Issue Date: 07/14/05 - 1 - MC 2690

NRC INSPECTION MANUAL NMSS/SFPO

MANUAL CHAPTER 2690

INSPECTION PROGRAM FOR DRY STORAGE OF SPENT REACTOR FUEL AT

INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS AND FOR PART 71

TRANSPORTATION PACKAGINGS

2690-01 PURPOSE

To define the inspection program requirements for the dry storage of spent reactor fuel and

other radioactive materials associated with spent fuel storage at an independent spent fuel

storage installation (ISFSI). This inspection manual chapter (IMC) covers all activities

related to dry storage ISFSIs and transportation packagings, including: operations,

maintenance, surveillance testing, preoperational testing, design control, fabrication, and

construction. Guidance on scheduling inspections is contained in Appendices A, B, and C.

The Fort St Vrain Modular Vault Dry Storage system is an ISFSI and is within the scope of

this IMC. The guidance contained in Appendix B of this IMC may also be used for the

inspection of a monitored retrievable storage (MRS) facility and an away from reactor

(AFR) site ISFSI. 

2690-02 OBJECTIVES

02.01 To establish the general policy and responsibilities for the inspection of ISFSIs. 

02.02 To define the program for inspecting ISFSIs and related activities. 

02.03 To provide a framework to achieve a uniform level of inspection. 

02.04 To provide a recognition of design, fabrication, testing, and maintenance of

transportation packagings.

2690-03 DEFINITIONS

03.01 ISFSI. An independent spent fuel storage installation (ISFSI) is a facility designed

and constructed for the interim storage of spent nuclear fuel and other radioactive materials

associated with the spent fuel (10 CFR 72.3). The term ISFSI refers to the facility

authorized for storage of spent nuclear fuel under Part 72 and includes the storage pad,

the storage containers, and any support facilities. However, if the ISFSI is located at a

reactor site, it does not include any structures, facilities, or services that are part of the 10
MC 2690 - 2 - Issue Date: 07/14/05

CFR Part 50 license, unless they are identified as being shared jointly. Additional

background information on ISFSIs may be found in Reference 07.01. 

03.02 DCSS. Dry cask storage system (DCSS) is the term used to describe the physical

system, either a cask or a canister in its shielding overpack, that holds the spent fuel and

is a component of the ISFSI. An ISFSI may contain several different DCSS designs. 

03.03 MRS. A monitored retrievable storage (MRS) installation is a complex designed,

constructed, and operated by the Department of Energy under the Nuclear Waste Policy

Act of 1987 (NWPA) for the receipt, transfer, handling, packaging, possession,

safeguarding, and storage of spent nuclear fuel and solidified high-level radioactive waste

resulting from civilian nuclear activities (10 CFR 72.3). 

03.04 For this inspection program, four different entities will be discussed. 

 a. Licensee. An organization that is operating an ISFSI for the storage of spent fuel

and other radioactive materials associated with spent fuel under a Part 72 license.

The licensee is ultimately responsible for ensuring that the ISFSI is designed,

fabricated, constructed, and operated in accordance with the requirements

contained in Part 72 and the site-specific license or the general license CoC. The

licensee may also fabricate DCSS components or construct ISFSI structures, such

as the storage pad. 

 b. Vendor. An organization, typically independent from the licensee, that is

responsible for the design of a particular DCSS and ensuring that design

commitments contained in the safety analysis report (SAR) are met during the

fabrication of the DCSS. For a general license ISFSI, the vendor is also typically

the CoC holder for the DCSS. For a site-specific license ISFSI, there is no CoC,

and the SAR contains the relevant information on the design and fabrication of the

specific DCSS being used. Regardless of the type of license, the vendor is also

responsible for ensuring that the DCSS is designed and fabricated in accordance

with the applicable requirements. 

 c. CoC Holder. A vendor that has obtained Nuclear Regulatory Commission (NRC)

approval for a specific DCSS under Part 72, Subpart L. The issuance of a CoC to

the vendor authorizes the use of the DCSS in an ISFSI under the general license.

 d. Fabricator. An organization that is physically building the DCSS components and

receives design oversight from either the vendor, licensee, or both. The fabricator

is responsible for manufacturing the DCSS in accordance with the vendor's

requirements and drawings. 

03.05 There are two types of licenses governed by Part 72 - a general license or a sitespecific license (10 CFR 72.6). 

 a. General License. Any person issued a license under 10 CFR Part 50 to possess

or operate nuclear power reactors is also issued a general license under Part 72,

Subpart K, to store spent fuel at an ISFSI located at that power reactor site. This
Issue Date: 07/14/05 - 3 - MC 2690

general license authorizes the use of a DCSS that has been previously approved

under Part 72, Subpart L. 

 b. Site-Specific License. Any person or entity may submit an application under Part

72 for a site-specific ISFSI license. The application should contain detailed

information on the ISFSI's site characteristics and the particular DCSS to be used.

