Regulatory Guide 3.50: Difference between revisions

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{{Adams
{{Adams
| number = ML14043A080
| number = ML13038A424
| issue date = 09/30/2014
| issue date = 01/31/1982
| title = Rev. 2, Standard Format and Content for a License Application for an Independent Spent Fuel Storage Installation or a Monitored Retrievable Storage Facility
| title = Guidance on Preparing a License Application to Store Spent Fuel in an Independent Spent Fuel Storage Installation
| author name = Parks J
| author name =  
| author affiliation = NRC/RES/DE/RGDB
| author affiliation = NRC/RES
| addressee name =  
| addressee name =  
| addressee affiliation =  
| addressee affiliation =  
| docket =  
| docket =  
| license number =  
| license number =  
| contact person = White B
| contact person =  
| case reference number = DG-3042
| case reference number = TASK FP 907-4
| document report number = RG 3.50, Rev. 2
| document report number = RG-3.050
| package number = ML14042A476
| document type = Regulatory Guide
| document type = Regulatory Guide
| page count = 11
| page count = 8
}}
}}
{{#Wiki_filter:U.S. NUCLEAR REGULATORY COMMISSION                                                       September 2014 OFFICE OF NUCLEAR REGULATORY RESEARCH                                                                   Revision 2 REGULATORY GUIDE                                                                                Technical Lead B. White REGULATORY GUIDE 3.50
{{#Wiki_filter:0  U.S. NUCLEAR REGULATORY COMMISSION                                                                     January 1982 REGULATORY GUIDE
                                    (Draft was issued as DG-3042, dated December 2013)
                        OFFICE OF NUCLEAR REGULATORY RESEARCH
        STANDARD FORMAT AND CONTENT FOR A SPECIFIC
                                                        REGULATORY GUIDE 3.50
      LICENSE APPLICATION FOR AN INDEPENDENT SPENT
                                                              (Task FP 907-4)
              FUEL STORAGE INSTALLATION OR MONITORED
                    GUIDANCE ON PREPARING A LICENSE APPLICATION TO STORE SPENT
                              RETRIEVABLE STORAGE FACILITY
                      FUEL IN AN INDEPENDENT SPENT FUEL STORAGE INSTALLATION
                        INTRODUCTION                                      170 -    Fees for Facilities and Materials Licenses and other Regulatory Services under the Atomic Energy Act Subpart B, "License Application, Form, and Contents,"                          of 1954, as Amended.


==A. INTRODUCTION==
of 10 CFR Part 72, "Licensing Requirements for the Storage of Spent Fuel in an Independent Spent Fuel                          Part 72 provides for a single licensing procedure. The Storage Installation," specifies the information to be                  smooth functioning of this one-step licensing procedure covered in an application for a license to store spent fuel in          requires that the license application be essentially complete an independent spent fuel storage installation (ISFSI).                  in its initial submission. A license under this part will be However, Part 72 does not specify the format to be followed              issued before the start of construction of any physical in the license application. This regulatory guide suggests a             facilities involved. Under this procedure, the final design format acceptable to the NRC staff for submitting the                    details of those ISFSI components, systems, and structures information specified in Part 72 for a license application to            that are important to safety must be available for review store spent fuel in an ISFSI.                                            and evaluation. Part 72 also requires that a site evaluation be provided to ensure that the natural characteristics of the Other regulations applicable to the licensing of spent              site and its environs are sufficiently known and have been fuel storage in an ISFSI are in the following parts of Title 10,        factored into the engineering design of the installation. The
Purpose This regulatory guide provides a description of a standard format and content that the U.S.
  "Energy," of the Code of Federal Regulations:                          document in which this information is presented is a Safety Analysis Report (SAR).
    2 -    Rules of Practice for Domestic Licensing Proceedings
    8 -    Interpretations                                                  Although an applicant may plan to contract with another
    9 -    Public Records                                                organization for the design, construction, and possibly the
    11 -    Criteria and Procedures for Determining Eligibility          operation of the proposed ISFSI, a licensee under Part 72 for Access to or Control over Special Nuclear                cannot delegate to a contractor the responsibility for Material                                                      meeting all applicable regulatory requirement


Nuclear Regulatory Commission (NRC) staff considers acceptable for specific license application for Independent Spent Fuel Storage Installations (ISFSIs) and Monitored Retrievable Storage (MRS)
====s. This means====
facilities.
    19 -    Notices, Instructions and Reports to Workers;                that the applicant must make a commitment that, as the Inspections.                                                  licensee, it will have an adequate staff to ensure that
    20 -    Standards for Protection against Radiation -                  regulatory requirements are met at each stage of the proposed
    21 -    Reporting of Defects and Noncompliance                        project. If the applicant plans to contract with another
    25 -    Access Authorization for Licensee Personnel                  organization for the operation of the proposed ISFSI, the
    51 -    Licensing and Regulatory Policy and Procedures                contractual arrangements must be described in the license for Environmental Protection                                  application. Any subsequent changes in such contractual
    73 -    Physical Protection of Plants and Materials                  arrangements may require an amendment to the license.


Applicable Rules and Regulations
75 -    Safeguards on Nuclear Material-Implementation of US/IAEA Agreement                                              This guide represents a standard format that is acceptable
*     Title 10, Part 72, of the Code of Federal Regulations(10 CFR 72), Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste (Ref. 1), Subpart B, License Application, Form, and Contents, specifies the information that must be in an application for a license to store spent nuclear fuel, high- level radioactive waste, and power-reactor-related greater than Class C (GTCC) waste in an ISFSI or in a MRS facility.
     95 -    Security Facility Approval and Safeguarding of               to the NRC staff for the license application. Conformance National Security Information and Restricted Data              with this guide, however, is not mandatory. License applica-
  150 -    Exemptions and Continued Regulatory Authority                tions with different formats will be acceptable to the staff in Agreement States and in Offshore Waters under              if they provide an adequate basis for the findings required Section 274                                                  for the issuance of a license. However, because it may be USNRC    REGULATORY GUIDES                            Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Regulatory Guides are Issued to describe and make available to the      Attention: Docketing and Service Branch.


Related Guidance
public methods acceptable to the NRC staff of Implementing specific parts -of the Commission's regulations, to delineate tech-      The guides are issued in the following ten broad divisions:
*    Regulatory Guide (RG) 3.62, Standard Format and Content for the Safety Analysis Report for Onsite Storage of Spent Fuel Storage Casks, (Ref. 2), provides guidance on the preparation of the Safety Analysis Report (SAR) for an ISFSI or MRS facility using dry storage. It also provides information on technical specifications that is useful for ISFSIs and MRS facilities
niques used by the staff in evaluating specific problems or postu- lated accidents, or to provide guidance to applicants. Regulatory       1.  Power Reactors                  6. Products Guides are not substitutes for regulations, and compliance with          2. Research and Test Reactors      7. Transportation them is not required. Methods and solutions different from those set     3.  Fuels and Materials Facilities  8. Occupational Health out in the guides will be acceptable If they provide a basis for the    4.  Environmental and Siting        9. Antitrust and Financial Review findings requisite to the issuance or continuance of a permit or        5.  Materials and Plant Protection  10. General license by the Commission.
*     NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance - Financial Assurance, Record Keeping and Timeliness, (Ref. 3), contains guidance on financial assurance for ISFSIs licensed under 10 CFR Part 72.


Written suggestions regarding this guide or development of new guides may be submitted through the NRCs public Web site under the Regulatory Guides document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/contactus.html Electronic copies of this regulatory guide, previous versions of this guide, and other recently issued guides are available through the NRCs public Web site under the Regulatory Guides document collection of the NRC Library at http://www.nrc.gov/reading-rm/doc-collections/. The regulatory guide is also available through the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html, under ADAMS Accession No. ML14043A080. The regulatory analysis may be found in ADAMS
Copies of issued guides may be purchased at the current Government This guide was Issued after consideration of comments received from      Printing Office price. A subscription service for future guides in spe- the Public. Comments and suggestions for improvements In these          cific divisions is available through the Government Printing Office.
under Accession No. ML12087A039 and the staff responses to the public comments on DG-3042 may be found under ADAMS Accession No.ML14043A068.


*    RG 5.55, Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities, (Ref. 4), although it does not specifically address ISFSIs or MRS facilities, contains information that could be useful in developing safeguards contingency plans for these facilities.
guides are encouraged at all times, and guides will be revised, as      Information on the subscription service and current GPO prices may appropriate, to accommodate comments and to reflect new informa-        be obtained by writing the U.S. Nuclear Regulatory Commission, tion or experience.                                                      Washington, D.C. 20555, Attention: Publications Sales Manager.


*    RG 3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities, (Ref. 5), provides format and technical content information for emergency plans which are required by 10 CFR 72.32.
more difficult to locate needed information, the staff                Physical Specifications review time may be longer, and there is a greater likelihood that the staff may regard the license application as incomplete.          1. Paper size: 8h x I Iinches As experience is gained in the licensing of spent fuel                2. Paper stock and ink: Suitable quality in substance, storage, the Commission's requirements for information                paper color, and ink density for handling and reproduction needed in its review of applications for licenses to store            by microfilming or image-cbpying equipment.


