ML23075A356
| ML23075A356 | |
| Person / Time | |
|---|---|
| Issue date: | 05/30/2023 |
| From: | NRC/EDO |
| To: | NRC/OIG |
| Shared Package | |
| ML23075A354 | List: |
| References | |
| OIG-20-012 | |
| Download: ML23075A356 (6) | |
Text
STAFF RESPONSE TO THE OFFICE OF THE INSPECTOR GENERALS SPECIAL INQUIRY INTO THE U.S. NUCLEAR REGULATORY COMMISSION REGION IIS INSPECTIONS OF INDEPENDENT SPENT FUEL STORAGE INSTALLATIONS AT OPERATING REACTORS (OIG-20-012)
Executive Summary The staff conducted a review of the finding presented in the Office of the Inspector Generals (OIG)-20-012, Special Inquiry into the U.S. Nuclear Regulatory Commission Region IIs Inspections of Independent Spent Fuel Storage Installations (ISFSIs) at Operating Reactors.
The OIG identified one finding with four subparts to the U.S. Nuclear Regulatory Commissions (NRC) staff. The finding identified that Region IIs past inspection practice resulted in missed opportunities to identify ISFSI violations. Specifically, the OIG determined that Region IIs inspections of repeat ISFSI loading campaigns from 2012 through 2020 deviated from NRC policies related to inspector qualification and inspection guidance. The OIG report further stated that fully qualified ISFSI inspectors began inspecting Region II ISFSIs in 2021, and since then, those inspectors have found multiple ISFSI violations that might have been detected earlier; however, there are still a significant number of loaded casks that have not been properly inspected according to the OIG report.
The NRC staff considered the finding and concluded that there is no immediate safety concern and that the NRC has reasonable assurance of the long-term safety of ISFSIs. The enhanced ISFSI inspection program implemented in January 2021 by all NRC regions, including Region II, provided for a more risk-informed, comprehensive, and consistent approach to oversight of spent fuel storage across the NRC. Since implementing the enhanced program, ISFSI inspections in Region II have been performed by inspectors qualified under the ISFSI qualification process described in Inspection Manual Chapter (IMC) 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-Than-Class C Waste at Independent Spent Fuel Storage Installations and for 10 CFR PART 71 Transportation Packagings. Further, NRC reviewed the violations that the OIG stated might have been detected earlier and found that all violations were of very low safety significance that did not result in safety consequences to ISFSI operations.
Staff Response to OIG Finding and Its Subparts Below is the OIGs finding followed by the NRC staffs response to each subpart of the finding, including completion dates of NRC actions taken (where applicable).
Finding: Region IIs past inspection practice resulted in missed opportunities to identify ISFSI violations.
Subpart A: Inspectors did not obtain ISFSI qualifications before inspecting ISFSIs.
NRC Response to Subpart A:
As of January 2021, all ISFSI inspections in Region II have been performed by inspectors qualified under the ISFSI qualification process described in IMC 2690. While Region IIs methodology of using reactor operations and health physics inspectors from 2012 until 2020 was not consistent with ISFSI inspector qualifications, these inspectors were qualified in areas that would provide an adequate level of understanding to identify issues to elevate to a qualified ISFSI inspector.
Enclosure
IMC 1246B03, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector, provides the qualifications requirements for ISFSI inspectors.
From 2012 until 2020, Region II conducted construction, preoperational, and initial operational inspections with ISFSI inspectors qualified in accordance with IMC 1246B03. However, during this timeframe, NRC Region II conducted ISFSI repeat operational inspections, which are inspections of routine licensee loading of spent nuclear fuel from the spent fuel pool to an ISFSI, with inspectors who were not qualified in accordance with IMC 1246B03, but who did possess qualifications under IMC 1245 App C1, Reactor Operations Inspector Technical Proficiency Training and Qualification Journal, or IMC 1245 App C3, Health Physics Inspector Technical Proficiency Training and Qualification Journal.
Rather than cross qualify all reactor operations inspectors and health physics inspectors as ISFSI inspectors, Region II opted to fully qualify a limited number of inspectors under IMC 1246B03. The qualified ISFSI inspectors did not perform the repeat operational inspections, but rather provided coordination and remote support of ISFSI operational inspections conducted by other inspectors. Even though the qualifications were not entirely the same, reactor operations and health physics inspectors possessed appropriate and sufficient knowledge to oversee and inspect ISFSI operations considering their training in common core areas of the oversight process. This framework was governed by Regional Office Instruction (ROI) 2294, Revision 4, Independent Spent Fuel Storage Installation Inspection Program, which set expectations for inspector communications when issues were identified that required specific attention by a qualified ISFSI inspector.
The NRC staff initiated a review of the ISFSI inspection program in June 2019, known as the ISFSI enhancements program initiative. The goal of this initiative was to evaluate and enhance the NRCs existing ISFSI inspection program by developing a clearer, more risk-informed, comprehensive, and consistent approach to ISFSI inspections across the four regions that emphasized focus on those areas most important to safety. The ISFSI enhancement program initiative included ensuring a consistent approach to inspection and specifically addressed the inconsistent use of qualified ISFSI inspectors.
