, radiological shielding, decay heat removal, and 

physical protection of spent fuel during normal, off-normal, and accident conditions. 

Certificate of compliance (CoC) (in a dry cask storage system for spent nuclear fuel): The 

certificate issued by the U.S. Nuclear Regulatory Commission (NRC), that approves the design 

of a spent fuel storage cask, in accordance with the provisions of Title 10 of the Code of Federal 

Regulations (10 CFR) Part 72, “Licensing Requirements for the Independent Storage of Spent 

Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater than Class C 

Waste,” Subpart L, “Approval of Spent Fuel Storage Casks.” 

Certificate holder (CoC holder): A person who has been issued a certificate of compliance 

(CoC) by the NRC for a spent fuel storage cask design. 

Confinement (in a dry cask storage system for spent nuclear fuel): The ability to limit or prevent 

the release of radioactive substances into the environment. 

Confinement systems: Those systems, including ventilation, that act as barriers between areas 

containing radioactive substances and the environment. 

Controlled area: The area immediately surrounding an ISFSI for which the licensee exercises 

authority over its use and within which it performs ISFSI operations. 

Criticality: The condition wherein a system or medium is capable of sustaining a nuclear chain 

reaction. 
x 

Degradation: Any change in the properties of a material that adversely affects the behavior of 

that material; adverse alteration. 

Design basis: Information that identifies the specific function(s) to be performed by SSCs and 

the specific values chosen for controlling parameters as reference bounds for design. These 

values may be (1) restraints, derived from generally accepted “state-of-the-art” practices for 

achieving functional goals, or (2) requirements, derived from analysis (based on calculation, 

experiments, or both) of the effects of a postulated accident, for which SSCs must meet their 

functional goals. 

Dry cask storage system (DCSS): Any system that uses a cask or canister as a component in 

which to store spent nuclear fuel without using water to remove decay heat. A DCSS provides 

confinement, radiological shielding, physical protection, and inherently passive cooling of its 

spent nuclear fuel during normal, off-normal, and accident conditions. 

Dry storage: The storage of spent nuclear fuel in an inert atmosphere after removal of the water 

in the DCSS cavity. 

General license: Authorizes a nuclear power plant licensed under 10 CFR Part 50, “Domestic 

Licensing of Production and Utilization Facilities,” or 10 CFR Part 52, “Licenses, Certifications, 

and Approvals for Nuclear Power Plants,” to store spent nuclear fuel in an ISFSI at a power 

reactor site. The general license is limited to the spent fuel that the general licensee is 

authorized to possess at the site under the specific license for the site, and to the storage of 

spent fuel in NRC-approved casks or canisters. 

Horizontal storage module (HSM): A reinforced, heavy-walled concrete structure designed to 

store dry spent fuel canisters in a horizontal position at an ISFSI. The HSM provides physical 

and radiological protection for canisters, while allowing passive cooling by natural convection. 

Independent spent fuel storage installation (ISFSI): A complex designed and constructed for 

the interim storage of spent nuclear fuel, solid reactor-related greater-than-Class-C (GTCC) 

waste, and other radioactive materials associated with spent fuel and reactor-related GTCC 

waste storage. 

Licensing basis: The collection of documents or technical criteria that provides the basis for the 

NRC to issue a license to receive, possess, use, transfer, or dispose of source material, 

byproduct material, or special nuclear material. 

Monitoring: Inspection, testing, and/or data collection to determine the status of a DCSS, ISFSI, 

or both, and to verify the continued efficacy of the system, on the basis of assessment of 

specified parameters, including temperature, radiation, functionality, and characteristics of 

components of the system. 

Normal events or conditions: The maximum level of an event or condition expected to routinely 

occur. 

Off-normal events or conditions: The maximum level of an event that, although not occurring 

regularly, can be expected to occur with moderate frequency and for which there is a 
xi 

corresponding maximum specified resistance, limit of response, or requirement for a given level 

of continuing capability (similar to Design Event II of American National Standards 

Institute/American Nuclear Society 57.9, “Design Criteria for an Independent Spent Fuel 

Storage Installation (Dry Type)”). 

Overpack: An overpack is a heavy-walled concrete right cylinder designed to store spent fuel 

canisters in a vertical position at an ISFSI. The overpack provides physical and radiological 

protection for canisters while allowing passive cooling by natural convection. 

Radiation shielding: Barriers to radiation that are designed to meet the requirements of 

10 CFR 72.104(a), 10 CFR 72.106(b), and 10 CFR 72.128(a)(2). 

Retrievability: The ability to remove spent nuclear fuel from storage. NRC staff guidance on the 

subject of fuel retrievability appears in the latest revision of Interim Staff Guidance 2, “Fuel 

Retrievability,” issued by the Division of Spent Fuel Storage and Transportation. 

Safety analysis report (SAR): The document that a CoC holder, specific licensee, an applicant 

for a CoC, or an applicant for a specific license supplies to the NRC for evaluation. For specific 

ISFSI license renewals, the SAR must contain information required in 10 CFR 72.24, “Contents 

of Application; Technical Information.” For CoC renewals, the SAR must meet the requirements 

of 10 CFR 72.240(b). The SAR provides references and drawings of the DCSS, ISFSI, or both; 

details of construction; materials; and standards to which the device has been designed. 

Safety evaluation report (SER): The document that the NRC publishes at the completion of a 

licensing review. The SER contains all of the findings and conclusions from the licensing 

review. 

Service conditions: Conditions (e.g., time of service, temperatures, environmental conditions, 

radiation, and loading) that a component experiences during storage. 

Specific license: A license for the receipt, handling, storage, and transfer of spent fuel, highlevel radioactive waste, or reactor-related greater than Class C (GTCC) waste that is issued to a 

named person, on an application filed pursuant to regulations in 10 CFR Part 72. 

Spent fuel storage cask: All the structures, systems, and components associated with the 

container in which spent fuel or other radioactive materials associated with spent fuel are stored 

in at an ISFSI. 

Spent nuclear fuel or spent fuel: Fuel that has been withdrawn from a nuclear reactor after 

irradiation, has undergone at least a 1-year decay process since being used as a source of 

energy in a power reactor, and has not been chemically separated into its constituent elements 

by reprocessing. Spent fuel includes the special nuclear material, byproduct material, source 

material, and other radioactive materials associated with fuel assemblies. 

Structures, systems, and components (SSCs) important to safety: Those features of the ISFSI 

and spent fuel storage cask with one of the following functions: 

• to maintain the conditions required to safely store spent fuel, high-level radioactive 

waste, or reactor-related GTCC waste 
xii 

• to prevent damage to the spent fuel, the high-level radioactive waste, or reactor-related 

GTCC waste container during handling and storage 

• to provide reasonable assurance that spent fuel, high-level radioactive waste, or reactorrelated GTCC waste can be received, handled, packaged, stored, and retrieved without 

undue risk to the health and safety of the public 

Time-limited aging analysis (TLAA): A licensee or CoC holder calculation or analysis that has 

all of the following attributes: 

 

• involves SSCs within the scope of license or CoC renewal 

• considers the effects of aging 

• involves time-limited assumptions defined by the current operating term (for example, 

40 years) 

• was determined to be relevant by the licensee or CoC holder in making a safety 

determination 

• involves conclusions or provides the basis for conclusions related to the capability of the 

SSCs to perform their intended functions 

• is contained or incorporated by reference in the licensing basis 

Transfer cask: A shielded enclosure required to transfer the fuel canister between the spent 

fuel handling area and the overpack or module location. 
1 

INTRODUCTION 

This Standard Review Plan (SRP) is intended to provide procedural guidance to the 

U.S. Nuclear Regulatory Commission (NRC) reviewer. It provides guidance for the safety 

review of specific license and certificate of compliance (CoC) renewal applications submitted by 

licensees and holders of CoCs for dry cask storage systems (DCSSs), respectively, as codified 

in Title 10 of the Code of Federal Regulations (10 CFR) Part 72, “Licensing Requirements for 

the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and ReactorRelated Greater than Class C Waste.” A license (site specific or general) authorizes a licensee 

to store spent fuel in an NRC-approved DCSS at a site under the requirements of 

10 CFR Part 72. 

To renew a specific license or a CoC, an applicant must submit a renewal application before the 

expiration of the license or the CoC, in accordance with the requirements of 10 CFR Part 72. 

The NRC may renew a specific license or a CoC for a term not to exceed 40 years. Both the 

license and the CoC renewal applications must contain revised technical requirements and 

operating conditions (fuel storage, surveillance and maintenance, and other requirements) for 

the independent spent fuel storage installation (ISFSI) or DCSS that address aging effects that 

could affect the safe storage of the spent fuel and must specify what the licensee of an ISFSI is 

authorized to store. 

The DCSSs listed in 10 CFR 72.214, “List of Approved Spent Fuel Storage Casks,” are generic 

designs that any 10 CFR Part 72 general licensee may use in accordance with 10 CFR 72.212, 

“Conditions of General License Issued Under § 72.210.” If the CoC holder chooses not to apply 

for the renewal of a particular CoC or is no longer in business, a cask user or user’s 

representative may apply for renewal of the CoC in place of the CoC holder. 