Under a site-specific license any DCSS design can be used at any location. While

a site-specific Part 72 license is independent from a co-located Part 50 reactor

license, some structures, systems, and programs—that are part of the licensing

basis for the reactor license—may be shared. 

03.06 Away-from-Reactor (AFR). For the purposes of this IMC, an AFR ISFSI is defined

as a site-specific licensed ISFSI that is located outside the site boundaries (property lines)

for any power reactor licensed under Part 50. The site boundaries for a power reactor are

described (pictured) in the associated Part 50 licensee's updated final safety analysis 

report (UFSAR). 

03.07 Integrated Inspection Plan. An integrated inspection plan (IIP) is a document

developed by the cognizant region, with input from the Spent Fuel Project Office (SFPO)

on technical, regulatory, prior performance, and lessons learned for each new specific |

license ISFSI site (see Section 05.05). The IIP provides supplemental guidance for |

planning and scheduling the numerous inspections and any technical reviews that are

required before initial loading of spent fuel into the ISFSI. The IIP is intended to ensure that

adequate resources are applied so that significant safety issues are resolved before initial

loading of spent fuel into |the ISFSI. 

2690-04 RESPONSIBILITIES AND AUTHORITIES

04.01 Director, SFPO, Office of Nuclear Material Safety and Safeguards (NMSS). Directs

the activities of the SFPO and is responsible for their implementation. Approves the 

inspection program and procedures for activities relating to the dry storage of spent reactor

fuel and other radioactive materials at ISFSIs. 

04.02 SFPO, NMSS

 a. Develops and implements the Agency's regulatory, licensing, and inspection

programs for the storage of nuclear reactor spent fuel. 

 b. Develops and assesses the overall effectiveness of the spent fuel dry storage

inspection program. 

 c. Develops, modifies, and revises inspection program guidance (NRC IMCs and

inspection procedures (IPs)) under SFPO's purview to ensure that ISFSI-related

activities are conducted in accordance with appropriate regulations and standards.

Incorporates lessons learned into the inspection program for IMCs and IPs under

SFPO's purview. Recommends changes to other organizations for IMCs and IPs

under their purview. 
MC 2690 - 4 - Issue Date: 07/14/05

 d. Serves as a source of technical expertise for questions on DCSS' or ISFSIs (e.g.,

DCSS design requirements, ISFSI siting criteria, accident analysis, or conditions

contained in the site-specific license or CoC). 

 e. Manages the assignment, scheduling, and performance of inspections of ISFSI

vendors (including CoC holders) and fabricators. 

 f. Provides SFPO inspection resources to support region-led inspections of ISFSIs.,

Plans, schedules, and coordinates, with the Regional Branch Chief, any

inspections of ISFSI vendors, fabricators, and CoC holders. While resources for

ISFSI inspections are budgeted in advance together with NRR, the regions are

allowed some flexibility in their actual allocation of ISFSI inspection resources to

reflect changes in inspection schedule and scope. 

 g. Serves as the focal point for collecting lessons learned from previous IIPs and

| provides expertise in the development of new IIPs for specific license ISFSI. 

|

 h. Participates with the Regional Branch Chief in the development of an IIP for each

| new specific license ISFSI site (see Section 05.05). 

 1. Provides input on technical and regulatory issues, associated with the

specific ISFSI and DCSS being used, to the region, for inclusion in the IIP.

 2. Based on review of the NRC safety evaluation report (SER), identifies any

special inspection resources necessary to resolve technical or regulatory

issues for inclusion in the IIP. 

 3. Based on lessons learned from prior IIPs and licensee, vendor, and fabricator

prior performance, identifies any technical, regulatory, performance, or

scheduling issues for inclusion in the IIP. 

 i. Interfaces, as necessary, with the various Office of Nuclear Reactor Regulation

(NRR), project and technical division staffs, regarding the inspection of ISFSI

activities at Part 50 reactor sites. 

04.03 SFPO Project Manager (SFPO/PM)

 a. For all assigned ISFSIs, serves as the focal point of contact for technical and

regulatory issues that affect the ISFSI. The NRR/PM is the point of contact for

ISFSI issues that affect the reactor's structures, systems, and components (SSCs)

(see Section 04.09). 

 b. For all assigned Part 50 reactor site ISFSIs, serves as the focal point of contact for

the NRR/PM where operation of reactor affects the ISFSI's SSCs. Serves as the

focal point of contact for the NRR/PM or Regional Branch Chief requests to obtain

SFPO resources. 
Issue Date: 07/14/05 - 5 - MC 2690

 c. For all assigned Part 50 reactor site ISFSIs, serves as the focal point of contact for

all ISFSI issues after site project management responsibilities have been assumed

by NMSS. 

 d. For all assigned AFR ISFSIs, serves as the focal point of contact for all AFR ISFSI

issues. 

