ML19274C637
| ML19274C637 | |
| Person / Time | |
|---|---|
| Issue date: | 10/01/2019 |
| From: | Harrison D Division of Fuel Cycle Safety, Safeguards, and Environmental Review |
| To: | |
| DGHarrison NMSS/FCSE 415.2470 | |
| References | |
| Download: ML19274C637 (19) | |
Text
Building a Smarter Fuel Cycle Facility Inspection Program Donnie Harrison Senior Level Advisor for Risk Assessment Division of Fuel Cycle Safety, Safeguards, and Environmental Review Office of Nuclear Material Safety and Safeguards 10/1/2019 NUPIC Presentation
- Overview of Fuel Cycle Facility Inspection Program
- Summary of Working Group on Building a Smarter Fuel Cycle Facility 10/1/2019 NUPIC Presentation
10 CFR 70 Domestic Licensing of Special Nuclear Material (SNM)
(Pu, U-233, enriched in U-233 or U-235) 10 CFR 70, Subpart H Licensees Authorized to Possess a Critical Mass of SNM
- Additional requirements:
- Perform Integrated Safety Analysis (ISA)
- Meet Performance Requirements
- Identify Items Relied On for Safety (IROFS)
- Apply Management Measures, etc.
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Safety, security, & compliance are licensee responsibility Fuel Cycle Inspection Program:
- Sampling approach to verify licensee continues to operate within their license/regulatory requirements
- Identifies indications of declining safety or safeguards performance 4
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- Inspection Manual Chapter (IMC) 2600 Fuel Cycle Facility Operational Safety and Safeguards Inspection Program
- Core inspection effort
- Reactive, supplemental, and generic safety issue inspections
- Implemented through inspection procedures (IPs)
- Resident inspectors are assigned to High Enriched Uranium (Category I) fuel cycle facilities 10/1/2019 NUPIC Presentation
6 Safety Operations Radiological Controls Facility Support Safeguards Plant Operations Radiation Protection Maintenance/Surveillance Material, Control and Accounting Criticality Safety Environmental Protection Emergency Preparedness Physical Protection Transportation Fire Protection Waste Management Permanent Plant Modifications Information Security 10/1/2019 NUPIC Presentation
- Accomplish agency goals more efficiently and effectively
- IMC 2600 Appendix B (Core Inspection Requirements)
- Review inspection scope, frequency, & resources Safety Operations Radiological Controls Facility Support Safeguards Plant Operations Radiation Protection Maintenance/Surveillance Material, Control and Accounting Criticality Safety Environmental Protection Emergency Preparedness Physical Protection Transportation Fire Protection Waste Management Permanent Plant Modifications Information Security 10/1/2019 NUPIC Presentation
- April 26, 2019 - NRC staff issued the Charter (ML19074A139)
- Conduct holistic assessment of Fuel Cycle inspection program
- Improve effectiveness and efficiency of program inspections (e.g., overlapping inspection areas)
- Look for areas of transformation and innovation while adhering to the NRC Principles of Good Regulations 10/1/2019 NUPIC Presentation
Evaluate changes with regards to NRC mission and NRC Principles of Good Regulations
- Independence
- Clarity
- Openness
- Reliability
- Efficiency 10/1/2019 NUPIC Presentation
- Engage internal and external stakeholders
- Active engagement is the key for success
- Broad range of ideas
- Continuous improvement effort
- Assessment of Inspection Procedures and Support Procedures
- Develop and evaluate recommendations
- Develop report with conclusions and recommendations 10/1/2019 NUPIC Presentation
- Improve efficiency and effectiveness of inspection procedures
- Determine if overlap exists between inspection procedures (examples)
- Operational Safety and Maintenance and Surveillance of Safety Controls
- Operational Safety and Fire Protection (Annual)
- Review frequency of inspections
- Fire Protection - annual vs triennial procedures
- Review roles and responsibilities of Senior Resident Inspectors
- Considering history of sustained compliance 10/1/2019 NUPIC Presentation
Identified Key and Support Inspection Areas
- Key
- Plant Operations*
- Permanent Plant Modifications
- Criticality Safety
- Material Control & Accounting
- Information Security
- Facility Support Areas
- Fire Protection
- Radiation Protection
- Transportation
- Environmental Protection
- Waste Management
- Emergency Preparedness 10/1/2019 NUPIC Presentation
- Maintenance/Surveillance merged into Plant Operations
Considerations in optimizing inspection program
- Maintain a high level of effort on the key performance areas
- Provide flexibility in scheduling and allocating resources, especially for facility support areas
- Cover inspection areas more efficiently and incorporate lessons learned into sampling inspection scope 10/1/2019 NUPIC Presentation
Public Meetings held in May, August, and September (twice), and more are planned
- Next public meeting to discuss draft recommendations planned for November Recommendations for improvements expected by end of year followed by revising the inspection guidance and procedures in 2020 Implement revised program in 2021 10/1/2019 NUPIC Presentation
NRC Lead for Smarter Inspection Program Jonathan Marcano Jonathan.Marcano@nrc.gov 15
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18 (b) The risk of each credible high-consequence event must be limited. Engineered controls, administrative controls, or both, shall be applied to the extent needed to reduce the likelihood of occurrence of the event so that, upon implementation of such controls, the event is highly unlikely or its consequences are less severe than those in paragraphs (b)(1)-(4)
(c) The risk of each credible intermediate-consequence event must be limited.
Engineered controls, administrative controls, or both, shall be applied to the extent needed so that, upon implementation of such controls, the event is unlikely or its consequences are less than those in paragraphs (c)(1)-(4)
(d) In addition, the risk of nuclear criticality accidents must be limited by assuring that under normal and credible abnormal conditions, all nuclear processes are subcritical, including use of an approved margin of subcriticality for safety. Preventive controls and measures must be the primary means of protection against nuclear criticality accidents.
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§70.61(b) - Credible High Consequence Event
§70.61(c) - Credible Intermediate Consequence Event Acute Radiological Chemical Radiological Chemical Worker (1) 100 rem (1 Sv)
(4)(i)
Endangers Life (1) 25 rem (0.25 Sv)
(4)(i)
Irreversible or Serious, Long-Lasting Health Effect Outside Controlled Area (Public)
(2) 25 rem (0.25 Sv)
OR (3)
Intake of 30 mg U in Soluble Form (4)(ii)
Irreversible or Serious, Long-Lasting Health Effect (2) 5 rem (0.05 Sv)
OR (3) 24-Hour Averaged Release of Material Outside Restricted Area 5000x Part 20 App B Table 2 (4)(ii)