*    RG 5.44, Perimeter Intrusion Alarm Systems. (Ref. 6), although it does not specifically address ISFSIs or MRS facilities, contains information that could be useful in developing physical security plans for these facilities.
spent fuel in an ISFSI may change. Revisions of the Commis- sion's needs for information in connection with such                      3. Paper margins:    A margin of no less than 1 inch licensing actions will be conveyed to the industry and the            should be maintained on the top, bottom, and binding side public by (1) amendments to NRC regulations, (2) revisions            of all pages.


*    NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS
to this regulatory guide, (3) issuance of new or revised regulatory guides, and (4) direct communications, as                      4. Printing:
    Programs, (Ref. 7), provides format and technical content information for environmental reports which are required by 10 CFR 72.34.
needed, with an applicant by the NRC staff.


Purpose of Regulatory Guides The NRC issues regulatory guides to describe to the public methods that the staff considers acceptable for use in implementing specific parts of the agencys regulations, to explain techniques that the staff uses in evaluating specific problems or postulated accidents, and to provide guidance to applicants. Regulatory guides are not substitutes for regulations and compliance with them is not required. Methods and solutions that differ from those set forth in regulatory guides will be deemed acceptable if they provide a basis for the findings required for the issuance or continuance of a permit or license by the Commission.
a. Composition:    Text should be single or 11/2 spaced.


Paperwork Reduction Act This regulatory guide contains information collection requirements covered by 10 CFR Part 72 that the Office of Management and Budget (OMB) approved under OMB control number 3150-0132.
Since the preparation of a license application pursuant to Part 72 will be a new experience, prospective applicants                  b. Type face and style:  Suitable for microfilming or are encouraged to meet with representatives of the Division            image-copying equipment.


The NRC may neither conduct nor sponsor, and a person is not required to respond to, an information collection request or requirement unless the requesting document displays a currently valid OMB control number.
of Fuel Cycle and. Material Safety of the Office of Nuclear Material Safety and Safeguards during the development of a                   c. Reproduction: Either mechanical or photographic.


==B. DISCUSSION==
license application to resolve any problems that may arise.           Text should be printed on both sides of the paper with the An early resolution of potential problems is beneficial to all        image printed head to head.
Reason for Revision This revision to RG 3.50 (Revision 2) was issued to conform to the format and content requirements in 10 CFR Part 72, which has been revised several times since Revision 1 was issued, and to update guidance on electronic submissions of applications. In addition, Revision 2 includes editorial changes to improve clarity.


Background RG 3.50 was originally issued in January 1982 to provide an acceptable format for the content of license applications for spent fuel facilities. Revision 1 of this guide was published in September1989 to include MRSs and updates to 10 CFR 72. Revision 1 of RG 3.50 became outdated because it discussed how to submit forms on microfilm and the agency has now moved most of its document submission to electronic form. Most of the guidance that was referenced in Revision 1 has been withdrawn, such as Regulatory Guide 3.44 Standard Format and Content for the Safety Analysis Report for an Independent Regulatory Guide 3.50, Revision 2, Page 2
concerned with the licensing process.


Spent Fuel Storage Installation (Water-Basin Type), and American Nuclear Society Institute (ANSI)
5. Binding: Pages. should be punched for a standard Contents of the License Application                                    3-hole loose-leaf binder.
Standard N299-1976 Administrative and Managerial Control for the Operation of Nuclear Fuel Reprocessing Plants. The information from these referenced documents has been captured in RG 3.62 Standard Format and Content for the Safety Analysis Report for onsite Storage of Spent Fuel Storage Casks and the current version 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.


Harmonization with International Standards The International Atomic Energy Agency (IAEA) has established a series of safety guides and standards constituting a high level of safety for protecting people and the environment. IAEA safety guides present international good practices and increasingly reflects best practices to help users striving to achieve high levels of safety. Pertinent to this regulatory guide, the IAEA safety series does not contain a similar document. The only format and content guidance that IAEA has issued is found in GS-G-4.1, Format and Content of the Safety Analysis Report for Nuclear Power Plants (Ref. 8). This document specifically describes format and content for SARs for nuclear plants, but does not cover spent fuel storage facilities. IAEA Safety Guide SSG-12, Licensing Process for Nuclear Installations (Ref. 9)
The license application is the basic document that must                6. Chapter and page numbering: Each requirement of address each of the requirements of Part 72 and must be                the regulation addressed should be shown as a separate complete in itself. However, the following subjects should            chapter with the same number as the chapter given in this be covered in separate reports that are identified as enclosures      guide, e.g., Chapter 8, "Operator Training." Pages should be to the license application, and the contents of each report            numbered sequentially in each chapter, e.g., 8-1, 8-2, etc.
contains a brief section that lists required contents of a license, but it is not specific to spent fuel storage facilities and it does not provide any detail or format. Lastly, IAEA Safety Guide SSG -15, Storage of Spent Nuclear Fuel (Ref. 10) addresses the design, operation and safety assessment of spent fuel storage facilities as well as the application of safety objectives, principles and criteria to the storage of spent nuclear fuel, but does not provide guidance on the format and content of applications.


C. STANDARD FORMAT AND CONTENT
should be summarized in a brief statement in the license              Do not number the entire document sequentially.
          This regulatory guide provides a format that the NRC considers acceptable for submitting the information for 10 CFR Part 72 license applications to store spent nuclear fuel, high-level radioactive waste, and reactor-related Greater than Class C (GTCC) waste pursuant to a specific license.


Conformance with this guide is not mandatory and the NRC staff will consider a license application with different formats acceptable if it provides an adequate basis for the findings required for the issuance of a license. The staff recommends using the format suggested in this regulatory guide because doing so will allow for a more efficient review by the staff and a potential reduction in the extent or the number of requests for additional information.
application:
                                                                      Procedures for Updating or Revising Pages
        1. Safety Analysis Report
        2. Decommissioning Plan                                            All pages submitted to update, revise, or add to the
        3. Emergency Plan                                              license application should. show the date of change and a
        4. Environmental Report                                        change or amendment number. The changed or revised
        5. Quality Assurance Program                                  portion of each page should be highlighted by a "change
        6. Physical Security Plan                                      indicator" mark consisting of a bold vertical line drawn in
        7. Safeguards Contingency Plan                                the margin opposite the binding side.


1.       Contents of the License Application The license application is the document that should address each of the requirements of
8. Personnel Training Program
10 CFR Part 72 and should be completed upon submittal. The application is required to contain general information about the applicant, pursuant to 10 CFR 72.22. The license application should also include the following documents:
        9. Proposed License Conditions, including Technical            Referenced Materials Specifications
*        SAR (see §72.24 and RG 3.62);
      10. Design for Physical Security                                    Caution should be used in references to information previously filed with the AEC or NRC. Such references Format and Style                                                      must be pertinent to the subject discussed, must contain current information, and must be readily obtainable or The applicant should strive for clear, concise presentation      extractable from the referenced documents. It may be more of the information provided in the application. The applica-          efficient in some cases to repeat in a license application tion should be written in plain English and should be                previously furnished information.
*        Quality assurance (QA) program (see 10 CFR 72.24(n) and 10 CFR Part 72.140 (d));
*        Physical security plan (including guard training) (see 10 CFR 72.24(o), and 10 CFR 72.180);
*        Safeguards contingency plan (see 10 CFR 72.184) ;
*        Proposed technical specifications (see 10 CFR 72.26 and RG 3.62);
*        Applicants technical qualifications (see 10 CFR 72.28);
*        Personnel training program (see 10 CFR 72.28(b));
                                    Regulatory Guide 3.50, Revision 2, Page 3


*        Decommissioning plan and decommissioning funding plan (see 10 CFR 72.30 (a) and 10 CFR
understandable to an educated lay person.
        72.54(g),;
*        Emergency plan (see 10 CFR 72.32),;
*        Environmental report (see 10 CFR 72.34); and
*        Proposed license conditions (see 10 CFR 72.44),.
2.      Format and Style The applicant should strive for a clear, concise presentation of the information provided in the license application. Confusing or ambiguous statements and unnecessarily verbose descriptions do not contribute to expeditious technical review. Claims about the adequacy of designs or design methods should be supported by technical bases (i.e., an appropriate engineering evaluation or description of actual tests). Terms should be used as defined in 10 CFR Part 72, specifically or including 10 CFR 72.3.


If a particular regulatory requirement does not apply to the proposed storage facility, the applicant should use the term Not Applicable instead of omitting the corresponding section. In addition, applicants should justify their decision not to address a particular requirement when its applicability is questionable.
Chapter 1. GENERAL AND FINANCIAL INFORMATION
    Abbreviations should be consistent throughout the license application and its enclosures. Any abbreviations,                The license application should address the requirements symbols, or special terms unique to the proposed activity or          of § 72.14 of 10 CFR Part 72 regarding details on the not in general use should be defined when they first appear.          identity of an applicant. If the applicant is other than the owner or planned operator of the proposed ISFSI, details A title page identifying key individuals responsible for          of the working and contractual arrangements between all the preparation of the license application and the oath              parties involved should be set forth. Any information on required under paragraph 72.11(b) should be included. A              such matters considered as proprietary information by the table of contents should also be included.                           applicant should be identified and submitted under separate
                                                                3.50-2


Appendices to each document in an application should include any appropriate detailed information that was omitted from the main text. The first appendix to a given document in an application should provide a list of documents that are referenced in the text of that application, including page numbers, if appropriate. If a license application references a proprietary document, it should also reference the nonproprietary summary description of that document. Applicants may also use appendices to provide supplemental information such as calculational methods or design approaches used by the applicant.
cover. The      procedures in 10 CFR 2.790(b) should be                basin), its design capacity, any unique features incorporated followed.                                                             in its design, and its mode of operation is adequate for the license application document.


