After more than 20 years of commercial nuclear power, the Federal Government has yet to develop a broadly supported policy for fulfilling its legal responsibility for the final isolation of high-level radioactive waste. OTA's study concludes that until such a policy is adopted in law, there is a substantial risk that the false starts, shifts of policy, and fluctuating support that have plagued the final isolation program in the past will continue.

Spent Fuel Project Office Interim Staff Guidance - 8

Spent Fuel Project Office, Interim Staff Guidance - 8, Revision 1

Spent Fuel Project Office, Interim Staff Guidance - 8, Revision 2 - Burnup Credit in the Criticality Safety Analyses of PWR Spent Fuel in Transport
and Storage Casks

America’s nuclear waste management program is at an impasse. The Obama Administration’s decision
to halt work on a repository at Yucca Mountain in Nevada is but the latest indicator of a policy that has
been troubled for decades and has now all but completely broken down. The approach laid out under
the 1987 Amendments to the Nuclear Waste Policy Act (NWPA)—which tied the entire U.S. high-level
waste management program to the fate of the Yucca Mountain site—has not worked to produce a

This Memorandum analyzes issues related to the Standard Contract between the U.S. Department of Energy (“DOE”) and the “utilities.” Beginning with a discussion of specific provisions of the Standard Contract, this Memorandum then analyzes the status of lawsuits involving the Standard Contract, reviews issues related to on-site storage of spent fuel and HLW, and assesses the prospects for modifying the current waste-disposal regime through Federal legislation or amendments to the Standard Contract.

This memo sets forth the Office of Standard Contract Management's current estimate of the US Government's liability in connection with the Government's partial breach of the "standard contracts" that it executed pursuant to the NWPA of 1982. The Office of Standard Contract Management estimates that liability, as of today and based on the analysis and qualifications set forth below, to be $15.4 billion.
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This paper, prepared to aid the Blue Ribbon Commission on America’s Nuclear Future in its
deliberations, includes a discussion of the issues that would be faced in the siting, permitting and
licensing of storage and disposal facilities for the “back end” of the commercial nuclear fuel
cycle and for the Department of Energy’s (DOE) high–level radioactive waste. It discusses the
authority that could be employed by non–federal levels of government in supporting or opposing

This Interim Staff Guidance (ISG) provides guidance to the staff for determining if
storage systems to be licensed under 10 CFR Part 72 allow ready retrieval of spent fuel.
This guidance is not a regulation or a requirement.

This Interim Staff Guidance (ISG) provides guidance to the staff on classifying spent nuclear
fuel as either (1) damaged, (2) undamaged, or (3) intact, before interim storage or
transportation. This is not a regulation or requirement and can be modified or superseded by
an applicant with supportable technical arguments.

Revision 2

The closure weld for the outer cover plate for austenitic stainless steel designs may be
inspected using either volumetric or multiple pass dye penetrant techniques subject to the
following conditions:
• Dye penetrant (PT) examination may only be used in lieu of volumetric
examination only on austenitic stainless steels. PT examination should be done
in accordance with ASME Section V, Article 6, “Liquid Penetrant Examination.”
• For either ultrasonic examination (UT) or PT examination, the minimum

Several changes have occurred since the issuance of NUREG-1536, “Standard Review Plan
(SRP) for Dry Cask Storage Systems,” that affect the staff’s approach to confinement
evaluation. The attachment to this ISG integrates the current staff approach into a revision of
ISG-5. The highlights of the changes include:
• Reflects October 1998 revisions to 10 CFR 72.104 and 10 CFR 72.106.
• Expands and clarifies acceptance criteria associated with confinement analysis and
acceptance of “leak tight” testing instead of detailed confinement analysis.

The Standard Review Plan, NUREG-1536, Chapter 5, Section V, 2 recommends that “the
applicant calculate the source term on the basis of the fuel that will actually provide the
bounding source term,” and states that the applicant should, “either specify the minimum initial
enrichment or establish the specific source terms as operating controls and limits for cask use.”
A specified source term is difficult for most cask users to determine and for inspectors to verify.

Staff raised two major issues concerning the adverse effects of fission gases to the gas-mixture
thermal conductivity in a spent fuel canister in a post accident environment. The two major
concerns were: (1) the reduction of the thermal conductivity of the canister gas by the mixing of
fission gases expelled from failed fuel pins and (2) the resultant temperature and pressure rise
within the canister. Since the fission gas is typically of a lower conductivity than the cover gas,

Title 10 of the Code of Federal Regulations (10 CFR) Part 71, Packaging and Transportation of
Radioactive Material, and 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, require that spent nuclear fuel (SNF) remain subcritical in transportation
and storage, respectively. Unirradiated reactor fuel has a well-specified nuclide composition
that provides a straightforward and bounding approach to the criticality safety analysis of

The purpose of this ISG is to clarify the technical criteria for types of materials that will be |
considered associated with the storage of spent fuel assemblies. While control rods are |
mentioned in the Standard Review Plan as possible contents, specific information and guidance
is lacking.

Revision 1

There is no existing American Society of Mechanical Engineers (ASME) Code for the design
and fabrication of spent fuel dry storage casks. Therefore, ASME Code Section III, is
referenced by NUREG-1536, “Standard Review Plan for Dry Cask Storage Systems,” as an
acceptable standard for the design and fabrication of dry storage casks. However, since dry
storage casks are not pressure vessels, ASME Code Section III, cannot be implemented
without allowing some alternatives to its requirements.

Revision 1

The staff has broadened the technical basis for the storage of spent fuel including assemblies
with average burnups exceeding 45 GWd/MTU. This revision to Interim Staff Guidance No. 11
(ISG-11) addresses the technical review aspects of and specifies the acceptance criteria for
limiting spent fuel reconfiguration in storage casks. It modifies the previous revision of the ISG
in three ways: (1) by clarifying the meaning of some of the acceptance criteria contained in

Fuel rod buckling analyses under bottom end drop conditions have traditionally been performed
to demonstrate integrity of the fuel following a cask drop accident. The methodology described
by Lawrence Livermore National Laboratory (LLNL) to analyze the buckling of irradiated spent
fuel assembly under a bottom end drop in their report UCID-21246 is a simplified approach. It
assumed that buckling occurred when the fuel rod segment between the bottom two spacer
grids reached the Euler buckling limit. The weight of fuel pellets was neglected in the analysis;

The purpose of this guidance is to, (1) clarify the meaning of a real individual as used in 10
CFR 72.104, (2) specify how the applicant may perform dose evaluations beyond the controlled
area for site-specific and general Independent Spent Fuel Storage Installation (ISFSI) licenses,
and (3) clarify standard review plan (SRP) text regarding dose calculations outside the
controlled area.

Guidance regarding supplemental shielding that may be installed at an independent
spent fuel storage installation (ISFSI) to meet the requirements of 10 CFR 72.104(a).

Due, in part, to a number of material-related issues identified during dry cask storage system
(DCSS) and transportation package application reviews and field implementation, the staff has
recognized the need for specific guidance for the review of materials selected by the applicant
for its DCSS or transportation package.