This SRP defines an acceptable method for satisfying the applicable regulatory requirements; it 

is not a regulatory requirement. An applicant may propose for staff to review other means for 

satisfying the appropriate regulatory requirements. However, deviation from this guidance in 

whole or in part may result in an extended staff review schedule. 

The NRC may revise and update this SRP to clarify the content, correct errors, or incorporate 

modifications approved by the Division of Spent Fuel Storage and Transportation. Comments, 

suggestions for improvement, and notices of errors or omissions will be considered by, and 

should be sent to, the Director, Division of Spent Fuel Storage and Transportation, Office of 

Nuclear Material Safety and Safeguards, U.S. Nuclear Regulatory Commission, 

Washington, DC 20555-0001. 

This guidance document is not intended to be used for the review of other 10 CFR Part 72 

renewal applications, such as those for wet storage facilities or monitored retrievable storage 

facilities. 

The renewal technical review is primarily a materials engineering effort. The materials discipline 

should coordinate its review of the renewal application with the structural, health physics, 

thermal, criticality, and quality assurance disciplines, as appropriate, to help ensure that the 

reviewer has addressed all relevant aspects of the application and review. 

Figure A is a flowchart of the license renewal process. 
2 

Figure A Chart of License Renewal Process 

1. Review of Regulatory Requirements 

• Licensee/CoC Holder Information 

• Financial Information 

• Application Content 

• Environmental Report 

2. Scoping Evaluation 

• Scoping Process (2.4.1) 

 Identification of Intended Function of Structures, Systems, 

and Components (SSCs) 

• SSCs within the Scope of License/CoC Renewal (2.4.2) 

 Identification of SSC Subcomponents within Scope 

• SSCs Not within the Scope of License/CoC Renewal (2.4.3) 

3. Aging Management Review 

• Identification of Materials and Environments (3.4.1) 

• Identification of Aging Effects (3.4.2) 

• Aging Management Activity (3.4.3) 

Approach for Addressing the Effects of Aging 

3.5 Time-Limited Aging Analysis (TLAA) 

• Identification of Applicable SSCs 

• TLAA for Extended Operation 

3.6 Aging Management Programs 

• Aging Effects Consideration 

• Prevention, Mitigation, Condition and 

Performance Monitoring 

• Corrective Actions 

3.7 Retrievability 
3 

Standard Review Plan Structure 

Each chapter of this SRP contains the following sections: 

Review Objective: This section provides the purpose and scope of the review and establishes 

the major review objectives for the chapter. It also discusses the information needed, or 

coordination expected, from other NRC reviewers to complete the technical review. 

Areas of Review: This section describes the structures, systems, and components (SSCs); 

analyses, data, or other information; and their sequence in the discussion of acceptance criteria. 

Regulatory Requirements: This section summarizes the regulatory requirements in 

10 CFR Part 72 pertaining to the scoping process, aging management review (AMR), and aging 

management activities (AMA), and includes the time-limited aging analyses (TLAA) review. 

This list is not all-inclusive, since some parts of the regulations, such as 10 CFR Part 20, 

“Standards for Protection Against Radiation,” are assumed to apply to all chapters of the safety 

analysis report (SAR). The reviewer should read the complete language of the current version 

of 10 CFR Part 72 to determine the proper set of regulations for the section being reviewed. 

Review Guidance: This section discusses the specific technical information that should be 

included in the application and reviewed for regulatory compliance. The review guidance can 

be supplemented by interim staff guidance (ISG), NUREGs, etc. 

Evaluation Findings: This section provides sample summary statements for evaluation findings 

to be incorporated into the safety evaluation report (SER) for each area of review. The reviewer 

prepares the evaluation findings based on the satisfaction of the regulatory requirements. The 

NRC publishes the findings in the SER. 
4 

 
5 

1. GENERAL INFORMATION REVIEW 

1.1 Review Objective 

The purpose of the general information review is to ensure that the license or CoC renewal 

application meets the requirements of Section 1.3 below. 

1.2 Areas of Review

Areas of review addressed in this chapter include the following: 

• licensee/CoC holder information 

• financial information 

• application content 

• environmental report 

Areas specifically excluded from the renewal review include the following: 

• SSCs associated with physical protection of the ISFSI or DCSS, pursuant to 

10 CFR Part 72, Subpart H, “Physical Protection” 

• SSCs associated with the ISFSI emergency plan, pursuant to 10 CFR 72.32, 

“Emergency Plan” 

1.3 Regulatory Requirements

The applicant and the NRC reviewer should consult the edition of 10 CFR Part 72 that was in 

effect at the time the license or CoC was issued. Table 1-1 presents a matrix that identifies the 

specific regulatory requirements pertaining to application content, licensee information, financial 

information, and the environmental report (ER). 

Table 1-1 Relationship of Regulations and General Information Review 

Areas of Review 10 CFR Part 72 Regulations1

 72.22 

(a), (b), 

(c), (d) 

72.22 

(e) 

72.34 72.48 72.122 72.240 

(b), (c) 

Application Content ● ●

Licensee 

Information ● 

Financial 

Information ● 

Environmental 

Report 

 ● ● 

1

 The requirements of 10 CFR 72.22, “Contents of Application: General and Financial Information,” and 

10 CFR 72.34, “Environmental Report,” apply only to specific license renewals. The requirements of 

10 CFR 72.240, “Conditions for Spent Fuel Storage Cask Reapproval,” apply only to CoC renewals.
6 

1.4 Review Guidance

The following subsections contain review guidance. Sections 1.4.1 to 1.4.3 below apply to 

specific licensee/CoC holders as indicated. 

1.4.1 Specific Licensee/Certificate of Compliance Holder Information 

The NRC project manager (PM) should ensure that the licensee has provided information 

pursuant to 10 CFR 72.22, including the licensee’s full name, address, and description of the 

business or occupation. If the licensee is a partnership, the application should identify the 

name, citizenship, and address of each partner and the principal location at which the 

partnership does business. If the licensee is a corporation or an unincorporated association, the 

application should specify the State in which it is incorporated or organized and the principal 

location at which it does business, along with the names, addresses, and citizenships of its 

directors and principal officers. If the licensee is acting as an agent or representative of another 

person in filing the application, the application should provide the above information for the 

principal. If the licensee is the U.S. Department of Energy, then the application should specify 

the organization responsible for the construction and operation of the ISFSI and describe any 

delegations of authority and assignments of responsibilities.

1.4.2 Specific Financial Information 

The scope of this SRP does not include specific guidance for reviewing financial information. 

Financial reviews should be coordinated with the Office of Nuclear Reactor Regulation. 

The PM should ensure that the renewal application contains financial data, pursuant to 

10 CFR 72.22(e), which show that the licensee can carry out the activities being sought for the 

requested duration. Information should state where the activity will be performed, the general 

plan for carrying out the activity, and the period of time for which the license is requested. The 

PM should ensure that the renewal application is based on the current licensing basis only and 

does not include additional construction costs beyond the current licensing basis. The 

application should identify other costs related to activities associated with managing aging 

effects, and it should identify ISFSI operating and decommissioning costs that have been 

revised from those specified in the original license application for construction, operation, and 

decommissioning. 

1.4.3 Specific Environmental Report 

The PM should ensure that the license renewal application contains an ER or supplement, as 

required by 10 CFR 51.60, “Environmental Report—Materials Licenses,” and 10 CFR 72.34. 

The supplemental report may be limited to incorporating, by reference, updates or supplements 

to the information previously submitted to reflect any significant environmental changes, 

including those that may result from operating experience as related to environmental 

conditions, a change in operations, or proposed decommissioning activities. If applicable, the 

ER should include operating experience during the initial licensing period, as well as reasonable 

assurance that SSCs that are important to safety performed their intended functions under 

postulated extreme loading events. 
7 

As required by 10 CFR 51.45(c), the ER should contain sufficient data to aid the NRC in its 

development of an independent analysis. 

The technical review of the ER should be coordinated with the Office of Federal and State 

Materials and Environmental Management Programs and, if necessary, the Office of Nuclear 

Reactor Regulation. 

1.4.4 Application Content 

License renewal includes the original CoC and all associated amendments. The associated 

amendments have the same termination date as the original CoC. 

The PM or reviewer should verify that the renewal application contains all of the following 

sections: 

• General Information 

• Scoping Evaluation 

• Aging Management Review 

• Time-Limited Aging Analyses 

• Aging Management Program 

• additional information related to the updated final safety analysis report (UFSAR) and 

changes or additions to technical specifications 

If size reduction of drawings has made any information unclear or illegible, the PM should ask 

the applicant for larger or full-size drawings. Particular attention should be devoted to ensuring 

that dimensions, materials, and other details on the drawings are consistent with those 

described in both the text of the SAR supplement and those used in supplementary analyses. 

All dimensions indicated on drawings should include tolerances that are consistent with the 

evaluation. Tolerances should be required only for dimensions of important-to-safety 

components where the safety analysis uses the dimension, and that safety analysis is sensitive 

to the variance in the dimension permitted by the tolerance. 

If changes have occurred in the design of the SSCs (i.e., through the application of 

10 CFR 72.48, “Changes, Tests, and Experiments”) of the ISFSI or DCSS, then the reviewer 

should verify that the applicant has updated the appropriate drawings to reflect these changes. 

