Standard Review Plan for 

Renewal of Independent 

Spent Fuel Storage Installation 

Licenses and Dry Cask Storage 

System Certificates of Compliance 

Draft Report for Comment 

Office of Nuclear Material Safety and Safeguards 

NUREG-1927
 
Standard Review Plan for 

Renewal of Independent 

Spent Fuel Storage Installation 

Licenses and Dry Cask Storage 

System Certificates of Compliance 

Draft Report for Comment 

Manuscript Completed: September 2009 

Date Published: September 2009 

Office of Nuclear Material Safety and Safeguards 

NUREG-1927 

ABSTRACT 

This Standard Review Plan (SRP) is intended for use by the U.S. Nuclear Regulatory 

Commission (NRC) reviewer. It provides guidance for the safety review of license renewal 

applications for currently operating independent spent fuel storage installations and holders of a 

certificate of compliance (CoC) for a dry cask storage system (DCSS), as codified in Title 10 of 

the Code of Federal Regulations (10 CFR) 72.214, “List of Approved Spent Fuel Storage 

Casks.” A license (site specific or general) authorizes a licensee to store spent fuel in an NRCapproved DCSS at a site under the requirements of 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.” To renew a specific license, an applicant must 

submit a license renewal application at least 2 years before the expiration of the license, and not 

less than 30 days before the expiration date of the CoC, in accordance with the requirements of 

10 CFR 72.42(b) and 10 CFR 72.240(b), respectively. The NRC may renew a specific license 

or a CoC for a term not to exceed 40 years. 

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 should be sent to the Director, 

Division of Spent Fuel Storage and Transportation, U.S. Nuclear Regulatory Commission, 

Washington, DC 20555-0001. 

iii 

CONTENTS 

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

CONTENTS ........................................................................................................................... v 

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

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

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

1.0 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 Licensee/Certificate of Compliance Holder Information ...................... 6 

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

1.4.3 Environmental Report ......................................................................... 7 

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

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

2.0 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 SSCs Within the Scope of License Renewal .................................... 12 

2.4.3 SSCs Not Within the Scope of License Renewal ............................. 13 

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

3.0 AGING MANAGEMENT REVIEW ............................................................................ 15 

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

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

3.3 Regulatory Requirements ............................................................................. 15 

3.4 Materials, Service Environment, Aging Effects, and Aging .......................... 17 

Management Activities ................................................................................. 17 

 3.4.1 Identification of Materials and Environment ...................................... 17 

 3.4.2 Identification of Aging Effects ........................................................... 17 

 3.4.3 Aging Management Activity .............................................................. 17 

 3.4.4 Evaluation Findings .......................................................................... 18 

3.5 Time-Limited Aging Management Analyses Evaluation ............................... 21 

 3.5.1 Review Guidance .............................................................................. 21 

 3.5.2 Evaluation Findings .......................................................................... 22 

3.6 Aging Management Program ....................................................................... 22 

 3.6.1 Review Guidance .............................................................................. 22

v 
vi 

 3.6.1.1 Aging Effects Subject to Aging Management ............ 23 

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 ................................................................................................. 25 

 3.7.1 Review Guidance .............................................................................. 25 

3.7.2 Evaluation Findings .......................................................................... 25 

 

APPENDIX A NONQUANTIFIABLE PHRASES (TERMS) .....................................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 GUIDANCE ............................................E-1 

LIST OF FIGURES ................................................................................................................vi

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

Figure 2.1 Flow Chart of Scoping Evaluation ................................................................ 11 

Figure 3.1 Flow Chart of AMR Process ......................................................................... 19 

LIST OF TABLES ..................................................................................................................vi 

Table 1-1 Relationship of Regulations and General Information Review ....................... 6 

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

Table 3-1 Relationship of Regulations and AMR .......................................................... 16 

Table A-1 Screening Criteria for Nonquantifiable Phrases (Terms) .............................A-2 

Table B-1 Example of Materials and Components of Cask System ............................B-2 

Table C-1 AMR Results for the HSMs ........................................................................ C-2 

Table D-1 Aging Effects and Possible Mechanisms ................................................... D-2 
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 

ER environmental report 

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 kips per square inch 

N/A not applicable 

NRC U.S. Nuclear Regulatory Commission 

PB pressure boundary 

PM NRC project manager 

psig pounds per square inch, gage 

PVC polyvinyl chloride 
viii 

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, for which there exist a specified 

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

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

accidents and the design basis for events and conditions caused by natural phenomena. 