04.04 Regional Administrator

 a. Oversees the implementation of the ISFSI inspection program elements that are

performed by the regional office. 

 b. Ensures, within assigned budget limitations, that the regional office staff includes

adequate numbers of inspectors necessary to carry out the inspection program

described in this IMC. 

04.05 Regional Division Director

 a. Manages the implementation of the ISFSI inspection program as assigned by the

Regional Administrator. 

 b. Directs the execution of the ISFSI inspection program elements that are performed

by his/her division. 

 c. Ensures that allocated inspection resources are appropriately scheduled for the

routine inspection of the region's ISFSIs, using the regional planning process. 

 d. Ensures that necessary reactive inspection resources are applied to deal with

events and problems at the Region's ISFSIs, as required. 

 e. Approves the IIP prepared for each new specific license ISFSI site in the region |

(see Section 05.05). 

04.06 Regional Branch Chief

 a. For each assigned ISFSI, manages the planning, scheduling, and performance of

inspections of ISFSIs using the inspection resources allocated by the regional

planning processes. 

 b. For each assigned ISFSI, contacts the SFPO/PM, as necessary, to request SFPO

resources in response to any events or problems at his/her assigned ISFSIs. 

 c. For each assigned ISFSI, ensures that accountability is maintained over the

implementation of the inspection program per the guidance in Sections 05.03 and

05.05. 

 d. For each assigned ISFSI, notifies the SFPO/PM of any changes to inspection

frequencies for the inspections listed in Tables A-2 and B-2of Appendices A and |

B of this IMC. |
MC 2690 - 6 - Issue Date: 07/14/05

 e. For each assigned ISFSI, ensures that inspections of ISFSI activities are

documented in accordance with Sections 05.07 and 05.08. 

| f. For each assigned new ISFSI, create an IIP in accordance with Section 05.05.

| Provides feedback and any lessons learned to the applicable SFPO/PM, after the

| IIP has been completed. 

|

04.07 Regional Liaison for Spent Fuel Storage Issues [Optional]

 a. Provides assistance to Regional Branch Chiefs and inspectors to ensure

consistency in inspection planning and oversight of the region's ISFSI activities. 

 b. Serves as a regional point of contact for interactions with the SFPO and NRR on

ISFSI policy and program issues. 

04.08 NRR

 a. Retains oversight of spent fuel at operating and decommissioned reactors, until the

fuel has either been safely stored in an ISFSI or transferred offsite. 

 b. Provides inspection resources, as requested, to NMSS or the Regions for routine

and reactive ISFSI inspection activities performed at Part 50 licensees in

accordance with IMCs 2515, "Light-Water Reactor Inspection Program -

Operations Phase," and 2561, "Power Reactor Inspection Program -

Decommissioning." 

04.09 NRR Project Manager (NRR/PM)

 a. Serves as the focal point of contact on issues where the operation of an ISFSI,

located at a Part 50 reactor site, affects the reactor's SSCs (e.g., 10 CFR 50.59

issues). Informs the SFPO/PM if any such issues are identified and of any technical

and regulatory issues related to a particular ISFSI. 

 b. Serves as the point of contact for the SFPO/PM in obtaining NRR resources and

support on ISFSI issues, for an ISFSI located at a Part 50 reactor site. 

 c. Contacts the assigned SFPO/PM with any requests for SFPO resources and

support on issues where the ISFSI is affecting the Part 50 reactor site. 

 d. Serves as the point of contact for public and media inquiries on ISFSI issues, for

an ISFSI located at a reactor site, and for any AFR ISFSI sites in the region.

Contacts the assigned SFPO/PM for additional information or guidance as

required. 

2690-05 PROGRAM DESCRIPTION

05.01 Inspection Program for ISFSI Activities. Where the ISFSI Is Located at a Part 50 
Issue Date: 07/14/05 - 7 - MC 2690

Reactor Site. The program for inspecting either a general or site-specific licensed ISFSI,

which is located at a reactor site, is described in Appendix A of this IMC. 

05.02 Inspection Program for AFR ISFSI Activities. The program for inspecting a sitespecific licensed AFR ISFSI is described in Appendix B of this IMC. 

05.03 Planning, Scheduling, and Tracking of Inspection Activities. Each region should 

implement a system for planning, scheduling, and recording of completed inspections of

ISFSI activities in accordance with regional requirements. 

05.04 SFPO Scheduling of Fabricator Inspections. The scheduling of vendor and 

fabricator inspections should consider vendor or fabricator performance and recent vendor

or fabricator inspections performed for other ISFSI licensees. Additional inspections may

be conducted as required. The SFPO will inform any affected regions of the schedule for

inspecting vendors or fabricators and any schedule changes, as soon as the need for the

change is identified. 