In January 2021, the NRC implemented changes to the inspection program to execute the ISFSI enhancement program. Accordingly, Region II employed changes that included shifting ISFSI inspection responsibilities from reactor operations and health physics inspectors to qualified ISFSI inspectors. The NRC initiated an assessment of the agencys implementation and adequacy of ISFSI enhancement program after 2 years of operating experience. The staffs preliminary findings have shown that overall, the enhancements made to the program were effective in developing a clearer, more risk-informed, comprehensive, and consistent inspection program.
The staff does not believe any further action is needed to address Subpart A of the OIG finding, because as of January 2021, ISFSI inspections in Region II have been performed by inspectors qualified under the ISFSI qualification process described in IMC 2690.
Subpart B: Region II likely did not fully meet ISFSI inspection requirements based on the inspection hours expended.
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NRC Response to Subpart B:
As of January 2021, all ISFSI inspections in Region II have been performed in accordance with IMC 2690, which states the frequency and approximate level of anticipated effort, and identifies four phases in the NRCs ISFSI inspection program:
- Phase 1: Design, fabrication, and construction;
- Phase 2: Preoperational testing, including dry runs;
- Phase 3: Spent fuel loading and unloading operations; and,
IMC 2690 specifies that Phase 3 operational inspections, the focus of the OIGs special inquiry, are to be performed in accordance with inspection procedure (IP) 60855.1, Operation of an ISFSI at Operating Plants, dated September 5, 2006, which indicated a level of effort of 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> for repeat ISFSI operational inspections. IMC 2690 indicated that IP 60855.1 should have been performed every 2 years (not to exceed 3 years).
From 2012 through 2020, Region II implemented Phase 3 operational inspections in accordance with ROI 2294. ROIs are supplemental guidance to inspectors that serve to disseminate, implement, clarify, or amplify policy or other information contained in other NRC documents (as described in ROI 0201, Revision 12, Systems of Notices and Instructions), and are approved by the regional administrator, or their designee. ROI 2294, Revision 4, stated that:
The frequency of inspection is a function of licensee loading campaigns, but safety inspections are expected to be completed in approximately ten hours of inspection per year.
Accordingly, the ROI 2294 guidance differed from the IMC 2690 guidance for Phase 3 ISFSI inspections.
As of January 2021, all NRC regions have implemented the enhanced ISFSI inspection program. Region II has implemented changes to the inspection program to conduct Phase 3 ISFSI inspections in accordance with IMC 2690 and has withdrawn ROI 2294.
The NRC has initiated an assessment of the agencys implementation and adequacy of ISFSI enhancement program after 2 years of operating experience. Preliminary findings of this assessment have shown that all Phase 3 inspections performed during the 2 years examined, including those performed by Region II, met inspection objectives. Specifically, the NRC has reviewed inspection reports and confirmed with inspectors that all inspection objectives were completed.
However, the NRC has identified that for Phase 3 inspections, consistently across all regions, the level of effort charged in the agencys time and labor reporting database has been, on average, approximately 30 percent less than that estimated by the enhanced ISFSI program.
The staff is taking action to develop and implement a strategy to address the discrepancy between hours charged and to evaluate the level of effort estimated in the inspection procedure.
The staff expects that this evaluation will be complete by October 1, 2023.
Subpart C: Qualified ISFSI inspectors found multiple ISFSI violations that might have been detected earlier.
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NRC Response to Subpart C:
To inform the staffs response to this subpart, the staff reviewed the 6 violations of more than minor safety significance identified since January 2021 at the 16 ISFSI sites inspected. The staff found that three of the violations were recent design changes that would have not been in place during the previous inspections, and the remaining three violations were legacy violations. The legacy violations were of very low safety significance and did not result in safety consequences to ISFSI operations. The low number of violations did not yield any adverse programmatic deficiencies or trends. Additionally, the staff reviewed operating experience across the ISFSI program, specifically evaluating violations across all regions over the previous 2 years and did not identify any operating experience that affected the safety of ISFSI sites. Therefore, the NRC staff concludes that no additional corrective action is needed to address Subpart C of the OIG finding.
Subpart D: A significant number of casks have not been properly inspected.
NRC Response to Subpart D:
The NRC has reasonable assurance of the long-term safety of ISFSIs.
The NRC reviewed a sample of results of inspections performed at Region II ISFSI sites. These included inspections of preoperational and initial cask loading during the period subject to the OIGs findings and inspection of these ISFSIs under the revised inspection program.
The NRCs inspection program evaluates ISFSI performance through selective inspections and does not inspect every activity performed at an ISFSI. Instead, the inspection program is focused on the most safety and risk significant activities at an ISFSI. The inspection program focuses on appropriate samples of ISFSI activities based on potential risk, past operational experience, and regulatory requirements.
The NRC staff determined that qualified ISFSI inspectors and qualified reactor engineering inspectors with experience in welding and non-destructive examination performed preoperational testing inspections at each site prior to its ISFSI operation and additionally performed an initial operational inspection for the first cask loaded at each site. These inspections contained extensive risk-significant reviews to ensure an adequate baseline for safe operations of an ISFSI.