NUREG-1536, NUREG-1567 

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 under the licensing-basis conditions during the license 

renewal period. 

Aging management program (AMP): A program for addressing aging effects that may include 

prevention, mitigation, condition monitoring, and performance monitoring. 

Aging management review (AMR): An assessment that addresses aging effects that could 

adversely affect the ability of SSCs to perform their intended important-to-safety functions 

during the license renewal period. 

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

both ends and is used to perform the function of confinement, while a separate overpack 

performs the functions of shielding and protecting the canister from the effects of impact 

loading. NUREG-1571 

Cask (in a dry cask storage system for spent nuclear fuel): A stand-alone device that performs 

the functions of confinement, radiological shielding, and physical protection of spent fuel during 

normal, offnormal, and accident conditions. See also, “Spent fuel ‘storage cask’ or ‘cask’” 

below. NUREG-1571 

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 Subpart L 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.” 10 CFR 72.3 

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

release of radioactive substances into the environment. NUREG-1571 

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

containing radioactive substances and the environment. 10 CFR 72.3 

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

authority and within which it performs ISFSI operations. 10 CFR 72.3 

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

reaction. ASTM C-859
x 

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

that material; adverse alteration. ASTM C-1174

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. 10 CFR 50.2 

Dry cask storage system: A dry cask storage system (DCSS) is 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, offnormal, and accident 

conditions. NUREG-1571 

Dry storage: The storage of spent nuclear fuel after removal of the water from the fuel, 

cladding, and all components of a DCSS, and after the atmosphere has been replaced with an 

inert atmosphere. ASTM C-1562-03 

General license: A 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 that 

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. 10 CFR 72.210,

10 CFR 72.212, NUREG-1536 

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. 10 CFR 72.3 

Monitoring: Testing and 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 measurements of specified 

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

the system. NUREG-1536

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

occur. NUREG-1536

Offnormal 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 

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)”). NUREG-1536
xi 

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 without the release of 

radioactive materials to the environment or radiation exposures in excess of the limits in 

10 CFR Part 20, “Standards for Protection against Radiation”; 10 CFR 72.122(l); and 

10 CFR 72.236(m). Additional 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 DCSS vendor or site-specific ISFSI licensee 

supplies to the NRC for analysis and confirmatory calculations. For site-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. 

NUREG-1571 

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

SAR review. It contains all of the findings and conclusions from the evaluation of the submitted 

SAR. NUREG-1571

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

radiation, and loading) that a component experiences during storage. ASTM C-1562-03 

Site-specific license: A license for the receipt, handling, storage, and transfer of spent fuel or 

high-level radioactive waste, or reactor-related GTCC waste that is issued to a named person, 

on an application filed pursuant to regulations in 10 CFR Part 72. 10 CFR 72.6 

Spent fuel “storage cask” or “cask”: All the components and systems associated with the 

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

in an ISFSI. 10 CFR 72.3 

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. 10 CFR 72.3 

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

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

(1) to maintain the conditions required to safely store spent fuel, high-level radioactive 

waste, or reactor-related GTCC waste 

(2) to prevent damage to the spent fuel, the high-level radioactive waste, or reactor-related 

GTCC waste container during handling and storage
xii 

(3) 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. 10 CFR 72.3

Thermal performance: Heat-removal capability having testability and reliability consistent with 

its importance to safety. 10 CFR 72.128 

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

the following attributes: 

(1) involve SSCs within the scope of license or CoC renewal 

(2) consider the effects of aging 

(3) involve time-limited assumptions defined by the current operating term; for example, 

40 years 

(4) were determined to be relevant by the licensee or CoC holder in making a safety 

determination 

(5) involve conclusions or provide the basis for conclusions related to the capability of the 

SSCs to perform their intended functions 

(6) are contained or incorporated by reference in the design basis. 10 CFR 54.3 

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

fuel handling area and the storage area. 
1 

INTRODUCTION

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

U.S. Nuclear Regulatory Commission (NRC) reviewer conducting the safety review of license 

renewal applications for currently operating independent spent fuel storage installations 

(ISFSIs), and holders of certificates of compliance (CoCs) for dry cask storage systems 

(DCSSs), as codified in Title 10 of the Code of Federal Regulations (10 CFR) 72.214, “List of 

Approved Spent Fuel Storage Casks.” 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, “Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, 

High-Level Radioactive Waste, and Reactor-Related Greater than Class C Waste.” 

