ML093010634
| ML093010634 | |
| Person / Time | |
|---|---|
| Issue date: | 10/30/2009 |
| From: | Russell Gibbs NRC/RGN-II/DFFI |
| To: | Killar F Nuclear Energy Institute |
| Mike Raddatz, NMSS, 301-492-3108 | |
| References | |
| Download: ML093010634 (8) | |
Text
October 30, 2009 Mr. Felix M. Killar, Jr.
Manager Fuel Supply and Materials Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006-3708
SUBJECT:
TRANSMITTAL OF CERTAIN REVISED FUEL CYCLE OVERSIGHT PROCESS DRAFT DOCUMENTS FOR REVIEW AND COMMENT
Dear Mr. Killar:
The purpose of this letter is to provide draft Revised Fuel Cycle Oversight Process (RFCOP) documents for review and comment and to facilitate discussions at the next public meeting to be scheduled for January, 2010. The 10 documents listed in Enclosure 1, are presented for review. We have provided document ML Numbers to allow access from the NRC document system (ADAMS) at your convenience. ADAMS is accessible from the U.S. Nuclear Regulatory Commissions (NRC) website at http://www.nrc.gov/reading-rm/adams.html. This letter and the enclosures will also be added to www.regulatons.gov where they can be found by using docket number NRC-2009-0386 in the search field.
These documents provide a significant level of detail to the proposed RFCOP which we anticipate will answer many questions raised at the last public meeting conducted on October 6 & 7, 2009. As the documents are reviewed, please note that much of the content represents implementing level guidance for NRC staff for various elements of the revised process. Therefore, it may be beneficial for the review to focus on information that would have a more direct impact on the NRCs assessment of licensee performance. For example, we suggest that the review focus on Attachments 1 and 2 to the significance determination process and the supplemental inspection procedures. To assist in the review, Enclosure 2 provides a summary for each document. When providing comments on the documents, we request that your comments be specific and that the associated page and paragraph be identified. We will also provide these documents in Microsoft Word format once they are declared as Official Agency Records and made publicly available.
provides the RFCOP Project Schedule which includes a listing of future documents to be developed by the NRC. Note that several important documents are scheduled to be issued for comment before November 13, 2009. Although these documents were originally scheduled for issuance in October 2009, additional time was needed for their development.
In accordance with 10 CFR 2.790 of the NRCs Rules of Practice, a copy of this letter and its enclosure(s) will be available electronically for public inspection in the NRC Public Document Room or from the NRC document system (ADAMS).
Should you have any questions concerning the information provided, please contact me at
(404) 562-4806 or at (301) 492-3120.
Sincerely,
/RA/
Russell A. Gibbs, Team Leader Revised Fuel Cycle Oversight Process Division of Fuel Facility Inspection
Enclosures:
- 1) Document List
- 2) Document Highlights
- 3) Revised List of Major Milestones cc w/ enclosures:
Mr. Charles Vaughn 1433 Avenel Drive Wilmington, NC 28411 Ms. Janet Schlueter, Senior Project Manager Nuclear Energy Institute 1776 I Street NW, Suite 400 Washington, DC 20006-3708 Mr. Michael Boren, Regulatory Compliance Manager United States Enrichment Corporation Paducah Gaseous Diffusion Plant P.O. Box 1410 Paducah, KY 42002-1410 Ms. Lori Butler, General Manager, Environment, Health and Safety GE Hitachi Nuclear Energy 3901 Castle Hayne Rd Wilmington, NC 28401 Mr. Gerard Couture, Manager, Licensing and Regulatory Programs Westinghouse Electric Company 5801 Bluff Rd, Drawer R Columbia, SC 29209
(cc w/enclosures: contd)
Mr. Doug Fogel, Manager, Nuclear Regulatory Affairs United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant P.O. Box 628 Piketon, OH 45661 Mr. Robert Link, Manager, EHS&L AREVA NP, Inc.
2101 Horn Rapids Rd Richland, WA 99354-5102 Mr. Scott Murray, Manager, Licensing and Liabilities COE Nuclear GE Hitachi Nuclear Energy P.O. Box 780 Wilmington, NC 28402 Mr. David Spangler, Manager, Radiation Protection Babcock & Wilcox Nuclear Operations Group P.O. Box 785 Lynchburg, VA 24505 Ms. Jennifer Wheeler, Licensing and ISA Manager Nuclear Fuel Services, Inc.
1205 Banner Hill Rd.
Erwin, TN 37650 Mr. Michael Greeno, Nuclear Regulatory Affairs Manager Honeywell Specialty Materials P.O. Box 430 Metropolis, IL 62960
(cc w/enclosures: contd)
Mr. Doug Fogel, Manager, Nuclear Regulatory Affairs United States Enrichment Corporation Portsmouth Gaseous Diffusion Plant P.O. Box 628 Piketon, OH 45661 Mr. Robert Link, Manager, EHS&L AREVA NP, Inc.