When a license application cites numerical parameters or values, the number of significant figures should reflect the accuracy or precision to which the number is known. When possible, the applicant should specify estimated limits of error or uncertainty. Applicants should not drop or round off significant figures if this action would affect subsequent conclusions.
If the proposed ISFSI is to be built on the site of another licensed activity or facility such as a nuclear power plant,               The SAR required for an ISFSI differs from the SARs details of the working arrangements and responsibilities of           for some other nuclear facilities in that the initial SAR is the licensees involved should be stated. Similarly, if unlicensed      expected *to be complete and comparable in scope and activities are carried out at the proposed site, any potential        detail to the final. SAR for facilities licensed under 10 CFR
interactions between the proposed ISFSI and these other                Part 50. Section 72.15 identifies the minimum information site activities should be explained.                                  that is required to be included in the SAR. Although
                                                                        § 72.50 provides for the subsequent updating of the SAR,
    Paragraph 72.14(e) specifically addresses the required            such changes during the design and construction phases of financial information that must be submitted with the                  the project are expected to be of minor importance. Any of application. If the applicant is a government agency or a              these changes deemed significant by the staff may cause regulated utility, the assumption is made that the applicant          delay in the granting of the final clearance to receive spent is financially qualified for a license under Part 72. If the          fuel.


Applicants should use acronyms, abbreviations, symbols, and special terms consistently throughout a license application and in a manner that is consistent with generally accepted usage. Each document in an application should define any acronyms, abbreviations, symbols, or special terms used in the given section that are unique to the proposed storage system or not common in general usage.
applicant is a corporation organized for the specific purpose of owning and operating the proposed ISFSI, details of its                Guidance on the preparation of the SAR for an ISFSI of organizational structure, including the responsibilities of its        the conventional water-basin type is contained in Regulatory members to meet the financial requirements of the proposed            Guide 3.44, "Standard Format and Content for the Safety ISFSI throughout its proposed operating life and ultimate              Analysis Report for an Independent Spent Fuel Storage decommissioning, must be stated. This requirement is                  Installation (Water-Basin Type)." For the dry storage applicable even if the proposed ISFSI is to be owned and               ISFSI, guidance on the preparation of the SAR is contained operated by a consortium of utilities.                                 in Regulatory Guide 3.48, "Standard Format and Content for the Safety Analysis Report for an Independent Spent Chapter 2. TECHNICAL QUALIFICATIONS                          Fuel Storage Installation (Dry Storage)."
    Paragraph 72.31 (a)(4) and § 72.17 require a finding by the             Chapter 4. CONFORMITY TO GENERAL DESIGN
staff that the applicant is qualified by training and experience                                  CRITERIA
to construct and operate an ISFSI.


Applicants should use drawings, diagrams, sketches, and charts when these media would more accurately or conveniently convey the information. However, applicants should ensure that drawings, diagrams, sketches, and charts present information in a legible and consistent form and define relevant symbols. In addition, applicants should not reduce drawings, diagrams, sketches, and charts to the extent that readers need visual aids to interpret pertinent information.
Subpart F of 10 CFR Part 72 contains the general design Although spent fuel storage in an ISFSI is generally              criteria for an ISFSI. The subject of conformity to the considered a relatively low-risk operation compared to                genera- design. criteria                in o.i.overed  tala 11-the C  A r3.II *
some other types of nuclear activities, the design, construc-          sufficient that the license application contain a summary tion, and operation of an ISFSI require certain skills and an          discussion of each criterion and reference where more understanding of the requirements involved to ensure that             detailed information on a specific subject can be found in the objective of a relatively low-risk operation is achieved in      the SAR.


Applicants should number pages sequentially within each document, section, and appendix. For example, the fourth page of Section six would be numbered 6-4.
practice. The license application should contain a commit- ment that the applicant will staff the project with an                      Chapter 5. OPERATING PROCEDURES; ADMINIS-
adequate cadre of personnel possessing the required skills                    TRATIVE AND MANAGEMENT CONTROLS
throughout all phases of the project. This element of the license. application is in addition to the discussion of the              Paragraph 72.31 (a)(5) requires a finding by the staff that conduct of operations covered in Chapter 9 of the SAR.                the applicant's proposed operating procedures to protect health and to minimize danger to life or property are The licensee is responsible for the execution of the              adequate. Essential to these operating procedures are the proposed project as described in the license application.            applicant's proposed administrative and management This means that, even though much of the actual work                  controls. Guidance on this subject is available in ANSI N299- involved during the site selection, design, procurement, con-          1976, "Administrative and Managerial Control for the struction, and even the operating phases of the project may          Operation of Nuclear Fuel Reprocessing Plants."* Although be performed by a contractor, the licensee must have a staff          ANSI N299-1976 is designed for the much more complex that is knowledgeable in all aspects of the project. If such a        operating requirements of a fuel reprocessing plant, the staff does not actually exist, the applicant should describe          basic principles set forth for administrative and managerial the staffing plans in sufficient detail to support the finding        controls are considered applicable to the operation of an required by paragraph 72.3 l(a)(4).                                  ISFSI. Paragraph 72.15(a)(8) identifies the information that is to be included in the SAR.


A title page should identify key individuals responsible for the preparation of the license application and should include the oath or affirmation as required by 10 CFR 72.16(b). A table of contents should also be included.
Chapter 3. TECHNICAL INFORMATION; SAFETY
                      ANALYSIS REPORT                                      If the proposed ISFSI is to be operated by the owner, a relatively brief explanation of how the requirements of As required by § 72.15, the technical information is              ANSI N299-1976 will be met may be adequate. However, if presented in the SAR, which should be submitted as an enclosure to the license application. A summary statement                *Copies may be obtained from the American National Standards identifying the type of installation proposed (e.g., a water          Institute, Inc., 1430 Broadway, New York, N.Y. 10018.


Regulatory Guide 3.50, Revision 2, Page 4
3.50-3


Applications that do not contain the information described in the regulations may be rejected for review by the NRC.
the proposed ISFSI is to be operated by a contractor, con-          Section 72.51 identifies the inventory and record require- siderable detail will be required on the working arrangements        ments for spent fuel stored at an ISFSI. Because of the between the parties involved. Particular attention should be        uncertainty as to the ultimate disposition of spent fuel placed on the description of the administration of the              stored in an ISFSI, the records on the identity of each fuel Independent Review and Audit Program that is identi-                assembly should be complete. As a minimum, these records fied in ANSI N299-1976.                                              should cover:
      Chapter 6. QUALITY ASSURANCE PROGRAM                                a. Fuel manufacturer, b. Date of manufacture, The quality assurance program required by § 72.80                      c. Reactor exposure history, must be submitted as an enclosure to the application and is                d. Burnup, briefly discussed in Chapter I I of the SAR. It is sufficient              e. Pertinent observations on discharge and during that the license application contain a commitment that                        storage at the reactor, transfer to the ISFSI, and the quality assurance program described is (or will be)                        storage in the ISFSI.


3.        Submissions and Revisions Procedures for Submissions Applications may be submitted either electronically, by mail, or by hand delivery to NRC
understood by all involved in its execution and that the program will be implemented, as applicable, for all phases          If storage of consolidated fuel rods is being considered, of the project, including any activities important to safety        special requirements concerning inventory and recordkeep- that have been carried out prior to submission of the license        ing for stored fuel pins should be described.
headquarters. For details on communications with the NRC, including submitting applications, see 10
CFR 72.4. Detailed guidance on submitting electronic applications and supplements can be found on the NRCs Web site at http://www.nrc.gov/site-help/e-submittals.html; by e-mail to MSHD.Resource@nrc.gov; or by writing to the Office of Information Services, U.S. Nuclear Regulatory Commission, Washington, DC 20555-0001.


The guidance on electronic submissions discusses, among other topics, the formats that the NRC
application.
can accept, the use of electronic signatures, and the treatment of nonpublic information. If electronic submissions are utilized, applicants are encouraged to also send an electronic copy to the pertinent NRC
project manager.


Procedures for Updating or Revising Pages For applicants making electronic submissions, a consolidated document is preferable to submission of individually edited pages and will enable reviewers to have the latest information with minimal effort to print and replace pages.
Chapter


For paper submissions, applicants should update data and text by replacing entire pages whenever a change is made to that page. Applicants should also highlight the updated or revised portion of each page using a change indicator consisting of a bold vertical line drawn in the margin opposite the binding margin.
===9. PHYSICAL PROTECTION===
    This program should cover the engineering aspects of the site investigation, facility design, procurement, shop fabrica-        Subpart H, "Physical Protection," of 10 CFR Part 72 tion, onsite construction, preoperational testing, conduct of        requires that a physical security plan (§ 72.81), a design for operations, and ultimate decommissioning. The emphasis of          physical protection (§ 72.82), and a safeguards contingency this program should be on those activities and items that            plan (§ 72.83) be submitted. Since the details of the are identified as being important to safety. The planned            provisions for physical protection are withheld from public quality assurance effort should be commensurate with the           disclosure, this subject should be covered in separate importance to safety of such identified activities and items.        reports. The license application should contain only a reference to the identity of the reports and when they were Chapter 7. OPERATOR TRAINING                          submitted.