Reviewers should be familiar with NUREG/CR-5502, “Engineering Drawings for 10 CFR Part 71 

Package Approvals,” issued May 1998. Although NUREG/CR-5502 was developed for 

transportation packages, the criteria for drawings may be useful for the review process. 

If the applicant provided drawings and descriptions as proprietary information in the application 

and requested them to be withheld from the public, these sketches, drawings, diagrams, and 

information must be annotated as proprietary, in accordance with the requirements of 

10 CFR 2.390, “Public Inspections, Exemptions, Requests for Withholding.” 
8 

A license or CoC renewal request should not include any changes to the current licensing basis. 

Changes to the licensing basis must be requested through a separate license or CoC 

amendment process. 

1.5 Evaluation Findings 

The reviewer prepares the evaluation findings based on satisfaction of the regulatory 

requirements in Section 1.3. The evaluation findings should be similar in wording to the 

following examples (the finding number is for convenience in cross-referencing within the SRP 

and SER): 

F1.1 The staff finds that the information presented in the renewal application 

satisfies the requirements of 10 CFR 72.2, 72.22, 72.48, and 72.240, as 

applicable. 

F1.2 The staff finds that a tabulation of all supporting information and docketed 

material incorporated by reference has been provided, in compliance with 

10 CFR 72.42 or 10 CFR 72.240, as applicable. 

The reviewer should make a summary statement similar to the following: 

The staff has reviewed the ISFSI or DCSS descriptions presented in Chapter I of 

the SAR and supplemental documentation and finds that there is sufficient detail 

to meet the requirements of 10 CFR Part 72. 

 
9 

2. SCOPING EVALUATION 

2.1 Review Objective 

The scoping process should identify the SSCs of the ISFSI or DCSS that should be reviewed for 

aging effects. 

2.2 Areas of Review 

The reviewer should ensure that the licensee has included information about the following areas 

of review: 

• scoping process 

• SSCs within the scope of license/CoC renewal 

• SSCs not within the scope of license/CoC renewal 

2.3 Regulatory Requirements 

The NRC bases a license or CoC renewal on the continuation of the existing licensing basis 

throughout the period of extended operation and on the maintenance of the intended functions 

of the SSCs important to safety. The NRC does not intend a license or CoC renewal to be a 

vehicle for imposing new regulatory requirements. If new safety-related deficiencies are 

discovered, they must be addressed through the license or CoC amendment process. The 

renewal process cannot be used to facilitate approval of design changes. 

 

Table 2-1 presents a matrix of regulatory requirements for license renewal. 

 

Table 2-1 Relationship of Regulations and Scoping Review 

Areas of Review 10 CFR Part 72 Regulations2

72.3 72.24 

(b), (c), 

(d) 

72.24 

(g) 

72.42 

(b) 

72.120

(a), (d)

72.122 

Applicable 

Sections 

 72.236 

Applicable

Sections

Scoping Process ● ● ●

SSCs within the 

Scope of License/CoC 

Renewal

● ● ● ● ● ●

SSCs Not within the 

Scope of License 

Renewal 

● ● ● ● 

2

 The requirements of 10 CFR 72.24 (“Contents of Application: Technical Information”), 10 CFR 72.42 

(“Duration of License; Renewal”), and 10 CFR 72.120 (“General Considerations”) apply only to specific 

license renewals. The requirements of 10 CFR 72.236 (“Specific Requirements for Spent Fuel Storage 

Cask Approval and Fabrication”) apply only to CoC renewals.
10 

2.4 Review Guidance 

The following subsections contain review guidance. 

Refer to Appendix A for assessing nonquantifiable terms. 

2.4.1 Scoping Process 

Figure 2-1 provides a flowchart of the scoping evaluation process. The reviewer should ensure 

that the application provides documentation of the scoping process (usually performed as a 

scoping study) that includes the following: 

 

• a description of the scoping process and methodology for the inclusion of SSCs in the 

renewal scope 

• a list of the SSCs (and appropriate subcomponents) that are identified as within the 

scope of renewal, their intended function, and safety classification or basis for inclusion 

in the renewal scope (see Appendix B for typical SSC classification) 

• a list of the sources of information used 

• any discussion needed to clarify the process, SSC designations, or sources of 

information used 

Some of the sources that support the scoping process may be provided in the application in 

detail or synopsis form. Sources may include the following: 

• SARs (including final SARs (FSARs), UFSARs, and topical SARs) 

• technical specifications 

• operating procedures 

• regulatory compliance reports, including SERs 

• design-basis documents (e.g., calculations, specifications, design change documents) 

• drawings 

• quality assurance plan or program 

• docketed correspondence 

• operating experience reports 

• 10 CFR 72.48 reviews 

• vendor information 

 

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

System Components According to Importance to Safety,” issued February 1996, contains 

additional guidance describing SSCs that may be included within the scope of license renewal. 

Section 3 defines the classification categories, and Section 6 discusses the classification of 

storage components. Note that the licensing basis for an ISFSI or DCSS may provide for 

classifications of SSCs that differ from those in NUREG/CR-6407. 

 
11 

Is the SSC 

important to 

safety?

Could the failure 

of the SSC “not important 

to safety” impact a 

safety function?

SSC is not 

within the scope of

renewal. 

SSC is 

within the scope of

renewal 

(see Figure 3-1).

Yes

No

No

Yes

Scoping evaluation

process of 

license/CoC renewal

Figure 2-1 Flowchart of Scoping Evaluation 
12 

2.4.2 Structures, Systems, and Components Within the Scope of License Renewal 

The reviewer should verify that the SSCs within the scope of renewal fall into the following 

scoping categories: 

(1) They are classified as important to safety, as they are relied on to do one of the 

following: 

– Maintain the conditions required by the regulations, license, or CoC to store 

spent fuel safely. 

– Prevent damage to the spent fuel during handling and storage. 

– Provide reasonable assurance that spent fuel can be received, handled, 

packaged, stored, and retrieved without undue risk to the health and safety of the 

public. 

These SSCs ensure that important safety functions are met for (1) criticality, 

(2) shielding, (3) confinement, (4) heat transfer, (5) structural integrity, and 

(6) retrievability. 

(2) They are classified as not important to safety but, according to the licensing basis, their 

failure could prevent fulfillment of a function that is important to safety, or their failure as 

support SSCs could prevent fulfillment of a function that is important to safety. 

The in-scope SSCs are further reviewed to identify and describe the subcomponents that 

support the intended function or functions of the SSCs. The intended functions of the 

subcomponents are the specific functions that support the safety functions of the SSCs of which 

they are a part. The intended functions of subcomponents may include the following: 

• providing criticality control of spent fuel 

• providing heat transfer 

• directly or indirectly maintaining a pressure boundary 

• providing radiation shielding 

• providing structural support, functional support, or both, to SSCs that are important to 

safety 

It should be noted that the fuel pellet is not within the scope of renewal. 

Most storage pads are not within the scope of license renewal. Some storage pads are 

classified as important to safety, but they do not perform a safety function, and their failure does 

not impact a safety function. 

Table B-1 in Appendix B provides an example of SSCs that the scoping evaluation may 

consider.
13 

2.4.3 Structures, Systems, and Components Not Within the Scope of License Renewal 

For those SSCs that are not within the scope of renewal, the reviewer should verify that these 

SSCs do not fall into either of the categories shown in Section 2.4.2 above. SSCs that perform 

support or not-important-to-safety functions are generally not within the scope of renewal. 

The following SSCs that are not important to safety may be eliminated from the scope, provided 

that they do not meet scoping Category 2 in Section 2.4.2 above: 

• equipment associated with cask loading and unloading, such as (1) welding and sealing 

equipment, (2) lifting rigs and slings, (3) vacuum-drying equipment, (4) transfer cask and 

transporter devices, (5) portable radiation survey equipment, and (6) other tools, fittings, 

hoses, and gauges associated with cask loading and unloading 

• SSCs associated with physical protection of the ISFSI, pursuant to 10 CFR Part 72, 

Subpart H 

• SSCs associated with the ISFSI emergency plan, pursuant to 10 CFR 72.32 

• miscellaneous hardware that does not support or perform any function that is important 

to safety 

• the ISFSI concrete pad, which is generally not within scope unless the pad provides a 

safety function (e.g., during a seismic event) 

2.5 Evaluation Findings

The reviewer prepares the evaluation findings based on satisfaction of the regulatory 

requirements described in Section 2.3. The evaluation findings should be similar in wording to 

the following examples (the finding number is for convenience in cross-referencing within the 

SRP and SER): 

F2.1 The staff finds that the applicant has identified all SSCs important to 

safety and SSCs the failure of which could prevent a function that is 

important to safety from being fulfilled, per the requirements of 

10 CFR 72.3, 10 CFR 72.24, 10 CFR 72.120, 10 CFR 72.122, and 

10 CFR 72.236, as applicable. 

F2.2 The staff finds that the justification for any SSC determined not to be 

within the scope of the license renewal is reasonable and acceptable. 
14 

 
15 

3. AGING MANAGEMENT REVIEW

3.1 Review Objective

The purpose of the AMR is to assess the SSCs determined to be within the scope of renewal. 

