ML23101A087

Enclosure - ISFSI Program Self-Assessment

ML23101A087
Person / Time
Issue date:	11/29/2023
From:	NRC/NMSS/DFM/IOB
To:	Division of Fuel Management
Shared Package
ML23101A086	List: ML23101A044 ML23101A087
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Download: ML23101A087 (9)

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Independent Spent Fuel Storage Installation Inspection Program Self-Assessment

1. BACKGROUND

The Independent Spent Fuel Storage Installation (ISFSI) inspection activities provide oversight of spent nuclear fuel storage at both dry cask storage facilities and wet pool storage facilities licensed under Title 10 of the Code of Federal Regulations (10 CFR) Part 72 in a manner consistent with the U.S. Nuclear Regulatory Commission (NRC) mission. The ISFSI Inspection Program objectives are to evaluate activities associated with spent fuel storage including fabrication, pre-operational testing, canister loadings, and long-term storage; and determine by direct observation and independent evaluation whether licensees adequately implement requirements. ISFSI inspections are performed at operating reactors with co-located ISFSIs and at stand-alone ISFSIs.

On June 4, 2019, a working group was formed as part of the ISFSI Inspection Program Enhancements Initiative 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 NRC regional offices that focuses on areas most important to safety (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19155A273).

The primary goal of the working group was to improve the effectiveness, efficiency, and consistency of ISFSI inspections, as well as the budget, planning, and tracking mechanisms used by the agency. To do so, the staff leveraged best practices of the existing program, while considering internal stakeholder feedback on how to enhance and improve the NRCs oversight of ISFSIs. The working group used probabilistic risk analyses, byproduct material radiation exposure studies, subject matter expertise, operating experience, and lessons learned from the last 30 years of ISFSI inspection history to inform the recommended enhancements to the program.

By memorandum dated March 19, 2020 (ML20079E064), the Director of the Division of Fuel Management (DFM), Office of Nuclear Material Safety and Safeguards (NMSS) endorsed recommendations to implement risk-informed enhancements to the ISFSI Inspection Program (ML20078P093). The implementation of the enhancement efforts was documented by memorandum dated February 9, 2021 (ML21006A040).

The ISFSIs are currently inspected on a triennial frequency for recurring loading or monitoring inspections, and when required throughout the construction, pre-operational testing, and initial loading of a new ISFSI. The program requirements for the ISFSI Inspection Program are contained in Inspection Manual Chapter (IMC) 2690 and Inspection Procedures (IPs) 60853 through 60858.

2. INTRODUCTION The purpose of this report is to present the results of the NRC staffs self-assessment of the ISFSI Inspection Program for calendar year (CY) 2021 and CY 2022. This review also included an assessment of the implementation and outcomes of each major change to the program made through the 2020 Enhancement Initiative (ML20078P093).

The self-assessment team included representatives from NMSS and the four regional offices with extensive knowledge and experience in ISFSI inspection and oversight activities. The team developed an approach and criteria to measure the effectiveness of the ISFSI Inspection Program and of the enhancements made to the program through the 2020 Enhancement

Enclosure Initiative. The team then established conclusions and recommendations based on findings from the information gathered.

As part of this approach, the team developed a set of criteria and used a combination of survey questions and quantitative data to assess the effectiveness of the program. The team gathered conclusions through review of actual inspection data available in agency and regional tracking systems, as well as through a survey of staff engaged in this oversight program, which provided opportunities for staff to share greater detail on their personal experiences under the program.

Overall, the results of this self-assessment show that the ISFSI Inspection Program is effective in achieving its program goals. Further, the enhancements made to the program through the 2020 Enhancement Initiative had the direct benefit of creating a more risk-informed, comprehensive, and consistent inspection program across the NRC.

While the self-assessment team concluded that the ISFSI Inspection Program is effective, the team developed seven recommendations that when implemented will further enhance the program. These include items such as incorporating guidance into IMC 2690 and provide training to ensure time is being charged consistently across the spent fuel storage program, adding the allowance of 10 additional hours for follow-up inspection between onsite inspections to IP 60858, retire IP 60857 and relocate the specific guidance to another place, provide regular training sessions that highlight 10 CFR 72.48 reviews, conduct a self-assessment of the ISFSI Inspection Program at the end of each triennial period, and revise IP 60855 to include a 15 percent range to the resource estimate.