05.05 IIP. For a new specific license ISFSI site being constructed, the applicable Regional |

Branch Chief, with input and assistance from the SFPO, should develop an IIP in

accordance with the guidance listed below. The cognizant Regional Division Director

should approve the IIP and the SFPO will concur in it. The IIP should be forwarded to the

NRR/PM for information and for use in planning and scheduling any requested

Headquarters inspections or technical reviews. The Region should inform the SFPO/PM

and NRR/PM if any changes are subsequently made to the IIP, as soon as the need for the

change is identified. 

 a. The IIP should be developed as early as possible with a goal of issuance 12 to 24

months before the licensee or applicant intends to begin storage of spent fuel in the

ISFSI. 

 b. For activities directly relating to the ISFSI (e.g., design, construction, fabrication,

preoperational testing, and operations), the IIP should include a list of the IPs to be

used, the number of inspections required to complete a specific IP, estimated

inspection resources, a principal inspector, and any requests for NRR or SFPO

technical assistance or inspection resources. 

 c. For activities that support operation of the ISFSI (e.g., the licensee's or applicant's

programs for quality assurance, security, emergency preparedness, or radiation

protection), the IIP should contain information similar to that specified in paragraph

b. above. SFPO should provide input on the scope of these reviews. Each support

program being reviewed should be listed as a specific element in the IIP. 

 d. The IIP should indicate licensee milestones, planned inspection dates, and any

linkages between the two (e.g., the relationship between dates for inspecting the

ISFSI support pad and the licensee's planned pad construction and concrete

placement schedule). 

 e. Based on the SAR, SER, previous inspections, vendor or fabricator prior

performance, and lessons learned from previous IIPs, the SFPO should identify to
MC 2690 - 8 - Issue Date: 07/14/05

the region any technical, regulatory, or performance issues that should be included

as specific elements in the IIP. This may include inspections of vendors or

fabricators. 

 f. For an AFR ISFSI, the SFPO and the region should jointly determine which NRC

Inspection Manual IPs, or sections of IPs, are appropriate to inspect the licensee's

or applicant's implementation of those programs that support operation of the ISFSI

(see list of typical programs in Section B of Appendix B).

 g. The following guidance should be used in scheduling inspections of licensee or

applicant activities: 

 • Inspection of the quality assurance program should be completed before design

activities are finished. If possible, inspections should be completed before design

activities are begun.

 • Inspection of design activities should be performed during the design process and

should be completed before construction or fabrication activities begin, if possible.

 • Inspection of design activities should include a review of any design changes or

modifications made by the licensee or CoC holder and the associated safety

evaluations completed in accordance with 10 CFR 72.48 or the CoC (see also

Section 05.09). 

 • Inspection of a general licensee's 10 CFR 72.212(b) evaluations should be

| completed before the preoperational testing begins. Review of the 72.212(b)

| evaluations (if available) of the ISFSI support pad should be performed before the

support pad is completed. Refer to IP 60856,”Review of 10 CFR 72.212(b)

Evaluations.” 

 • Initial inspection of ISFSI operating procedures (i.e., loading, unloading, abnormal,

and emergency) should be performed before the preoperational testing occurs. A

final inspection, if required, of the licensee's approved procedures should be

completed before the licensee begins to store spent fuel in the ISFSI. Note: Some

licensees may use the dry run (part of the preoperational testing) as a method of

validating these procedures before approving them for use.

 h. After the IIP has been completed, the Regional Branch Chief should provide an

assessment of the IIP and any lessons learned to the SFPO/PM for use in

developing future IIPs.

05.06 Reporting Procedures. Results of inspections conducted by the regional offices shall

be documented in accordance with regional requirements. Results of inspections

conducted by headquarters shall be documented as described below in 05.07. Inspection

reports or inspector notes shall contain the relevant Part 72 docket number and, for sitespecific licensees, the license number. Inspections of Part 72 activities that are combined

with inspection reports of Part 50 activities, for ISFSIs located at reactor sites, shall also

include the relevant Part 72 docket number and, for site-specific licenses, the Part 72

license number. 
Issue Date: 07/14/05 - 9 - MC 2690

05.07 Methods of Documenting Inspection Results for Headquarters-Led Inspections.

Inspection results shall be documented in inspector notes or in narrative report format

depending on inspection outcome. When using inspector notes, NRC Form 591 shall be

used to document the result of the inspection with respect to enforcement status. At SFPO

discretion, narrative reports may be used outside of the situations described below in

05.07(b). 

 a. Each IMC 2690 inspection procedure has a corresponding inspector notes form

that shall be used for inspection planning and for documenting inspection results.

