ML21082A073
| ML21082A073 | |
| Person / Time | |
|---|---|
| Issue date: | 04/12/2021 |
| From: | Leira Cuadrado Office of Nuclear Material Safety and Safeguards |
| To: | Andrea Kock, Ladonna Suggs Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation |
| Pearson A | |
| Shared Package | |
| ML21082A071 | List: |
| References | |
| Download: ML21082A073 (5) | |
Text
Fuel Cycle Annual Operating Experience Report for Calendar Year 2020
1.0 Purpose
The Fuel Cycle Operating Experience (FC OpE) Program supports technical and licensing staff, inspectors, and management by providing insights that can inform inspection planning, licensing reviews, and program changes. The purpose of this annual report is to provide an analysis of reported events at fuel cycle facilities and as necessary, make recommendations to improve fuel cycle programs.
2.0 Discussion
Fuel cycle events included in the FC OpE Program are reported under Title 10 of the Code of Federal Regulations (10 CFR), Part 40.60 Reporting Requirements, 10 CFR Part 70.50 Reporting Requirements, and 10 CFR Part 70 Appendix A, Reportable Safety Requirements.
Table A below shows the total number of events reported for operating fuel cycle facilities between 2007 and 2020. Events included in the FC OpE program are safety focused and therefore physical security and international events are not included in this data set. However, international events are evaluated for generic applicability to domestic licensees. For calendar year 2020 there were no international events that would have generic implications for the U.S.
fuel facility industry.
Total Number of Events per Facility by Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Framatome 3 3 5 1 2 2 2 1 2 2 0 0 1 1 B&W 8 4 2 2 1 2 1 0 3 1 1 1 2 1 Technologies Global Nuclear 4 5 1 7 13 8 3 2 0 2 1 5 7 9 Fuel Honeywell MT 2 1 4 1 16 10 7 12 5 0 0 0 0 0 Louisiana 0 0 0 0 3 0 1 0 2 1 2 3 4 1 Energy Services/
URENCO Nuclear Fuel 3 5 6 2 0 1 0 6 1 3 0 3 2 0 Services Westinghouse 2 1 2 5 1 2 0 0 1 2 1 3 5 2 Total number of 22 19 20 18 36 25 14 21 14 11 5 15 21 14 events per year Table A. Total number of reported events at licensed facilities between 2007 and 2020 Enclosure 1
2.1 Results of 2020 FC OpE Data Analysis In 2020, the staff received a total of fourteen (14) event reports. Of the 14 events, licensees retracted one event after determining that the event did not meet the reporting requirement threshold. Additionally, of the 14 events, licensees reported ten (10) events under 10 CFR 70 Appendix A (c), Concurrent Reports. Concurrent reports are required to be submitted to the United States Nuclear Regulatory Commission (NRC) when an event will be part of a press release or is required to be reported to other government agencies. Therefore, concurrent reports are not included in the data analysis. Additionally, events considered as occupational hazards or personal health related issues, such as certain unplanned medical treatments caused by personal health issues (e.g., low blood sugar, heart attacks) and non-radiological or non-chemical exposure events (e.g., a pinched finger or a fall), are not included in the data analysis.
After removing retracted events, concurrent reports, and events considered as occupational hazards or personal health related issues, a total of two (2) events remained to be included in the annual analysis. Of these events, one was a radiation protection event, related to unplanned medical treatment of an injured person and one was an operational safety event related to fire safety.
Table B shows the resulting number of events per year after screening the data.
Year 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Screened 21 18 16 18 29 17 9 13 12 11 4 6 9 2 Events Table B. Number of events after screening process Several factors influence the annual number of screened events shown in Table B. Some factors include extended periods of reduced operation or shutdown for multiple facilities between 2012 and 2019 and exemptions from certain radiological reporting requirements in 2017. For instance, in 2012, Honeywell ceased operations in response to Confirmatory Order (EA-12-157). In late 2016 through early 2017, Westinghouse ceased operations to take corrective actions following an event involving unexpected uranium accumulation. Another example is Honeywells ramp down in operations in 2016 to enter idle status in 2017. Another factor that may be reflected in 2020 and onward is the effect of the COVID-19 public health emergency on licensee operations, including requesting and receiving exemptions to certain regulatory requirements.