The AMR addresses aging effects that could adversely affect the ability of the SSCs to perform 

their intended functions during the period of extended operation. The reviewer should verify that 

the renewal application includes specific information that clearly describes the AMR performed 

on the in-scope SSCs. 

An ISFSI or DCSS is composed of passive SSCs. The degradation of passive SSCs may not 

be as readily apparent as the degradation of active SSCs. Therefore, to manage the effects of 

aging, an AMR must be conducted to identify adverse effects that could affect SSCs during the 

period of extended operation. 

3.2 Areas of Review 

The AMR in the renewal application should be reviewed in the context of the following areas: 

 

• identification of materials and environments for those SSCs and associated 

subcomponents determined to be within scope 

• identification of aging effects requiring management 

• identification of TLAAs 

• identification of aging management programs (AMPs) for managing the effects of aging 

• retrievability 

Figure 3-1 contains a flowchart for the AMR process. The UFSAR and supporting documents 

related to the design are the primary documents that describe the safety classification, intended 

function, materials, and environmental conditions for SSCs of ISFSIs, DCSSs, or both, identified 

as in scope for renewal. Examples of other documents that are used for the AMR process are 

calculations, specifications, drawings, technical reports, vendor manuals, and procedures. 

Industry reports, reference books, and codes and standards can be consulted, as appropriate, 

to evaluate aging effects. 

 

Appendix C, Table C-1, provides an example of an AMR for a horizontal storage module. 

The reviewer should consult ASTM C 1562, “Standard Guide for Evaluation of Materials Used in 

Extended Service of Interim Spent Nuclear Fuel Dry Storage Systems,” which may provide 

additional technical guidance, such as degradation mechanisms of materials. 
16 

SSCs 

within the scope of

license/CoC renewal.

(2.0) 

Identification of 

materials and 

environments.

(3.4.1)

Determination of the 

AMA required to manage

the effects of aging. 

(3.4.3)

Cont.

on next

page

Is the SSC 

subject to an 

aging effect?

(3.4.2)

Document in

SAR supplement. 

No further 

action necessary.

No

Yes

Identification of SSC 

requiring AMR 

and intended functions.

(2.0) 

Figure 3-1 Flowchart of AMR Process 
17 

Is TLAA 

reconfirmed for the 

period of extended 

operation?

TLAA confirmed and

documented in SAR 

Supplement.

No further action 

necessary. 

Yes

Yes

Yes

No

Is the SSC 

within an 

existing AMP?

(3.6)

Can TLAA 

adequately predict 

degradation associated 

with the identified 

aging effect?

Is the 

identified aging

effect managed by 

the existing AMP 

for the period 

of extended

operation?

No

Aging effect on SSCs

is adequately managed. 

Document in SAR 

supplement. 

No further action necessary.

Action Required:

Modification of 

existing site

AMA or 

introduction of a 

new AMA

to be reviewed

by the NRC and

documented in SAR 

supplement.

TLAA AMP

Yes

No

No

Cont.

from

previous

page

 

Figure 3-1 Flowchart of AMR process (continued) 
18 

3.3 Regulatory Requirements

Table 3-1 presents a matrix of regulatory requirements for license and CoC renewal. Other 

parts of 10 CFR Part 72 may also apply. 

Table 3-1 Relationship of Regulations and AMR 

Areas of Review 10 CFR Part 72 Regulations3

72.24 

(d) 

72.82 

(d) 

72.104 

(a) 

72.106 

(b) 

72.120 

(a),(d) 

Aging Effects ● ● ● ●

Aging Management, Maintenance, 

or Surveillance Programs ● 

TLAAs ● ● ● ●

Retrievability 

Areas of Review 10 CFR Part 72 Regulations3

72.122 

(a),(b),(c),(h)(1),(h)(5),(l)

72.122 

(f),(h)(4),(i) 

72.124 72.128 

(a) 

Aging Effects ● ● 

Aging Management, Maintenance, 

or Surveillance Programs ● ●

TLAAs ● ● ● ●

Retrievability ● 

Areas of Review 10 CFR Part 72 Regulations3

72.162 72.168 

(a) 

72.170 72.172 72.236 

(g),(m) 

72.236 

Applicable 

Sections 

Aging Effects ● ●

Aging Management, Maintenance, 

or Surveillance Programs ● ● ● ● ● ●

TLAAs ● 

Retrievability ● 

3

 The regulations in 10 CFR 72.24, 10 CFR 72.120, and 10 CFR 72.128, “Criteria for Spent Fuel, High-Level 

Radioactive Waste, and Other Radioactive Waste Storage and Handling,” apply only to site-specific license 

renewals. The regulations in 10 CFR 72.236 apply only to CoC renewals. 
19 

3.4 Materials, Service Environment, Aging Effects, and Aging Management 

Activities

3.4.1 Identification of Materials and Environments 

The AMR process includes the identification of the materials of construction and the 

environments to which these materials are exposed. Appendix B provides an example of the 

typical SSC material description(s), operating environment, and intended function an applicant 

should provide. The reviewer should ensure that the renewal applicant has provided 

environmental data that include temperature, wind, relative humidity, exposure to rain or water, 

radiation field, and gaseous environment (e.g., external: air; internal: inert gas such as helium), 

such that the operating and service conditions of the SSCs can be determined. 

3.4.2 Identification of Aging Effects 

The renewal applicant should evaluate potential aging effects, in terms of material and 

environment combinations. The reviewer should ensure that the applicant has provided an 

analysis and documentation that identify all the potential and actual aging effects pertinent to 

the SSCs determined to be within the scope of renewal. The applicant should include aging 

effects that may theoretically occur, as well as aging effects that have actually occurred, based 

on industry and site operating experience(s) and component testing. 

Identification of applicable aging effects may be through review of site maintenance records, 

inspection of an SSC condition at the time of renewal (see Appendix E), maintenance and 

inspection records from ISFSI sites with similar SSC materials and operating environments, 

research review of industry records, or other methods for determining if an aging effect should 

be managed for the period of extended operation. If an SSC is determined to be within scope 

and is found to have no potential aging effects for the period of extended operation, then the 

applicant need not take further action. The reviewer should ensure that the SAR supplement 

documents the SSCs requiring no further review. 

The staff should review any synopses of root cause evaluations, repair or modification history, 

and maintenance activities identified under a corrective action program, including both sitespecific and industrywide experience. This information may indicate repetitive or periodic 

conditions that may require an AMP. Applicants should consider possible mitigating measures 

for one-time events during the period of extended operation and include such measures as part 

of the application. 

3.4.3 Aging Management Activity 

The reviewer should ensure that the applicant has identified those aging effects requiring either 

an AMP or TLAA. Figure 3-1 illustrates the process for handling those SSCs that are 

determined to be within the scope of renewal and subject to a potential aging effect. The AMA 

defines two methods for addressing potential aging effects: TLAA, discussed in Section 3.5; 

and AMP, discussed in Section 3.6. Figure 3-1 provides a flowchart depicting the logic 

sequence. 

Since the DCSS interior and cladding cannot reasonably be inspected, the reviewer relies on 

lessons learned from NUREG/CR-6745, “Dry Cask Storage Characterization Project—Phase 1; 
20 

CASTOR V/21 Cask Opening and Examination,” issued September 2001, and 

NUREG/CR-6831, “Examination of Spent PWR Fuel Rods after 15 Years in Dry Storage,” 

issued September 2003. This research demonstrated that a DCSS interior and low-burnup fuel 

cladding had no deleterious effects after 15 years of storage. This research formed the basis 

for ISG-11, “Cladding Considerations for the Transportation and Storage of Spent Fuel,” 

Revision 3, issued November 2003. ISG-11 limits the temperature and stresses in the cladding. 

These research results suggest that degradation of low-burnup fuel cladding should not occur 

during extended storage, provided that the design-basis internal environment has been 

maintained. 

The staff should assess whether the applicant has considered the most recent revision of 

ISG-11 and research results in this area, especially with respect to high-burnup fuel. Research 

into fuel performance in storage is ongoing. It is expected that the applicants would monitor 

these developments to ensure that they have identified potential degradation effects. There are 

presently no data regarding potential long-term degradation of high-burnup fuel cladding. Thus, 

the applicant should provide any new supporting data demonstrating high-burnup fuel 

performance during extended storage. As an example, should an applicant have the 

opportunity for a DCSS interior and cladding inspection, the licensee should report any 

inspection findings in its evaluations. 

The reviewer should refer to Appendix E for other component specific guidance. 

The NRC may condition the approval of a renewal on the requirements of a given AMA being 

met during the period of extended operation. The DCSS user (not the CoC holder) would 

ordinarily carry out such an AMA. According to 10 CFR 72.212(b)(7) and 10 CFR 72.240, the 

NRC would make the AMA applicable to the general licensee by adding the appropriate 

condition or technical specification requirement to the renewed CoC. Specific licenses may also 

be similarly conditioned.

3.4.4 Evaluation Findings 

The reviewer prepares the evaluation findings based on satisfaction of the regulatory 

requirements in Sections 3.3. The evaluation findings should be similar in wording to the 

following examples (the finding number is for convenience in cross-referencing within the SRP 

and SER): 

F3.1 The staff finds the applicant’s review process to be comprehensive in 

identifying the materials of construction and associated operating 

environmental conditions for those SSCs within the scope of renewal and 

has provided a summary of the information in the application and SAR 

supplement. 