To renew a specific license or a CoC, an applicant must submit a license 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 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, or the holder of a CoC 

for a DCSS, is authorized to store. 

The CoCs listed in 10 CFR 72.214 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 general licensee may apply for renewal of the CoC in its place. 

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

is not a regulatory requirement. An applicant may propose, for staff 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 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 flow chart of the license renewal process. 
2 

Figure A Chart of license renewal process 

2.0 Scoping Evaluation 

 Scoping Process (2.4.1) 

 Identification of Structures, Systems, and Components’ 

(SSCs’) Intended Function 

 SSCs Within the Scope of License Renewal (2.4.2) 

 Identification of SSC Subcomponents within Scope 

 SSCs Not Within the Scope of License Renewal (2.4.3) 

3.0 Aging Management Review 

 Identification of Materials and Environments (3.4.1) 

 Identification of Potential Aging Effects Requiring Management (3.4.2) 

 Determination of Aging Management Activity or Approach for 

Addressing the Effects of Aging (3.4.3) 

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 

1.0 Review of Regulatory Requirements 

 Application Information 

 Financial Information 

 Application Content 
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 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, and they include 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, as well as applicable interim staff guidance (ISG) documents, to determine the 

proper set of regulations for the section being reviewed. 

Review Guidance: The review guidance identifies the type and level of information that the 

application should include. ISGs contain supplemental information that clarifies important 

aspects of the regulatory requirements and may specify review procedures. For this reason, the 

reviewer should use the ISGs to enhance the review procedures specified in this SRP. 

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. 

Paperwork Reduction Act Statement 

This NUREG contains information collection requirements that are subjected 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 numbers 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 requiring document displays a 

currently valid OMB control number. 

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

The NRC project manager (PM) should review the general description to ensure that the 

applicant has included information regarding the description of the licensee or CoC holder, the 

financial standing of the licensee or CoC holder, the application content, and an environmental 

assessment. Areas of review addressed in this chapter include the following: 

 licensee/CoC holder information 

 financial information 

 application content 

 environmental assessment 

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 most current edition of 10 CFR Part 72 

to verify that the application complies with the most current regulatory requirements. 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). 
6 

Table 1-1 Relationship of Regulations and General Information Review 

Areas of Review 10 CFR Part 72 Regulations1

72.2 

(a)(1) 

72.22 

(a), (b), 

(c), (d) 

72.22 

(e) 

72.34 772.48 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 site-specific license renewals. The requirements of 

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

1.4 Review Guidance

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

to site-specific ISFSI licenses. 

1.4.1 Licensee/Certificate of Compliance Holder Information 

The 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 an individual, the application should specify the licensee’s citizenship and age. 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 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 design basis only and 
7 

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

should identify other costs related to activities associated with managing aging effects, and it 

should identify operating and decommissioning costs, for an ISFSI, that have been revised from 

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

decommissioning. 

1.4.3 Environmental Report 

The PM should ensure that license renewal application contains an ER, 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, 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. 

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

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. 
8 

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 can be applied to the renewal of an ISFSI 

license or DCSS CoC. 

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.” 

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

Changes to the design 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 1.4. The evaluation findings should be similar in wording to the 

following examples: 

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 renewal 

 SSCs not within the scope of license renewal 

2.3 Regulatory Requirements 

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

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

of the SSCs. The NRC does not intend a license or CoC renewal to be a vehicle for imposing 

new regulatory requirements, unless it identifies new safety-related deficiencies. In this case, 

the NRC may require changes to the design basis, which would be dispositioned 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 

(g) 

72.24 

(b), (c), 

(d) 

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 site-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 procedures. 

Refer to Appendix A for assessing nonquantifiable phrases and terms. 

2.4.1 Scoping Process 

Figure 2.1 provides a flow chart 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 

Sources that may support the scoping process 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 

 drawings 

 quality assurance plan or program 

 docketed correspondence 

 operating experience reports 

 10 CFR 72.48 evaluations 

 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 design 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 Flow chart of scoping evaluation 
12 

2.4.2 SSCs 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, as identified in the design basis. 

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 design 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. 

(3) They are identified as in-scope subcomponents. 

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

that support the intended function(s) of the SSCs. The intended function(s) of the 

subcomponents are the specific function(s) that support the safety function(s) of SSCs of 

which they are a part. The intended function(s) 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 because they are not important to 

safety. For storage pads considered within the scope of license renewal, the staff should review 
13 

the applicant's assessment that the inspection program considers the effects of aging, as 

identified in Table C-1 in Appendix C. 

