ML20105A161
| ML20105A161 | |
| Person / Time | |
|---|---|
| Issue date: | 04/14/2020 |
| From: | Eric Michel NRC/RGN-II/DFFI |
| To: | |
| Terry T | |
| Shared Package | |
| ML20105A160 | List: |
| References | |
| Download: ML20105A161 (17) | |
Text
T7: Enhancements to Fuel Cycle and Independent Spent Fuel Storage Installation Oversight Programs Enhancements to the Fuel Cycle Oversight Program Eric Michel Region 2/Division of Fuel Facility Inspection
Orientation
- 10 CFR Part 40 and 10 CFR Part 70 licensees
- Conversion
- Enrichment
- Fabrication 2
Drivers for Change
- The industry continues to evolve Evolution of industry
- Historic changes Holistic review implemented incrementally 3
Fuel Cycle Core Inspections Safety Radiological Facility Function Safeguards Operations Controls Support Material Plant Radiation Maintenance/
Control &
Operations Protection Surveillance Accountability Criticality Physical Environmental Emergency Safety Protection Protection Preparedness Area Information Waste Plant Fire Protection Security Management Modifications Transportation 4
Smarter Inspection Program
- Fast Facts:
- Working Group established and charter issued in April 2019
- Collaboration between Headquarters and Region 2 staff 5
Smarter Inspection Program
- Fast Facts:
- Physical security and information security areas omitted
- Sought significant feedback from stakeholders
- 10 public engagements
- Current program adequate 6
Considerations
- Principles of Good Regulation
- Efficiency
- Independence
- Openness
- Clarity 7
EvaluationInformation Gathering Public Input Violations Expert panel and ranking matrix Operating Performance Experience Reviews Report 8
EvaluationExpert Panel
- Reviewed inspection procedures and manual chapters for:
- Redundancies and gaps
- Opportunities for more efficient use of resources 9
EvaluationPrioritization and Ranking Safety Radiological Facility
- Evaluated eight Operations Safeguards Controls Support program areas Plant Operations Material Control &
Accountability Radiation Protection Maintenance/
Surveillance Criticality Physical Environmental Emergency Safety Protection Protection Preparedness Information Waste Plant Fire Protection Security Management Modifications Transportation 10
EvaluationPrioritization and Ranking
- Evaluated eight program areas against four criteria
- Accident sequences
- Operating experience
- Complexity of regulatory requirements
- Public interest
- Factors were weighted 11
Topics for Consideration
- Reactor engineering inspection benchmarking
- System of annual, focused, and comprehensive inspections designed to increase program flexibility
- Resident inspectors
- Shift some inspection from the region to the senior resident inspectors 12
Topics for Consideration
- Approved Corrective Action Program (CAP)
- Reduce inspection resourcing based on an approved CAP
- Integrated Safety Analysis (ISA)
- Modify the core based on each plants ISA 13
Recommended Tiering 14
Example Recommendations
- Operations (Category 1 facilities)
- Reassigned hours from residents, criticality safety and maintenance, re-emphasized chemical sequences
- Resourcing change: 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />s/year to 90 hour0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />s/year
- Fire Protection (Category 1 facilities)
- New biennial procedure
- Resourcing change: 50 hour5.787037e-4 days <br />0.0139 hours <br />8.267196e-5 weeks <br />1.9025e-5 months <br />s/year to 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />s/year 15
Overall Recommended Results Annual Hours Direct Inspection Category I Category III Uranium Gas Centrifuge Gas Centrifuge Laser Conversion w/CAP Enrichment Current 1672 500 364 708 708 136 Proposed 1502 397 277 573 520 136
% Change -10.2% -20.6% -23.9% -19.1% -26.6% 0.0%
16
Next Steps, and Timeframe
- The NRC will make a final decision and issue a tasking memorandum with the final recommendations report
- Program documents will be revised consistent with the final decision.
- Implement revised programcalendar year 2021 17