SFPO maintains the files for these forms. Inspector notes do not have to be typed,

but should be legible and should contain: (1) sufficient detail to describe the

inspection that was conducted, including observations; (2) the compliance status

of topics examined during the inspection; (3) the status of follow-up items involving

prior enforcement or reported licensee or vendor events; (4) any additional

information related to violation findings, and completed or anticipated corrective

actions to any identified violations, documented on the NRC Form 591; and (5)

sufficient detail for management and other inspectors to evaluate the licensee's or

vendor’s overall status with respect to implementation of their quality assurance

program. A different inspector should be able to use the inspector notes in

preparing for a subsequent inspection, and to determine whether corrective actions

have been taken.

 b. A narrative report is required for reactive inspections and for findings which may

involve an enforcement conference or escalated enforcement. For escalated

cases, the narrative report should only address the areas in which safety concerns

and violations are identified and all other areas shall be covered in the inspector

notes. Inspector notes must document routine inspection activities that are not

covered in the narrative report. All inspection documentation shall be filed in the

licensee or vendor docket file. 

05.08 Methods of Transmitting Inspection Results. Region-based inspection reports shall

be transmitted to licensees in accordance with regional instructions. For headquarters-led

inspections, results shall be reported to the licensee or vendor by issuing the following: 1)

an NRC Form 591 (in accordance with the guidance in this IP and the Enforcement

Manual), or 2) issuance of a narrative report for those situations described in 05.07(b). 

Inspector notes (used for headquarters-led inspections) shall be reviewed and signed by

the Transportation and Storage Safety and Inspection Section (TSSI) Section Chief and

shall be entered into ADAMS. |

 a. NRC Form 591, "Safety Inspection," shall be used: (1) to document clear

inspections and inspections resulting in Severity Level IV violations (that are neither

willful nor repetitive) that can be corrected while the inspector is present, or that the

licensee or vendor is able to correct easily; and (2) to document non-cited

violations (NCVs), as discussed in the Enforcement Manual, Section 4.3. When the

NRC Form 591 is used to document the results of an inspection, the inspector must

ensure that for each cited and non-cited violation, the form includes a brief

statement of the circumstances, including the date(s) of the violation or NCV and
MC 2690 - 10 - Issue Date: 07/14/05

the facts necessary to demonstrate that a requirement was not met, and reference

to the regulation or license condition that was violated. The inspector shall also

document on the form (as well as in inspector notes) the corrective actions that the

licensee or vendor has taken or plans to take to address each violation identified.

The following are examples of how to document citations on an NRC Form 591: 

 1. Design calculation did not receive required independent review. [10 CFR

72.146(b)] 

 2. Purchased material was not obtained from an approved vendor. [10 CFR

72.154(a)] 

The inspector must also ensure that the findings are documented in the inspector notes

in sufficient detail for the reader to determine what requirement was violated, how it was

violated, who violated the requirement, and when it was violated. If the licensee or

vendor provides corrective action for the violations, this information should also be

included in the inspector notes. In addition, for NCVs, the inspector notes shall document

why the violation was not cited and the corrective action taken or planned. The inspector

will present NRC Form 591 to the licensee or vendor at the conclusion of the exit

interview, or, on rare occasions where consultation with management is necessary, the

inspector may mail NRC Form 591 from the office. 

05.09 Authority to Approve Changes to the ISFSI or DCSS. Effective with a rule change

that became effective April 5, 2001, licensees, vendors and CoC holders are all authorized

|by the provisions of 10 CFR 72.48 to make changes to the ISFSI or DCSS described in the

SAR, to approve changes to procedures described in the SAR, or to perform tests or

experiments not described in the SAR without prior NRC approval. 

2690-06 DEFINITIONS OF INSPECTION FREQUENCIES FOR APPENDIX A AND

B

| 06.01 When Required (W). The inspection effort should be performed when the activity or

event occurs at the facility as specified in Appendices A, B, or the guidance section of

specific inspection procedures.

2690-07 REFERENCES

07.01 NUREG-1571, "Information Handbook on Spent Fuel Storage Installations," 

December 1996 

07.02 NUREG-1536, "Standard Review Plan for Dry Cask Storage System," February 

1997 

07.03 NUREG-1567, "Standard Review Plan for Spent Fuel Storage Facilities," March 

2000 
Issue Date: 07/14/05 - 11 - MC 2690

END

Appendices:

A. "Inspection Program Guidance for Reactor Site ISFSIs"

B. "Inspection Program Guidance for Away From Reactor Site ISFSIs"
MC 2690 - 12 - Issue Date: 07/14/05

Appendix A

INSPECTION PROGRAM GUIDANCE FOR REACTOR SITE ISFSIs

A.SCOPE

This appendix describes the inspection program for ISFSI activities authorized under the

provisions of the general license, or a site-specific license, for an ISFSI located at a Part