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

consider. 

2.4.3 SSCs 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 nonsafety-related functions are generally not within the scope of renewal. 

The following nonsafety-related SSCs may be eliminated from the scope, provided 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 during a seismic event 

2.5 Evaluation Findings

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

requirements described in Section 2.4. The evaluation findings should be similar in wording to 

the following examples: 

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. 

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 renewal period. The reviewer should verify that the renewal 

application includes specific information that clearly describes the AMR performed on the inscope 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 

renewal period. 

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 

 determination of the type of program for managing the effects of aging 

 review of TLAAs 

Figure 3.1 contains a flow chart 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 

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 American Society for Testing and Materials 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. 

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 be applicable. 
16 

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) 

72.122 

(a), (b), 

(c), (h)(1), 

(h)(5), (l) 

72.122 

(f), 

(h)(4), 

(i) 

Aging Effects ● ● ● ● ●

Aging Management, 

Maintenance, or 

Surveillance Programs 

● ●

TLAAs ● ● ● ● ● ●

Retrievability ●

Areas of Review 10 CFR Part 72 Regulations3

72.124 72.128 

(a) 

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. 
17 

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 provided an analysis 

and documentation that identified 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). 

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 renewal period. If an SCC is determined to be within scope and is found to 

have no potential aging effects for the renewal term, then the applicant need not take further 

action. The reviewer should ensure that the SAR supplement documents these SSCs requiring 

no further review. 

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

maintenance activities identified under a corrective action program, including both site-specific 

and industrywide experience. This information may indicate repetitive or periodic conditions that 

may require an aging management program (AMP). One-time events should be evaluated for 

possible mitigating measures during the renewal period. 

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 dispositioning those SSCs, determined 

to be within the scope of renewal, that are subject to a potential aging effect. The aging 

management activity (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 flow chart 

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; 

CASTOR V/21 Cask Opening and Examination,” issued September 2001; and 
18 

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,” issued 

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

canister loading. These research results suggest that low-burnup fuel-cladding degradation 

should not occur during extended storage, provided that the design-basis internal environment 

has been maintained. 

The applicant should assess the most recent revision to ISG-11 and research results in this 

area, especially with respect to high-burnup fuel. Research into fuel performance in storage is 

ongoing. Applicants should 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. Should 

an opportunity for a DCSS interior and cladding inspection arise, the licensee should inform the 

NRC and industry, for potential participation in the inspection effort. 

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

being met during the renewal term. The cask user, the general licensee, 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.

3.4.4 Evaluation Findings 

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

requirements in Sections 3.4.1, 3.4.2, and 3.4.3. The evaluation findings should be similar in 

wording to the following examples: 

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: 

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

supplement satisfies the requirements of 10 CFR Part 72. 
19 

 

SSCs 

within the scope of

license renewal

(2.0) 

Identification of 

materials and 

Env ironments

(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)

No f urther 

action necessary.

Document in

SAR Supplement 

No

Yes

Identification of SSC 

subcomponents requiring 

AMR and intended functions

(2.0) 

Figure 3.1 Flow chart of AMR process 
20 

Is the SSC 

subjected to TLAA

review?

(3.5)

TLAA confirmed.

Document in SAR 

Supplement.

No further action 

Yes

Yes Yes

No

Determination of the 

AMA

required to manage the 

effects of aging

Is the SSC 

within an 

existing AMP?

(3.6)

Is TLAA

reconfirmed for the

period of license 

renewal?

Is the 

identified aging

effect managed by 

the existing AMP 

for the period 

of license 

renewal?

No

Aging effect on SSCs

are adequately managed. 

Document in SAR 

Supplement. No further 

action necessary

Action Required:

Modification of 

Existing siteAMA or 

introduction of a 

new AMA

to be reviewed

by the NRC

Document in SAR 

Supplement

TLAA AMP

Yes

No

No

Cont.

from

previous

page

Figure 3.1 Flow chart of AMR process (continued) 
21 

3.5 Time-Limited Aging Management Analysis Evaluation

A TLAA is a process to assess SSCs that have a time-dependent operating life, as defined by 

the design basis. 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, as defined by the design basis, and that the applicant has 

concluded that continued operation of the SSC is acceptable for the renewal period. 