The team also assessed the status of recommendations in the March 19, 2020 (ML20079E064) memorandum from the DFM Director which endorsed recommendations to implement risk-informed enhancements to the ISFSI Inspection Program (ML20078P093). Most notably, the revisions in inspection procedures and priorities have further aided the inspection staff in focusing on higher risk activities and will benefit newer inspectors in guiding their inspection efforts. In addition, the revised triennial inspection frequency contributed to improved consistency in timing of inspections among the regional teams and licensees.

Additionally, the team identified that for IP 60855 inspections, consistently across all regions, the level of effort charged in the agencys time and labor reporting database had been, on average, approximately 30 percent less than that estimated in the inspection procedure. The team performed an evaluation to determine the causes and identify correction actions to address this underutilization of inspection hours. This report highlights corrective actions that have been taken to date and corrective actions still planned. For example, the team is recommending a 15 percent range be added to the resource estimate listed in the IP.

3. SELF ASSESSMENT RESULTS

The results of this self-assessment show that the ISFSI Inspection Program is effective in achieving its program goals. The discussion below details the CY 2021 and CY 2022 ISFSI program self-assessment results.

Element 1: Measure regional program effectiveness and uniformity in implementing the ISFSI Inspection Program Regional Performance Metric The team measured the effectiveness of, and adherence to, the current ISFSI Inspection Program using the Congressional Budget Justification (CBJ), CBJ-SF-15, metric. The CBJ-SF-

2 15 metric is a new metric that was put in place in 2022. The metric reports the percent of inspections completed by NMSS and each regional office in accordance with Manual Chapter 2690 requirements. The percent completed is calculated by the number of IMC 2690 inspections completed during the quarter divided by IMC 2690 inspections required to be performed.

The team found that this new metric has been effective in ensuring inspection procedures are performed within timeliness requirements as stated in the IMC and ensuring inspection objectives are completed in accordance with IP requirements. Specifically, one inspection was found to be overdue for IP 86001 and was subsequently completed in the next fiscal year.

NMSS staff recently developed a dashboard that clearly displays inspection hour data. This dashboard will be used to streamline the data collection for the CBJ-SF-15 metric in the future.

Data Trending Focus Areas The Spent Fuel Storage and Transportation Operating Experience Report provides an analysis that identifies trends in operational data and makes recommendations to improve our regulatory programs. The Spent Fuel Storage and Transportation Operating Experience Report for fiscal year (FY) 2022 (ML23030B922) examined inspection findings for FY 2021 and FY 2022 to identify any trends and make recommendations. The report highlights an increase in tornado hazard findings. The NRC has taken actions to address this increase through the use of Enforcement Guidance Memorandum (EGM) 22-001. EGM 22-001 provides guidance to staff to exercise enforcement discretion for violations of 10 CFR 72.122(b), Protection against environmental conditions and natural phenomena, 10 CFR 72.212, Conditions of general license issued under 10 CFR 72.210, and/or 10 CFR 72.48, Changes, tests and experiments during ISFSI handling operations when certain conditions are met by the licensee. Further on February 16, 2022, the Nuclear Energy Institute (NEI) submitted NEI 22-02, Guidelines for Weather-Related Administrative Controls for Short Duration Outdoor Dry Cask Storage Operations, Revision 0 for the staffs review and endorsement. A draft regulatory guide, DG-3057, endorsing NEI 22-02, with clarification and exceptions, was issued for 30-day public comment on June 5, 2023. Staff have completed evaluating public comments and made conforming changes to the final Regulatory Guide 3.77, Weather-Related Administrative Controls at Independent Spent Fuel Storage Installations which will be issued in fall 2023. No other notable trends were identified in the FY 2022 report.