50 reactor site. Guidance is provided on the scheduling and conduct of inspections during

various phases of ISFSI activities: design, fabrication, and construction; preoperational

testing; loading and unloading; and storage monitoring. Guidance is also provided on the

frequency of performing periodic inspections once spent fuel has been placed in the ISFSI

for storage. For the purposes of this Appendix, ISFSI activities are viewed as occurring in

the following four phases: (NOTE: Phase 3 and 4 activities may occur concurrently) 

Phase 1 - Design, fabrication, and construction 

Phase 2 - Preoperational testing, including dry runs 

Phase 3 - Spent fuel loading and unloading operations 

Phase 4 - Storage monitoring of the loaded ISFSI 

Because the ISFSI is located at a Part 50 reactor site, the licensee's programs (e.g., quality

assurance, safety evaluations, radiation protection, emergency preparedness, or security)

that support operation of the ISFSI were previously reviewed under the IMC 2500 series

inspection programs. Consequently, for an ISFSI located at a reactor site, the IMC 2690

inspection program has been simplified with regard to reviewing these licensee or applicant

programs. Inspection efforts should be directed at verifying that activities relating to the

ISFSI have been properly incorporated into the existing licensee programs such that a full

reinspection of the licensee's or applicant's programs is not required. In contrast, activities

specifically related to the ISFSI (e.g., DCSS fabrication, support pad construction, and

loading and unloading procedures) are unique and should be reviewed in depth. The scope

and time frame of these inspections should be defined in the IIP (See Section 05.05 of the

IMC).

B.CONDUCT OF ROUTINE INSPECTIONS

Table A-1 provides milestones for completing inspection activities during Phases 1, 2, and

3, before initial storage of spent fuel in the ISFSI. Although performance of these IPs is

mandatory, individual sections may be omitted if the licensee has recently demonstrated

satisfactory performance in the inspected area or if this would duplicate inspection

| activities. The scope and dates of these inspections should be defined in the IIP for specific

| license ISFSIs. 

The completion milestones in Table A-1 should be viewed as "by no-later-than (NLT)" dates

for each IP. Conversely, sections of specific IPs may need to be completed before the

overall milestone specified in Table A-1 due to the need to observe in-process work or

because of weak prior performance in some areas. If several casks are being fabricated

at one time, then the milestone associated with IP 60852 should be completed before the

fabricator finishes manufacturing the last of that series of casks. 
Issue Date: 07/14/05 - 13 - MC 2690

Selected IPs from Table A-1 should be re-performed if a licensee intends to use a new

model or type of DCSS. Specifically, portions of IPs 60854 through 60856 should be reperformed to verify that the licensee can safely use the new model or type of DCSS.

TABLE A-1

IP NUMBER IP SUBJECT NLT MILESTONE

60851 Design control of ISFSI

components

Beginning of fabrication

60852 ISFSI component

fabrication by outside

fabricators

Completion of fabrication

60853 On-Site fabrication of

components and

construction of an ISFSI

Completion of construction

60854 Pre-operational testing of

an ISFSI

Completion of preop

testing

60855 Operation of an ISFSI

(other than initial fuel

loading,

unloading, and

surveillances)

Before loading begins1

60856 Review of 10 CFR

72.212(b)

Evaluations

Completion of preop

testing2

60857 Review of 10 CFR 72.48

evaluations

As needed to support

above IPs

1 Note: All loading and unloading procedures should be reviewed before initial loading of

spent fuel into the ISFSI.

2 Note: Review of the licensee’s 10 CFR 72.212(b) evaluations (if available) of the ISFSI |

support pad should be completed before the licensee begins construction of the support

pad. IP 60856 should be used to accomplish this review.

Subsequent to initial cask loading, Phases 3 and 4 inspection activities should focus on

loading/unloading activities, modifications, 10 CFR 72.48 safety evaluations, 10 CFR

72.212(b) evaluations if new DCSS designs are used, and surveillance monitoring of active

ISFSIs. Inspection guidance for these activities is contained in IPs 60855, 60856, and |

60857. Table A-2 provides guidance on scheduling Phase 3 and 4 inspection activities.

Scheduling and performance of these inspections should be tracked in accordance with

Section 05.05 of this IMC. 
MC 2690 - 14 - Issue Date: 07/14/05

Table A-2

IP NUMBER INSPECTION ACTIVITY FREQUENCY

60855 Loading additional casks (each

occurrence), performing surveillances,

and unloading casks (each occurrence) 

W

60856 First use of different DCSS design W

60857 Modifications to the ISFSI or DCSS

design 

W

Licensee programs that support ISFSI operations are under the Part 50 license and are

subject to periodic reinspection by the IMC 2515 and IMC 2561 programs. Consequently,

these licensee programs that support operation of the ISFSI need not be periodically

reinspected per IMC 2690 until after the Part 50 license has been terminated. These

licensee programs should then be periodically reinspected using the guidance for an AFR

| ISFSI contained in Appendix B.