The reviewer should verify if 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 reduced to license conditions, for site-specific license 

renewals, or conditions or technical specifications, for CoC 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. The 

assertions should be supported by a calculation, analyses, or testing that explicitly 

includes a time limit. 

 

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

Such documentation includes: (1) SAR, (2) SER, (3) technical specifications, (4) fire 

protection plan and hazards analysis, (5) correspondence to and from the NRC, 

(6) quality assurance plan, and (7) topical reports included as references in the SAR. 

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

predetermined life span. 

(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 renewal period. The 

TLAAs must show either one of the following: 

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

operation. 
22 

 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 dispositioning 

each SSC, with a predetermined life span, 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 3.5.1. The evaluation findings should be similar in wording to the 

following example: 

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 renewal period, 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 elements of an AMP, to determine the adequacy and 

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

 Scope: The scope of the AMP may be for a specific SSC or a group of SSCs. If one 

AMP is selected to manage a group of SSCs, then the AMP must consider the similarity 

of materials of construction, design, installation, operating environments, and aging 

effects. 

 Parameters Monitored or Inspected: This AMP element must describe what is being 

monitored or inspected. These descriptions include observable parameters or indicators 

to be monitored or inspected for each aging effect managed. The observable 

parameters must be linked to the degradation of the intended functions of the SSCs in 

the renewal period. 

 Detection of Aging Effects: By performing the monitoring and trending, as described 

below, the AMP will detect the aging effect(s) before the SSCs lose their intended 

function(s). 

 Monitoring and Trending: The AMP or inspection should describe a method that is 

capable of either: (1) detecting the effects of aging before the SSC would lose the ability 

to perform its intended function under design conditions, or (2) demonstrate that the 
23 

intended function of the SSC will be maintained during the renewal, without the need for 

an AMP. The AMP or inspection should include a methodology for analyzing the results 

of the inspection against applicable acceptance criteria. The methodology should be 

capable of determining the ability of the SSC to perform its intended function for the 

renewal period under the design conditions required by the ISFSI license or DCSS CoC. 

 When an inspection is necessary, sampling may be used to evaluate a group of SSCs. 

If sampling is used, a program should be developed that describes and justifies the 

methods used for selecting the population and the sample size. A sample may consist 

of one or more SSCs drawn from the scope. The applicant must determine a sample 

size that is adequate to provide reasonable assurance that the effects of aging on the 

SSC will not prevent the performance of its intended function during the renewal period. 

The size of the sample should include, for example, consideration of the specific aging 

effect(s), location, existing technical information, materials of construction, service 

environment, and previous failure history. The sample should be biased toward 

locations most susceptible to the specific aging effect(s) of concern. The results of the 

inspection should also be evaluated to assess whether the sample size is adequate or if 

it needs to be expanded. 

 An inspection for renewal (as described in Appendix E) may be performed at various 

times. It may be performed before submittal of the renewal application. The renewal 

application may include a commitment to perform an inspection before the beginning of 

the period of extended operation. There may also be justification for performing the 

inspection during the period of extended operation. Trending is the comparison of the 

current monitoring results with previous monitoring results, to make predictions for the 

future. Trending is not applicable for one-time new inspections. 

 Acceptance Criteria: The acceptance criteria for the AMP or inspection may be based 

on design-basis information, as well as established industry codes and standards. The 

acceptance criteria should be sufficient to ensure maintenance of the intended function 

of the SSC during the renewal period. 

 Corrective Action Program Review: The corrective action database should be examined 

for potential aging issues. Considerations should be given to root cause analysis, 

actions to prevent recurrence, and repair or replacement. 

 Operating Experience: Operating experience should be considered when developing a 

new AMP or inspection program. A review of previous applications and NRC SERs 

issued in support of renewed licenses may provide supporting experience for new 

programs or inspections. 

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 renewal term (Section 3.4.2). 
24 

Regardless of the specific aging effects, only aging effects that lead to degraded performance or 

cause a condition affecting 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. 

 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: prevention, mitigation, condition monitoring, and performance 

monitoring: 

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

prevent external corrosion of a tank). 

(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 reviewer should ensure that, for each 

DCSS design subject to renewal, there is an analysis of historic radiation survey data. The 

applicant should provide the results of this analysis in the renewal application and examine 

them for 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 be indicative of shielding 

degradation. This assessment is primarily directed at polymeric neutron-shield materials, since 

the organic resins incorporated in these materials are subject to thermal and radiation-induced 

degradation. 
25 

3.6.1.3 Corrective Actions 

The reviewer should ensure that corrective actions described by the applicant include root 

cause determinations for SSCs that are important to safety, and that the actions to be taken can 

prevent recurrence in a timely manner. 

