ML21029A332

Closure Memo - Building a Smarter Fuel Cycle Inspection Program

ML21029A332
Person / Time
Issue date:	03/29/2021
From:	Leira Cuadrado NRC/NMSS/DFM/IOB
To:	Andrea Kock Division of Fuel Management
APearson - NMSS/DFM/IOB - 301.415.3174
References
Download: ML21029A332 (9)

Text

March 29, 2021 MEMORANDUM TO: Andrea Kock, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: Leira Cuadrado, Chief Digitally signed by Marlone F Inspection and Oversight Branch Marlone F Davis Davis Date: 2021.03.29 11:45:33 -04'00' Division of Fuel Management Office of Nuclear Material Safety and Safeguards

SUBJECT:

IMPLEMENTATION OF SMARTER FUEL CYCLE INSPECTION PROGRAM By memorandum dated March 18, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20077L247), the Director of the Division of Fuel Management of the Office of Nuclear Material Safety and Safeguards endorsed the recommendation to build a smarter fuel cycle inspection program (ADAMS Accession No. ML20073G659).

With the execution of the Smarter Fuel Cycle Inspection Program Implementation Plan (ADAMS Accession No. ML20189A064), the staff has implemented a large part of the working group recommendations to enhance inspection manual chapters and inspection procedures related to fuel facilities.

This memorandum documents the implementation of the smarter fuel cycle inspection program, to date, as well as remaining actions for calendar year 2021.

CONTACT: Alayna Pearson, NMSS/DFM/IOB 301-415-3174

Enclosure:

Implementation of a Smarter Fuel Cycle Inspection Program

A. Kock

SUBJECT:

IMPLEMENTATION OF SMARTER FUEL CYCLE INSPECTION PROGRAM DOCUMENT DATE: March 29, 2021 DISTRIBUTION:

Email:

PUBLIC LCuadrado, NMSS/DFM Apearson, NMSS/DFM Dduvigneaud, NMSS/DFM Akock, NMSS/DFM Cregan, NMSS/DFM Caraguas, NMSS/DFM Lsuggs, RII/DFFI Emichel, RII/DFFI Rwilliams, RII/DFFI ADAMS Accession Number: ML21029A332 *via email OFFICE PM:IOB:DFM* LA:DFM* BC:NLRP:DNRL*

NAME Apearson Elee Lcuadrado DATE 02/05/2021 02/08/2021 03/22/2021 OFFICIAL RECORD COPY

Implementation of a Smarter Fuel Cycle Inspection Program Background and Objective:

On April 26, 2019, the U.S. Nuclear Regulatory Commission (NRC) established a working group to conduct a holistic assessment of the fuel cycle inspection program to improve the effectiveness and efficiency of the program (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19074A139).

In consideration of the agencys focus on transformation and innovation, the primary objective of the working group was to integrate risk-informed insights to ensure that the appropriate focus is applied to those areas most important to safety. The working group, composed of experienced staff from the Office of Nuclear Material Safety and Safeguards (NMSS) and Region II, used both domestic and international operating experience, risk insights, inspection data, and lessons learned to assess the program and develop recommendations for enhancement.

Recommendations:

By memorandum dated March 18, 2020 (ADAMS Accession No. ML20073G659), the working group proposed a series of changes to the fuel cycle inspection program, including:

(1) modifications to inspection frequencies and resource estimates associated with completion of inspection procedures, (2) modifications to inspection procedures to reduce overlaps, and (3) modifications to inspection frequencies of inspection procedures for facilities with an NRC--approved corrective action program.

Specifically, the working group issued the following six recommendations in the development of a smarter fuel cycle inspection program:

1) In-depth assessment of the scope of resident inspector guidance and its referenced procedures as part of the implementation phase of this initiative. The assessment should consider potential changes to ensure the scope of the resident inspector program is focused on the areas that provide the greatest safety benefit and should also consider recommendations provided by external stakeholders. Based on this review, further adjustment of inspection activities between regional and resident inspector activities may be recommended.

2) A reduction in the frequency of inspection to Tier 2 and Tier 3 inspection technical areas for licensees with an NRC-approved CAP.

3) The following inspection frequencies and hours based on the tier ranking of each of the inspection areas.

o Tier 1 areas - Annual inspection frequency and a minimum of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br /> o Tier 2 areas - Biennial inspection frequency and a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> o Tier 3 areas - Triennial inspection frequency and a minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> with a range of hours to accommodate for any necessary adjustments on inspection scope based on the length of time between inspections Enclosure

4) A revision to Inspection Manual Chapter (IMC) 2600 to include an acceptable variance of plus or minus 10 percent in the core hours. In addition, language on the acceptable variance should be included in the resources estimate section for each inspection procedure.