C. CONDUCT OF REACTIVE INSPECTIONS

The SFPO/PM and the Regional Branch Chief should coordinate with the cognizant 

NRR/PM, as necessary, regarding the conduct of reactive inspections at ISFSIs located 

at Part 50 licensees. Reactive inspections of abnormal situations and events may use the

IPs given in Table A-1. However, this inspection guidance may be supplemented by other

IPs from the IMC 2515 and IMC 2561 inspection programs, as appropriate. The SFPO/PM

and the Regional Branch Chief should coordinate with the cognizant NRR/PM, as

necessary, regarding the conduct of Augmented Inspection Team (AIT) inspections at

ISFSIs located at Part 50 licensees. The conduct of AITs should be per IP 93800,

"Augmented Inspection Team Implementing Procedure." 

END
Issue Date: 07/14/05 - 15 - MC 2690

Appendix B

INSPECTION PROGRAM GUIDANCE FOR AWAY FROM REACTOR SITE ISFSIs

A. SCOPE

This appendix describes the inspection program for away-from-reactor site (AFR) ISFSI 

activities authorized by a site-specific license. Guidance is provided on the scheduling 

and conducting inspections of the applicant's programs that support operation of the 

ISFSI and of design, fabrication, construction, preoperational testing, loading and 

unloading, and storage-monitoring activities. Guidance is also provided on the 

frequency of performing periodic inspections once spent fuel has been placed in the 

ISFSI for storage. For the purposes of this Appendix, AFR ISFSI activities are viewed 

as occurring in the following four phases: (Note: Phases 3 and 4 activities may occur 

concurrently) 

Phase 1 - Design, fabrication, and construction activities 

Phase 2 - Preoperational testing and dry runs 

Phase 3 - Spent fuel loading and unloading operations 

Phase 4 - Storage monitoring of the loaded ISFSI 

B. ISFSI SUPPORT PROGRAM REVIEW

In addition to the inspections described in the following four Phases, inspection of the 

applicant's programs that support operation of the ISFSI should also be performed. 

These programs include, but are not limited, to the following: 

• Quality Assurance Program

• Operations Program

• Maintenance Program

• Radiation Protection Program

• Radioactive Waste Management Program (Radwaste)

• Radiological Effluents and Environmental Monitoring Program (REMP)

• Packaging, Shipping, and Transportation Program

• Emergency Preparedness Program

• Training Program

• Security Program

• Material Control and Accounting Program

• Fitness for Duty Program

• 10 CFR Part 21 Program

• Fire Protection

• Administration

The applicant for a site-specific ISFSI license has provided information on these programs

as part of its application and SAR. After SFPO has reviewed the applicant's programs as

part of the licensing process, a list of the programs that require inspection of implementing

procedures should be provided to the Regional Branch Chief for inclusion as elements in

the IIP for specific license ISFSIs (see Section 05.05 of the IMC). For each program that |

is required to be inspected, SFPO and the Region should identify which NRC Appendix B,
MC 2690 - 16 - Issue Date: 07/14/05

2690 B-2 Issue Date: 12/03/01 Inspection Manual IPs or sections of IPs will be used to

perform the inspections. This information should be included in the IIP. When establishing

the scope of these inspections any questions raised during review of the SAR and the

applicant's previous experience and performance should be considered. Questions on

applicant programs that support operation of the ISFSI should be referred to the SFPO/PM

for further assistance, if required. For timekeeping purposes, all time spent in inspecting

the implementation of these programs should be 

charged to IP 60855. 

C. CONDUCT OF ROUTINE INSPECTIONS

Table B-1 provides milestones for completing inspection activities during Phases 1, 2, and

3, before initial storage of spent fuel in the ISFSI. Although performance of these IPs is

mandatory, individual sections may be omitted if the licensee has recently demonstrated

satisfactory performance in the inspected area or if this would duplicate 

inspection activities. The scope and dates of these inspections should be defined in 

the IIP. 

The completion milestones in Table B-1 should be viewed as "by no-later-than (NLT)" 

dates for each IP. Conversely, sections of specific IPs may need to be completed 

before the overall milestone specified in Table B-1 due to the need to observe inprocess work or because of weak prior performance in some areas. If several casks 

are being fabricated at one time, then the milestone associated with IP 60852 should be

completed before the fabricator finishes manufacturing the last of that series of casks. 

Selected IPs from Table B-1 should be re-performed if a licensee intends to use a new 

model or type of DCSS. Specifically, portions of IPs 60854 through 60856 should be 

re-performed to verify that the licensee can safely use the new model or type of DCSS. 