All pages submitted to update, revise, or add pages to an application should show the date of the revision and the corresponding change or amendment number. A transmittal letter, including a guide page listing the pages to be inserted and removed, should accompany the revised pages. When applicable, supplemental pages may follow the revised page, with the pages still being numbered sequentially. Applicants should distinguish between changes made under the change authority in 10 CFR
ISFSI operators are not required to be licensed. However,           Interim guidance regarding the proposed design for they must have a level of qual!ifications and      training in      phy-Jc seclrity and the format and content of the physical subjects and operating procedures applicable to the opera-           security plan can be obtained from the Director, Division of tion of an ISF SI comparable to the requirements of 10 CFR          Safeguards, Office of Nuclear Material Safety and Safe- Part 55 on spent fuel pool operation for licensed operators        guards; U.S. Nuclear Regulatory Commission, Washington, of a reprocessing plant or nuclear power plant. Appropriate        D.C. 20555.
72.48 (c)(1) and amendment to the license or Certificate of Compliance as required by 72.48 (c)(2).
           All statements on a revised page should be accurate as of the date of each submittal. Applicants should take special care to ensure that they revise the documents submitted as part of the application to reflect any changes to the design, contents, analysis, and tests reported in supplemental information (e.g., responses to NRC staff requests for information or responses to regulatory positions).
Referenced Materials Under 10 CFR 72.18, applicants may avoid repetition by incorporating by reference material previously filed with the NRC. However, applicants should use caution in making such references and should ensure that they are pertinent to the subject discussed, contain current information, and are readily obtainable or extractable from the referenced documents. It may be more efficient in some cases to repeat, or summarize, information furnished in the previously submitted document.


Regulatory Guide 3.50, Revision 2, Page 5
documentation of training activities and certifications of proficiency should be included in the ISFSI records.                  Guidance for the safeguards contingency plan is contained Subpart I, "Training and Certification of ISFSI Personnel,"        in Regulatory Guide 5.55, "Standard Format and Content of 10 CFR Part 72 requires that a training program be              of Safeguards Contingency Plans for Fuel Cycle Facilities."
established and that the personnel training program document be included as an enclosure to the license application. A                      Chapter 1


Protection of Proprietary Information The applicant should identify and submit under separate cover any information that it considers proprietary. The requirements in 10 CFR 2.390(b) (Ref. 11) should be followed for such information.
===0. DECOMMISSIONING PLAN===
brief summary of the program. should be included in the application.                                                          Section 72.18 requires the submission of a decommis- sioning plan as part of the license application. A brief In addition to the specific operating requirements of the        description of the decommissioning plan is included in planned facility, the training program should also cover the        Section 9.6 of the SAR. The license application need nuclear engineering principles involved in the safe handling        contain only a brief summary statement, enough to identify and storage of spent fuel and the regulations, regulatory          what will be involved and the basis for the estimated costs guides, and national standards applicable to ISFSI operations.      of decommissioning.


For safeguards information, applicants should also adhere to requirements in 10 CFR 73.21, 10 CFR
Guidance on the content of the required training program is available from the Fuel and Spent Fuel Licensing Branch,               However, the financial provisions for carrying out the Division of Fuel Cycle and Material Safety, Office of              decommissioning plan at the end of useful life of the Nuclear Material Safety and Safeguards, U.S. Nuclear Regu-          proposed ISFSI are not necessarily addressed in the SAR
73.22, and 10 CFR 73.23 as applicable.
latory Commission, Washington, D.C. 20555.                         and must be covered in either the license application or the decommissioning plan.


4.      Further Information General and Financial Information Information on the contents of applications is found in 10 CFR 72.22. Applicants, except for DOE, must provide sufficient information to demonstrate to the Commission that they can satisfy the financial qualifications of activities associated with an ISFSI or MRS facility. This includes but is not limited to: estimated construction costs, estimated operating costs over the planned life of the facility, and estimated decommissioning costs.
Chapter 8. INVENTORY AND RECORDS
                      REQUIREMENTS                                                Chapter 1


Safety Analysis Report Each application for a license should include a SAR as described in 10 CFR 72.24. The information should describe the proposed ISFSI or MRS facility for the receipt, handling, packaging, and storage of spent fuel, high-level radioactive waste and/or reactor related GTCC wast
===1. EMERGENCY PLAN===
    A description of the inventory and records system for             Section 72.19 requires that an emergency plan be the stored fuel should be included in the license application.      provided as part of the license applicatio


====e. Regulatory Guide====
====n. The plan must====
3.62, (Ref. 2), Standard Format and Content for a Safety Analysis Report for Dry Storage of Spent Fuel at an Independent Spent Fuel Storage Installation or Monitored Retrievable Storage Facility, provides additional guidance on the preparation of the SARs for ISFSIs and MRS facilities using dry storage.
                                                              3.50-4


Quality Assurance Program The application should contain either the QA program required by 10 CFR Part 72, Subpart G,
include the information listed in Section IV, "Content of            should be taken to ensure that such references are clear and Emergency Plans," of Appendix E to 10 CFR Part 50.                   explicit.
Quality Assurance (as an enclosure), or should reference a currently NRC-approved QA program. The SAR should briefly describe the QA program. A QA program that has been approved by the NRC as meeting Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities (Ref. 12), may be applied to the ISFSI. Note that 10 CFR 72.140(d) states, A quality assurance program previously approved by the Commission as satisfying the requirements of Appendix B of Part 50 of this chapter, Subpart H to part 71 of this chapter, or Subpart G to this part will be accepted as satisfying the requirements of paragraph (b) of this section, except that a licensee, applicant for a license, certificate holder, and applicant for a CoC who is using an Appendix B or Subpart H quality assurance program shall also meet the record keeping requirement of 72.174. In filing the description of the quality assurance program required by paragraph (c) of this section, each licensee, applicant for license, certificate holder, and applicant for a COC shall notify the NRC, in accordance with section 72.4, of its intent to apply its previously-approved quality assurance program to ISFSI activities or spent fuel storage casks activities. The notification shall identify the previously-approved quality assurance program by date of submittal to the Commission, docket number, and date of Commission approval.


Physical Protection Plan As discussed in 10 CFR 72.24(o), as part of the licensing process, the applicant must submit a physical protection program that satisfies the requirements in 10 CFR Part 72, Subpart H, Physical Protection. Because the details of the provisions for physical protection are withheld from public disclosure, the applicant may submit this document(s) separately from the rest of the application. The Regulatory Guide 3.50, Revision 2, Page 6
Proposed license conditions should address such subjects Chapter 12. ENVIRONMENTAL REPORT                          as:
    Section 72.20 requires that an environmental report be              1. Administrative and management organization; proce- provided as part of the license application. Guidance on the        dures and controls, including review and approval activities;
format and content of an environmental report for an                and auditing and reporting requirements. In particular, the ISFSI may be found in 10 CFR Part 51, "Licensing and                subject of interfaces between the licensee and its contractors Regulatory Policy and Procedures for Environmental                  should be covered.


license application should contain a reference to the submission for the physical security program and the date of NRC approval if the NRC had approved the program before submittal of the application.
Protection."
                                                                        2. Verification of design features that are important to safety. In particular, those quality assurance activities that In the interests of keeping the size of this report within      confirm that design and construction are being carried out reasonable bounds and its structure and language keyed to            in accordance with plans, e.g., inspection hold points, should the general public, it is recommended that a prospective            be covered.


The physical protection plan should describe the design criteria for the physical protection of the proposed ISFSI or MRS facility, the design bases, and how the design bases relate to the design criteria, and should ensure that the physical protection plan meets the requirements in 10 CFR 73.51, Requirements for the physical protection of stored spent nuclear fuel and high-level radioactive waste (Ref. 13).
applicant confer with the NRC staff to obtain definitive guidance on the scope and content of this report.                       3. Test procedures throughout the life of the project.
Safeguards Contingency Plan A safeguard contingency plan is a documented plan to give guidance to licensee personnel in order to accomplish specific defined objectives in the event of threats, theft, or radiological sabotage relating to special nuclear materials or nuclear facilities. As required by 10 CFR 72.184, the licensee shall prepare and maintain a safeguards contingency plan in accordance with Appendix C to 10 CFR Part
73 Nuclear Power Plant Safeguards Contingency Plans. Although RG 5.55, Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities (Ref. 4) relates to a fuel cycle plant, it provides information that might be useful for creating safeguards contingency plans for ISFSIs and MRS
facilities.


Proposed Technical Specifications The regulations in 10 CFR 72.26 Contents of application: Technical specifications, require applications to include proposed technical specifications in accordance with requirements of 10 CFR
Such subjects as conditions applicable to site evaluation, component testing during design and construction, preopera- Chapter 13. PROPOSED LICENSE CONDITIONS                        tional testing prior to startup, and conditions applicable to tests that may be desirable after the commencement of License conditions proposed by an applicant constitute a         operations should be covered.
72.44 License conditions, in addition to a summary statement of the bases of and justifications for these technical specifications. For more information on technical specifications, please review RG 3.62.


