ML20212A064
| ML20212A064 | |
| Person / Time | |
|---|---|
| Issue date: | 09/02/1997 |
| From: | NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20212A051 | List: |
| References | |
| REF-WM-3 MC-2641, NUDOCS 9710230145 | |
| Download: ML20212A064 (6) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 90tu4001 v % ,yl,. /
NRC INSPECTION MANUAL NMSS/ URB MANUAL CHAPTER 2641 IN-SITU LEACH FACILITIES INSPECTION PROGRAM 2641 01 PURPOSE This chapter establishes the routine safety inspection program for in situ leach (ISL) facilities. Included in the program are operating ISL facilities, research and development facilities, and facilities in preoperation, startup, and decommissioning status.
2641-02 OBJECTIVES 02.01 To establish general policy for the ISL facilities inspection program, including priorities for inspection.
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02.02 To establish specific requirements for the frequency with which referenced inspection procedures (IPs) should be performed at ISL facilities.
02.03 To achieve consistency in performing inspections, whether performed by inspectors based in the region or in Headquarters.
2641 03 PROGRAM ASSUMPTIONS The )rogram described here deals primarily with inspection of operating ISL faci'ities, it also addresses inspection requirements and assessment activities for facilities in construction, preoperation, startup status, and decom-missioning, inspections during the operating phase begin on issuance of the facility license.
The program continues until the facility ceases all operation and is placed in standby or inactive status, or is decommissioned. For guidance for facilities in standby or inactive status, or in decommissioning status refer to inspection Manual Chapters 2801 and 2605: Inspection Procedure 87654: NUREG/CR 5849: and
. other Nuclear Regulatory Commission documents relating to decomissioning.
ISL facilities in non operating status generally do not pose the same risk levels
, as operating facilities, especially if nuclear material has not yet been introduced into the facility, or has been placed in storage and is not in (7 process, Certain IPs may not be applicable in these cases, and others may need to be adjusted to the given situation to reflect the actual level of risk
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attached to each situation. However, ground water restoration costs may continue Issue Date: 09/02/97 2641 02g 971003 ~
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Q .s to rise as equipment ages or is removed from the site. Therefore, IPs may play an important role in confirming estimates of ground water restoration sureties, Inspection activities for new facilities, or those undergoing major i modifications, when no nuclear material is present, are conducted as an adjunct l to the licensing process. Their purpose is to establish the accuracy of ;
representations mace in the license application that certain facility structures or equipment meet stated safety and environmental criteria. Inspections are . .
justified before a license is issued where inspection for the intended purpose l would not be practical after construction is completed (e.g., ventilation i systems). .
Facilities for which decomissioning plans are being 3re)ared, or have beca submitted, but not ap? roved, are considered operating fac'lities. Inspection requirements specifiec in this chapter remain in effect in these situations, but may be adjusted through coordination between the region and Headquarters, to account for the lower risk associate 1 with curtailed operations.
For sites in decommissioning not all the inspection procedures may be applicable in these cases and others may need to be adjusted to reflect the different activities and the increased or decreased levels of risk. Inspection requirements for decomissioning can be found in several Nuclear Regulatory Comission documents.
2641-04 DEFINITIONS 04.01 In situ Leach, in situ leach mining involves the use of a leaching solution (11x1viant) to extract the mineral of interest from the geologic formation in which it occurs.
04.02 Performance Based License. Consistent with the regulatory reduction effort initiated by the staff in 1994, the staff is currently issuing all new and renewed licenses as performance-based. A performance based license allows the licensee to make changes to the facility without prior Nuclear Regulatory Comission approval if certain conditions are met. These conditions ce specified in the Performance Based License.
2641-05 PROGRAM DESCRIPTION 05,01 General. This chapter identifies requirements for the inspection of the health, safety, and environmental aspects of licensee operations. The inspector should be completely familiar with the current regulatory requirements and comitments associated with the license. These include the comparable parts of title 10. U.S. Code of Federal Regulations, licensee Operation Plans, the license application, applicable guides, and other codes to which licensees may comit by reference, in the case that Nuclear Regulatory Comission guidance documents are updated after a license or amendment is issued, the licensee is generally only comitted to follow the original guidance. Thus, the particular revision of the guidance to which the licensee has been comitted is of importance. .
The IPs and frecuencies for the different programatic areas are identified in the ap)endix. ]t identifies both a minimum and a normal level of effort for .
inspec; ion of certain program areas. The minimum and normal levels of inspections are specified as different frequencies of implementation of the various IPs comprising the overall program for a facility, 2641 Issue Date: 09/02/97
The " Minimum" frequency of inspection specified for a procedure is the lowest frequency to which the inspection should be reduced. The
- Normal" frequency is the frequency with which the procedure should be conducted absent strong
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indications in either direction that the licensee's performance is sufficiently outstanding or poor in the area covered by the procedure that a change is warranted. For a " Normal" inspection frecuency, all elements of a procedure should be completed within the specified "hormal" frequency, regardless of the number of inspection visits required for completion.