F3.2 The staff finds the applicant’s review process to be comprehensive in 

identifying all potential and actual aging effects on the SSCs within the 

scope of renewal and has provided a summary of the information in the 

application and SAR supplement. 

The reviewer should make a summary statement similar to the following: 
21 

The staff concludes that the information presented in Chapter XX of the SAR 

supplement satisfies the requirements of 10 CFR Part 72. 
22 

 

3.5 Time-Limited Aging Analysis Evaluation

A TLAA is a process to assess SSCs that have a time-dependent operating life. Time 

dependency may be fatigue life (number of cycles to predicted failure) or time limited (number of 

operating hours until replacement). At the end of the identified operating period, the component 

is typically replaced or renewed. Examples of possible TLAAs are (1) fluence level that causes 

embrittlement of metallic components, (2) depletion of neutron absorber material, and 

(3) thermal fatigue of the canister shell. 

The reviewer should ensure that the applicant has provided appropriate analyses of all SSCs 

with a time-dependent operating life and that the applicant has concluded that continued 

operation of the SSC is acceptable for the period of extended operation. 

The reviewer should verify that the applicant has considered future monitoring of the potential 

aging effects analyzed in the TLAAs. If the applicant has recommended future inspection(s) or 

examination(s), then the reviewer should assess the adequacy of these proposed action(s). 

Such proposed actions may need to be included as license conditions for renewals. If there are 

no proposed action(s), the reviewer should determine the adequacy of that approach. 

3.5.1 Review Guidance 

The reviewer should ensure that the applicant has appropriately identified TLAAs by applying 

the five criteria described below for existing or newly identified SSCs with a time-dependent 

operating life: 

(1) The TLAA should involve time-limited assumptions defined by the current operating term 

(e.g., 20 years). The defined operating term should be explicit in the analyses. Simply 

asserting that the SSC is designed for a service life or ISFSI life is not sufficient. 

Calculations, analyses, or testing that explicitly includes a time limit should support the 

assertions. 

 

(2) The TLAA should already be contained or incorporated by reference in the design 

documents. Such documentation includes the (1) SAR, (2) SER, (3) technical 

specifications, (4) correspondence to and from the NRC, (5) quality assurance plan, and 

(6) topical reports included as references in the SAR. 

(3) The TLAA must address SSCs that are within the scope of license renewal and have a 

predetermined lifespan. 

(4) The TLAA must consider the extended operational lifetime of any SSC materials that 

have a defined lifetime limit (e.g., thermal fatigue condition). 

(5) The TLAA should provide conclusions or a basis for conclusions regarding the capability 

of the SSC to perform its intended function through the license period of extended 

operation. The TLAAs must show either one of the following: 

• The analyses have been projected to the end of the period of extended 

operation.
23 

• The effects of aging on the intended function(s) of the SSC will be adequately 

managed for the period of extended operation. Component replacement is an 

acceptable option for managing the TLAA. 

This review will ensure that the licensee has provided a justification and basis for addressing 

each SSC that has a predetermined lifespan and is determined to be within the scope of 

renewal. 

3.5.2 Evaluation Findings

The reviewer prepares the evaluation findings based on satisfaction of the regulatory 

requirements in Section 3.3. The evaluation findings should be similar in wording to the 

following example (the finding number is for convenience in cross-referencing within the SRP 

and SER): 

F3.3 The staff finds that the applicant’s review is comprehensive in identifying 

in-scope SSCs, associated time-limited aging effects, and respective 

analyses. Some analyses were revised by the applicant and found to be 

appropriate as revised. Thus, the staff finds that the applicant’s TLAAs 

provide reasonable assurance that the SSCs will maintain their intended 

function(s) for the term of the period of extended operation, require no 

further action, and meet the requirements for renewal. 

3.6 Aging Management Program

The purpose of the AMP is to ensure that no aging effects result in a loss of intended function of 

the SSCs that are within the scope of renewal, for the term of the renewal. 

 

3.6.1 Review Guidance 

The elements of an AMP or inspection may vary, depending on the specific SSC. However, the 

reviewer should consider the following 10 elements of an AMP, to determine the adequacy and 

applicability of the applicant’s proposed method for managing an aging effect: 

(1) Scope of the program: The scope of the program should include the specific structures 

and components subject to an AMR. 

(2) Preventive actions: Preventive actions should mitigate or prevent the applicable aging 

effects. 

(3) Parameters monitored or inspected: Parameters monitored or inspected should be 

linked to the effects of aging on the intended functions of the particular structure and 

component. 

(4) Detection of aging effects: Detection of aging effects should occur before there is a loss 

of any structure and component intended function. This includes aspects such as 

method or technique (i.e., visual, volumetric, surface inspection), frequency, sample 

size, data collection, and timing of new or one-time inspections to ensure timely 

detection of aging effects. 
24 

(5) Monitoring and trending: Monitoring and trending should provide for prediction of the 

extent of the effects of aging and timely corrective or mitigative actions. 

(6) Acceptance criteria: Acceptance criteria, against which the need for corrective action 

will be evaluated, should ensure that the particular structure and component intended 

functions are maintained under the existing licensing-basis design conditions during the 

period of extended operation. 

(7) Corrective actions: Corrective actions, including root cause determination and 

prevention of recurrence, should be timely. 

(8) Confirmation process: The confirmation process should ensure that preventive actions 

are adequate and appropriate corrective actions have been completed and are effective. 

(9) Administrative controls: Administrative controls should provide a formal review and 

approval process. 

(10) Operating experience: Operating experience involving the AMP, including past 

corrective actions resulting in program enhancements or additional programs, should 

provide objective evidence to support a determination that the effects of aging will be 

adequately managed so that the structure and component intended functions will be 

maintained during the period of extended operation. 

The AMP should be reviewed in the context of the areas described below. 

 

3.6.1.1 Aging Effects Subject to Aging Management 

The reviewer should ensure that the applicant has identified all potential aging effects for all 

SSCs, within the scope of license renewal for the duration of the period of extended operation 

(Section 3.4.2). 

Regardless of the specific aging effects, only aging effects that could result in a loss of an 

SSC’s intended function during the period of extended operation is of principal concern for 

license or CoC renewal. 

Appendix D, Table D-1, lists potential aging effects and possible aging mechanisms that the 

AMP should consider. 

It is important to recognize that implementing confirmatory inspection or monitoring and 

surveillance is essential to resolving conflicting information or indications of the presence of a 

specific potential aging effect or degraded condition. 

3.6.1.2 Prevention, Mitigation, Condition Monitoring, and Performance Monitoring Programs 

The reviewer should ensure the following: 

• Each SSC with an identified aging effect that requires management should have an 

associated AMP. 
25 

• Each AMP can effectively manage or monitor that aging effect, using the elements of an 

adequate AMP, described above in Section 3.6.1. 

AMPs generally are of four types: 

(1) Prevention programs keep the aging effect from occurring (e.g., coating programs to 

prevent external corrosion of a metal canister or cask). 

(2) Mitigation programs attempt to slow the effects of aging (e.g., cathodic protection 

systems, which are used to minimize corrosion of buried metallic components). 

(3) Condition monitoring programs search for the presence and extent of aging effects 

(e.g., visual inspection of concrete structures for cracking). 

(4) Performance monitoring tests verify the ability of the SSCs to perform their intended 

functions (e.g., periodic radiation monitoring). 

As an example of a condition monitoring assessment, the applicant could include historic 

radiation survey data and evaluation of trends. The reviewer should ensure that the applicant, 

either through analysis or through implementation of an appropriate AMP, adequately assesses 

trending from historical measures or deviations from calculated radiation levels that could 

indicate shielding degradation. This assessment is primarily directed at polymeric neutronshield materials, since the organic resins incorporated in these materials are subject to thermal 

and radiation-induced degradation. 

3.6.1.3 Corrective Actions 

The operating history, including corrective actions and design modifications, is an important 

source of information for evaluating the ongoing condition of in-scope SSCs. Applicants should 

discuss such history in detail. Applicants may consider both site-specific and industrywide 

experience, as relevant, as part of the overall condition assessment of in-scope SSCs.

Appendix C contains an example of an AMR discussion. 

3.6.1.4 Component-Specific Guidance 

Appendix E provides specific guidance for selected SSCs. 

3.6.2 Evaluation Findings 

The reviewer prepares the evaluation findings based on satisfaction of the regulatory 

requirements in Section 3.3. These statements should be similar to the following examples (the 

finding number is for convenience in cross-referencing within the SRP and SER): 

F3.4 The staff finds that the applicant considered potential aging effects, 

maintenance and operating history, modifications, root cause 

determinations, analyses or calculations, and inspections that provide 

reasonable assurance of continued safe operation of the ISFSI or DCSS 

for the period of extended operation. 
26 

F3.5 The staff finds that the applicant has identified maintenance and 

surveillance programs that will provide reasonable assurance that aging 

effects would be managed during the period of extended operation, in 

accordance with 10 CFR Part 72. 