Technical Qualifications Title 10 CFR 72.40(a)(4) requires a finding by the NRC that the applicant is qualified through training and experience to operate an ISFSI or MRS facility. Information that the application must include for this purpose can be found in 10 CFR 72.28, Contents of application: Applicants technical qualifications. The licensee is responsible for implementing the proposed project as described in the license application. This means that, even though a contractor may perform much of the actual work involved during the site selection, design, procurement, construction, and even the operating phases of the project, the licensee must have staff that is knowledgeable in all aspects of the project.
commitment by the applicant to take the actions specified therein. Because a license issued pursuant to Part 72 is                4. Functional and operating limits of monitoring instru- issued prior to the commencement of construction, license            ments and limiting control settings.


The application should include the applicants experience to show that it has the technical qualifications to construct and operate (or oversee the construction and operation of) the ISFSI or MRS
conditions cover the entire proposed life of the ISFSI, from site selection through the subsequent phases of design,                  5. Limiting conditions of operation. The functional construction, operation, and ultimate decommissioning.              capabilities or performance levels of equipment and systems that are important to safety should be addressed. The License conditions can be considered in two broad                subject includes setpoint limits on monitoring instruments categories: (1) administrative and management organization           and any controls that may need to be imposed on personnel and controls and (2) technical specifications, Those addressing      access to any part of the installation.
facility. Note that if previous sections have discussed the operating organization and delegations and/or adequately described the minimum skills and experience, the information need not be repeated but may be referenced as appropriate.


Personnel Training Program Applicants should describe a training program in their application as discussed in 10 CFR
administrative and management subjects should be covered in the license application; those addressing technical subjects          6. Surveillance requirements. Such items as the periodic can be covered very briefly in the license application with          inspection of cranes and, for water pools, water purity and appropriate references to Chapter 10 of the SAR. Care                evidence of corrosion should be covered.
72.28(b). Requirements for the personnel training program are in 10 CFR Part 72, Subpart I Training and Certification of Personnel.


Regulatory Guide 3.50, Revision 2, Page 7
3.50-5


Decommissioning Plan and Decommissioning Funding Plan The proposed final decommissioning plan should include all the criteria discussed in 10 CFR
VALUE/IMPACT STATEMENT
72.54(g). Updated and detailed plans must be submitted and approved by the Commission prior to the start of any decommissioning activity. Each application should include a decommissioning plan and decommissioning funding plan that contains sufficient information on proposed practices and procedures for decontamination and decommissioning and associated funding in accordance with the requirements of
1. ACTION                                                           
10 CFR 72.30, Financial assurance and recordkeeping for decommissioning. NUREG-1757, Volume 3, Revision 1, Consolidated Decommissioning Guidance -- Financial Assurance, Recordkeeping and Timeliness, contains additional guidance on financial assurance for ISFSIs licensed under 10 CFR Part
72.


Emergency Plan The applicant should submit a plan for coping with emergencies as discussed in 10 CFR 72.32. If the ISFSI is located on the site of a facility licensed under 10 CFR Part 50, the emergency plan required by 10 CFR 50.47, Emergency plans, satisfies the requirements in 10 CFR 72.32, Emergency Plan.
===3. PROCEDURAL APPROACH===
1.1 Description                                                      3.1 Procedural Alternatives This guide is an updating of the material in -Regulatory              The following are potential NRC procedures that may be Guide 3.24 to correct omissions and reflect regulatory devel-        used to disseminate the information contained in the guide:
opments since Regulatory Guide 3.24 was issued. Regulatory Guide 3.24 was withdrawn on February 27, 1981 (46 FR 14507).             *  Regulation
                                                                          *  Regulatory guide
1.2 Need                                                                  *  Branch position paper
                                                                          *  NUREG-series report There is increasing interest in the nuclear community in the licensing requirements for the storage of spent fuel in an        3.2 Value/Impact of Procedural Alternatives ISFSI. The guide is designed to assist prospective applicants by discussing in more detail specific requirements of Part 72            A regulation is not a suitable means of disseminating the for the license application.                                         explanatory type of information contained in the proposed guide. A NUREG-series report is also not a viable alternative
1.3 Value/Impact                                                      because the proposed guide contains regulatory positions.


Additionally for ISFSIs or MRS facilities that are not located on the site of a nuclear power plant, the guidance in Regulatory Guide 1.101, Emergency Response Planning and Preparedness for Nuclear Power Reactors (Ref. 5), provides useful information for applicants when developing the Emergency Plan for a site-specific ISFSI.
Only a regulatory guide or branch position paper are
  .1.3.1 NRC                                                        considered to be viable alternatives.


Environmental Report The regulations at 10 CFR 72.34, Environmental report, require applicants to submit as part of the license application, an environmental report that satisfies the requirements in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions (Ref. 14), Subpart A, National Environmental Policy ActRegulations Implementing Section 102(2).
The further explanation of the content of license applica-            Branch positions are sometimes presented for guidance tions covering the storage of spent fuel in an ISFSI will be          of this sort. However, because of the limited distribution helpful to the licensing staff in their contacts with potential      within NRC for concurrence, branch positions should be licensees and in the review of these applications when received,      formalized by the issuance of a. regulatory guide. In this particularly during the "mini-review" before docketing of            case, no branch position has been prepared or is anticipated.
Chapter 6 of NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS Programs, (Ref. 6) issued August 2003, provides format and technical content information for the environmental report that is required by 10 CFR 72.34.


Proposed License Conditions According to 10 CFR 72.44, license conditions are required to be included with the license.
such applications.


Applicants may propose license conditions to address design, construction and operation of the facilities.
3.3 Decision on Procedural Approach
    1.3.2 Other Government Agencies


Regulatory Guide 3.50, Revision 2, Page 8
* A regulatory guide should be prepared.


==D. IMPLEMENTATION==
The Tennessee Valley Authority has expressed interest in the storage of spent fuel in an ISFSI and is now trying to         4. STATUTORY CONSIDERATIONS
The purpose of this section is to provide information on how applicants and licensees1 may use this regulatory guide and information regarding the NRC staffs plans for using this guide. In addition, it describes how the NRC staff has complied with the backfitting provisions in 10 CFR 72.62 and issue finality provisions of 10 CFR Part 52.
determine the applicable licensing requirements.


The staff recommends that applicants use the format suggested in this regulatory guide because doing so will allow for a more efficient review by the staff and potentially reduce the extent or the number of staff requests for additional information. Conformance with this guide is not mandatory and the NRC staff will consider license applications with different formats acceptable if they provide an adequate basis for the findings required for the issuance of a license.
4.1 NRC Authority
    1.3.3 Industry Authority for this guide is derived from the Atomic The further explanation of the content of license applica-        Energy Act of 1954, as amended, and the Energy Reorganiza- tions covering the storage of spent fuel in an ISFSI is               tion Act of 1974, as amended, and implemented through thought to be particularly useful to the utilities, which deal        the Commission's regulations.


This regulatory guide applies only to applicants who are not within the scope of entities protected by § 72.62. In addition, the subject matter of this regulatory guide does not concern matters dealing with either of the structures, systems and components of an ISFSI or MRS, or the procedures or organization for operating an ISFSI or MRS. Therefore, the matters addressed in this regulatory guide are not within the scope of the backfitting provisions in § 72.62(a)(1) or (2).
primarily with the NRC Office of Nuclear Reactor Regula- tion and which now will be dealing with the NRC Office of             4.2 Need for NEPA Assessment Nuclear Material Safety and Safeguards, which handles the licensing of spent fuel storage in an ISFSI and operates                  The action is not a major Federal action as defined by somewhat differently.                                                 10 CFR 51(a)(10) and does not require an environmental impact statement.
            This regulatory guide does not apply to entities protected by issue finality provisions in 10 CFR
Part 52 with respect to the matters addressed in this regulatory guide. Although Part 52 combined license applicants and holders may apply for specific ISFSI licenses, the guidance in this regulatory guide is directed to ISFSI applicants and does not make a distinction between ISFSI applicants who are also combined license applicants or holders and ISFSI applicants who are not combined license applicants and holders, and presents no more onerous guidance for ISFSI applicants who are also combined license applicants or holders versus ISFSI applicants who are not combined license applicants and holders.


Accordingly, the NRC concludes that the staffs use of this regulatory guide is not inconsistent with any Part 52 issue finality provisions.
1.3.4 Public There is a need to aid the public in becoming better              5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED
informed on the various aspects of the licensing of spent fuel            REGULATIONS OR POLICIES
storage in an ISFSI. The guide will contribute to meeting this need.                                                                The guide is one of a series of guides that will replace Regulatory Guide 3.24, Other guides in this series include
2. TECHNICAL APPROACH                                                Regulatory Guide 3.44, "Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel The guide is nontechnical in its content.                        Storage Installation (Water-Basin Type)"; Regulatory
                                                              3.50-6


1 In this section, licensees refers to holders of, and the term applications for, the following: (1) special nuclear material licenses under 10 CFR Part 70; (2) Licenses for independent spent fuel storage installations or monitored retrievable storage installations or certificates of compliance for spent fuel storage cask designs under 10 CFR Part 72; and (3) certificates of compliance or approvals or a compliance plan for gaseous diffusion plants under 10 CFR Part 76.
Guide 3.48, "Standard Format and Content for the Safety        6. SUMMARY AND CONCLUSIONS
Analysis Report for an Independent Spent Fuel Storage Installation (Dry Storage)"; and Regulatory Guide 3.49,          The regulatory guide should be issued to meet a current
"Design of an Independent Spent Fuel Storage Installation      need in the written development of the regulatory bases for (Water-Basin Type)."                                          the licensing of spent fuel storage in an ISFSI.


