ML23026A291
| ML23026A291 | |
| Person / Time | |
|---|---|
| Issue date: | 02/16/2023 |
| From: | NRC/NMSS/DFM/IOB |
| To: | Division of Fuel Management, NRC/RGN-II/DFFI |
| Shared Package | |
| ML23026A289 | List: |
| References | |
| Download: ML23026A291 (7) | |
Text
Fuel Cycle Annual Operating Experience Report for Partial Calendar Year 2021 and Fiscal Year 2022
1.0 Purpose
The Fuel Cycle Operating Experience (FC OpE) Program supports U.S. Nuclear Regulatory Commission (NRC) 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
2.1 Data Set Prior to fiscal year (FY) 2022, reported events were analyzed per calendar year. Starting in FY2022, events will be analyzed on a fiscal year basis. Due to limitations in available Inspection and Oversight Branch (IOB) staff during calendar year (CY) 2021, no report was issued for CY2021 events. This report includes reported events from FY2022 (October 2021 - September 2022) and events that occurred between January 2021 and September 2021. This 9-month period will be referred to as Partial CY2021 in this report.
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 70.50 Reporting Requirements, and 10 CFR Part 70, Appendix A, Reportable Safety Requirements. Thus, reported events included in the FC OpE Program are nuclear safety focused. Physical security (safeguards information) is not included in this data set. Appendix A, Table 1 shows the total number of reported events (prior to performing any screening1) for operating fuel cycle facilities since 2012. International events are evaluated for generic applicability to domestic licensees.
For FY2022 and Partial CY2021, there were no international reported events that would have generic implications for the U.S. fuel facility industry.
There were no Part 21 reports, including Counterfeit, Fraudulent, and Suspect Items (CFSI),
relevant to Fuel Cycle Facilities in Partial CY2021 and FY2022.
This report does not consider inspection findings unrelated to reported events in Partial CY2021 and FY2022. An assessment of inspection findings will be included in the FY2023 FC OpE report.
1 The data screening process determines the appropriate performance area, safety significance, and contributing factors. Events are further screened in this report to remove concurrent reports, retracted events, etc.
Enclosure
There were no Orders or Confirmatory Action Letters in Partial CY2021 or FY2022.
2.2 Results of FY2022 and Partial CY2021 FC OpE Data Analysis The average total number of events reported annually since 2012 is 16. Twenty events were reported in FY2022, and 12 events were reported in partial CY2021. The total number of reported events increased by approximately 30 percent in FY2022 compared to the last 12-month reporting cycle (CY2020) and is approximately 20 percent higher than average.
Of the 20 reported events in FY2022, licensees retracted three after determining that the event did not meet the reporting requirement threshold. Additionally, of the 20 reported events, seven were reported under 10 CFR 70 Appendix A (c), Concurrent Reports. Concurrent reports are required to be submitted to the 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. Of the 12 reported events in Partial CY2021, nine were reported under Concurrent Reports.
Inspectors follow up on retracted reports to determine if the retraction is correct, and to determine if other violations related to the event may have occurred. Of the three events retracted in FY2022, one was determined to be correctly retracted with no additional findings (EN55930), one was determined to be incorrectly retracted as the licensee failed to meet performance requirements in 10 CFR 70.61(b) by not establishing items relied upon for safety (IROFS) barriers (EN55770), and one was correctly retracted based on an update to a criticality calculation performed by the licensee, but determined to still be a minor violation in accordance with Example 1.g of IMC 0616 Appendix B for failure to follow their own operational requirements (EN55564). EN55564 was related to 10 CFR 70.24 which requires clearly audible alarm signals if accidental criticality were to occur.
The violation stemming from EN55770 is being treated as an apparent violation pending a final significance (enforcement) determination. The violation stemming from retracted event EN55564 was minor because the licensee updated their calculation and demonstrated that the failure of the equipment did not adversely impact the safety function of the system. This minor violation is closed and is not subject to enforcement action in accordance with the NRCs Enforcement Policy.