Element 2: Assess effectiveness of ISFSI Inspection Program enhancements Frequency of ISFSI Inspection Based on recommendations from the 2020 Enhancement Initiative, the inspection frequency for routine loading campaigns and monitoring operations at ISFSIs was extended from every two years, not to exceed three years, to a triennial frequency. In the triennial frequency the inspection is performed at least once during the 3-year cycle, which aligns with the Reactor Oversight Program triennial inspection cycles as defined in IMC 2515, Light-Water Reactor Inspection Program - Operations Phase, Attachment 1. Additionally, a quarterly inspection frequency for extended loading campaigns was added to IMC 2690.

IMC 2515, Attachment 1, defined the 8 th triennial inspection cycle as CY 2020, CY 2021, and CY 2022. The enhancements to the ISFSI program were implemented and became effective at the beginning of CY 2021. Each ISFSI site was inspected during the 8th triennial inspection cycle as required by the program.

3 The team determined that the enhancement to a triennial inspection frequency was effective and contributed to improved consistency in the timing of inspections among the regional teams and licensees. The revised frequency allowed for flexibility when planning inspections to account for different loading campaign schedules at each individual site while ensuring one site was not inspected more or less than another site. Additionally, the team observed greater consistency in the frequency of inspections for continuous loading campaigns, which has improved efforts across the program to observe higher risk activities.

The team identified the number of IP 60855 operational inspections performed per year before and after the enhancements were implemented and found that there was no significant change in the number of operational loading campaign inspections due to the frequency change.

Further, the team looked at the number of inspection findings identified per year before and after the enhancements and found that there was no significant change in the amount of inspection findings identified.

The team found that quarterly inspections were performed at a total of seven licensee facilities for continuous campaigns. In each case the quarterly inspection frequency was met. The staff provided feedback through survey responses noting that the enhancement helped the program by clearly defining a frequency for these types of inspections and helping with consistency across the regions.

The enhancements made by defining a triennial inspection frequency for routine loading campaigns and a quarterly inspection frequency for continuous loading campaigns had the direct benefit of creating a more consistent oversight program.

Cross-Qualification Program

Based on recommendations from the 2020 Enhancement Initiative, IMC 2690 Appendix C was added to include requirements for IMC 1245, Appendix C1/C2 qualified inspectors to cross-qualify as ISFSI inspectors. The IMC allows for inspectors who are qualified under IMC 1245, Appendix C1/C2 to complete a partial qualification to conduct independent inspections under IP 60855, Operation of an ISFSI or full qualification to independently conduct all ISFSI inspection procedures.

The team determined that the enhancement to add a cross-qualification program was effective.

The new cross-qualification program was used by staff to streamline qualifications for inspectors already qualified under IMC 1245. This helped with the resource challenges the ISFSI Inspection Program has had in recent years by quickly adding qualified inspectors to the program.

The Office of Inspector General report (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, (ML23053A241) determined that Region IIs inspections of repeat ISFSI loading campaigns from 2012 to 2020 deviated from NRC policies related to inspector qualification. The ISFSI Inspection Program enhancements included ensuring a consistent approach to inspection and specifically addressed the inconsistent use of qualified ISFSI inspectors. The cross-qualification for inspectors already qualified under IMC 1245, Appendix C1/C2 contributed to Region IIs ability to perform all 2021 and 2022 ISFSI inspections by inspectors qualified under the ISFSI qualification process described in IMC 2690.

4 The team identified a recommendation to move the justification for cross-qualification to the actual qualification journal, IMC 1246B03, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector (Recommendation 1).

ISFSI Inspection Program Level of Effort Based on recommendations from the 2020 Enhancement Initiative, the level of effort for IPs 60853, 60854, 60855, 60856, 60857, and 60858 was revised.

The team determined that the revisions to level of effort made in each IPs resource estimate section was effective. Level of effort was adequate and focused on the most safety significant activities.