5) Incorporation of changes described in Section d. of the report (ADAMS Accession No. ML20073G659), along with the marked-up version of the Appendix B to IMC 2600 with the recommended hours and frequencies for each area of the core inspection program.

6) Formalizing into the inspection program the results of the Operating Experience Program and the Fuel Cycle Inspection Assessment Program to determine, on a frequent basis, if changes to the core inspection program are needed.

Approval of Recommendations and Staff Plan for Implementation:

By memorandum dated March 18, 2020 (ADAMS Accession No. ML20077L247), the Director of Division of Fuel Management (DFM) of NMSS endorsed the working groups recommendations to build a smarter fuel cycle inspection program, with completion of updates to inspection guidance by December 2020, and implementation of inspection activities starting in calendar year 2021.

On August 26, 2019, the staff developed an Implementation Plan (ADAMS Accession No. ML20189A064), with the objective to implement the working groups recommendations to enhance IMCs and inspection procedures (Ips) related to fuel facilities, as endorsed by the DFM Director on March 19, 2020. Specifically, the staff focused its initial implementation efforts on Recommendations 1 - 5.

The staff deferred the implementation of Recommendation 6 to calendar year 2021.

Implementation of Recommendations:

To date, the staff revised 91 percent of the fuel cycle program guidance, including all procedures to support scheduled inspections in the first quarter of 2021. Four training sessions were conducted to familiarize inspection staff with the revisions to the procedures and to ensure common understanding of any new and revised guidance. The training sessions were recorded for future use and made available to the staff as a reference.

The remaining 9 percent will be issued in early 2021 or retired by late 2021.

The following procedures have been issued for use:

IP/IMC Title 1 IP 88015 Nuclear Criticality Safety 2 IP 85401 Management Structure 3 IP 85309 Measurement Systems and Control 4 IP 85311 Physical Inventory Program 5 IP 85313 Alarm Resolution Program 6 IP 88055 Fire Protection 7 IP 88051 Evaluation of Exercises and Drills 8 IP 88020 Operational Safety 9 IP 88135 Resident Inspection Program for Category I Fuel Cycle Facilities 10 IP 88135.02 Resident Inspection Program Plant Status Activities 11 IP 88135.04 Resident Inspection Program Operational Safety 12 IP 88135.05 Resident Inspection Program Fire Protection 13 IP 88135.17 Resident Inspection Program Plant Modifications 14 IP 88135.19 Post Maintenance Testing 15 IP 88135.22 Surveillance Testing 16 IP 88070 Plant Modifications 17 IMC 2683 Material Control and Accounting Inspection of Fuel Cycle Facilities 18 IMC 2600 Fuel Cycle Facility Operational Safety and Safeguards Inspection Program 19 IMC 2600, NRC Core Inspection Requirements Appendix B 20 IMC 2600, Inspection Program Modifications During Pandemics, Epidemics, Appendix E or Other Widespread Illnesses or Diseases 21 IP 85303 Material Control and Accounting Management Structure and Personnel Training and Qualification 22 IP 85305 Item Monitoring 23 IP 85307 Processing Monitoring 24 IP 86740 Inspection of Transportation Activities 25 IP 85315 Internal Control 26 IP 85402 Measurement Program 27 IP 85403 Measurement Control Program 28 IP 85407 Assessment Program 29 IP 85408 Recordkeeping 30 IP 85501 Physical Inventory Program for Uranium Enrichment Facilities 31 IP 85502 Detection Program for Uranium Enrichment Facilities 32 IP 88050 Emergency Preparedness 33 IP 85404 Physical Inventory Program for Low Enriched Uranium Fuel Facilities 34 IP 85405 Item Control 35 IP 85406 Resolution Program for Low Enriched Uranium Fuel Facilities 36 IP 85503 Resolution Program for Uranium Enrichment Facilities 37 IP 88030 Radiation Protection 38 IP 88045 Effluent Control and Environmental Protection The remaining procedure will be issued in early 2021:

IP/IMC Title 1 IMC 0616 Fuel Cycle Safety and Safeguards Inspection Reports Additionally, another revision of IMC 2600, Appendix B was issued in February 2021, to clarify how estimated resources for some functional areas will be distributed. Specifically, for those functional areas that will receive two inspections in one year, the frequency of inspections and estimated resources were revised to clarify the estimated resources per inspection.