2101 Horn Rapids Rd Richland, WA 99354-5102 Mr. Scott Murray, Manager, Licensing and Liabilities COE Nuclear GE Hitachi Nuclear Energy P.O. Box 780 Wilmington, NC 28402 Mr. David Spangler, Manager, Radiation Protection Babcock & Wilcox Nuclear Operations Group P.O. Box 785 Lynchburg, VA 24505 Ms. Jennifer Wheeler, Licensing and ISA Manager Nuclear Fuel Services, Inc.
1205 Banner Hill Rd.
Erwin, TN 37650 Mr. Michael Greeno, Nuclear Regulatory Affairs Manager Honeywell Specialty Materials P.O. Box 430 Metropolis, IL 62960 DISTRIBUTION:
FCSS r/f PMNS RHannah, RII JLedford, RII MWeber, NMSS CHaney, NMSS MTschiltz, NMSS DDamon, NMSS DMorey, NMSS JDeJesus, NMSS MRaddatz, NMSS PSilva, NMSS MBailey, NMSS FBrown, NRR WDean, NSIR LReyes, RII VMcCree, RII JShea, RII SVias, RII CPayne, RII JHenson, RII DRich, RII MErnstes, RII IHall, RII RBernhard, RII JDiaz, RII OLopez, RII AGooden, RII JFoster, RII RGibson, RII CCarpenter, OE JCai, OE MBurrell, OE SDingbaum, OIG CMarco, OGC RKahler, NSIR MLayton, NSIR LHarris, NSIR CMiller, NSIR Region II Regional Coordinator Region II Administrator's Secretary Region II Division Directors and Deputies Headquarters Operations Officer ML093010621 OFFICE NMSS/FCSS NMSS/FCSS RII/DFFI NAME PJenifer PSilva RGibbs DATE 10/29/2009 10/30/2009 10/30/2009 OFFICIAL RECORD COPY
Document List ML Number IMC1 -RFCOP-Fuel Cycle Significance Determination Process (Provided August 28, 2009)
- Determination of Finding of Greater than Minor Significance ML093010646
- Examples of Minor Performance Deficiencies ML093010685 IMC 2600 Fuel Cycle Facility Assessment Program (Provided August 28, 2009)
Appendix A - Risk-Informed Baseline Inspection Program ML093010686 Appendix B - Supplemental Inspection Program ML093010688 Appendix C - Special and Infrequently Performed Inspections ML093010689 Appendix D - Plant Status ML093010691 Appendix E - Inspection Program Modifications During a Pandemic ML093010693 IMC - 0616 Fuel Cycle Facility Safety And Safeguards Inspection Reports ML093010694 IP2 950X1 Supplemental Inspection For One Or Two White Inputs In A Strategic Performance Area At Fuel Cycle Facilities ML093010695 IP 950X2 Supplemental Inspection For One Degraded Cornerstone Or Any Three White Inputs In A Strategic Performance Area For Fuel Cycle Facilities ML093010696 1 Inspection Manual Chapter 2 Inspection Procedure
DOCUMENT HIGHLIGHTS IMC-RFCOP-SDP, Attachment 1, FCSDP Determination of Findings of Greater than Minor Significance Provides a framework to identify those issues that may be potentially risk-significant and thus require further evaluation.
Process starts with how to determine if the issue is a performance deficiency, and then proceeds through consideration of traditional enforcement, whether the item is more than minor, and concurrent multiple failures.
Includes flow charts of the process.
Directs staff to appropriate appendices for each cornerstone.
Includes tables to document screening information and conclusions. Information in tables can be cut and pasted into inspection report.
IMC-RFCOP-SDP, Attachment 2, Examples of Minor Performance Deficiencies Lists examples of minor performance deficiencies in general areas and by cornerstone.
Several minor examples to be developed later.
Supplemental IP 950X1, Supplemental Inspection for One or Two White Inputs in a Strategic Performance Area at Fuel Cycle Facilities Performed after licensee has completed investigation and determined root and contributing causes Done to assure licensee understands root and contributing causes of issues and adequate extent of cause and condition Done to assure licensees corrective actions are sufficient Review of licensees reviews, not an independent evaluation of the performance deficiency Inadequate consideration of safety culture elements in determination of root or contributing causes could result in separate inspection Supplemental IP 950X2, Supplemental Inspection for One Degraded Cornerstone or any Three White Inputs in a Strategic Performance Area at Fuel Cycle Facilities Performed after licensee has done licensees investigation and determined root and contributing causes Done to assure licensee understands root and contributing causes of issues Independently assess extent of cause and condition Independently determine if safety culture components caused or contributed to white inputs Done to assure licensees corrective actions are sufficient Inadequate consideration of safety culture elements in determination of root or contributing causes could result in separate inspection (PI&R or safety culture)
IMC RFCOP 2600 Appendix A, Baseline Inspection Program Provides description of oversight program Primarily indicative not diagnostic (diagnostic in Supplemental)
Uses ISA risk information Minimum program to be implemented at a licensee with acceptable regulatory performance Inspectable areas based on key attributes of each cornerstone. Inspection to determine whether key attributes satisfactory. Inspectable areas to be determined by an expert panel based on key attributes of safety or security for each cornerstone.
