ML18341A055
| ML18341A055 | |
| Person / Time | |
|---|---|
| Issue date: | 04/01/2019 |
| From: | Dylanne Duvigneaud NRC/NMSS/DFCSE/LOB |
| To: | Margie Kotzalas Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| DDuvigneaud NMSS/FCSE/LOB 415.4010 | |
| References | |
| Download: ML18341A055 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 1, 2019 MEMORANDUM TO: Margie A. Kotzalas, Chief Licensing and Oversight Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards FROM: DyLanne D. Duvigneaud /RA/
Fuel Cycle Operations Engineer Licensing and Oversight Branch Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards
SUBJECT:
WESTINGHOUSE LESSONS LEARNED CLOSEOUT REPORT On July 14, 2016, Westinghouse reported the unplanned accumulation of a significant quantity of special nuclear material in a ventilation scrubber system. Following the event, as part of the U.S. Nuclear Regulatory Commission (NRC) platform of continuous improvement, the NRC staff developed a report entitled, Report on Lessons Learned from Uranium Accumulation in Scrubber and Ventilation Systems at Westinghouse Columbia Fuel Fabrication Facility, dated January 30, 2017, (Agencywide Documents Access and Management System Accession Number ML16330A642). This report identified areas needing further evaluation, specifically:
licensing, inspection, and operating experience. To identify the topics and activities to address the observations in the lessons-learned report, the Westinghouse Lessons-Learned Action Plan was developed. Each action plan item was prioritized as high, medium, or low. The staff addressed the high priority items and any additional items that were related to a high priority item or could be easily completed. Management determined that resources would not be applied to address the lower priority action items. to this memorandum provides a description of the staff's actions to close the high priority action plan items.
Enclosures:
- 1. Westinghouse Lessons Learned Closeout for High Priority Action Items CONTACT: DyLanne Duvigneaud, NMSS/FCSE (301) 415 - 4010
M. Kotzalas 2
SUBJECT:
WESTINGHOUSE LESSONS LEARNED CLOSEOUT REPORT DATED: April 1, 2019 DISTRIBUTION: DDuvigneaud MKotzalas ADAMS Package Accession Number: ML18341A055 OFC FCSE/FLOB FCSE/FLOB NAME DDuvigneaud MKotzalas DATE 3/29/2019 4/01/2019 OFFICIAL RECORD COPY
WESTINGHOUSE LESSONS LEARNED CLOSEOUT FOR HIGH PRIORITY AND RELATED ACTION ITEMS On October 28, 2016, the NRC issued a charter to evaluate lessons learned from recent experiences with significant uranium accumulations in scrubber and ventilation systems at the Westinghouse Columbia Fuel Fabrication Facility (Westinghouse) (Agencywide Document and Management System (ADAMS) Accession Number ML17031A183). The charter directed the staff to seek and incorporate input from stakeholders on the following topics:
- License review process
- Inspection program
- Operating experience program
- Roles and responsibilities of the Division of Fuel Facility Inspection (DFFI) and the Division of Fuel Cycle Safety, Safeguards, and Environmental Review (FCSE)
- Knowledge management On January 30, 2017, the staff issued a publicly available report on the lessons-learned from the Westinghouse event (ADAMS Accession Number ML16330A642). In the report, the staff identified recommendations for further evaluation within the topics listed above. The report focused on recommendations directly associated with the causes of the event. The recommendations were prioritized as high, medium, and low and an action plan was developed.
Each of the topics have specific actions to be taken to address the lessons learned report observations. A description of the topic and the staff's actions to address the topic are provided below.
High Priority Items Develop guidance for examining the technical justification for accident sequences designated as low risk.
The American Nuclear Society (ANS) is developing an integrated safety assessment (ISA) standard that would provide clear guidelines for licensees to perform an ISA and improve the ability to identify those elements which serve as leading indicators of ISA quality. When ANS 57.11, Integrated Safety Assessments for Fuel Cycle Facilities, is issued and endorsed by the NRC, the NRC staff will revise NUREG-1520, Standard Review Plan for Fuel Cycle Facilities License Applications, to clarify review guidance on examining the technical justification for accident sequences designated as low risk. In SRM-SECY-12091, Completeness and Quality of Integrated Safety Analyses, dated, October 12, 2012, the staff is restricted from revising certain topics in NUREG-1520 until an ANS Standard is issued on ISA.
That effort has not been achieved, therefore, a standard cannot be endorsed at this time. The staff is currently engaging with the working group of ANS 57.11 to drive the standard to completion. The work on this standard and subsequent revision to NUREG-1520 will continue in processes outside of this lessons-learned activity. Therefore, this lesson-learned item is complete.
Revise inspection program to modify scope and focus of inspections such that processes with potential for high or intermediate consequences are inspected within specified time.
IMC 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program, Appendix D, Fuel Cycle Facility Inspection Planning, (ADAMS Accession Number ML18099A227) was revised to state that all systems that present a high or intermediate Enclosure 1
2 consequence hazard, albeit the probability of occurrence is low, are inspected at least once every five calendar years. Based on the revision described above, this lesson-learned item is complete.
10 CFR 70.72 changes and ISA Summary updates to support inspection planning and in-depth inspection sampling.
The NRC staff revised IP 88070, Plant Modifications (Annual), (ADAMS Accession Number ML18102A499) and developed IP 88072, Plant Modifications (Triennial), (ADAMS Accession Number ML18102A536). Both of these procedures provide guidance for inspectors on reviewing 10 CFR 70.72 changes and ISA Summary updates to support inspection planning and in-depth inspection sampling. This is to ensure that multiple plant modification are considered in inspection planning. Based on the revision described above, this lesson-learned item is complete.
Enhance the capabilities of the Operating Experience Database and application of the information to the licensing and oversight programs.
The staff generated an internal Operation Experience (OpE) database. The database includes events from 2007 to the present that were reported per Title 10 of the Code of Federal Regulations Part 40, Part 70, and Part 76 reporting requirements. The OpE Database is designed to facilitate the trending and analysis capabilities in order to identify challenging areas that will merit changes to the oversight programs. Based on the above description, this lesson-learned item is complete.
Revise qualification programs to ensure staff has knowledge base to challenge licensees' assumptions.
Revision to the training and qualification manuals (IMC 1246 and IMC 1247) will include specific items tied to questioning attitude, critical thinking, and enhancing technical abilities. Both are currently under management review. Because these revisions will be completed in another NRC process, this lesson-learned item is complete.
Revise guidance and training on use of ISA Summary Updates and development of safety evaluations (SEs).
The NRC staff revised internal staff guidance to support improved knowledge sharing between the NRC headquarters staff and the Region on the development of SEs. This includes reinforcing discussions between Project Managers (PMs) and Project Inspectors about current major licensing activities, events, and inspection findings. The staff guidance was also revised to better define the PM's role in processing the licensees annual ISA Summary since Region II has been assigned responsibility for reviewing the annual ISA Summaries. Based on the above discussion, this lesson-learned item is complete.
3 Related Items Evaluate periodic review of licensing program to identify gaps and support continuous improvement.
NRC staff evaluated its procedures for conducting self-assessments for licensing activities. The staff found the procedures provide adequate guidance. However, to mitigate possible inconsistencies some areas of guidance could be further clarified and expanded. Those revisions have been made to the applicable procedure. Therefore, this lesson-learned items is complete.
Hold technical counterpart meetings of specific disciplines to discuss inspection and licensing issues.
Region II has biannual counterpart meetings in which there is a day dedicated to discussing inspection observations and licensing issues. The staff finds that no additional meetings are needed. Therefore, this lesson-learned items is complete.