Regulatory Guide 3.50, Revision 2, Page 9
3.50-7


REFERENCES1
UNITED STATES
1.  U.S. Code of Federal Regulations (CFR), Title 10, Energy, Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor- Related Greater Than Class C Waste, U.S. Nuclear Regulatory Commission, Washington, DC.
NUCLEAR REGULATORY COMMISSION
 
    WASHINGTON, 0. C. 20555 POSTAGE AND FEES PAID
2.  Regulatory Guide (RG) 3.62, Standard Format and Content for the Safety Analysis Report for Onsite Storage of Spent Fuel Storage Casks, U.S. Nuclear Regulatory Commission, Washington, DC.
      OFFICIAL BUSINESS                                  U.S. NUCLEAR REGULATORy PENALTY FOR PRIVATE USE, $300                                  COMMISSION
 
                                120  9550,5 5 466  1 op (IS NPC
3.  NUREG-1757, Volume 3, Revision 1Consolidated Decommissioning Guidance -- Financial Assurance, Recordkeeping, and Timeliness, issued February 2012, U.S. Nuclear Regulatory Commission, Washington, DC.
                                ofCm P 7-G GY    SHUTTL EWD:TH
 
                                AP rf3 WASH! NG Tr-N                oC    2r955}}
4.  RG 5.55, Standard Format and Content of Safeguards Contingency Plans for Fuel Cycle Facilities, U.S. Nuclear Regulatory Commission, Washington, DC
5.  RG 3.67, Standard Format and Content for Emergency Plans for Fuel Cycle and Materials Facilities, U.S. Nuclear Regulatory Commission, Washington, DC.
 
6.  RG 5.54, Perimeter Intrusion Alarm Systems, U.S. Nuclear Regulatory Commission, Washington, DC.
 
7.  NUREG-1748, Environmental Review Guidance for Licensing Actions Associated with NMSS
    Programs, issued August 2003, U.S. Nuclear Regulatory Commission, Washington, DC.
 
8.  International Atomic Energy Agency (IAEA) Safety Guide GS-G-4.1, Format and Content of the Safety Analysis Report for Nuclear Power Plants, Vienna, Austria, issued April 2004.2
9.  IAEA Safety Guide SSG-12, Licensing Process for Nuclear Installations, Vienna, Austria, issued November 2010.
 
10. IAEA Safety Guide SSG-15, Storage of Spent Nuclear Fuel, Vienna, Austria, issued March
    2012.
 
11. CFR, Title 10, Energy, Part 2, Rules of Practice for Domestic Licensing Proceedings and Issuance of Orders.
 
12. CFR, Title10, Energy, Part 50, Domestic Licensing of Production and Utilization Facilities.
 
1 Publicly available NRC published documents are available electronically through the NRC Library on the NRCs public Web site at http://www.nrc.gov/reading-rm/doc-collections/ and the NRCs Agencywide Documents Access and Management System (ADAMS) at http://www.nrc.gov/reading-rm/adams.html The documents can also be viewed online or printed for a fee in the NRCs Public Document Room (PDR) at 11555 Rockville Pike, Rockville, MD. For problems with ADAMS, contact the PDR staff at 301-415-4737 or (800) 397-4209; fax (301) 415-3548; or e-mail pdr.resource@nrc.gov.
 
2 Copies of International Atomic Energy Agency (IAEA) documents may be obtained through their Web site:
    www.IAEA.org/ or by writing the International Atomic Energy Agency P.O. Box 100 Wagramer Strasse 5, A-1400
    Vienna, Austria. Telephone (+431) 2600-0, Fax (+431) 2600-7, or E-Mail at Official.Mail@IAEA.org Regulatory Guide 3.50, Revision 2, Page 10
 
13. CFR, Title 10, Energy, Part 73, Physical Protection of Plants and Materials.
 
14. CFR, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.
 
Regulatory Guide 3.50, Revision 2, Page 11}}


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Guidance on Preparing a License Application to Store Spent Fuel in an Independent Spent Fuel Storage Installation
ML13038A424
Person / Time
Issue date: 01/31/1982
From:
Office of Nuclear Regulatory Research
To:
References
TASK FP 907-4 RG-3.050
Download: ML13038A424 (8)
v • d • e


0 U.S. NUCLEAR REGULATORY COMMISSION January 1982 REGULATORY GUIDE

OFFICE OF NUCLEAR REGULATORY RESEARCH

REGULATORY GUIDE 3.50

(Task FP 907-4)

GUIDANCE ON PREPARING A LICENSE APPLICATION TO STORE SPENT

FUEL IN AN INDEPENDENT SPENT FUEL STORAGE INSTALLATION

INTRODUCTION 170 - Fees for Facilities and Materials Licenses and other Regulatory Services under the Atomic Energy Act Subpart B, "License Application, Form, and Contents," of 1954, as Amended.

of 10 CFR Part 72, "Licensing Requirements for the Storage of Spent Fuel in an Independent Spent Fuel Part 72 provides for a single licensing procedure. The Storage Installation," specifies the information to be smooth functioning of this one-step licensing procedure covered in an application for a license to store spent fuel in requires that the license application be essentially complete an independent spent fuel storage installation (ISFSI). in its initial submission. A license under this part will be However, Part 72 does not specify the format to be followed issued before the start of construction of any physical in the license application. This regulatory guide suggests a facilities involved. Under this procedure, the final design format acceptable to the NRC staff for submitting the details of those ISFSI components, systems, and structures information specified in Part 72 for a license application to that are important to safety must be available for review store spent fuel in an ISFSI. and evaluation. Part 72 also requires that a site evaluation be provided to ensure that the natural characteristics of the Other regulations applicable to the licensing of spent site and its environs are sufficiently known and have been fuel storage in an ISFSI are in the following parts of Title 10, factored into the engineering design of the installation. The

"Energy," of the Code of Federal Regulations: document in which this information is presented is a Safety Analysis Report (SAR).

2 - Rules of Practice for Domestic Licensing Proceedings

8 - Interpretations Although an applicant may plan to contract with another

9 - Public Records organization for the design, construction, and possibly the

11 - Criteria and Procedures for Determining Eligibility operation of the proposed ISFSI, a licensee under Part 72 for Access to or Control over Special Nuclear cannot delegate to a contractor the responsibility for Material meeting all applicable regulatory requirement

s. This means

19 - Notices, Instructions and Reports to Workers; that the applicant must make a commitment that, as the Inspections. licensee, it will have an adequate staff to ensure that

20 - Standards for Protection against Radiation - regulatory requirements are met at each stage of the proposed

21 - Reporting of Defects and Noncompliance project. If the applicant plans to contract with another

25 - Access Authorization for Licensee Personnel organization for the operation of the proposed ISFSI, the

51 - Licensing and Regulatory Policy and Procedures contractual arrangements must be described in the license for Environmental Protection application. Any subsequent changes in such contractual

73 - Physical Protection of Plants and Materials arrangements may require an amendment to the license.

75 - Safeguards on Nuclear Material-Implementation of US/IAEA Agreement This guide represents a standard format that is acceptable

95 - Security Facility Approval and Safeguarding of to the NRC staff for the license application. Conformance National Security Information and Restricted Data with this guide, however, is not mandatory. License applica-

150 - Exemptions and Continued Regulatory Authority tions with different formats will be acceptable to the staff in Agreement States and in Offshore Waters under if they provide an adequate basis for the findings required Section 274 for the issuance of a license. However, because it may be USNRC REGULATORY GUIDES Comments should be sent to the Secretary of the Commission, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555, Regulatory Guides are Issued to describe and make available to the Attention: Docketing and Service Branch.

public methods acceptable to the NRC staff of Implementing specific parts -of the Commission's regulations, to delineate tech- The guides are issued in the following ten broad divisions:

niques used by the staff in evaluating specific problems or postu- lated accidents, or to provide guidance to applicants. Regulatory 1. Power Reactors 6. Products Guides are not substitutes for regulations, and compliance with 2. Research and Test Reactors 7. Transportation them is not required. Methods and solutions different from those set 3. Fuels and Materials Facilities 8. Occupational Health out in the guides will be acceptable If they provide a basis for the 4. Environmental and Siting 9. Antitrust and Financial Review findings requisite to the issuance or continuance of a permit or 5. Materials and Plant Protection 10. General license by the Commission.

Copies of issued guides may be purchased at the current Government This guide was Issued after consideration of comments received from Printing Office price. A subscription service for future guides in spe- the Public. Comments and suggestions for improvements In these cific divisions is available through the Government Printing Office.

guides are encouraged at all times, and guides will be revised, as Information on the subscription service and current GPO prices may appropriate, to accommodate comments and to reflect new informa- be obtained by writing the U.S. Nuclear Regulatory Commission, tion or experience. Washington, D.C. 20555, Attention: Publications Sales Manager.

more difficult to locate needed information, the staff Physical Specifications review time may be longer, and there is a greater likelihood that the staff may regard the license application as incomplete. 1. Paper size: 8h x I Iinches As experience is gained in the licensing of spent fuel 2. Paper stock and ink: Suitable quality in substance, storage, the Commission's requirements for information paper color, and ink density for handling and reproduction needed in its review of applications for licenses to store by microfilming or image-cbpying equipment.

spent fuel in an ISFSI may change. Revisions of the Commis- sion's needs for information in connection with such 3. Paper margins: A margin of no less than 1 inch licensing actions will be conveyed to the industry and the should be maintained on the top, bottom, and binding side public by (1) amendments to NRC regulations, (2) revisions of all pages.

to this regulatory guide, (3) issuance of new or revised regulatory guides, and (4) direct communications, as 4. Printing:

needed, with an applicant by the NRC staff.

a. Composition: Text should be single or 11/2 spaced.