Subsequent to initial cask loading, Phases 3 and 4 inspection activities should focus on

loading/unloading activities, modifications, 10 CFR 72.48 safety evaluations, 10 CFR 

72.212(b) evaluations if new DCSS designs are used, and surveillance monitoring of 

active ISFSIs. Inspection guidance for these activities is contained in IPs 60851, 60855,

60856, and 60857. Table B-2 provides guidance on scheduling Phase 3 and 4 inspection

activities. Scheduling and performance of these inspections should be tracked in

accordance with Section 05.05 of this IMC. 

During Phases 3 and 4 activities, periodic reinspection of programs reviewed in Part B 

| should be performed at the frequency given in Table B-3. These inspections are intended

to verify that the licensee's programs are still being 

effectively implemented. 
Issue Date: 07/14/05 - 17 - MC 2690

TABLE B-1

IP NUMBER IP SUBJECT NLT MILESTONE

60851 Design control of ISFSI

components 

Beginning of fabrication

60852 ISFSI component

fabrication by outside

fabricators 

Completion of fabrication

60853 On-Site fabrication of

components and

construction of an ISFSI

Completion of construction

60854 Pre-operational testing of

an ISFSI 

Completion of preop

testing

60855 Operation of an ISFSI

(other than initial fuel

loading, unloading, and

surveillances)

Before loading begins1

60857 Review of 10 CFR 72.48

evaluations 

As needed to support

above IPs

1 Note: All loading and unloading procedures should be reviewed before initial loading of

spent fuel into the ISFSI.
MC 2690 - 18 - Issue Date: 07/14/05

Table B-2

IP NUMBER INSPECTION ACTIVITY FREQUENCY

60851 Modifications to the ISFSI W

60855 Loading additional casks

(each occurrence),

performing

surveillances, and

unloading casks (each

occurrence)

W

60856 First use of different DCSS

design 

W

60857 Modifications to the ISFSI

or DCSS design 

W
Issue Date: 07/14/05 - 19 - MC 2690

Table B-3

PROGRAM ACTIVITY FREQUENCY |

Quality Assurance Program Annual Review W |

Fire Protection Program W |

Operational Status of the Emergency

Preparedness Program

W |

Maintaining Occupational Exposures ALARA W |

Inspection of Transportation Activities W |

The Regional Division Director should adjust the inspection frequency of these

inspections based on the licensee's performance and the presence of activity (e.g.,

review of the transportation program should be deferred if no shipments of radioactive

material are occurring). Similarly, the licensee's fire protection program should only be

reinspected if the ISFSI has significant fire hazards (e.g., a radwaste storage area or

maintenance area where flammable liquids are stored). 

D. CONDUCT OF REACTIVE INSPECTIONS

The SFPO/PM and the Regional Branch Chief should coordinate with each other

regarding the conduct of reactive inspections at AFR ISFSIs. Reactive inspections of

abnormal situations and events may use the IPs given in Table B-2. However, this

inspection guidance may be supplemented by other IPs from the IMC 2515 and IMC

2561 inspection programs, as appropriate.

The SFPO/PM and the Regional Branch Chief should coordinate with each other

regarding the conduct of Augmented Inspection Team (AIT) inspections at AFR ISFSIs.

The conduct of AITs should be in accordance with IP 93800, "Augmented Inspection

Team Implementing Procedure."

END
MC 2690 - 20 - Issue Date: 07/14/05

Appendix C

INSPECTION PROGRAM GUIDANCE FOR TRANPORTATION PACKAGINGS

A. SCOPE

This appendix provides a recognition of IP 86001 for the inspection program for the

activities related to design, modification, fabrication, assembly, testing, procurement, repair,

and maintenance of transportation packagings. The primary certificate of compliance

(CoC) holder is responsible for maintaining all permanent records required by 10 CFR Part

71, Subpart H.

B. INSPECTION REQUIREMENTS OF TRANSPORTATION PACKAGINGS

The inspection establishes that these activities are in accordance with commitments and

requirements specified in the CoC, Safety Analysis Report for Packagings (SARP), NRCapproved Quality Assurance (QA) Program for Transportation of Radioactive Materials, and

10 CFR Part 71. Determine that the transportation packaging is safe to use based on

observation

of activities, and examination of permanent quality records and other supporting

documentation. The SARP describes design, fabrication, test, and maintenance

commitments and functions for a given transportation packaging. An additional inspection

guidance is in NUREG/CR-6314, “Quality Assurance Inspections for Shipping and Storage

Containers.” The related document is Regulatory Guide 7.10, "Establishing Quality

Assurance Programs for Packaging Used in the Transport of Radioactive Material."

TABLE C-1

IP NUMBER IP SUBJECT NLT MILESTONE

86001 Design, fabrication,

testing, and maintenance

of transportation

packagings 

Beginning of fabrication

END