3.7 Retrievability

Storage systems must be designed to allow ready retrieval of spent fuel for further processing or 

disposal for the duration of the licensing period, according to 10 CFR 72.122(l) and 

10 CFR 72.236(m). ISG-2, “Fuel Retrievability,” Revision 1, issued February 2010 by the 

Division of Spent Fuel Storage and Transportation, provides additional guidance regarding 

retrievability. 

3.7.1 Review Guidance 

The reviewer should ensure that the applicant has addressed any potential retrievability issue 

and provided justification for continued operation during the period of extended operation. For 

example, galling may cause a seizure between the canister shell and support structure rails 

during the canister retrieval process and should be addressed during the license renewal 

process.

3.7.2 Evaluation Findings 

The reviewer prepares the evaluation findings based on satisfaction of the regulatory 

requirements in Section 3.7. These statements should be similar to the following example, 

provided that the application supports positive findings for each of the regulatory requirements 

(the finding number is for convenience in cross-referencing within the SRP and SER): 

F3.6 The staff finds that the applicant has adequately determined that longterm degradation effects on SSCs would not prevent ready retrieval of 

spent fuel for further processing or transfer for ultimate disposition by the 

U.S. Department of Energy, as required by 10 CFR 72.236(m). 
A-1 

APPENDIX A 

NONQUANTIFIABLE TERMS 

(NONMANDATORY) 
A-2 

The following nonquantifiable terms, as well as others, may appear in the safety analysis report (SAR) 

(renewal application) and updated final safety analysis report (UFSAR): 

• large 

• small 

• slight 

• slightly 

• significant 

• significance 

• moderate 

• moderately 

• low 

• minor 

• many 

• few 

• little 

• routine 

Table A-1 may be used as guidance for the terms listed above, for additional consideration, or to 

provide quantitative measures or information. 

 
A-3 

 

Table A-1 Screening Criteria for Nonquantifiable Terms 

 Terms Actions Screened In 

The term requires additional consideration if 

it is used for one of the following: 

• characterizing an aging effect 

(e.g., degradation, cracking, fatigue, 

corrosion, loss of material, change in 

material properties) 

• providing important information about the 

operations, functions, or other 

characteristics of an in-scope SSC 

• describing dose, environmental impact, or 

other hazard, such as combustible 

material or dust 

If the term screens in, one of 

the following must be 

provided: 

• quantitative information, 

if it is available 

• additional descriptions 

• definition of the meaning 

of the term 

(e.g., “insignificant” 

means the function of 

the SSC is not impaired) 

Screened Out 

The term is considered not material to the 

SAR and ISFSI UFSAR for one of the 

following reasons: 

• The term is included in the title of 

reference document. 

• The term is included in a quote. 

• The term is explained by adjacent 

quantitative information (e.g., small: less 

than 20 percent). 

• Use of the term is NOT related to any of 

the following: 

 – in-scope SSCs per AMR results 

 – aging effect 

 – dose, environment impact, or other 

hazard (e.g., combustible material) 

• Use of the term does not provide important 

information. It is merely descriptive and the 

meaning of the statement is not changed if 

the term is deleted (e.g., the word “small” 

could be deleted from the following statement 

without altering the meaning: “Water in the 

grapple ring is drained through a small hole”). 

No action 
B-1 

APPENDIX B 

EXAMPLE OF INDEPENDENT SPENT FUEL STORAGE INSTALLATION 

MATERIALS AND COMPONENTS 
B-2 

Table B-1 provides an example of independent spent fuel storage installation (ISFSI) or dry cask 

storage system (DCSS) components and materials for one style of cask design. The components on 

this list are among those considered in the scoping evaluation. Such data sheets should be part of an 

application for ISFSI or DCSS license renewal, since this information aids in identifying systems, 

structures, and components that are within the scope of license renewal. 
B-3 

Table B-1 Example of Materials and Components of Cask System

Primary Component Drawing Safety Codes/Standards Material 

Function Class 

Containment Lid 972-70-2 It 2 A ASME Subsection NB SA-350, LF3 or SA- 

 203 Gr. E 

 Inner Containment 972-70-2 It 3 A ASME Subsection NB SA-203 Gr.E 

 Bottom Cont. 972-70-2 1t.5 A ASME Subsection NB SA-203 Gr. E 

 Flange 972-70-2 1t.35 A ASME Subsection NB SA-350, LF3 

 Lid Bolt (48) 972-70-2 It. 14 A ASME Subsection NB SA-540 Gr. B24 Cl. I 

 Lid Seal 972-70-2 It. 16 A Double Metallic O-Ring 

 Drain Port Cover 972-70-2 It.22 A ASME Subsection NB SA-240, Type 304 

 Vent Port Cover 972-70-2 It.23 A ASME Subsection NB SA-240, Type 304 

 Threaded Insert 972-70-2 It.45 A 304 SST 

 Vent & Drain Port Cover Seal 972-70-2 11.24 A Double Metallic O-Ring 

 Vent & Drain Port Cover Bolts 972-70-2 1t.25 A ASME Subsection NB SA-193 Gr. B7

Criticality Control Poison Plates 972-70-2 It33 A Borated Aluminum or 

 Carbide/Aluminum 

Metal 

 Matrix Composite 

 Basket Rail Type 1 972-70-2 It28 A B221, 6061-T6 

Aluminum 

 Basket Rail Type 2 972-70-2 lt.29 A B221, 6061-T6 

 Aluminum 

 Basket Rail Type 3 972-70-2 It 30 A B221, 6061-T6 

Aluminum 

 Fuel Compartment 972-70-2 132 A ASME Subsection NG SA-240 Type 304 

 Structural Plates 972-70-2 It.34 A ASME Subsection NG SA-240 Type 304 

 Basket Holddown 972-70-2 lt39 A ASME Subsection NG SA-240 Type 304

Shielding Gamma Shield 972-70-2 It. I A ASME Subsection NF SA-266 Class 2 

 Shield Plate 972-70-2 It 8 B ASME Subsection NF SA-105 or 

SA-516, Gr. 70 

 Bottom 972-70-2 ht.4 A ASME Subsection NF SA-516 Gr. 70 or 

SA-266 Cl. 2 

 Radial Neutron Shield 972-70-2 It.9 B Borated Polyester 

Resin 

 Outer Shell 972-70-2 Itý 10 B SA-516 Gr. 70 

 Soc. Head Cap Screw 972-70-2 It.47 B 30i SST 

 Shim 972-70-2 ht36 A SA-S16 Gr. 70 

 Top Neutron Shield 972-70-2 It. 12 B Polypropylene 

Heat Transfer Radial Neutron Shield Box 972-70-2 It. 13 B 6063-TS Aluminum 

 Poison Plates 972-70-2 Ilt33 A Borated Aluminum or 

Boron Carbide/Aluminum 

 Basket Rail Shim 972-70-2 It 31 B 6061-T6 Aluminum 

 Basket Rail Type 1 972-70-2 It.28 A B221, 6061-T6 

Aluminum 

 Basket Rail Type 2 972-70-2 11.29 A B221, 6061-T6 

 Aluminum 

 Basket Rail Type 3 972-70-2 It.30 A B221, 6061-T6 

 Aluminum 

Structural Integrity Gamma Shield 972-70-2 It. I A ASME Subsection NF SA-266 Class 2 

 Bottom 972-70-2 Ilt4 A ASME Subsection NF SA-5 16 Gr. 70 or 

SA-266 Cl. 2 

Operations Support Upper Trunnion 972-70-2 It.6 A ANSI N14.6 SA-182 Gr. F6NM 

 Lower Trunnion 972-70-2 Ilt7 B SA-105 

 Protective Cover 972-70-2 It. I I C SA-516 Gr. 70 

 Protective Cover Bolt 972-70-2 It. 15 C SA-193 Gr.B7 

 Protective Cover Seal 972-70-2 It. 17 C Elastomer 

 Top Neutron Shield Bolt 972-70-2 Ilt.20 C SA-193 Gr.B7 

 Trunnion Bolt 972-70-2 1t.37 A SA-320 L43 

 Fuel Spacer 972-70-2 lit38 C Aluminum 

 Shear Key 972-70-2 It40 A SA-203 Gr.E 

 Pressure Relief Valve 972-70-2 It.41 C SST 

 Security Wire 972-70-2 It.42 C 304 SST 

 Security Wire Seal 972-70-2 lt.43 C Lead 

 Flat Washer 972-70-2 It.46 C SST 

 Threaded Insert 972-70-2 It,44 C 304 SST 

 Quick Disconnect Couplings 972-70-3 C SST 

 Lid Alignment Pin 972-70-2 It.27 C A479, Type 316 

Leakage Monitoring Overpressure Port Cover 972-70-2 It. 18 C SA-240 Type 304 

Secondary Seal Overpressure Port Cover Seal 972-70-2 It. 19 C Single Metallic O-Ring 

 Pressure Monitoring System 972-70-2 h21 C Carbon Steel/SST 

 Overpressure Port Cover Ports 972-70-2 lt.26 C SA-193 Gr. B7
B-4 

 

Table B-1 Examples of Materials and Components of Cask System (Continued)

Primary Component Strength Coating Welding/Weld Filler 

Function (MPa [ksi]) 