Since the preparation of a license application pursuant to Part 72 will be a new experience, prospective applicants b. Type face and style: Suitable for microfilming or are encouraged to meet with representatives of the Division image-copying equipment.

of Fuel Cycle and. Material Safety of the Office of Nuclear Material Safety and Safeguards during the development of a c. Reproduction: Either mechanical or photographic.

license application to resolve any problems that may arise. Text should be printed on both sides of the paper with the An early resolution of potential problems is beneficial to all image printed head to head.

concerned with the licensing process.

5. Binding: Pages. should be punched for a standard Contents of the License Application 3-hole loose-leaf binder.

The license application is the basic document that must 6. Chapter and page numbering: Each requirement of address each of the requirements of Part 72 and must be the regulation addressed should be shown as a separate complete in itself. However, the following subjects should chapter with the same number as the chapter given in this be covered in separate reports that are identified as enclosures guide, e.g., Chapter 8, "Operator Training." Pages should be to the license application, and the contents of each report numbered sequentially in each chapter, e.g., 8-1, 8-2, etc.

should be summarized in a brief statement in the license Do not number the entire document sequentially.

application:

Procedures for Updating or Revising Pages

1. Safety Analysis Report

2. Decommissioning Plan All pages submitted to update, revise, or add to the

3. Emergency Plan license application should. show the date of change and a

4. Environmental Report change or amendment number. The changed or revised

5. Quality Assurance Program portion of each page should be highlighted by a "change

6. Physical Security Plan indicator" mark consisting of a bold vertical line drawn in

7. Safeguards Contingency Plan the margin opposite the binding side.

8. Personnel Training Program

9. Proposed License Conditions, including Technical Referenced Materials Specifications

10. Design for Physical Security Caution should be used in references to information previously filed with the AEC or NRC. Such references Format and Style must be pertinent to the subject discussed, must contain current information, and must be readily obtainable or The applicant should strive for clear, concise presentation extractable from the referenced documents. It may be more of the information provided in the application. The applica- efficient in some cases to repeat in a license application tion should be written in plain English and should be previously furnished information.

understandable to an educated lay person.

Chapter 1. GENERAL AND FINANCIAL INFORMATION

Abbreviations should be consistent throughout the license application and its enclosures. Any abbreviations, The license application should address the requirements symbols, or special terms unique to the proposed activity or of § 72.14 of 10 CFR Part 72 regarding details on the not in general use should be defined when they first appear. identity of an applicant. If the applicant is other than the owner or planned operator of the proposed ISFSI, details A title page identifying key individuals responsible for of the working and contractual arrangements between all the preparation of the license application and the oath parties involved should be set forth. Any information on required under paragraph 72.11(b) should be included. A such matters considered as proprietary information by the table of contents should also be included. applicant should be identified and submitted under separate

3.50-2

cover. The procedures in 10 CFR 2.790(b) should be basin), its design capacity, any unique features incorporated followed. in its design, and its mode of operation is adequate for the license application document.

If the proposed ISFSI is to be built on the site of another licensed activity or facility such as a nuclear power plant, The SAR required for an ISFSI differs from the SARs details of the working arrangements and responsibilities of for some other nuclear facilities in that the initial SAR is the licensees involved should be stated. Similarly, if unlicensed expected *to be complete and comparable in scope and activities are carried out at the proposed site, any potential detail to the final. SAR for facilities licensed under 10 CFR

interactions between the proposed ISFSI and these other Part 50. Section 72.15 identifies the minimum information site activities should be explained. that is required to be included in the SAR. Although

§ 72.50 provides for the subsequent updating of the SAR,

Paragraph 72.14(e) specifically addresses the required such changes during the design and construction phases of financial information that must be submitted with the the project are expected to be of minor importance. Any of application. If the applicant is a government agency or a these changes deemed significant by the staff may cause regulated utility, the assumption is made that the applicant delay in the granting of the final clearance to receive spent is financially qualified for a license under Part 72. If the fuel.

applicant is a corporation organized for the specific purpose of owning and operating the proposed ISFSI, details of its Guidance on the preparation of the SAR for an ISFSI of organizational structure, including the responsibilities of its the conventional water-basin type is contained in Regulatory members to meet the financial requirements of the proposed Guide 3.44, "Standard Format and Content for the Safety ISFSI throughout its proposed operating life and ultimate Analysis Report for an Independent Spent Fuel Storage decommissioning, must be stated. This requirement is Installation (Water-Basin Type)." For the dry storage applicable even if the proposed ISFSI is to be owned and ISFSI, guidance on the preparation of the SAR is contained operated by a consortium of utilities. in Regulatory Guide 3.48, "Standard Format and Content for the Safety Analysis Report for an Independent Spent Chapter 2. TECHNICAL QUALIFICATIONS Fuel Storage Installation (Dry Storage)."

Paragraph 72.31 (a)(4) and § 72.17 require a finding by the Chapter 4. CONFORMITY TO GENERAL DESIGN

staff that the applicant is qualified by training and experience CRITERIA

to construct and operate an ISFSI.

Subpart F of 10 CFR Part 72 contains the general design Although spent fuel storage in an ISFSI is generally criteria for an ISFSI. The subject of conformity to the considered a relatively low-risk operation compared to genera- design. criteria in o.i.overed tala 11-the C A r3.II *

some other types of nuclear activities, the design, construc- sufficient that the license application contain a summary tion, and operation of an ISFSI require certain skills and an discussion of each criterion and reference where more understanding of the requirements involved to ensure that detailed information on a specific subject can be found in the objective of a relatively low-risk operation is achieved in the SAR.

practice. The license application should contain a commit- ment that the applicant will staff the project with an Chapter 5. OPERATING PROCEDURES; ADMINIS-

adequate cadre of personnel possessing the required skills TRATIVE AND MANAGEMENT CONTROLS

throughout all phases of the project. This element of the license. application is in addition to the discussion of the Paragraph 72.31 (a)(5) requires a finding by the staff that conduct of operations covered in Chapter 9 of the SAR. the applicant's proposed operating procedures to protect health and to minimize danger to life or property are The licensee is responsible for the execution of the adequate. Essential to these operating procedures are the proposed project as described in the license application. applicant's proposed administrative and management This means that, even though much of the actual work controls. Guidance on this subject is available in ANSI N299- involved during the site selection, design, procurement, con- 1976, "Administrative and Managerial Control for the struction, and even the operating phases of the project may Operation of Nuclear Fuel Reprocessing Plants."* Although be performed by a contractor, the licensee must have a staff ANSI N299-1976 is designed for the much more complex that is knowledgeable in all aspects of the project. If such a operating requirements of a fuel reprocessing plant, the staff does not actually exist, the applicant should describe basic principles set forth for administrative and managerial the staffing plans in sufficient detail to support the finding controls are considered applicable to the operation of an required by paragraph 72.3 l(a)(4). ISFSI. Paragraph 72.15(a)(8) identifies the information that is to be included in the SAR.

Chapter 3. TECHNICAL INFORMATION; SAFETY

ANALYSIS REPORT If the proposed ISFSI is to be operated by the owner, a relatively brief explanation of how the requirements of As required by § 72.15, the technical information is ANSI N299-1976 will be met may be adequate. However, if presented in the SAR, which should be submitted as an enclosure to the license application. A summary statement *Copies may be obtained from the American National Standards identifying the type of installation proposed (e.g., a water Institute, Inc., 1430 Broadway, New York, N.Y. 10018.

3.50-3

the proposed ISFSI is to be operated by a contractor, con- Section 72.51 identifies the inventory and record require- siderable detail will be required on the working arrangements ments for spent fuel stored at an ISFSI. Because of the between the parties involved. Particular attention should be uncertainty as to the ultimate disposition of spent fuel placed on the description of the administration of the stored in an ISFSI, the records on the identity of each fuel Independent Review and Audit Program that is identi- assembly should be complete. As a minimum, these records fied in ANSI N299-1976. should cover:

Chapter 6. QUALITY ASSURANCE PROGRAM a. Fuel manufacturer, b. Date of manufacture, The quality assurance program required by § 72.80 c. Reactor exposure history, must be submitted as an enclosure to the application and is d. Burnup, briefly discussed in Chapter I I of the SAR. It is sufficient e. Pertinent observations on discharge and during that the license application contain a commitment that storage at the reactor, transfer to the ISFSI, and the quality assurance program described is (or will be) storage in the ISFSI.

understood by all involved in its execution and that the program will be implemented, as applicable, for all phases If storage of consolidated fuel rods is being considered, of the project, including any activities important to safety special requirements concerning inventory and recordkeep- that have been carried out prior to submission of the license ing for stored fuel pins should be described.

application.

