ML18332A182
| ML18332A182 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18332A182 (3) | |
Text
Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP): 71130.11, Material Control and Accounting (MC&A)
Inspection Procedure Lead: Glenn Tuttle Estimated Hours to Complete Review: 12 Date Review Completed: 10/31/18
- 1. Results and assessment of review of IMC 308, ROP basis document review Material control and accounting (MC&A) is a key attribute of the security cornerstone in the ROP. Attachment 6 of IMC 0308 contains the basis document for the security cornerstone.
Figure 11 of Attachment 6 contains the basis summary for the MC&A area. MC&A was added to the security cornerstone in 2007 after a series of issues at several power reactors concerning control of special nuclear material (SNM). The basis document remains current and applicable for the MC&A area. No changes to the basis are needed at this time.
- 2. Results and assessment of review of any applicable changes to PIs A three year review by the PI lead did not identify any significant changes to PIs that would impact IP 71130.11.
- 3. Results and assessment of review of any applicable changes to Rules or STSs A three year review of recent STS revisions did not identify any significant changes that would impact IP 71130.11.
A current Part 74 MC&A rulemaking could impact MC&A at power reactors and therefore IP 71130.11. The final rule package was sent to the Commission in October 2018. If the final rule language is approved, the IP will need to be revised to address the revised regulations.
- 4. Results and assessment of review of recent Operating Experience A review of recent Operating Experience Notes did not identify any issues warranting revisions to IP 71130.11.
- 5. Results and assessment of review based on RRPS data (see separate IP 71130.11 Assessment Data file for details of RRPS data)
Adverse trends or outliers noted: Yes RRPS data show a small number of findings over the past 5 years, all Green findings or lower. The small number of findings means the trending across years or by region isnt very meaningful.
The IP estimates 6-12 hours per year. Hours actually expended is consistently above the estimate with a five year average of about 12-24 hours per year. This is consistent with inspector feedback that inspectors require more than 6-12 hours per inspection.
2 Region I inspectors typically expend more hours than the other three regions. Consideration should be given to either increasing estimated hours or reducing required samples.
Roughly 90% of findings appear to be inspector identified.
- 6. Feedback Forms There is an open feedback form, 71130.11-1811, that provides recommendations to re-order and re-word some of the inspection requirements to make the inspection process clearer, and to add additional inspection guidance on physical inventory and review of licensee MC&A procedures. The IP was revised to incorporate the recommendations and was sent out to the regions for comment. Regions I and IV provided additional comments on the revised IP, and those comments were also incorporated, where appropriate. However, a delay in the IP revision process due to an ongoing Part 74 rulemaking effort and other reactor MC&A issues will necessitate resending the IP for concurrence.
- 7. Other Considerations None.
- 8. Results of discussions with regions A call with the regional points of contact (POCs) occurred on 10/23/2018.
There was consensus that the hours of actual onsite inspection effort were above the estimate of 6-12 hours in the IP, which is consistent with the data from the RRPS report.
The callers thought that 12-20 hours was a more reasonable estimate. One POC also suggested that reducing the number of inspection samples (from the current 15) should be considered, or that the 15 inspection samples should be prioritized to ensure inspectors are focused on the most important activities.
There was a discussion of the number of items to verify in Step 02.03 of the IP, and a request for clarification on whether the sample size of 10 fuel assemblies in the spent fuel pool was per site or per unit. The callers discussed the verification effort in general, including the historical basis for the current inspection requirement to verify 10 assemblies.
The POCs discussed the need for clarification of inspection activities related to Nuclear Materials Management and Safeguards System (NMMSS) reporting. The discussion included: (1) the usefulness of requesting NMMSS reports in advance of the inspection; (2) the level of onsite inspection effort needed in reviewing NMMSS reports and verifying the report data; and (3) the need for clarification of the significance of findings related to NMMSS reporting.
One POC also indicated that a number of MC&A issues have been formally raised by inspectors and industry in the past few years, but it appeared that the issues were never addressed, or if they were, resolution was not reflected in changes to the IP. These issues were raised through the report on interaction (ROI) and security frequently asked question (SFAQ) processes. The issues included: (1) the need for examples or minor/more-than-
3 minor findings; (2) the interface between physical security and MC&A; and (3) clarification of inventory requirements and what constitutes a proper inventory. Staff noted that some of these issues should be addressed at the program level, not the IP level, but agreed that any useful information that came out of the issue resolution process should be incorporated in the IP.
Recommendations
- 1. Revise IP 71130.11 as needed to: (1) address recommendations from feedback form 71130.11-1811; (2) address regional POC comments discussed above; and (3) incorporate information from resolution of issues raised by inspectors and industry through past ROIs and SFAQs.