Additionally, the NRC staff considered additional insights that may have been gained from ISFSI operational inspections performed by qualified reactor operations and health physics inspectors.
The NRC staff also recognizes that ISFSI operational areas overlap with functional areas inspected through the Record of Purchase through IMC 2515, Light Water Reactor Inspection Program Operations Phase, including: radiation protection, environmental monitoring, change management, emergency response, fire protection, maintenance, problem identification and resolution, in-service testing, and quality assurance. These overlapping programmatic areas would provide an additional means to identify issues of concerns or adverse trends related to ISFSI operations.
The NRC staff determined that qualified inspectors have performed operational inspections, meeting the inspection objectives, at each ISFSI in Region II in accordance with the enhanced ISFSI program since January 2021.
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The staff assessed results of these inspections and identified that no violations of greater than very low safety significance were identified. The staff found that dry storage systems met design and functional requirements. Additionally, based upon interviews with inspectors, no adverse programmatic deficiencies or trends were identified that would call into question the safety of previously loaded dry storage systems. The staff determined that these results provide an indication of adequate safety that covers the timeframe from 2012 until 2020.
Casks loaded from 2012 until 2020 will continue to be subject to inspection during routine operational inspections by qualified ISFSI inspectors. These inspections include observations of various operations, maintenance, surveillance, engineering, and plant support activities performed at the ISFSI. Normal activities include monitoring temperatures, calibrating instruments, inspecting ventilation openings for obstructions, surveying radiation levels, monitoring the structural condition of the dry storage system and ISFSI pad, and environmental monitoring. Inspectors will continue to perform a walkdown and an independent radiation survey of the ISFSI to perform an assessment of its material and radiological condition. Any adverse findings will be dispositioned in accordance with the licensees corrective action program and will be dispositioned by the NRC under its enforcement policy.
Following the initial casks licensing term, aging management inspections of previously loaded casks will be performed by the licensee to ensure continued safe operation. The results of these inspections will be reviewed by NRC staff through the ISFSI inspection program.
Considering these factors, the NRC has reasonable assurance of long-term storage safety, and no further action is necessary.
Conclusion The staff recognizes that Region IIs past inspection practice could have potentially resulted in missed opportunities to identify ISFSI violations. However, the staff considered additional context and has reasonable assurance of long-term storage safety of Region II ISFSIs.
Additionally, in 2021 the NRC implemented the enhanced ISFSI inspection program, which provides a consistent approach to oversight of ISFSIs across all four regions of the NRC.
The NRC has concluded that all Phase 3 inspections performed during the 2 years examined, including those performed by Region II, met the inspection objectives. However, the NRC has identified that for Phase 3 inspections, the level of effort charged in the agencys time and labor reporting database is, on average, approximately 30 percent less than that estimated by the enhanced ISFSI program. The staff is taking action to develop and implement a strategy to address the discrepancy between hours charged and to evaluate the level of effort described in the inspection procedure.
Date of planned completion: October 1, 2023 Point of
Contact:
Matthew Learn, NMSS/DFM/IOB, 630-829-9603 References
- 1. NRC, OIG-20-012, Special Inquiry into the U.S. Nuclear Regulatory Commission Region IIs Inspections of Independent Spent Fuel Storage Installations at Operating Reactors, Washington, DC, March 2023. (Agencywide Documents Access and Management System Accession No. ML23053A241) 5
- 2. NRC, IMC 2690, Inspection Program for Storage of Spent Reactor Fuel and Reactor-Related Greater-Than-Class C Waste at Independent Spent Fuel Storage Installations and for 10 CFR PART 71 Transportation Packagings, Washington, DC, December 2020. (ML20338A192)
- 3. NRC, IMC 1246 B03, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector, Washington, DC, November 2011.
- 4. NRC, IMC 1245 C1, Reactor Operations Inspector Technical Proficiency Training and Qualification Journal, Washington, DC, November 2020. (ML20112F347)
- 5. NRC, IMC 1245 C3, Health Physics Inspector Technical Proficiency Training and Qualification Journal, Washington, DC, February 2017. (ML15323A464)
- 6. NRC, Final Decision of Independent Spent Fuel Storage Installation Inspection Program Enhancements - Working Group Recommendations, Washington, DC, March 2020.
- 7. NRC, IMC 2690, Inspection Program for Dry Storage of Spent Reactor Fuel at Independent Spent Fuel Storage Installations and for 10 CFR Part 71 Transportation Packagings, Washington, DC, March 2012. (ML120390415)
- 8. NRC, ROI 0201, Systems of Notices and Instructions, Atlanta, GA, September 2020.
- 9. NRC, ROI 2294, Revision 4, Independent Spent Fuel Storage Installation Inspection Program, Atlanta, GA, March 2018.
- 10. NRC, IMC 2515, Light Water Reactor Inspection Program Operations Phase, Washington, DC, March 2021. (ML21062A084) 6