ML20105A164

RIC 2020 ISFSI Inspection Program Enhancement 3-5-2020

ML20105A164
Person / Time
Issue date:	04/14/2020
From:	Jeremy Tapp Division of Fuel Management
To:
Terry T
Shared Package
ML20105A160	List: ML20105A161 ML20105A163 ML20105A164 ML20105A165
References
Download: ML20105A164 (15)

Text

T7: Enhancements to Fuel Cycle and Independent Spent Fuel Storage Installation Oversight Programs ISFSI Inspection Program Enhancement Initiative Overview Jeremy Tapp Office of Nuclear Material Safety and Safeguards Division of Fuel Management

Background

• Internal feedback to provide a more risk-informed independent spent fuel storage installation (ISFSI) inspection program

• The Nuclear Energy Institute submitted one recommendation in their letter on Reactor Oversight Process enhancements (September 19, 2018) regarding ISFSI inspection

• Initiated a proactive review to enhance the ISFSI inspection program in June 2019

ISFSI Enhancement Working Group A working group of NRC regional ISFSI inspectors and NRC Headquarters staff was formed to evaluate and enhance the NRCs existing ISFSI inspection program by developing a clearer, more risk-informed, comprehensive, and consistent approach to ISFSI inspections across the four regions that focuses on those areas most important to safety

• Working Group Charter, Agencywide Documents Access and Management System (ADAMS) Accession No. ML19155A273

ISFSI Enhancement Scope

• Oversight of ISFSI operations:

o Onsite component construction o Dry runs o Loading o Monitoring

• Not in scope of review:

o Transportation o Vendor inspections o Aging management o Security

Focus Areas of ISFSI Program The working group identified five safety focus areas:

• Occupational dose

• Public dose/exposure

• Fuel damage

• Confinement/canister integrity

• Impact to plant operation

Areas Reviewed for Potential Enhancement

• Application of risk insights (methodology) o Frequency of inspections o Level of effort

• Qualification and training

Methodology

• Holistic approach to develop a more risk-informed, performance-based ISFSI program that takes into account information from o Probabilistic models ISFSI pilot probabilistic risk assessmentNUREG-1864 Materials systems risk analysisNUREG/CR-6642 o Operating experience o Subject matter expertise

• Evaluated all ISFSI inspection procedures and ranked the risk of each inspection activity according to the five safety focus areas o Risk prioritization tool to help inspectors identify and focus inspections on the most risk-significant items

Key Considerations

• A comprehensive and objective review to develop a more risk informed inspection program to focus on those areas most important to safety

• Increase in inspection for risk-significant activities and decrease in other activities

• Greater flexibility to perform inspections during more risk significant ISFSI operations

• Recommendations considered varied stakeholder feedback

Working Group Recommendations Inspection Frequencies

• Informed by operating experience, subject matter expertise, and risk insights, which included the fixed radiographic installation and irradiator facility inspection frequencies o Proposed Program Routine inspectionstriennial cycle Extended loading campaignquarterly until complete All other inspection frequenciesas needed o Current Program Routine inspectionsevery 2 years, not to exceed 3 years All other inspection frequenciesas needed

Working Group Recommendations Formal qualification and training specific for ISFSI inspectors

• Applicable to regional or resident inspectors

• Cross-qualification program developed for reactor inspectors already fully qualified as a resident or regional engineering inspector

• Partial qualification table developed for those resident or regional engineering inspectors who only perform routine loading inspections

• No recommendation on who performs inspection

Working Group Recommendations Inspection Effort

• Routine inspections o Level of effort assessed by performing line-by-line review of hours needed for the risk-significant inspection activities Welding, heavy loads, fuel loading activities o Proposed program 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> every triennial cycle for routine loading inspections 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> every quarter during extended loading campaign 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every triennial cycle (includes Away From Reactor ISFSIs) for routine monitoring inspections o Current program 132 hours0.00153 days <br />0.0367 hours <br />2.18254e-4 weeks <br />5.0226e-5 months <br /> every 2 years, not to exceed 3 years, for routine loading inspections 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every 2 years, not to exceed 3 years (includes Away From Reactor ISFSIs) for routine monitoring inspections

Working Group Recommendations Inspection Effort (cont.)

• Preoperational and initial loading inspections o Based on revised risk-informed inspection procedures and taking into account actual resource expenditures o Proposed program Preoperational inspection (Inspection Procedure (IP) 60854)200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> Review of 10 CFR 72.212 evaluations (IP 60856)160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br /> o Current program Preoperational inspection (IP 60854)120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> Review of 10 CFR 72.212 evaluations (IP 60856)120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />

• No change to ISFSI construction inspection (IP 60853)120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />

Additional Areas for Consideration The working group also recommended the following:

• Assess and provide recommendations for enhancement in the areas of inspection readiness for o Transportation of spent nuclear fuel o Consolidated interim storage facilities

• Review possible efficiency gains and overall improvement related to the creation of a Center of Expertise for ISFSI oversight activities

• Develop a routine assessment of the ISFSI inspection program

Recommendation Development

• Issued a memorandum with the working groups initial assessment and recommendations on October 2, 2019 (ADAMS Accession No. ML19277G895) o Includes two enclosures (ADAMS Accession Nos. ML19277G878 and ML19277G879) with recommendations

• Solicited internal and external feedback on the initial recommendations o Includes public meetings that provided an opportunity for feedback from stakeholders in various geographic areas

• Updated the working groups recommendations to incorporate feedback (ADAMS Accession No. ML20045D870)

Status and Next Steps

• The NRC will make a final decision and issue a tasking memorandum to the regions with the final recommendations report

• Program documents will be updated, as needed, based up final decision o New technical basis document o Revisions to Inspection Manual Chapters and inspection procedures

• Implementation planned for start of calendar year 2021