ML21172A286
| ML21172A286 | |
| Person / Time | |
|---|---|
| Issue date: | 06/30/2021 |
| From: | Francis Peduzzi NRC/NMSS/DFM/IOB |
| To: | Shana Helton Division of Fuel Management |
| APearson NMSS/DFM/IOB 301.415.3174 | |
| References | |
| Download: ML21172A286 (5) | |
Text
June 30, 2021 MEMORANDUM TO: Shana R. Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards FROM: F. Paul Peduzzi, Chief Inspection and Oversight Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
COMPLETED - 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 recommendations to build a smarter fuel cycle inspection program (ADAMS Accession No. ML20073G659).
On March 29, 2021, the staff documented the implementation of the working group recommendations to enhance fuel cycle inspection manual chapters and inspection procedures, as well as remaining actions for calendar year 2021 (ADAMS Accession No. ML21029A332).
This memorandum documents the closure the Smarter Fuel Cycle Inspection Program initiative, and all actions and assessments resulting from the working group recommendations endorsed in the March 18, 2020 memorandum.
CONTACT: Alayna Pearson, NMSS/DFM/IOB 301-415-3174
Enclosure:
Completed - Implementation of a Smarter Fuel Cycle Inspection Program
ML21172A286 *via email OFFICE DFM/IOB/PM* DFM/FFLB/LA* DFM/IOB/BC*
NAME APearson ELee FPeduzzi DATE 6/21/2021 06/23/2021 06/30/2021 COMPLETED - IMPLEMENTATION OF A SMARTER FUEL CYCLE INSPECTION PROGRAM
Background:
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 and Implementation:
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.
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 (ADAMS Accession No. ML20077L247).
On April 26, 2019, the staff developed an Implementation Plan (ADAMS Accession No. ML20189A064) to implement the working groups recommendations as endorsed by the Director of DFM.
On March 29, 2021, the staff documented the implementation of the working group recommendations as well as remaining actions for calendar year 2021 (ADAMS Accession No. ML21029A332).
Implementation of Recommendations:
The following table summarizes the current status of the Smarter Fuel Cycle Inspection Program working group recommendations:
Recommendation Planned Actions for 2021 1 Assessment of the scope of resident The staff determined that several changes to inspection inspector guidance procedures made as a result of other Smarter Inspection revisions have improved the focus of the resident inspection program. Notably, additional Enclosure
guidance was added to the suite of resident inspection procedures (IP 88135 - 88135. 22) to ensure resident inspection plans are developed using plant-specific risk information to determine what systems and activities are of higher risk significance given the plant configuration. This information is used to make adjustments to the inspection plan so as to inspect activities of higher risk significance as they occur.
Additionally, to reduce duplication of efforts and increase efficiency, credit was given in certain regional IPs for facilities that have resident inspectors. For example, sections of IP 88030 Radiation Protection are omitted at facilities that have a resident inspector, since the scope is performed as part of the resident inspection program.
The viability of suggestions provided by external stakeholders during early Smarter Inspection public meetings were evaluated. These included the transfer of additional IPs (such as waste management, transportation, fire protection, maintenance and surveillance, environmental) to the resident inspection program. The staff determined that the majority of these recommendations were addressed in some manner by other changes made to both resident and regional inspector guidance. For example, the inspection frequency of the transportation IP was changed to triennial, and the radiation protection IP provides for the omission of aspects that are inspected by the resident.
The staff determined that the changes made to resident inspection guidance balanced a focus on areas that provide the greatest safety benefit with the need to maintain awareness of plant areas, equipment, and processes regardless of safety significance. The flexibility in the program should be maintained to ensure appropriate evaluation of all licensed activities and licensee performance and conformance to regulatory requirements.
The staff does not recommend any other changes to the scope of the resident inspector program resulting from recommendations on the Smarter Inspection Program and relevant assessments.
2 Reduction of frequency of inspection Completed. See ADAMS Accession No. ML21029A332 to Tier 2 and Tier 3 inspection technical areas for licensees with an NRC-approved CAP 3 Recommends the following inspection Completed. See ADAMS Accession No. ML21029A332 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.
4 Revision to IMC 2600 to include an Completed. See ADAMS Accession No. ML21029A332 acceptable variance of plus or minus 10 percent in the core hours.
Language on the acceptable variance should be included in the resources estimate section for each inspection procedure.
5 Incorporation of changes described in Completed. See ADAMS Accession No. ML21029A332 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 The staff has initiated an effort to develop a program the results of the Operating comprehensive operating experience program for all Experience Program and the Fuel business lines within NMSS. This effort will explore Cycle Inspection Assessment how an NMSS operating experience program can Program to determine, on a frequent provide meaningful insights based on a variety of basis, if changes to core inspection relevant data sources to identify trends, insights and program are needed lessons learned that can be communicated to stakeholders or applied in regulatory activities.
The intent of this recommendation will be addressed under the broader NMSS operating experience effort and will be tracked internally.