ML20148M598
| ML20148M598 | |
| Person / Time | |
|---|---|
| Issue date: | 06/20/1997 |
| From: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Kane W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9706250054 | |
| Download: ML20148M598 (6) | |
Text
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UNIT ED STATES t
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Q y E REGloN IV E
611 RYAN PLAZA DRIVE, SulTE 400 g
ARLINGioN, TEXAS 76011-8064 JUN 2 0 1997 I
MEMORANDUM TO:
William F. Kane, Director Spent Fuel Project Office Office of Nuclear Material Safety and Safeguards FROM:
Ross A. Scarano, Director ivision of Nuclear Mat i l Safety, RIV
SUBJECT:
REGION IV INPUT FOR UPDATE OF NRC ENFORCEMENT POLICY ON ISFSIS Attached is Region IV's input for updating the NRC Enforcement Policy on ISFSIs as requested by your memorandum dated May 19,1997. Please note that our input includes examples of violations and recommended severity levels for spent fuel pool operations which we believe should be considered in developing ISFSI enforcement policy statements.
If you have any questions concerning these comments, please contact Dr. D. Blair Spitzberg of my staff at (817) 860-8191.
Attachment:
As stated 7
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9706250054 976620 PDR ORG NOMA
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e SPENT FUEL OPERATIONS ENFORCEMENT EXAMPLES A.
Examples of Severity Level I Violations A criticality event or failure of a system important to safety that results in injury or significant radiation exposure to workers or member of the public.
Failure to maintain adequate security controls resulting in the damage or loss of spent fuel.
Failure to maintain sufficient water in the spent fuel pool such that the fuel becomes uncovered.
B.
Examples of Severity Level II Violations A system designed to prevent criticality or exposures to workers or the public that was not, under any circumstances, able to perform its intended safety function.
Failure to maintain adequate security controls that could result in the loss or damage of spent fuel.
A certified fuel handler involved in procedural errors which result in, or worsens the consequences of an alert emergency classification.
C.
Examples of Severity Level III Violations Inadequate or incomplete safety review (10CFR72.48) of a design change resulting in a potential or actual degradation of equipment that is important to safety.
The placement of a loaded cask into the ISFSI containing fuel that does not meet the specification required by the Certificate of Compliance.
Failure to implement adequate quality controls resulting in a significant defect in a system designated as important to safety.
Several violations. that in the aggregate. indicate a breakdown in the licensee's control or oversight of vendor activities resulting in the use of products or services that are defective. degraded, or indeterminate quality on a system important to safety.
Violations which result in a significant impairment to the ready retrievability of the fuel.
Movement of fuel by someone other than a certified fuel handler resulting in an unsafe condition.
Inadequate implementation of the surveillance program resulting in a failure to detect a significant degradation or loss of sealing of the cask confinement system.
Failure to notify the NRC of the discovery of information related to an actual reduction in the margin of safety for a component identified as important to safety.
2-Inadequate procedures or a violation of procedures during the loading, movement, or unloading process resulting in an unsafe condition that places personnel or members of the public at risk of radiological exposure or damaging fuel.
Failure to comply with the requirements of the Certificate of Compliance resulting in the inability of a component identified as important to safety to perform its intended function.
Exceeding the annual radiological exposure limits of 10 CFR 72.104 or the emergency exposure limits established in 10 CFR 72.106.
Failure to report a Part 21 defect that, if left uncorrected, could result in the loss of the function of the storage system.
D.
Examples of Severity Level IV Violations Inadequate or incomplete safety review (10CFR72.48) of a design change resulting in a potential or actual degradation of equipment that is important to safety, but does not rise to a Severity Level III violation.
Failure to maintain the cask system in compliance with technical specifications which if left uncorrected could result in a more significant violation.
Movement of fuel by someone other than a certified fuel handler which does not result in an unsafe condition.
Operations of equipment and controls that have been identified as important to safety by someone other than a certified person or under the direct visual supervision of a certified person.
Inadequate implementation of the surveillance program resulting in a violation of technical specifications.
Failure to notify the NRC of the discovery of information related to the potential for the reduction in the margin of safety related to the dry cask storage system.
Lack of recognition of a change in conditions tha+ effected the design basis of the dry cask storage system.
Inadequate procedures or a violation of procedures during the loading. cask movement or unloading process resulting in a potentially unsafe condition.
Failure to comply with the requirements of the Certificate of Compliance which does not result in a higher severity level.
Unidentifled or undocumented objects or material stored in the spent fuel pool Failure to report a Part 21 defect.
1
William F. Kane E-Mail report to Document Control Desk (DOCDESK) bec to DCD (IE07) bec distrib. by RIV:
RIV Regional Administrator Jim Dyer, DRA/RIV William L. Axelson, DRA/RI Bruce S. Mallett, DRA/Rll James L. Caldwell, DRA/ Rill Elizabeth O. Ten Eyck, D/FCSS/NMSS Donald A. Cool, D/IMNS/NMSS John T. Greeves, D/DWM/NMSS Gail H. Marcus, D/NRR/DRPW/PDill-3 Lawrence J. Chandler, OGC Mark A. Satorius, DD/OE LLHowell GSanborn GMVasquez CLCain DBSpitzberg FAWenslawski VEverett DNMS Al File DOCUMENT NAME: G:\\Al97-157.DBS Al97-157 To receive copy of cocument, indicate in box: "C" = Copy without enclosures "E" = Copy wth enclosures "N = No copy RIV:C:NMl&FCDB l DD:DNMSl()
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%WFICIAL RECORD COPY
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William F. Kane E-Mail report to Document Control Desk (DOCDESK) l' l
bec to DCD (IE07) bec distrib. by RIV:
l RIV Regional Administrator l
Jim Dyer, DRA/RIV l
William L. Axelson, DRA/RI Bruce S. Mallett, DRA/Ril ames L. Caldwell, DRA/ Rill Elizabeth Q. Ten Eyck, D/FCSS/NMSS Donald A. Cool, D/IMNS/NMSS John T. Greeveo. D/DWM/NMSS l
Gail H. Marcus, O/NhR/DRPW/PDill-3 Lawrence J. Chandler, OGC Mark A. Satorius, DD/OE i
LLHowell GSanborn GMVasquez l
CLCain DBSpitzberg FAWenslawski VEverett DNMS Al File l
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Al97-157 DOCUMENT NAME: G:\\Al97-157.DBS i
To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Ccoy with e1 closures "N" = No copy RIV:C:NMi&FCDB l DD:DNMS j()
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DBSpitzberg bl59 - LLHowelLp RAScfrano 06//7/97 06/b9/'/D 06]//97 06/ /97 06/ /97
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