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 

provide detailed discussions of such history. 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 3.6.1. These statements should be similar to the following examples: 

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 for continued safe operation of the 

ISFSI or DCSS for the renewal period. 

 

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 

renewal period, 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). The latest revision of ISG-2, “Fuel Retrievability,” issued by the Division of 

Spent Fuel Storage and Transportation, provides additional guidance regarding retrievability. 

3.7.1 Review Guidance 

An example of the possible long-term effect may be a galling effect causing a seizure between 

the cask shell and support structure rails during the canister retrieval process. The reviewer 

should ensure that the applicant has addressed any potential retrievability issue and provided 

justification for continued operation during the renewal period. 

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, 
26 

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

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

F3.6 The staff finds that the applicant has adequately determined that long-term 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 236(m). 
A-1 

APPENDIX A 

NONQUANTIFIABLE PHRASES (TERMS) 
A-2 

The following nonquantifiable phrases, 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, to provide 

quantitative measures or information. 

 
A-3 

 

Table A-1 Screening Criteria for Nonquantifiable Phrases (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 

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, 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 term does not provide important 

information. It is merely descriptive and the 

meaning of the statement is not changed if 

the term were 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. 
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 Covet 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-3 
 

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

Primary Component Strength Coating Welding/Weld Filler 

Function (ksi) 

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

and Section IX 

 Inner Containment 70 None ASME Section III, NB 

and Section IX 

 Bottom Containment 70 None ASME Section III. NB 

and Section IX 

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

 and Section IX 

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

 Lid Seal None N/A 

 Drain Port Cover 75 None N/A 

 Vent Port Cover 75 None N/A 

 Threaded Insert 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 38 None N/A 

 Basket Rail Type 2 38 None N/A 

 Basket Rail Type 3 38 None N/A 

 Fuel Compartment 75 None ASME Section III, NB 

and Section IX 

 Structural Plates 75 None ASME Section III, NB 

and Section IX 

 Basket Holddown 75 None ASME Section III, NB 

 and Section IX 

Shielding Gamma Shield 70 Epoxy Paint on Exterior ASME Section IX 

 Shield Plate 70 None ASME Section IX 

 Bottom 70 Epoxy Paint on Exterior ASME Section IX 

 Radial Neutron Shield None 

 Outer Shell 70 Epoxy Paint on Exterior 

 Soc. Head Cap Screw 70 None 

 Shim 70 None 

 Top Neutron Shield None 

Heat Transfer Radial Neutron Shield Box None 

 Poison Plates None 

 Basket Rail Shim 38 None 

 Basket Rail Type 1 38 None 

 Basket Rail Type 2 38 None 

 Basket Rail Type 3 38 None 

Structural Integrity Gamma Shield 70 Epoxy Paint on Exterior 

 Bottom 70 Epoxy Paint on Exterior 

Operations Support Upper Trunnion 115 Nuclear-Grade Neolobe 

 Lower Trunnion 70 Epoxy Paint on Exterior 

 Protective Cover 70 Epoxy Paint on Exterior 

 Protective Cover Bolt Nuclear-Grade Neolube 

 Protective Cover Seal None 

 Top Neutron Shield Bolt None 

 Trunnion Bolt 125 Nuclear-Grade Neolube 

 Fuel Spacer None 

 Shear Key 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 75 None 

Secondary Seal Overpressure Port Cover Seal None 

 Pressure-Monitoring System Epoxy Paint on Exterior 

 Overpressure Port Cover Ports Nuclear-Grade Neolube 

 B-4
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) 

 (ksi) (ksi) (o

F) (oF) Storage Storage (psig) (psig) 

 (o

F) (oF) 