There is no maximum frequency expressed or implied by the appendix. Any level
. of effort (i.e., frequency of inspection) above that specified as the " Normal" frequency must be based on a significant and demonstrated concern for safety and the environment in the continued operation of the in situ leach facility. This would be determined by the responsible regional or Headquarters management.
Substantial adjustments to inspection frecuency must be approved in writing by the Office of Nuclear Material Safety and' Safeguards, as specified in Section 2641 05.02 of this chapter.
Some inspection procedures listed in the aforementioned appendix are normally required to be conducted more frequently than annually (e.g., " Operations Review." IP 88020). This is so closer attention can be paid to licensees' efforts to implement changes in their safety programs, resulting from modifications in plant processes and procedures.
The scope of IPs. taken as a whole. is not intended to be limited to only those elements discussed in the procedures. The descriptions and examples contained in the procedures are provided primarily for illustrative purposes, as examples of things that shoulc be examined. Examination of other safety-significar.t activities not expressed or implied in a procedure is left to the inspector's (7
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judgment, in consideration of the relative degree of safety risk posed by the subject activity.
The environmental aspects of the operations relate to those license conditions that have been olaced on the operation by the Nuclear Regulatory Commission as a result of rev'ews conducted under the authority of the National Environmental Policy Act. Environmental inspections would be conducted at the same time as health and safety inspections.
Most ISL licensees have been issued a performance based li ense delegating the licensee additional regulatory authority for various aspects of licensed activities. A performance based license licensee is required to establish a Safety and Environmental Review Panel to evaluate all safety issues pertinent to the associated performance based license conditions. This portion of the licensee's program should be inspected at each inspection.
During inspections, emphasis should be placed on performing physical examinations. observirg conduct of operations, making independent measurements.
and interviewing personnel. Records review should be de emphasized and involve a random selection of only those records that have safety and environniental significance. In addition to determining if the licensee is complying with reguldtory or license requirements, the inspector's primary concern should be to determine if the licensed facility is being operated safely.
05.02 Proaram Adiustments. The program provides the responsible Headquarters and regional office flexibility to adjust the frequencies, focus, and intensity (3 of inspections for different functional areas at a licensed facility. Periodic
\") adjustnents shall be based on the results of inspection history and licensee performance. Occasional adjustments may also occur in response to other events issue Date: 09/02/97 2641
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or activities, as determined by the responsible regional or Headquarters management.
A reasonable allowance for responding to these events or activities should normally be incorporated in the inspection plan for the facility. In some cases, necessary adjustments may be difficult to implement within the constraints imposed by limited inspection resources within the region. in such cases.
implementation may involve a shif t in the focus of already scheduled inspection .
resources for the subject facility, or a shift in allocated inspection resources from other facilities in the region that have exhibited superior performance.
Resources also may be borrowed temporarily f rom other regions. or from .
Headquarters, in a coordinated response to address significant safety or environmental issues that cannot otherwise be deferred.
Inspections during the construction and pre-operational phase of facility activities will be conducted on a case by case basis. Pre operational inspections will be conducted at least once before startup of facility operations. The inspection procedures for the construction / pre-operational phase are indicated in the appendix, as applicable.
Substantial adjustments in the planned inspection schedule for a facility (i.e.,
those that involve shifts in resources that may affect other facilities. or which may result in exceeding a 'norrnal' inspection frequency described in the '
appendix) shall be coordinated between the Division of Waste Management. Uranium Recovery Branch, and the region. These adjustments must be aaproved in writing by the Office of Nuclear Material Safety and Sat 0 guards before being implemented.
2641 06 REVIEW 0F EVENTS All inspections should include, as appropriate a review of licensee reportable and non reportable events received by the Nuclear Regulatory Comission or maintained at a licensee's facility. In the case of reports received by Nuclear Regulatory Comission involving radiological health and safety. the region is resporaible for determining the seriousness of the reported incident and whether an imediate reactive inspection is necessary. When such reports involve programatic areas normally addressed by Headquarters' programs, the region shall confer with Headquarters, to jointly determine what response, if any, is required. including whether the NucNar Regulatory Commission response should include personnel from Headcuarters.
Non reportable events are those determined ih U e licensee to fall outside criteria requiring them to be reported to the Nuclear Regulatory Commission.