Three procedures will be retired in 2021, the contents of which have already been incorporated into other documents:

Retiring Procedure Information Incorporated Into 1 IP 88025, Maintenance and

• IP 88020, Operational Safety Surveillance of Safety Controls

• IP 88015, Nuclear Criticality Safety

• IP 88030, Radiation Protection 2 IP 88035, Radioactive Waste

• IP 88030, Radiation Protection Processing, Handling, Storage,

• IP 88045, Effluent Control and and Transportation Environmental Protection 3 IP 88054, Fire Protection

• IP 88055, Fire Protection Triennial The following table summarizes the current status of the Smarter Fuel Cycle Inspection Program working group recommendations:

Recommendation Status as of Planned Actions March 2021 for 2021 1 Assessment of the scope of resident Issued revisions to the The staff plans to inspector guidance resident inspector reassess the scope of guidance to reduce the resident inspector overlap. guidance by May 2021.

2 Reduction of frequency of inspection Completed in the Not Applicable to Tier 2 and Tier 3 inspection revisions to IMC 2600, technical areas for licensees with an Appendix B.

NRC-approved CAP 3 Recommends the following inspection Completed in the Not Applicable frequencies and hours based on the revisions to all IPs and tier ranking of each of the inspection IMCs.

areas.

o Tier 1 areas - annual inspection frequency and a minimum of 90 hours0.00104 days <br />0.025 hours <br />1.488095e-4 weeks <br />3.4245e-5 months <br />.

o Tier 2 areas - biennial inspection frequency and a minimum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />.

o Tier 3 areas - triennial inspection frequency and a minimum of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> with a range of hours to accommodate for any necessary adjustments on inspection scope based on the length of time between inspections.

4 Revision to IMC 2600 to include an The Resource Estimate Not Applicable acceptable variance of plus section of each of the or minus 10 percent in the core hours. revised IPs includes Language on the acceptable variance language for a variance of should be included in the resources plus or minus 10 percent estimate section for each inspection of the estimate contained procedure. in IMC 2600 Appendix B.

Where appropriate, increases or decreases greater than 10 percent shall be approved by a Branch Chief, as described in IMC 2600 Section 7.02.

5 Incorporation of changes described in The changes described in Not Applicable Section d. of the report (ADAMS Section d. of the report, Accession No. ML20073G659), along related to inspection with the marked-up version of the frequency, resource Appendix B to IMC 2600 with the estimates, plant recommended hours and frequencies operations, criticality for each area of the core inspection safety, fire protection, program material control and accounting, radiation protection, environmental protection, waste management, transportation, maintenance and surveillance, emergency preparedness and plant modifications were completed with revisions to IMC 2600, Appendix B, all IPs and applicable IMCs.

The changes described in Section d. of the report related to inspection preparation and documentation were evaluated and where appropriate, incorporated into revisions to IMC 2600, IMC 0616 and internal inspection guidance. Specifically, the recommendations were addressed as follows:

• Guidance on increasing the use of technology to aide in document reviews and the efficient review of licensing documents was added to IMC 2600.

• The staff considered a range of variables involved in inspection preparation and documentation including the varying experience of inspectors, inspection type, facility type, the complexity of issues and potential event follow up, and determined that expectations for the appropriate depth and time for inspection preparation and documentation are sufficient. Additionally, significant deviations for inspection preparation and documentation will continue to be managed at the supervisor level and no further action is needed.

• The staff implemented updates to the Reactor Program System and expanded the use of Inspection Scheduling, Tracking and Reporting (ISTAR). These updates standardize inspection documentation and report generation. IMC 0616 was revised to include tables, fields and instructions required to use ISTAR to generate reports.

The staff expects these updates to result in reduced inspection documentation time.

• Appropriate IPs were revised to include additional guidance on sample selection, and internal guidance is being used to ensure inspection preparation is focused on items of regulatory significance to the specific licensee or facility type.

6 Formalizing into the inspection The 2020 implementation The staff has initiated program the results of the Operating effort focused on revising an effort to improve Experience Program and the Fuel all the inspection the effectiveness of Cycle Inspection Assessment guidance and excluded the FC OpE program, Program to determine, on a frequent this recommendation from to address this basis, if changes to core inspection the implementation plan recommendation and program are needed for 2020. explore how to provide more meaningful insights based on a variety of relevant data sources and best practices from other operating experience programs. This effort is kicking off in Quarter 3 of CY2021 and is expected to be completed by the end of the calendar year.