Chapter

9. PHYSICAL PROTECTION

This program should cover the engineering aspects of the site investigation, facility design, procurement, shop fabrica- Subpart H, "Physical Protection," of 10 CFR Part 72 tion, onsite construction, preoperational testing, conduct of requires that a physical security plan (§ 72.81), a design for operations, and ultimate decommissioning. The emphasis of physical protection (§ 72.82), and a safeguards contingency this program should be on those activities and items that plan (§ 72.83) be submitted. Since the details of the are identified as being important to safety. The planned provisions for physical protection are withheld from public quality assurance effort should be commensurate with the disclosure, this subject should be covered in separate importance to safety of such identified activities and items. reports. The license application should contain only a reference to the identity of the reports and when they were Chapter 7. OPERATOR TRAINING submitted.

ISFSI operators are not required to be licensed. However, Interim guidance regarding the proposed design for they must have a level of qual!ifications and training in phy-Jc seclrity and the format and content of the physical subjects and operating procedures applicable to the opera- security plan can be obtained from the Director, Division of tion of an ISF SI comparable to the requirements of 10 CFR Safeguards, Office of Nuclear Material Safety and Safe- Part 55 on spent fuel pool operation for licensed operators guards; U.S. Nuclear Regulatory Commission, Washington, of a reprocessing plant or nuclear power plant. Appropriate D.C. 20555.

documentation of training activities and certifications of proficiency should be included in the ISFSI records. Guidance for the safeguards contingency plan is contained Subpart I, "Training and Certification of ISFSI Personnel," in Regulatory Guide 5.55, "Standard Format and Content of 10 CFR Part 72 requires that a training program be of Safeguards Contingency Plans for Fuel Cycle Facilities."

established and that the personnel training program document be included as an enclosure to the license application. A Chapter 1

0. DECOMMISSIONING PLAN

brief summary of the program. should be included in the application. Section 72.18 requires the submission of a decommis- sioning plan as part of the license application. A brief In addition to the specific operating requirements of the description of the decommissioning plan is included in planned facility, the training program should also cover the Section 9.6 of the SAR. The license application need nuclear engineering principles involved in the safe handling contain only a brief summary statement, enough to identify and storage of spent fuel and the regulations, regulatory what will be involved and the basis for the estimated costs guides, and national standards applicable to ISFSI operations. of decommissioning.

Guidance on the content of the required training program is available from the Fuel and Spent Fuel Licensing Branch, However, the financial provisions for carrying out the Division of Fuel Cycle and Material Safety, Office of decommissioning plan at the end of useful life of the Nuclear Material Safety and Safeguards, U.S. Nuclear Regu- proposed ISFSI are not necessarily addressed in the SAR

latory Commission, Washington, D.C. 20555. and must be covered in either the license application or the decommissioning plan.

Chapter 8. INVENTORY AND RECORDS

REQUIREMENTS Chapter 1

1. EMERGENCY PLAN

A description of the inventory and records system for Section 72.19 requires that an emergency plan be the stored fuel should be included in the license application. provided as part of the license applicatio

n. The plan must

3.50-4

include the information listed in Section IV, "Content of should be taken to ensure that such references are clear and Emergency Plans," of Appendix E to 10 CFR Part 50. explicit.

Proposed license conditions should address such subjects Chapter 12. ENVIRONMENTAL REPORT as:

Section 72.20 requires that an environmental report be 1. Administrative and management organization; proce- provided as part of the license application. Guidance on the dures and controls, including review and approval activities;

format and content of an environmental report for an and auditing and reporting requirements. In particular, the ISFSI may be found in 10 CFR Part 51, "Licensing and subject of interfaces between the licensee and its contractors Regulatory Policy and Procedures for Environmental should be covered.

Protection."

2. Verification of design features that are important to safety. In particular, those quality assurance activities that In the interests of keeping the size of this report within confirm that design and construction are being carried out reasonable bounds and its structure and language keyed to in accordance with plans, e.g., inspection hold points, should the general public, it is recommended that a prospective be covered.

applicant confer with the NRC staff to obtain definitive guidance on the scope and content of this report. 3. Test procedures throughout the life of the project.

Such subjects as conditions applicable to site evaluation, component testing during design and construction, preopera- Chapter 13. PROPOSED LICENSE CONDITIONS tional testing prior to startup, and conditions applicable to tests that may be desirable after the commencement of License conditions proposed by an applicant constitute a operations should be covered.

commitment by the applicant to take the actions specified therein. Because a license issued pursuant to Part 72 is 4. Functional and operating limits of monitoring instru- issued prior to the commencement of construction, license ments and limiting control settings.

conditions cover the entire proposed life of the ISFSI, from site selection through the subsequent phases of design, 5. Limiting conditions of operation. The functional construction, operation, and ultimate decommissioning. capabilities or performance levels of equipment and systems that are important to safety should be addressed. The License conditions can be considered in two broad subject includes setpoint limits on monitoring instruments categories: (1) administrative and management organization and any controls that may need to be imposed on personnel and controls and (2) technical specifications, Those addressing access to any part of the installation.

administrative and management subjects should be covered in the license application; those addressing technical subjects 6. Surveillance requirements. Such items as the periodic can be covered very briefly in the license application with inspection of cranes and, for water pools, water purity and appropriate references to Chapter 10 of the SAR. Care evidence of corrosion should be covered.

3.50-5

VALUE/IMPACT STATEMENT

1. ACTION

3. PROCEDURAL APPROACH

1.1 Description 3.1 Procedural Alternatives This guide is an updating of the material in -Regulatory The following are potential NRC procedures that may be Guide 3.24 to correct omissions and reflect regulatory devel- used to disseminate the information contained in the guide:

opments since Regulatory Guide 3.24 was issued. Regulatory Guide 3.24 was withdrawn on February 27, 1981 (46 FR 14507). * Regulation

  • Regulatory guide

1.2 Need * Branch position paper

  • NUREG-series report There is increasing interest in the nuclear community in the licensing requirements for the storage of spent fuel in an 3.2 Value/Impact of Procedural Alternatives ISFSI. The guide is designed to assist prospective applicants by discussing in more detail specific requirements of Part 72 A regulation is not a suitable means of disseminating the for the license application. explanatory type of information contained in the proposed guide. A NUREG-series report is also not a viable alternative

1.3 Value/Impact because the proposed guide contains regulatory positions.

Only a regulatory guide or branch position paper are

.1.3.1 NRC considered to be viable alternatives.

The further explanation of the content of license applica- Branch positions are sometimes presented for guidance tions covering the storage of spent fuel in an ISFSI will be of this sort. However, because of the limited distribution helpful to the licensing staff in their contacts with potential within NRC for concurrence, branch positions should be licensees and in the review of these applications when received, formalized by the issuance of a. regulatory guide. In this particularly during the "mini-review" before docketing of case, no branch position has been prepared or is anticipated.

such applications.

3.3 Decision on Procedural Approach

1.3.2 Other Government Agencies

  • A regulatory guide should be prepared.

The Tennessee Valley Authority has expressed interest in the storage of spent fuel in an ISFSI and is now trying to 4. STATUTORY CONSIDERATIONS

determine the applicable licensing requirements.

4.1 NRC Authority

1.3.3 Industry Authority for this guide is derived from the Atomic The further explanation of the content of license applica- Energy Act of 1954, as amended, and the Energy Reorganiza- tions covering the storage of spent fuel in an ISFSI is tion Act of 1974, as amended, and implemented through thought to be particularly useful to the utilities, which deal the Commission's regulations.

primarily with the NRC Office of Nuclear Reactor Regula- tion and which now will be dealing with the NRC Office of 4.2 Need for NEPA Assessment Nuclear Material Safety and Safeguards, which handles the licensing of spent fuel storage in an ISFSI and operates The action is not a major Federal action as defined by somewhat differently. 10 CFR 51(a)(10) and does not require an environmental impact statement.

1.3.4 Public There is a need to aid the public in becoming better 5. RELATIONSHIP TO OTHER EXISTING OR PROPOSED

informed on the various aspects of the licensing of spent fuel REGULATIONS OR POLICIES

storage in an ISFSI. The guide will contribute to meeting this need. The guide is one of a series of guides that will replace Regulatory Guide 3.24, Other guides in this series include

2. TECHNICAL APPROACH Regulatory Guide 3.44, "Standard Format and Content for the Safety Analysis Report for an Independent Spent Fuel The guide is nontechnical in its content. Storage Installation (Water-Basin Type)"; Regulatory

3.50-6

Guide 3.48, "Standard Format and Content for the Safety 6. SUMMARY AND CONCLUSIONS

Analysis Report for an Independent Spent Fuel Storage Installation (Dry Storage)"; and Regulatory Guide 3.49, The regulatory guide should be issued to meet a current

"Design of an Independent Spent Fuel Storage Installation need in the written development of the regulatory bases for (Water-Basin Type)." the licensing of spent fuel storage in an ISFSI.

3.50-7

UNITED STATES

NUCLEAR REGULATORY COMMISSION

WASHINGTON, 0. C. 20555 POSTAGE AND FEES PAID

OFFICIAL BUSINESS U.S. NUCLEAR REGULATORy PENALTY FOR PRIVATE USE, $300 COMMISSION

120 9550,5 5 466 1 op (IS NPC

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AP rf3 WASH! NG Tr-N oC 2r955


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