Procedures will specify number of samples to be inspected to consider procedure closed Appendix A to IMC 2600 will be one work product of the expert panel; the current version is a proposed template.
Listing of baseline will be performance-based inspections vs. program inspections (except for problem identification and resolution inspection)
IMC RFCOP 2600 Appendix B, Supplemental Inspection Program Outlines Supplemental Program using three basic supplemental procedures, 950X1, 950X2, and 950X3 (to be developed later)
Supplemental inspections could also include portions of other inspection procedures IMC RFCOP 2600 Appendix C, Infrequently Performed Inspections Lists procedures available beyond baseline procedures May have program procedures from current IMC 2600, Appendix A added IMC RFCOP 2600 Appendix D, Plant Status Activities Outlines plant status activities by resident and project (regional) inspectors Recognizes what now being done to keep up with status, including plant tours and project inspector periodic phone calls Includes debrief of other inspectors by project inspectors after other inspectors return from project inspectors sites IMC RFCOP 2600 Appendix E, Inspection Program in Case of Pandemic Program modifications in case of a pandemic Basically provides what is in Agency Pandemic Plan IMC RFCOP 0616, Inspection Reports No Form 591s Starting point for all findings is a performance deficiency.
Reports for most inspections for a site will be integrated and issued in an integrated report quarterly. Supplemental, Special and Augmented, security, and PI&R inspections will have separate reports.
Only cover letters for security reports will be released to public and it will not give substance of any findings, only list number of green findings if any. It will not include anything about greater than green.
Screening for finding significance will be performed using IMC RFCOP SDP.
Only findings will be discussed in integrated reports - so if no finding, no discussion.
As proposed, for green findings, minimal documentation - Description and Analysis.
Description is a brief discussion of performance deficiency. Analysis is a brief discussion of the appendix of IMC RFCOP SDP used to determine green, how appendix was applied, assumptions used, cornerstone, summary statement that since of very low safety or security significance, no enforcement.
IMC RFCOP SDP will provide flow charts to determine color. If performance deficiency is beyond these flow charts, then the issue will be evaluated by a risk analyst.
As proposed for greater than green or potentially greater than green, there would be a four-part format - Introduction, Description, Analysis, and Enforcement.
The level of detail must allow a knowledgeable reader to reconstruct the decision logic to arrive at the final conclusion.
Minor violations not documented as is the case now (with some exceptions specifically defined)
URIs will remain the same.
No IFIs
Revised Fuel Cycle Oversight Process Major Milestones Documents Due Date to Industry IMC SDP, Appendix A Criticality Safety and Chemical Process Safety, Phase 1 11/13/2009 IMC SDP, Appendix C Fuel Cycle Occupational Radiation Safety Significance Determination Process 11/13/2009 IMC SDP, Appendix D Fuel Cycle Public Radiation Safety Significance Determination Process 11/13/2009 IP 88152, Identification and Resolution of Problems at Fuel Cycle Facilities 11/13/2009 IMC RFCOP-SDP-Attachment 3 FCSDP Significance and Enforcement 1ST Qtr 2010 Review Panel Process IMC RFCOP-SDP-Attachment 4 FCSDP Process for Appealing NRC 1ST Qtr 2010 Characterization of Inspection Findings (SDP Appeal Process)
IMC RFCOP-SDP-Attachment 5 Fuel Cycle Risk Analyst Support 1ST Qtr 2010 Expectations IMC RFCOP-SDP-Appendix E - Physical Security 1ST Qtr 2010 IMC RFCOP-SDP-Appendix F - Material Control and Accounting (MC&A) 1ST Qtr 2010 Enforcement Policy 1ST Qtr 2010 Reactive Inspection Procedures 1ST Qtr 2010 IP 950X3 - Supplemental Inspection for Repetitive Degraded Cornerstones, 1ST Qtr 2010 Multiple Degraded Cornerstones, Multiple Yellow Inputs or One Red Input IMC RFCOP-Basis Document-Phase 2 TBD IMC RFCOP-SDP-Appendix G - Information Security TBD