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).

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.

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 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

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 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

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

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,

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.

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.