The 2020 Enhancement Initiative developed a risk prioritization tool in IMC 2690 Appendix D, Guidance for Risk-Informed Inspection Prioritization, to help inspectors identify the most risk significant activities to inspect starting from construction and pre-operational activities to initial and subsequent ISFSI loading campaigns. Standard inspection activities were evaluated and prioritized in accordance with their relative risk. Priority level 1 activities were determined to have the highest amount of risk, necessitating the greatest level of inspection effort while priority level 3 activities were determined to have the lowest amount of risk, necessitating the lowest level of inspection effort. The team found that the risk prioritization tool was clear and helped focus the inspectors on the more risk significant activities. Additionally, the new prioritization scheme in IMC 2690 Appendix D was found to be more effective in focusing inspectors on more risk significant activities with 90 percent of the staff saying they spent 50-75 percent of their time on priority level 1 activities. The risk prioritization tool directly contributed to the inspectors ability to apply the appropriate level of effort with appropriate risk while on inspections.

Inspection hour data for the last 5 years was collected to gather insights on the effectiveness of the level of effort change for each inspection procedure. The data showed that the number of inspections and level of effort had become more consistent among the regions. However, the level of effort expended under IP 60855, Operation of an Independent Spent Fuel Storage Installation per inspection, on average, was approximately 30 percent less than the estimated level of effort stated in the inspection procedure resource estimate. The team confirmed that all inspection objectives and requirements included within the inspection procedure had been met by reviewing 100 percent of the inspection reports and through discussions with inspectors and branch chiefs. Further, the team performed an initial evaluation to determine the causes and identify any corrective actions that might be needed to address the underutilization of inspection hours. The results of this evaluation can be seen in Element 3 below.

The 2020 Enhancement Initiative added an additional 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per site to be performed as needed to follow-up on risk-important licensee ISFSI activities between onsite inspections within the triennial cycle. The team found that the 10 additional hours per site between onsite inspections were not used since the enhancements were implemented because there were no circumstances when they were needed. However, feedback was provided, indicating that inspectors need additional guidance on how to use these 10 additional hours for follow-up inspections and how to account for the time in the Human Capital Management time and labor system. Training on when and how to use the 10 additional hours will be provided at the next ISFSI Inspection Program counterpart meeting in February 2024. Further, the team recommends including the allowance of 10 additional hours for follow-up inspection between onsite inspections to IP 60858 so that this can also be used to follow-up on any activities at Away-from-Reactor (AFR) licensees (Recommendation 2).

5 The 2020 Enhancement Initiative incorporated the level of effort to review 10 CFR 72.48 evaluations into the applicable complementary ISFSI inspection procedures and specified the use of IP 60857, Review of 10 CFR 72.48 Evaluations, as a reference for ISFSI inspections.

Staff indicated that use of IP 60857 as a guidance document made their reviews more consistent. However, feedback was also given that specific guidance should be added to the respective IP rather than having a stand-alone procedure. Based on these survey results, and the fact that IP 60857 is not used to charge inspection hours, the team recommends retiring IP 60857 and relocating the specific guidance to another place (i.e., other inspection procedure or an Appendix to the IMC) (Recommendation 3).

The Spent Fuel Storage and Transportation Operating Experience Report for FY 2022 (ML23030B922) showed that certificate of compliance (CoC) holder and licensee changes made through the use of 10 CFR 72.48 is an area where violations have been previously identified. Six 10 CFR 72.48 violations were issued in FY 2021 and four 10 CFR 72.48 violations were issued in FY 2022. The NRC staff inspects a sample of 10 CFR 72.48 screenings and evaluations during each inspection to verify that changes made are screened correctly and the appropriate regulatory review is provided to ensure safe storage of spent fuel. CoC holders and licensees perform hundreds of 72.48 screenings per year, therefore it is important that inspectors are well versed with the guidance that is currently located in IP 60857. The team recommends that regular training sessions during headquarters (HQ) and regional counterpart meetings that highlight 10 CFR 72.48 reviews would be beneficial for both new inspectors going through the qualification process and as a refresher for experienced inspectors (Recommendation 3).

In summary, the enhancements that have been implemented over the last two years have directly contributed to a more effective and consistent approach to inspection across the agency. The team recommends that further guidance and training be added to ensure that time is being charged consistently across the spent fuel storage program; the allowance of 10 additional hours for follow-up inspection between onsite inspections should be included in IP 60858; staff retire IP 60857 and relocate the specific guidance to another place; and regular training sessions on 10 CFR 72.48 review be added to HQ and regional counterpart meetings.

