NRC SFST ISG-2: Fuel Retrievability

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.

There is an increasing need to transfer spent fuel from reactor spent fuel pools to dry
Independent Spent Fuel Storage Installations (ISFSIs). These ISFSIs generally consist
of an array of spent fuel storage casks on a licensee’s site and are licensed or approved
under the provisions of 10 CFR Part 72 (Ref. 1). The casks are loaded with spent fuel in
an existing spent fuel pool at the licensee’s site and transferred to the ISFSI storage
pad.

There are two aspects of ready retrieval: 1) the ability to transfer a sealed canister from
the storage cask to either a) a transportation package without unloading the spent fuel
or, b) a spent fuel pool or other facility for unloading and transfer, and 2) if it is not
possible to demonstrate that the spent fuel condition is suitable for transportation, then
there must be the ability to unload a storage cask and either repackage the fuel into a
transportable configuration or to place the fuel in a different storage cask that is
appropriate for future transportation. Both conditions must be met for the storage cask
design to satisfy the requirement of 10 CFR 72.122(l) (for specific and general licensees)
that “storage systems must be designed to allow ready retrieval of spent fuel . . . for
further processing or disposal,” and 10 CFR 72.236(m) (for Certificate of Compliance
holders) that “…consideration should be given to compatibility with removal of the stored
spent fuel from a reactor site, transportation, and ultimate disposition by the Department
of Energy.”

Revision 1