After screening out the events based on the criteria above, a total of 11 FY2022 events remained for analysis, and a total of three Partial CY2021 events remained for analysis.
Appendix A, Table 2 shows the resulting number of reported events per year after screening the data since CY2012. In FY2022, there is a significant increase in screened events compared to both CY2020, and the Partial CY2021 data. The average number of events since 2012 is 2
approximately nine per year. Therefore, although the increase is relatively significant since CY2020, it is only slightly higher than an average year since CY2012.
Several factors influence the annual number of screened events shown in Table 2. Some factors include extended periods of reduced operation or shut down 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 a 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. A potentially significant factor impacting reported events starting in 2020 is the effect of the COVID-19 public health emergency on licensee operations, including requesting and receiving exemptions to certain regulatory requirements. Changes in facility productivity/output would likely correlate to numbers of reported events but cannot be considered in this analysis due to limited information available from licensees in this area.
Although the number of overall reported events and screened events have increased from CY2020, the total number of events is still too limited to make quantitative statistical conclusions. Other than identifying an increase in events since the height of the pandemic, the staff considered the limited data from the fourteen events in Partial CY2021 and FY2022 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 2.2.1 and 2.2.2 of this report.
2.2.1 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 2. 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. The staff performed the screening, during which they considered initial event notification information, applicable 60-day reports and inspection reports.
2.2.2 Performance Area and Contributing Factors Evaluation Each event is categorized into 1 of 10 performance areas (Criticality Safety, Radiation Protection - Public, Radiation Protection - Occupational, Emergency Preparedness, Operational Safety - Fire, Operational Safety - Chemical, Material Control and Accounting -
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Shipping, Material Control and Accounting - Onsite, Construction, and Natural Phenomena Hazard).
Figure 1 illustrates the number of events per year by performance area. The figure shows that on average, criticality safety events are the most common, followed by operational safety, and radiation protection.
- Prior to FY2022, Material Control and Accounting events were not broken out into shipping or onsite, and Radiation Protection events were not broken out into Occupational and Public.
- As previously stated, events reported in the figure for 2021 are for a partial year (9 months) as we transitioned to fiscal year reporting in 2022.
Figure 1. Events per year by performance area Of the eleven events in FY2022, three were radiation protection performance area events, four were criticality safety performance area events, three were construction performance area events, and one was an operational safety fire performance area event. Of the three Partial CY2021 events, two were radiation protection performance area events, and one was a criticality safety performance area event. As is typically the case, radiation protection, and criticality safety performance area events dominated Partial CY2021 and FY2022.
Various violations and unresolved items related to events reported in Partial CY2021 and FY2022 are listed below. As a result, not all actions associated with events from the analyzed timeframe are closed. Notably, the safety significance of two apparent violations is still being evaluated, both related to IROFS construction barriers (EN55770 and EN55956). All other violations are either SL IV violations, non-cited violations, or minor violations. There is also one unresolved item (URI) in FY2022 that is still under review related to EN55802.
EN55956: An Apparent Violation (AV) of 10 CFR 70.61(b) was identified for failure to maintain independence between IROFS during a barrier breach resulting in degraded IROFS. The safety significance of this AV is still under review.
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EN55770: An Apparent Violation (AV) of 10 CFR 70.61(b) was identified for failure to establish IROFS barriers. The safety significance of this AV is still under review.
EN55802: As part of the extent of condition for EN55770, the licensee reported a potential unanalyzed condition in accordance with 10 CFR 70 Appendix A(b)(1). Some vehicles that could potentially result in a hazard to the facility were previously brought near buildings of concern without establishing IROFS. An unresolved item was opened to review evaluations and assessments of various vehicles by the licensee. This item is still under review.
EN55480: A severity level IV, non-cited violation (NCV) of 10 CFR 70.50(c)(1) was documented for failure to report that the Criticality Accident Alarm System (CASS) was not clearly audible in all areas of the Immediate Evacuation Zone (IEZ). This item is closed.