Funding for the ISFSI Inspection Program Based on recommendations from the 2020 Enhancement Initiative, the budget structure was updated to have the ISFSI Inspection Program solely funded by the Spent Fuel Storage and Transportation business line. The Office of Nuclear Reactor Regulation transferred their funding portion for ISFSI efforts for FY2022 and beyond to NMSS. Additionally, as of CY 2021, IPs 60854.1, 60855.1, and 60856.1 were retired and IMC 2690 and IMC 2515 were revised to remove the references to these IPs. Previously, IPs 60854.1, 60855.1, and 60856.1 were only in place to highlight prioritized sections of IPs 60854, 60855, and 60856 respectively, which were intended to be used at ISFSIs not collocated with an operating reactor, and to track funding of ISFSI inspections performed specifically at operating reactors.

The team determined that the enhancement to update the budget structure was beneficial and effective based on survey responses from branch chiefs and staff across the ISFSI Inspection Program.

Although the regions acknowledged that an adequate level of funding for the implementation of the ISFSI Inspection Program exists, hiring, training, and retaining inspectors continues to be a challenge. While NMSS/DFMs Inspection and Oversight Branch (IOB) has been able to support the regions with additional inspectors when needed, regions are encouraged to look for ways to increase the amount of qualified ISFSI inspectors to the extent possible through cross-

6 qualification training that would allow for staffing and schedule flexibilities, and greater effectiveness in implementing the program, as discussed in the Cross-Qualification Program section above. Additionally, IOB will continue to assess the funding needs in all regions through the annual budget formulation process to decide if additional resources are needed based on implementation of the enhanced ISFSI Inspection Program.

Additional Areas for Consideration

The 2020 Enhancement Initiative identified additional follow-on efforts, including 1) inspection readiness for transportation of spent nuclear fuel; 2) develop inspection guidance and resources for Consolidated Interim Storage Facilities (CISFs); and 3) develop a routine assessment of the ISFSI Inspection Program to evaluate changes to the oversight program and explore areas involving further enhancements, inspector agility, and efficiencies.

A separate working group was formed to assess inspection readiness for transportation of spent nuclear fuel. The working group completed its assessment in October 2021 (ML21298A164).

Currently the modifications to the procedures are on hold pending resources and other higher priority work.

A separate working group was formed to develop inspection guidance and resources for CISFs.

This working group is currently on hold pending resources and other higher priority work.

This report documents the results of the first self-assessment of the ISFSI Inspection Program.

The team determined that additional self-assessments should be completed at the end of each triennial period. The staff will develop a procedure to assist in conducting these recurring self-assessments (Recommendation 4).

Element 3: Focused Assessment

Evaluation of Level of Effort

As described above, the team identified that for IP 60855 inspections, consistently across all regions, the level of effort charged in the agencys time and labor reporting database had been, on average, approximately 30 percent less than that estimated in the inspection procedure. To further evaluate the data the team collected more specific information associated with each inspection where the inspection hours were more than 10 percent below the resource estimate listed in the inspection procedure. The team found that the underutilization of resources was due to several factors such as scheduling conflicts, operational issues that arose during a loading campaign, time charging inconsistencies, and the COVID-19 public health emergency.

Through review of all inspection reports and discussions with inspectors and branch chiefs, it was determined that all program areas were covered during these inspections. Further, the team found that although most regions were hiring and training new inspectors during this timeframe, branch chiefs and inspectors in the regions worked closely with DFM/IOB to ensure there were adequate resources assigned to complete the inspection program requirements.

Although inspectors charged on average approximately 30 percent less than the resource estimate, this is a resource estimate and not an inspection requirement. Based on the review, management determined that all inspection program requirements were met.