Containment Lid 4.5 5.3 -20 247 247 204 0 100 Helium 

 Inner Containment 25.8 53.3 -20 277 277 223 0 100 Helium 

 Bottom Containment -20 289 289 218 0 100 Helium 

 Flange 3.1 29.6 -20 247 247 204 0 100 Helium 

 Lid Bolt (48) 40.7 25 -20 247 247 204 0 100 Helium 

 Lid Seal -20 247 247 204 0 100 Helium 

 Drain Port Cover -20 247 247 204 0 100 Helium 

 Vent Port Cover -20 247 247 204 0 100 Helium 

 Threaded Insert -20 247 247 204 0 100 Helium 

 Vent and Drain Port Cover Seal -20 247 247 204 0 100 Helium 

 Vent and Drain Port Cover Bolts 26 47.4 -20 237 237 204 0 100 Helium 

Criticality Control Poison Plates -20 462 462 359 

 Basket Rail Type 1 0.15 1 -20 330 330 258 

 Basket Rail Type 2 0.15 1 -20 330 330 258 

 Basket Rail Type 3 0.15 1 -20 30 30 258 

 Fuel Compartment -20 482 482 359 

 Structural Plates 0.56 6.03 -20 482 482 359 

 Basket Holddown -20 482 482 359 

Shielding Gamma Shield 25.3 55.3 -20 258 258 211 

 Shield Plate 2.8 5.4 -20 247 247 204 

 Bottom -20 269 269 218 3 5 Air

 Radial Neutron Shield -20 258 258 211 

 Outer Shell 4.3 9.1 -20 218 218 185 3 5 Air

 Soc. Head Cap Screw -20 218 218 185 

 Shim -20 247 247 204 

 Top Neutron Shield -20 247 247 204

Heat Transfer Radial Neutron Shield Box -20 258 258 211 

 Poison Plates -20 482 482 359 

 Basket Rail Shim -20 330 330 258 

 Basket Rail Type 1 0 15 1 -20 330 330 258 

 Basket Rail Type 2 0.15 1 -20 330 330 258 

 Basket Rail Type 3 0.15 1 -20 330 330 258

Structural Integrity Gamma Shield -20 258 258 211 

 Bottom -20 269 269 218 3 5 Air

Operations Support Upper Trunnion 10.65 -20 277 277 223 3 5 Air

 Lower Trunnion -20 277 277 223 3 5 Air

 Protective Cover -20 216 218 185 3 5 Air

 Protective Cover Bolt 17 -20 247 247 204 3 5 Air 

 Protective Cover Seal -20 247 247 204 

 Top Neutron Shield Bolt -20 247 247 204 

 Trunnion Bolt -20 277 277 223 

 Fuel Spacer -20 330 330 258 

 Shear Key -20 330 330 258 

 Pressure Relief Valve -20 258 258 211 

 Security Wire -20 247 247 204 

 Security Wire Seal -20 247 247 204 

 Flat Washer -20 247 247 204 

 Threaded Insert -20 247 247 204 

 Quick Disconnect Couplings -20 247 247 204 

 Lid Alignment Pin -20 247 247 204 

Leakage Monitoring Overpressure Port Cover -20 247 247 204 

Secondary Seal Overpressure Port Cover Seal -20 247 247 204 

 Pressure Monitoring System -20 216 218 185 3 5 Air

 Overpressure Port Cover Ports -20 247 247 204

B-5

C-1 

APPENDIX C 

EXAMPLE OF AGING MANAGEMENT REVIEW RESULTS 
Table C-1 provides an example of the results of an aging management review (AMR) for the various componen

spent fuel storage installation (ISFSI) with a horizontal storage module (HSM) design. It should be noted that Tinclude all the systems, structures, and components (SSCs) associated with the HSM design. It merely illustratmethod of presenting AMR process results in the safety analysis report for license renewal. The evaluation shoin-scope SSC, (2) the intended function of the SSC that caused it to be considered within scope, (3) material(s) (4) environmental operating conditions, and (5) potential aging effects requiring management and a determinatio

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 e

None does not have a function that is important to safety, but its failure could affect performance of a s

 C-2
Table C-1 AMR Results for the HSM 

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

Concrete (Above Grade) 

HT, RS, 

SS Concrete Yard 

Loss of Material 

Cracking

Change in Material Properties 

Site-Sp

Mana

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

SS Carbon Steel Embedded None Identified N

Yard Loss of Material Site-Sp

Mana

Anchorages/ Transfer Cask Restraints (Exposed) 

SS Carbon Steel Sheltered Loss of Material Site-Sp

Mana

Carbon 

Steel Sheltered Loss of Material Site-Sp

Mana

Stainless 

Steel Expansion Anchors SS Sheltered None Identified N

Stainless 

Steel Yard None Identified N

Carbon 

Steel Sheltered Loss of Material Site-Sp

DSC Support ManaAssembly SS Stainless 

Steel Sheltered None Identified N

HSM Access Ring (Exposed Embedment) 