EN55431: A severity level IV, non-cited violation (NCV) of 10 CFR 71.5 was documented for failure to properly survey, package, mark and label, and placard licensed material contained in a process enclosure before transporting the material outside the site on public highways. Additionally, the licensee failed to store licensed material in a sealed package in accordance with the license application. This item is closed.
EN55911: A minor violation was documented for failure to perform an item(s) relied on for safety sample prior to transfer of a tank which is a safety condition in the licensees license application. This item is closed.
EN55902: A severity level IV, cited violation (CV) of 10 CFR 70.24 was documented for failure to maintain the Criticality Accident Alarm System capable of energizing clearly audible alarm signals in certain areas of the facility in which licensed special nuclear material is handled, used, or stored for a period greater than eight hours. This item is closed.
EN55861: A severity level IV, non-cited violation (NCV) of 10 CFR 70.50 was documented for failure to report a radiological spill.
EN55712: A severity level IV, cited violation (CV) of a license condition was documented for the failure to follow standard operating procedures during material inventory cleanout activities leading to a small fire involving NRC-licensed material. This item is closed.
In addition to the events from the Partial CY2021 and FY2022 timeframe, the evaluation of an operational safety event from CY2020 regarding a fire and resultant fatality at the licensees supercompactor is ongoing. Apparent violations have been identified, and an enforcement decision is pending. The Occupational Safety and Health Administration (OSHA) has completed their investigation, cited the licensee, and issued fines. The licensee reported this industrial safety event to OSHA and as a concurrent report to the NRC in accordance with Appendix A to 10 CFR Part 70. Given the potential significance of the pending enforcement decision, this event is included in this report for thoroughness and informational purposes.
The predominant contributing factor in most of the fourteen events analyzed 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 5
recommended as an inspection focus area. Inadequate procedures, and inadequate training were also common contributing factors.
2.2.3 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 partial CY2021 and FY2022. The staff rates safety significance from high to low using criteria consistent with the NRC Enforcement Policy. Based on the rating criteria, twelve of the fourteen events from partial CY2021 and FY2022 were of low safety significance. The safety significance of two of the fourteen events is still being evaluated.
3.0
Conclusions:
Based on the reported events this year, the staff concludes:
- 1) There is an increase of events over the past year compared to the previous 12-month reporting period, but the number of events is not significantly higher than an average year within the analyzed time period.
- 2) Failure or degradation of management measures continues to be the most common contributing factor to events and should continue to be an area of inspection focus.
- 3) Twelve of the fourteen screened events in partial CY2021 and FY2022 were of low safety significance, and two are currently under review for potentially higher safety significance.
- 4) The staffs analysis did not identify any new or emerging trends.
4.0 Recommendations
No new recommendation is identified this year. OpE program staff will continue to evaluate event notification trends, in collaboration with the regional offices, and provide recommendations to management if trends emerge that will improve the fuel cycle program.
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Attachment:
Summary Tables of Events Total Number of Events Per Facility Facility 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021* 2022**
Framatome 2 2 1 2 2 0 0 1 1 1 5 BWXT 2 1 0 3 1 1 1 2 1 1 0 Global Nuclear Fuels Americas 8 3 2 0 2 1 5 7 9 4 3 Honeywell Metropolis 10 7 12 5 0 0 0 0 0 0 0 Louisiana Energy Services/ URENCO USA 0 1 0 2 1 2 3 4 1 1 7 Nuclear Fuel Services 1 0 6 1 3 0 3 2 0 2 2 Westinghouse 2 0 0 1 2 1 3 5 2 1 2 American Centrifuge 0 0 0 0 0 0 0 0 0 2 0 Total number of events per year 25 14 21 14 11 5 15 21 14 12 20 Table 1: Total number of reported events at licensed facilities between 2012 and 2022
- Partial year report (January 2021 through September 2021)
- First fiscal year data reporting (October 2021 through September 2022)
Year 2012 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 Screened Events 17 9 13 12 11 4 6 9 2 3 11 Table 2: Number of events after screening process between 2012 and 2022 Attachment