ML20010E852
| ML20010E852 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/2020 |
| From: | Alayna Pearson NRC/NMSS/DFM/IOB |
| To: | Andrea Kock, Ladonna Suggs Division of Fuel Management, NRC/RGN-II/DFFI |
| Ramirez A | |
| Shared Package | |
| ML20010E782 | List: |
| References | |
| Download: ML20010E852 (6) | |
Text
Enclosure 1 Fuel Cycle Annual Operating Experience Report 2019
1.0 Purpose
The Fuel Cycle Operating Experience (FC OpE) Program supports technical and licensing staff, inspectors, and management by providing insights that can inform inspection planning, licensing reviews, and program changes. The purpose of this annual report is to provide an analysis of reported events at fuel cycle facilities and make recommendations to improve fuel cycle programs.
2.0 Discussion
Fuel cycle events included in the FC OpE Program are reported under Title 10 of the Code of Federal Regulations (10 CFR), Part 40.60 Reporting Requirements, 10 CFR Part 70.50 Reporting Requirements, and 10 CFR Part 70 Appendix A, Reportable Safety Requirements.
Table A below shows the total number of events reported for operating fuel cycle facilities between 2007 and 2019. Physical security events are not included in this data set.
Total Number of Events per Facility by Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Framatome 3
3 5
1 2
2 2
1 2
2 0
0 1
B&W Technologies 8
4 2
2 1
2 1
0 3
1 1
1 2
Global Nuclear Fuel 4
5 1
7 13 8
3 2
0 2
1 5
1 4
1 16 10 7
12 5
0 0
0 0
Louisiana Energy Services/
URENCO 0
0 0
0 3
0 1
0 2
1 2
3 4
Nuclear Fuel Services 3
5 6
2 0
1 0
6 1
3 0
3 2
1 2
5 1
2 0
0 1
2 1
3 5
Total number of events per year 22 19 20 18 36 25 14 21 14 11 5
15 21 Table A. Total number of reported events at licensed facilities between 2007 and 2019 2.1 Results of 2019 FC OpE Data Analysis In 2019, the staff received a total of 21 event reports. Of the 21 events, licensees retracted four events after determining that the events did not meet the reporting requirement threshold. Also, licensees reported eight (8) events under 10 CFR 70 Appendix A (c), Concurrent Reports.
Concurrent reports are required to be submitted to the United States Nuclear Regulatory Commission (NRC) when an event will be part of a press release or is required to be reported to other government agencies. Therefore, concurrent reports may not be included in the data
2 analysis. After removing retracted events and concurrent reports, a total of nine (9) events remained to be included in the annual analysis. Of these nine events, three were criticality safety events; four operational safety events (two related to chemical processes and two related to fire safety), and two material control and accountability (MC&A) events.
To identify trends in events reported since 2007, the staff screened the data to remove retracted events, concurrent reports, and events considered as occupational hazards or personal health related issues, such as certain unplanned medical treatments. In the case of unplanned medical treatments, the staff removed those that were caused by personal health issues (e.g.,
low blood sugar, heart attacks) and non-radiological or non-chemical exposure events (e.g., a pinched finger or a fall). After removing these events, the staff retained a total of 183 events for further analysis. Table B shows the resulting number of events per year after screening the data.
Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Screened Events 21 18 16 18 29 17 9
13 12 11 4
6 9
Table B. Number of events included in the analysis Several factors influence the annual number of screened events shown in Table B. Some factors include extended periods of reduced operation or shutdown for multiple facilities between 2012 and 2019 and exemptions from certain reporting requirements in 2017. For instance, in 2012, Honeywell ceased operations in response to Confirmatory Order (EA 157). In late 2016 through early 2017, Westinghouse ceased operations to take corrective actions following an event involving unexpected uranium accumulation. Another example is Honeywells ramp down in operations in 2016 to enter idle status in 2017.
Given these factors, the staff notes any quantitative statistical conclusions based on the annual total number of screened events should be supported by a detailed analysis of the underlying events. For completeness, the staff performed quantitative statistical analyses of the annual total number of events. However, those analyses did not yield any significant or actionable insights. Therefore, the staff focused on the results of the detailed qualitative analyses of performance areas in Sections 2.1.1 and 2.1.2 of this report.
2.1.1 Event Classification Process To further analyze the data for trends and OpE insights, the staff developed an event classification process to categorize and characterize the screened data in Table B. The event classification process consists of three steps:
(1) Determine the applicable performance areas, i.e., areas that align with core inspection procedures;
3 (2) Determine contributing factors that led to the events; and (3) Determine the level of safety significance (see the Office of Nuclear Material Safety and Safeguards (NMSS) Policy and Procedure (P&P) 6-14, Fuel Cycle Operating Experience, for details regarding the screening criteria). The staff performed the screening, during which they considered initial event notification information, applicable 60-day reports and inspection reports.