Containment Lid 483 [70] SST Cladding on Sealing Surfaces ASME Section III, NB 

and Section IX 

 Inner Containment 483 [70] None ASME Section III, NB 

and Section IX 

 Bottom Containment 483 [70] None ASME Section III, NB 

and Section IX 

 Flange 483 [70] SST Cladding on Sealing Surfaces ASME Section III, NB 

 and Section IX 

 Lid Bolt (48) 1138 [165] Nuclear-Grade Neolube N/A 

 Lid Seal None N/A 

 Drain Port Cover 517 [75] None N/A 

 Vent Port Cover 517 [75] None N/A 

 Threaded Insert 2068 [300] None N/A 

 Vent and Drain Port Cover Seal None N/A 

 Vent and Drain Port Cover Bolts Nuclear-Grade Neolube N/A

Criticality Control Poison Plates None N/A 

 Basket Rail Type 1 262 [38] None N/A 

 Basket Rail Type 2 262 [38] None N/A 

 Basket Rail Type 3 262 [38] None N/A 

 Fuel Compartment 517 [75] None ASME Section III, NB 

and Section IX 

 Structural Plates 517 [75] None ASME Section III, NB 

and Section IX 

 Basket Holddown 517 [75] None ASME Section III, NB 

 and Section IX 

Shielding Gamma Shield 483 [70] Epoxy Paint on Exterior ASME Section IX 

 Shield Plate 483 [70] None ASME Section IX 

 Bottom 483 [70] Epoxy Paint on Exterior ASME Section IX 

 Radial Neutron Shield None 

 Outer Shell 483 [70] Epoxy Paint on Exterior 

 Soc. Head Cap Screw 483 [70] None 

 Shim 483 [70] None 

 Top Neutron Shield None 

Heat Transfer Radial Neutron Shield Box None 

 Poison Plates None 

 Basket Rail Shim 262 [38] None 

 Basket Rail Type 1 262 [38] None 

 Basket Rail Type 2 262 [38] None 

 Basket Rail Type 3 262 [38] None 

Structural Integrity Gamma Shield 483 [70] Epoxy Paint on Exterior 

 Bottom 483 [70] Epoxy Paint on Exterior 

Operations Support Upper Trunnion 793 [115] Nuclear-Grade Neolube 

 Lower Trunnion 483 [70] Epoxy Paint on Exterior 

 Protective Cover 483 [70] Epoxy Paint on Exterior 

 Protective Cover Bolt Nuclear-Grade Neolube 

 Protective Cover Seal None 

 Top Neutron Shield Bolt None 

 Trunnion Bolt 862 [125] Nuclear-Grade Neolube 

 Fuel Spacer None 

 Shear Key 483 [70] None 

 Pressure Relief Valve None 

 Security Wire None 

 Security Wire Seal None 

 Flat Washer None 

 Threaded Insert None 

 Quick-Disconnect Couplings None 

 Lid Alignment Pin None 

Leakage Monitoring Overpressure Port Cover 517 [75] None 

Secondary Seal Overpressure Port Cover Seal None 

 Pressure-Monitoring System Epoxy Paint on Exterior 

 Overpressure Port Cover Ports Nuclear-Grade Neolube 
B-5 

Table B-1 Example of Materials and Components of Cask System (Continued)

Primary Component Stress Stress Temp. Temp Temp Temp Press Press Gas 

Function Normal Accident Min Max 0 Year XX Year Min Max (Type) 

 (MPa[ksi]) (MPa[ksi]) (o

C [oF]) (oC [oF]) Storage Storage (kPag (kPag 

 (o

C [oF]) (oC [oF]) [psig]) [psig]) 

Containment Lid 31 [4.5] 37 [5.3] -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Inner Containment 178 [25.8] 367 [53.3] -29 [-20] 136 [277] 136 [277] 106 [223] 0 [0] 689 [100] Helium 

 Bottom Containment -29 [-20] 143 [289] 143 [289] 103 [218] 0 [0] 689 [100] Helium 

 Flange 21 [3.1] 204 [29.6] -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Lid Bolt (48) 281 [40.7] 172 [25] -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Lid Seal -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Drain Port Cover -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Vent Port Cover -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Threaded Insert -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Vent and Drain Port Cover Seal -29 [-20] 119 [247] 119 [247] 96 [204] 0 [0] 689 [100] Helium 

 Vent and Drain Port Cover Bolts 179 [26] 327 [47.4] -29 [-20] 114 [237] 114 [237] 96 [204] 0 [0] 689 [100] Helium 

Criticality Control Poison Plates -29 [-20] 239 [462] 239 [462] 182 [359] 

 Basket Rail Type 1 1 [0.15] 7 [1] -29 [-20] 166 [330] 166 [330] 126 [258] 

 Basket Rail Type 2 1 [0.15] 7 [1] -29 [-20] 166 [330] 166 [330] 126 [258] 

 Basket Rail Type 3 1 [0.15] 7 [1] -29 [-20] -1 [30] -1 [30] 126 [258] 

 Fuel Compartment -29 [-20] 250 [482] 250 [482] 182 [359] 

 Structural Plates 4 [0.56] 42 [6.03] -29 [-20] 250 [482] 250 [482] 182 [359] 

 Basket Holddown -29 [-20] 250 [482] 250 [482] 182 [359]

Shielding Gamma Shield 174 [25.3] 381 [55.3] -29 [-20] 126 [258] 126 [258] 99 [211] 

 Shield Plate 19 [2.8] 37 [5.4] -29 [-20] 119 [247] 119 [247] 96 [204] 

 Bottom -29 [-20] 132 [269] 132 [269] 103 [218] 21 [3] 34 [5] Air

 Radial Neutron Shield -29 [-20] 126 [258] 126 [258] 99 [211] 

 Outer Shell 30 [4.3] 63 [9.1] -29 [-20] 103 [218] 103 [218] 85 [185] 21 [3] 34 [5] Air

 Soc. Head Cap Screw -29 [-20] 103 [218] 103 [218] 85 [185] 

 Shim -29 [-20] 119 [247] 119 [247] 96 [204] 

 Top Neutron Shield -29 [-20] 119 [247] 119 [247] 96 [204]

Heat Transfer Radial Neutron Shield Box -29 [-20] 126 [258] 126 [258] 99 [211] 

 Poison Plates -29 [-20] 250 [482] 250 [482] 182 [359] 

 Basket Rail Shim -29 [-20] 166 [330] 166 [330] 126 [258] 

 Basket Rail Type 1 1 [0 15] 7 [1] -29 [-20] 166 [330] 166 [330] 126 [258] 

 Basket Rail Type 2 1 [0.15] 7 [1] -29 [-20] 166 [330] 166 [330] 126 [258] 

 Basket Rail Type 3 1 [0.15] 7 [1] -29 [-20] 166 [330] 166 [330] 126 [258]

Structural Integrity Gamma Shield -29 [-20] 126 [258] 126 [258] 99 [211] 

 Bottom -29 [-20] 132 [269] 132 [269] 103 [218] 21 [3] 34 [5] Air

Operations Support Upper Trunnion 73 [10.65] -29 [-20] 136 [277] 136 [277] 106 [223] 21 [3] 34 [5] Air

 Lower Trunnion -29 [-20] 136 [277] 136 [277] 106 [223] 21 [3] 34 [5] Air

 Protective Cover -29 [-20] 102 [216] 103 [218] 85 [185] 21 [3] 34 [5] Air

 Protective Cover Bolt 117 [17] -29 [-20] 119 [247] 119 [247] 96 [204] 21 [3] 34 [5] Air 

 Protective Cover Seal -29 [-20] 119 [247] 119 [247] 96 [204] 

 Top Neutron Shield Bolt -29 [-20] 119 [247] 119 [247] 96 [204] 

 Trunnion Bolt -29 [-20] 136 [277] 136 [277] 106 [223] 

 Fuel Spacer -29 [-20] 166 [330] 166 [330] 126 [258] 

 Shear Key -29 [-20] 166 [330] 166 [330] 126 [258] 

 Pressure Relief Valve -29 [-20] 126 [258] 126 [258] 99 [211] 

 Security Wire -29 [-20] 119 [247] 119 [247] 96 [204] 

 Security Wire Seal -29 [-20] 119 [247] 119 [247] 96 [204] 

 Flat Washer -29 [-20] 119 [247] 119 [247] 96 [204] 

 Threaded Insert -29 [-20] 119 [247] 119 [247] 96 [204] 

 Quick Disconnect Couplings -29 [-20] 119 [247] 119 [247] 96 [204] 

 Lid Alignment Pin -29 [-20] 119 [247] 119 [247] 96 [204]

Leakage Monitoring Overpressure Port Cover -29 [-20] 119 [247] 119 [247] 96 [204] 

Secondary Seal Overpressure Port Cover Seal -29 [-20] 119 [247] 119 [247] 96 [204] 

 Pressure Monitoring System -29 [-20] 102 [216] 103 [218] 85 [185] 21 [3] 34 [5] Air