SS Carbon Steel Sheltered Loss of Material Site-Sp

Mana

Inlet/Outlet Screens and Frames HT Stainless Steel Yard None Identified N

 C-3
Table C-1 AMR Results for the HSM (Continued) 

HSM Access Door Support Frame SS Carbon Steel Yard Loss of Material Site-Sp

Mana

Carbon 

Steel Yard Loss of Material Site-Sp

Mana

Polymeric 

Neutron 

Shield 

Material 

HSM Access Door RS, SS Embedded None Identified N

Concrete 

(Phase 2) Embedded None Identified N

Heat Shield HT Stainless Steel Sheltered None Identified NSeismic Restraint Assembly for DSC SS Carbon Steel Sheltered Loss of Material Site-Sp

Mana

Fasteners SS Carbon Steel Sheltered Loss of Material Site-Sp

Mana

Yard Loss of Material Site-Sp

Mana

Embedded None Identified N

Bronze 

Underground None Identified N

Connectors(2) SS 

Stainless 

Steel Yard None Identified N

Yard None Identified N

Cable Embedded None Identified N

(2) SS Copper 

Underground None Identified N

Lead Sheathing(2) SS Lead Yard None Identified NGround Rod(2) SS Copper None Identified NHandrail and Bracing(2) SS Carbon Steel Yard Loss of Material Site-Sp

Mana

Galvanized Flashing/ConcreteNails None N/A N/A N/A 

 C-4
Table C-1 AMR Results for the HSM (Continued) 

Ladder and Attachments None N/A N/A N/A 

Caulk, Sealants, Expansion Joint Fillers 

None N/A N/A N/A 

Lubricants (Permaslik RN and Everlube 823) 

None N/A N/A N/A 

PVC Drain Pipe/PVC Electrical Conduit (Embedded) 

None N/A N/A N/A 

Electrical Conduit, Boxes, and Cable None N/A N/A N/A Alignment Targets None N/A N/A N/A (1) Each individual HSM contains the listed subcomponents, unless indicated otherwise. (2) Lightning protection system only. 

 C-5
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 GUIDANCE 
E-2 

20-Year Interval “Lead” Dry Cask Storage System Inspection 

A “lead” cask or canister and overpack is one or more dry cask storage systems (DCSSs) 

selected for additional inspections, on the basis of longest time in service, or hottest thermal 

load, or other parameter(s) that contribute to aging. The reviewer should ensure that the 

applicant’s selection of the lead DCSS considers the environment, operating conditions, 

materials, operating history, industry experience, and any other factor(s) that may affect the 

DCSS condition. Inspection of such selected DCSS major components (e.g., cask(s), 

canister(s), or overpack) would serve as a “lead” structure for assessing the condition of other 

loaded DCSSs. The lead cask inspection does not have to be performed at the independent 

spent fuel storage installation (ISFSI) site seeking renewal, as long as the applicant can 

demonstrate that the parameters for the DCSS being inspected are bounding for the DCSS to 

be renewed. 

The reviewer should ensure that the applicant’s inspection program justifies the number of 

individual canisters to receive visual inspection by their removal from the concrete overpack, so 

that selected surfaces of the various components exposed to the ambient air environment are 

examined (including the canister bottom, for vertical systems). This examination is performed to 

detect unanticipated degradation, in areas of the DCSS that are not normally accessible or 

observable. In lieu of canister removal from overpacks or similar structures, remote inspection 

methods may be acceptable, with justification. The applicant should indicate that it will also 

inspect the interior of the overpack. A DCSS can have portions or areas that are not normally 

observable, which should also be inspected (e.g., the cask bottom). 

Those who hold a current 20-year license and certificate of compliance (CoC) should perform 

this inspection before the end of the operating period, as it is part of the basis for renewal. They 

should repeat the inspection at 20-year intervals, thereafter. The licensee and CoC holder may 

propose alternative inspection intervals for staff approval. 

If the inspection demonstrates no adverse condition(s), the licensing basis is met. If adverse 

conditions are discovered that cannot be corrected within the licensing basis, a license or CoC 

amendment or other licensing action may be required to meet the design basis. 

If two or more different DCSS designs are in service at a common ISFSI site, then the licensee 

should justify the number of different designs to be inspected. This does not imply that all

DCSS designs at an ISFSI site must be so inspected. If one design can be shown to envelope 

the conditions of another design(s), the licensee would need to inspect only one design. The 

licensee should demonstrate that the results of the lead inspection reflect the conditions of all 

the other DCSSs at its site.