2.1.2 Performance Area Evaluation Based on the performance areas determined from the first step of the event classification process, the staff analyzed the number of events per year. Figure 2 illustrates the number of events per year by performance area. The plot consistently shows that, on average, there are more criticality safety events per year, followed by operational safety events. In addition, the plot consistently shows that the leading performance area with the highest number of events is criticality safety.
In 2019, the nine events were distributed among criticality safety, operational safety (chemical and fire) and MC&A. Of the three criticality safety events reported in 2019, one involved an unanalyzed condition in the facilitys integrated safety analysis (ISA); one involved an error in the calculation for a criticality item relied for safety (IROFS), and one involved a criticality accident and alarm system (CAAS) unavailability. Of the four operational safety events, two were related to chemical safety, and two were related to fire safety. The two events regarding chemical safety involved configuration management where equipment was not in its specified configuration. One fire safety event involved procedural noncompliance where specified fire administrative IROFS were not followed. The other fire safety event was related to an incident involving a fire inside a drum. Lastly, the two remaining MC&A events involved the loss and subsequent retrieval of material within the facility. The predominant contributing factor for all these reported events continues to be failure or degradation of management measures (e.g.,
configuration management, adherence to procedures).
4 Figure 2. Events per year by performance area 2.1.3 Safety Significance Evaluation All events, regardless of significance, are maintained in the FC OpE Database for future reference, tracking, and trending. However, the staff used the screened data to analyze the safety significance of the events in 2019. The staff rates safety significance from high to low using the criteria described in NMSS P&P 6-14 which is consistent with the NRC Enforcement Policy. Based on the rating criteria, all the events reported during 2019 were of low safety significance.
2.2 FC OpE Program and other Fuel Cycle Initiatives The staff recognizes that greater familiarity with the FC OpE Program will facilitate implementation of any recommendations. Through knowledge management (KM) activities initiated in 2018, licensing and inspection staff became more aware of the FC OpE Program.
Specifically, the staff conducted KM sessions focused on the preparation and execution of inspections while incorporating insights of operating experience and recommended best practices. In addition, other KM sessions provided an overview of the FC OpE database and applicable guidance to leverage in preparation for an inspection or licensing review. With enhanced awareness of the database and guidance available, operating experience was used in the assessment of and proposed improvements to the fuel cycle inspection program as part of the Building a Smarter Fuel Cycle Inspection Program initiative started in 2019 (ADAMS Accession No. ML19074A139). Part of the assessment involved reviewing previous FC OpE reports and the events in the FC OpE database to inform decisions regarding inspection performance areas. The staff recommends continuing to provide KM sessions to ensure staff maintains awareness of the FC OpE Program.
5 In parallel with the initiative to improve the inspection program, the staff executed a similar activity to build a smarter fuel cycle licensing program (ADAMS Accession No. ML19115A011). Once completed, both initiatives will result in reports that recommend changes to inspection procedures and license review guidance documents. Some of these changes may involve providing guidance to inspection and licensing staff on specific technical areas related to criticality, chemical, radiation and fire safety. The staff could apply information from previous FC OpE Program reports and the database to determine on which specific technical areas to provide additional guidance. Therefore, the staff recommends that the resources of the FC OpE Program be further leveraged during the implementation of any recommendations from the smarter inspection and licensing initiatives.
3.0
Conclusions:
Based on the reported events this year the staff concludes:
- 1) An analysis by performance area highlights that the most common areas for reported events continue to be criticality and operational safety. In addition, the staff observed that the events reported under these areas in 2019 were related to unanalyzed conditions, failures of CAAS, and operational safety (e.g. configuration, control, procedural noncompliance, fire incident).
- 2) Similar to previous years, the predominant contributing factors associated with the events in 2019 were failures or degradation of management measures (i.e., configuration management, adherence to procedures).
- 3) Knowledge management sessions on the FC OpE Program raised staff awareness of tools to use while implementing the smarter fuel cycle inspection program initiative.
- 4) The safety significance of events in 2019 was low.
4.0 Recommendations
- 1) The staff should maintain KM sessions on the FC OpE Program for inspection and licensing staff to ensure awareness of the available tools.
- 2) The staff should collaborate with internal stakeholders like licensing and inspection staff to gather feedback on how to further leverage the FC OpE Program and results of the annual Fuel Cycle Oversight Program self-assessment.
- 3) The staff should evaluate the FC OpE Program to determine its scope, including relevant sources of data to inform the OpE report and alignment, as appropriate, with other agency OpE programs.
6
- 4) The staff should continue to study reported events to identify any focus areas, changes, or trends such as those identified in the 2017 and 2018 FC OpE reports
- 5) The staff will monitor the impact of these recommendations through the fuel cycle oversight program self-assessment.