 Overpressure Port Cover Ports -29 [-20] 119 [247] 119 [247] 96 [204]
C-1 

APPENDIX C 

EXAMPLE OF AGING MANAGEMENT REVIEW RESULTS 
Table C-1

 C-2

provides an example of the results of an aging management review (AMR) for the various components of an independent 

spent fuel storage installation (ISFSI) with a horizontal storage module (HSM) design. It should be noted that Table C-1 does not include all the systems, structures, and components (SSCs) associated with the HSM design. It merely illustrates one possible method of presenting AMR process results in the safety analysis report for license renewal. The evaluation should identify (1) the in-scope SSC, (2) the intended function of the SSC that caused it to be considered within scope, (3) material(s) of construction, (4) environmental operating conditions, and (5) potential aging effects requiring management and a determination of the type of

program for managing the effects of aging. The table uses the following intended function codes for brevity: 

CC provides criticality control of spent fuel HT provides heat transfer PB directly or indirectly maintains a pressure boundary RS provides radiation shielding SS provides structural support, functional support, or both, for equipment that is important to safety equipment None does not have a function that is important to safety, but its failure could affect performance of a safety-related SSC 
 C-3

Table C-1 AMR Results for the HSM 

Component(1) Intended Function Material Environment Aging Effects Requiring Management Aging Management Activity 

Concrete (Above Grade) 

HT, RS, 

SS Concrete Yard 

Loss of Material 

Cracking

Change in Material Properties 

Site-Specific ISFSI Aging 

Management Program 

Concrete (Below Grade) HT, RS Concrete Underground None Identified None Required Anchorages/ Embedments/ Rebar 

SS Carbon Steel Embedded None Identified None Required 

Anchorages/ Transfer Cask Restraints (Exposed) 

SS Carbon Steel Yard Loss of Material Site-Specific ISFSI Aging Management Program Sheltered Loss of Material Site-Specific ISFSI Aging Management Program 

Expansion Anchors SS 

Carbon 

Steel Sheltered Loss of Material Site-Specific ISFSI Aging Management Program 

Stainless 

Steel Sheltered None Identified None Required 

Stainless 

Steel Yard None Identified None Required 

DSC Support Assembly SS 

Carbon 

Steel Sheltered Loss of Material Site-Specific ISFSI Aging Management Program 

Stainless 

Steel Sheltered None Identified None Required 

HSM Access Ring (Exposed Embedment) 

SS Carbon Steel Sheltered Loss of Material Site-Specific ISFSI Aging Management Program 

Inlet/Outlet Screens and Frames HT Stainless Steel Yard None Identified None Required 
 C-4

Table C-1 AMR Results for the HSM (Continued) 

Component(1) Intended Function Material Environment Aging Effects Requiring Management Aging Management Activity

HSM Access Door Support Frame SS Carbon Steel Yard Loss of Material Site-Specific ISFSI Aging Management Program HSM Access Door RS, SS 

Carbon 

Steel Yard Loss of Material Site-Specific ISFSI Aging Management Program 

Polymeric 

Neutron 

Shield 

Material 

Embedded None Identified None Required 

Concrete 

(Phase 2) Embedded None Identified None Required 

Heat Shield HT Stainless Steel Sheltered None Identified None Required Seismic Restraint Assembly for DSC SS Carbon Steel Sheltered Loss of Material Site-Specific ISFSI Aging Management Program Fasteners SS Carbon Steel Sheltered Loss of Material Site-Specific ISFSI Aging Management Program Connectors(2) SS 

Bronze 

Yard Loss of Material Site-Specific ISFSI Aging Management Program 

Embedded None Identified None Required 

Underground None Identified None Required 

Stainless 

Steel Yard None Identified None Required 

Cable(2) SS Copper 

Yard None Identified None Required 

Embedded None Identified None Required 

Underground None Identified None Required 

Lead Sheathing(2) SS Lead Yard None Identified None Required Ground Rod(2) SS Copper Underground None Identified None Required Handrail and Bracing(2) SS Carbon Steel Yard Loss of Material Site-Specific ISFSI Aging Management Program 
 C-5

Table C-1 AMR Results for the HSM (Continued) 

Component (3) Intended Function Material Environment Aging Effects Requiring Management Aging Management Activity

Galvanized Flashing/Concrete Nails 

None N/A N/A N/A N/A 

Ladder and Attachments None N/A N/A N/A N/A Caulk, Sealants, Expansion Joint Fillers 

None N/A N/A N/A N/A 

Lubricants (Permaslik RN and Everlube 823) 

None N/A N/A N/A N/A 

PVC Drain Pipe/PVC Electrical Conduit (Embedded) 

None N/A N/A N/A N/A 

Electrical Conduit, Boxes, and Cable None N/A N/A N/A N/A Alignment Targets None N/A N/A N/A N/A (1) Each individual DCSS contains the listed SSCs, unless indicated otherwise. (2) Lightning protection system only. (3) Not-in-scope SSCs. 
D-1 

APPENDIX D 

AGING EFFECTS TABLE 
D-2 

Table D-1 lists potential aging effects and possible aging mechanisms. Table D-1 is an excerpt 

from a table in Appendix C to NUREG-1557, “Summary of Technical Information and 

Agreements from Nuclear Management and Resources Council Industry Reports Addressing 

License Renewal,” issued October 1996. It should be noted that the intent of the aging 

management review is to identify potential aging effects and address those effects through an 

effective aging management program. 
D-3 

Table D-1 Aging Effects and Possible Mechanisms 

Aging Effects of SSCs Possible Aging Mechanism 

Concrete Structures: 

1. Scaling, cracking, and spalling Freeze-Thaw 

2. Increase in porosity and permeability Leaching of Calcium Hydroxide 

3. Increase in porosity and permeability, 

cracking 

Aggressive Chemical Attack 

4. Expansion and cracking Reaction with Aggregates 

5. Loss of strength and modulus Elevated Temperature 

6. Loss of strength and modulus Irradiation of Concrete 

7. Deformation Creep 

8. Cracking Shrinkage 

9. Loss of material Corrosion 

10. Loss of material Abrasion and Cavitation 

11. Cracking Restrain, Shrinkage, Creep and Aggressive 

12. Loss of strength Concrete Interaction with Aluminum 

13. Cathodic protection effect on bond 

strength 

Cathodic Protection Current 

Structural Steel: 

1. Loss of material Corrosion, Local or Atmospheric 

2. Loss of strength and modulus Elevated Temperature 

3. Loss of fracture toughness Irradiation 

4. Crack initiation and growth Stress-Corrosion Cracking 

Reinforcing Steel (Rebar): 

1. Cracking, spalling, loss of bond and 

material 

Corrosion of Embedded Steel 

2. Loss of strength and modulus Elevated Temperature 

3. Loss of strength and modulus Irradiation 

Miscellaneous: 

1. Cracking, distortion, increase in component 

stress 

Settlement 

2. Loss of fracture toughness Strain Aging (of Carbon Steel) 

3. Reduction in design margin Loss of Prestress 

4. Loss of material Corrosion of Steel Piles 

5. Loss of material Corrosion of Tendons 

Cask Internals: 

1. Loss of material Corrosion, Boric Acid Corrosion 

2. Change in dimension Creep 

3. Wall thinning Erosion/Corrosion 

4. Crack initiation and growth Stress-Corrosion Cracking 

5. Loss of fracture toughness Neutron Irradiation Embrittlement 

6. Loss of preload Stress Relaxation 

7. Loss of fracture toughness Thermal Embrittlement 

8. Attrition Wear 
E-1 

APPENDIX E 

COMPONENT-SPECIFIC AGING MANAGEMENT 
E-2 

Component-Specific Aging Management 

“Lead Canister” External Remote Visual Inspection

Canister materials are selected to be resistant to environmentally induced degradation during 

the initial license period. To ensure confinement function of the canister for the license renewal, 

it is necessary to demonstrate that canisters have not undergone unanticipated degradation. A 

staff-accepted way to verify canister condition at an independent spent fuel storage installation 

is by remote visual inspection of one or more canisters (“lead canisters”). A lead canister is 

selected on the basis of longest time in service, or hottest thermal load, and/or other parameters 

that contribute to degradation. A similar methodology is acceptable for casks that are 

performing a confinement function. 

The interior of the associated concrete overpack or HSM should also be examined as part of the 

lead canister inspection. 

This inspection is expected to be performed before submittal of the license renewal application. 

The inspection results become part of the justification for license renewal. The reviewer should 

evaluate these canister inspection results provided with the safety analysis report. 

Typically, a repeat inspection is conducted at 20-year intervals as a license condition for 

renewal. The licensee/certificate of compliance holder may propose alternative inspection 

intervals for staff approval. 

Horizontal Storage Module Canister Support Steel

The canister support structure should be inspected to support the license renewal application. 

This is especially pertinent for ISFSIs located at coastal marine sites where atmospheric 

corrosion is known to be more severe. Support structure inspection may be done on a sampling 

basis. Selection of one or more support structures to be inspected should be based on longest 

service time, material, and/or environmental conditions. 

Normally, carbon steel is specified for this support structure. Some locations may have 

employed protective coatings on the support structure. Other ISFSI locations may have 

employed 0.2% copper bearing steel. Differences in materials and environmental conditions at 

various sites could make comparisons between different ISFSI sites invalid. 

The licensee should specify the re-inspection interval for the support structure based upon the 

findings of the initial license renewal inspection.