ML20079E064

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Final Decision on Independent Spent Fuel Storage Installation Inspection Program Enhancements - Working Group Recommendations
ML20079E064
Person / Time
Issue date: 03/19/2020
From: Andrea Kock
Division of Fuel Management
To: Mark Franke, Mary Muessle, David Pelton, James Trapp
NRC Region 1, NRC/RGN-II, NRC/RGN-III, NRC Region 4
Tapp J
References
Download: ML20079E064 (3)


Text

March 19, 2020 MEMORANDUM TO: James Trapp, Director Division of Nuclear Materials Safety, RI Mark Franke, Director Division of Reactor Safety, RII David Pelton, Director Division of Nuclear Materials Safety, RIII Mary Muessle, Director Division of Nuclear Materials Safety, RIV FROM: Andrea Kock, Director /A. Kock Electronic RA/

Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUBJECT:

FINAL DECISION ON INDEPENDENT SPENT FUEL STORAGE INSTALLATION INSPECTION PROGRAM ENHANCEMENTS - WORKING GROUP RECOMMENDATIONS This memorandum provides the final decision on recommendations of the working group established to provide risk-informed enhancements to the Independent Spent Fuel Storage Installation (ISFSI) Inspection Program. Thank you for your considerable support and leadership provided to this initiative throughout the entire enhancement process.

The working group completed their work per the direction of the Division of Fuel Management (DFM) Division Director, as described in the working group guidance dated June 4, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19155A273). The working group used probabilistic risk analyses, byproduct material radiation exposure studies, subject matter expertise, operating experience, and lessons learned from 30 years of ISFSI inspection history to inform the recommended revisions to the program.

The results of the working groups assessment and initial recommendations were documented in a memorandum and two enclosures dated October 2, 2010 (ADAMS Accession Nos.

ML19277G895, ML19277G878 and ML19277G879). After further engagement with both internal and external stakeholders including regional office comments and concurrence, the working group updated the recommendations to incorporate the feedback received. The final memorandum and recommendations report can be found at ADAMS Accession No. ML20078P093.

CONTACT: Jeremy E. Tapp, NMSS/DFM 301-415-8047

I endorse the working groups recommendations for a more risk-informed inspection program that includes: 1) a triennial inspection frequency for routine inspections, 2) inspections performed by qualified inspectors using current qualification requirements for ISFSI inspectors or application of a partial qualification option for inspectors that may complete specific aspects of ISFSI inspections, 3) a revised level of effort for each applicable inspection procedure, 4)

ISFSI inspections funded solely by the Spent Fuel Storage and Transportation business line, and 5) follow-on efforts to assess and provide recommendation for enhancement in areas not covered by this effort.

I am requesting a working group member from each region to assist the Inspection and Oversight Branch implement the recommendations through revisions to the inspection manual and procedures in accordance with Inspection Manual Chapter (IMC) 0040, Preparing, Revising and Issuing Documents for the NRC Inspection Manual (ADAMS Accession Nos.

ML18003A122). Please submit names of your proposed working group members to me and Alayna Pearson by April 14, 2020. Completion of the enhancement activities is planned to occur by the end of calendar year 2020 with full implementation of the new ISFSI inspection program starting in calendar year 2021.

Successful implementation of the working groups recommendations will ensure that the NRC maintains focus on its mission while supporting the NRCs vision of becoming a modern, risk-informed regulator by embracing improvements in our decision-making and a graded approach to safety.

cc:

Alayna Pearson, Acting Chief, IOB/DFM/NMSS Jeremy Tapp, IOB/DFM/NMSS

ML20079E064 OFFICE: NMSS/DFM NAME: AKock DATE: 3/19/2020