Given these factors, the staff recognizes any quantitative statistical conclusions based on the annual total number of screened events should be supported by an analysis of the underlying events. The staff considered the limited data from the events in 2020 and did not identify any new or emerging trends. Furthermore, the analyses did not yield any significant or actionable insights. The staff focused on the results of the qualitative analysis of performance areas in Sections 2.1.1 and 2.1.2 of this report.
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2.1.1 Event Classification Process To further analyze the data for trends and OpE insights, the staff developed an event classification process to categorize and characterize the screened data in Table B. The event classification process consists of three steps:
(1) Determine the applicable performance areas, i.e., areas that align with core inspection procedures; (2) Determine contributing factors that led to the events; and (3) Determine the level of safety significance (see the Office of Nuclear Material Safety and Safeguards (NMSS) Policy and Procedure (P&P) 6-14, Fuel Cycle Operating Experience, for details regarding the screening criteria). The staff performed the screening, during which they considered initial event notification information, applicable 60-day reports and inspection reports.
2.1.2 Performance Area and Contributing Factors Evaluation Based on the performance areas determined from the first step of the event classification process, the staff analyzed the number of events per year. Figure 2 illustrates the number of events per year by performance area. The plot consistently shows that, on average, there are historically more criticality safety events per year, followed by operational safety events. In addition, the plot consistently shows that the leading performance area with the highest number of events is criticality safety.
However, in 2020 there were no reported criticality safety events. One event was in radiation protection involving unplanned medical treatment of a person working with radioactive material.
The other event was an operational safety event related to a fire in a supercompactor room. For the radiation protection event, the predominant contributing factor was failure or degradation of management measures (e.g., configuration management, adherence to procedures). Previous FC OpE Program reports identified this factor, in general, as predominant across all events since 2007, and therefore management measures continue to be recommended as an inspection focus area. The contributing factor for the fire event has not yet been identified, since the NRC staff investigation is ongoing.
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Figure 2. Events per year by performance area 2.1.3 Safety Significance Evaluation All events, regardless of significance, are maintained in the FC OpE Database for future reference, tracking, and trending. However, the staff used the screened data to analyze the safety significance of the events in 2020. The staff rates safety significance from high to low using the criteria described in NMSS P&P 6-14 which is consistent with the NRC Enforcement Policy. Based on the rating criteria, the radiation protection event was of low safety significance. The significance of the fire event has not yet been determined, as the NRC staff investigation is ongoing.
3.0
Conclusions:
Based on the reported events this year, the staff concludes:
- 1) The safety significance of the radiation safety event in 2020 was low. At the time that this report was being developed, the significance of the fire event was still under investigation.
- 2) Given the limited data from the events in 2020, the staffs analysis did not identify any new or emerging trends.
4.0 Recommendations
In alignment with agency transformation activities, the staff is initiating an effort to evaluate the FC OpE program. The staff anticipates this evaluation will reveal opportunities to better leverage a variety of data sources, beyond reportable events, and best practices from other operating experience programs, to provide more meaningful insights regarding operating experience and further enhance this program. The staff plans to complete this initiative in calendar year 2021, and any improvements identified will be used in the development of the 2021 annual operating experience report. As part of this evaluation, the staff recommends considering the incorporation of data elements into the FC OpE Program (to the extent that they 4
may influence operating experience) that can capture the effects of the public health emergency on licensee operations and NRC staff oversight. For example, the database could capture facilities that received exemptions, the nature of those exemptions and oversight activities that may be adjusted as a result.
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