Although these events are not reported formally to the Nuclear Regulatory Commission, licensees occasionally may contact regional staff informally to describe the event and explain it is not required to be reported. Still, licensees are often required, through license conditions or commitmeats, to maintain records of non reportable events on-site. The recorde Generally describe the events, the licensee's immediate response, the action'. taken to investigate th'eir safety significance, and the follow up actions taken, both of a specific or generic nature, to prevent similar events in the future. .
Individually, such events may not appear safety significant. However, a series of such events may demonstrate that a precursor condition may exist for the future occurrence of a far more serious event. .
Inspections should examine non-reportable events for the particular programatic area being inspected. The exaniination should be used to determine that licensee management has taken appropriate corrective actions to preclude recurrence. It 2641 Issue Date: 09/02/97 l
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also may provide an overview of the types of safety challenges experienced during plant operation and_the general character of the licensee's responses to such events.
O.* 2641 07 INDEPENDENT INSPECTION EFFORT Each inspector should spend some onsite inspection time performing independent inspection effort. -The amount of time spent should be commensurate with the level of risk, the complexity of the iacility, and the degree to which inspection
. resources have already been comitted to significant safety and environmental issues that have already been identified in the facility. This effort may include more in-depth inspection in selected technical areas than that normally called for by the formal procedures. The major objective of this effort should be to gain increased understanding of potential safety and environmental hazards of particular operations of interest, such as those that may lave been involved in a series of recent non-reportable-events.
Comparison of the findings from this type of effort with the licensee's findings may uncover unresolved safety and environmental questions, improper maintenance practices, and other problems-that may not be discovered through other means.
Discovered hazards outside the scope of Nuclear Regulatory Comission IPs or Nuclear Regulatory Commission regulatory authority should be conveyed to the licensee at the exit interview (Os set forth in IP 88002), described to regional management during debriefing, and included in the formal inspection report. In cases where reguiatory jurisdiction for the observed potential hazard is clear, the finding shall be reported to the responsible agency for action (i.e.. State.
Mine Safety and Health Administration. Environmental Protection Agency. etc.).
In all cases where the finding involves a potential effect on radiological health
( and safety, the finding shall be followed during subsequent inspections until the licensee has addressed the concern. However, special follow up inspections solely on the basis of Mine Safety and Health Administration issues are not required unless the potential hazard also directly involves radiological health or safety.
2641 08 RANDOM SEl.ECTION AND EXAMINATION OF RECORDS Many of the inspection procedures normally require the inspector to select certain types of records at random for closer examination. However, random selection 1s not always required. The inspector may seek out certain records of.
interest when so inclined.
Random selection is a technique that recognizes the fact that the Nuclear Regulatory Commission does not have the resources to inspect every detail of plant. The Nuclear Regulatory Commission inspection program is predicated on the fact that the licensee is ultimately responsible for the safety of the licensed facility. Random selection, where specified in a procedure, allows the inspector to sample specific aspects of the licensee's safety and environmental program to
=be studied at a level of detail that would be impractical if exercised uniformly across the entire safety program. When random selection in a procedure is specified, the inspector should select records corresponding to activities that relate to the Nuclear Regulatory Commission's regulatory role, such as effluent
. -monitoring records or ground-water restoration records. Also included should be records required to be retained for later decommissioning.
To reasonably verify that 0]erations are conducted safely and in an environ-mentally acceptable manner. The inspector also should randomly select personnel Issue Date: 09/02/97 15- 2641
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for interviews. The extent and depth to which random selections or examinations are needed are left to the inspector's judgment, depending on how satisfied the .l inspector is that operational and safety safeguards procedures are being followed -!
uniformly. ,
I 2641 09 RESPONSIBILITY FOR INSPECTIONS The responsibility for inspection resides with the Region IV Office, except in the case of inspections for certain licensee functions handled directly out of Headquarters. In the interest of efficiencies in the use of resources, the .
Region IV office should ask Headquarters to assist in the conduct of inspections when special technical expertise is not available within the region.
2641-10 INSPECTION SCHEDULE An inspection schedule that involves radiological health, safety, and environmental inspections shall be maintained by the Region IV office. These ins)ections will be coordinated to ensure that: (1) inspections are performed wit 1 the required frequencies (as prescribed in the appendix, or modified in writing in accordance with this chapter); and (P) inspections do not overlap and cause undue adverse impacts on normal operations at the facility.
Most inspections on the inspection schedule will be considered announced inspections, with adequate advance notice given to the licensee to ensure that the appropriate licensee personnel can be made available and inspectors can arrange to observe certain activities not conducted on a routine nor regularly scheduled basis. However inspection staffs retain the responsibility for conducting some inspections on an unannounced basis, where this aspect of an inspection is necessary to the purpose or conduct of the inspection.
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Attachment:
Appendix, " Inspection Procedures and Frequencies For Different Programmatic Areas" l
l O l 2641 Issue Date: 09/02/97