IMC 2690 issued on December 15, 2020, defines deviations as not completing all inspection procedure requirements as stated in the individual inspection procedure or not completing the inspection procedure within the required frequency as stated in Appendix A or B of the IMC. If a deviation occurs, it shall be reported to the DFM/IOB Branch Chief. IP 60855 defines inspection procedure completion as completion of the inspection procedure requirements in accordance with the inspection procedure frequency specified in IMC 2690 Appendix A. The staff confirmed

7 that all inspection procedure requirements were met within the specified frequency for all CY 2021 and CY 2022 inspections. The confirmation was accomplished by reviewing all completed inspection reports and discussions with inspectors and branch chiefs.

On February 19, 2021, NMSS Director issued a memorandum, Actions Required to Maintain the Effectiveness of Office of Nuclear Material Safety Inspection Programs, to the NMSS Division Directors and Regional Administrators (ML21048A030). The memorandum included a requirement for the regions to report on a quarterly basis any inspections that were 10 percent below the resource estimate hours. This memorandum was interpreted as only having to report if the reason was related to the COVID-19 public health emergency. Given this, no inspections were reported to IOB from February 2021 through December 2021 meeting the criteria of the memorandum.

The team identified a missed opportunity to clarify how the memo should have been implemented to identify this level of discrepancy sooner. The team found that there were 11 inspections in CY 2021 and 17 inspections in CY 2022 that met the 10 percent below the resource estimate criteria and therefore should have been reported.

The team identified corrective actions to improve accounting and tracking of time charged to inspections. Corrective actions taken to date include: 1) Resource estimate training provided at monthly ISFSI Inspection Program counterpart call on April 27, 2023; 2) Inspection Hour Dashboard developed to make tracking inspection hours simpler and quicker; 3) communication with inspectors to ensure they have access and are appropriately charging to the correct labor code. Corrective actions still planned include: 1) refresher training during annual ISFSI Inspection Program counterpart meeting to be held in February 2024 (Recommendation 5); 2)

Revise IMC 2690 to incorporate guidance on charging time to the direct inspection labor code and preparation and documentation (prep/doc) labor code (Recommendation 5); and 3) Revise IP 60855 to include a 15 percent range to the resource estimate (Recommendation 6).

Additionally, if the staff sees that inspectors continue to spend less than the estimated resources after the corrective actions have been implemented, the staff should explore if there is a need to change the resource estimate. (Recommendation 7)

The resource estimate training provided to staff included discussion of the resource estimate listed in the IPs, clarity on which inspection activities should be charged to prep/doc and direct inspection, and awareness of the need to accurately charge time during inspections. The dashboard created to track inspection hours has allowed staff to more easily keep track of hours spent on each inspection in real time. Additionally, the dashboard allowed IOB staff to track the data needed for this evaluation. Going forward, the IOB Chief will complete quarterly dashboard reviews to determine if any inspections are below 10 percent of the resource estimate. This expectation will be captured in a future guidance document that will capture roles and responsibilities for assessing effectiveness of the NMSS oversight programs.

Based on the data collected for this evaluation the team recommends a 15 percent range be added to the resource estimate listed in the IP. The 2020 working group estimated the average time to complete the inspection requirements to be 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> of direct inspection per triennial cycle. The 2020 working group chose 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> with the intention of having two qualified inspectors on the inspection team, with a portion of the inspection being completed during the preparation week (i.e. reviewing 72.48 evaluations, fuel selection packages, etc.) and the rest of the paperwork review and onsite observations during the week of the inspection. As described above there were a variety of causes to the 30 percent level of effort discrepancy seen during CY 2021 and CY 2022. The staff considered all of the data and determined that the resource estimate is reasonable as an average; however, the program should have the flexibility of a range. The actual hours to complete the inspection requirements may vary due to a number of

8 factors, including the length of licensee activities and program changes that need to be reviewed during each individual inspection. A range allows the inspectors to follow the risk informed structure of the program. Further, differences in inspector experience could have an effect on the number of hours spent on an inspection. For example, a more experienced inspector may use less hours to complete the same inspection requirement than a less experienced inspector. Lastly, the team sampled various other inspection procedures across other inspection programs to determined how each program defines the resource estimate. The team found some inspection procedures had resource estimates with no range, while some had resource estimates listed with ranges of up to 20 percent. Each inspection program varies significantly based on the types of activities being inspected, therefore the team used this information as a data point only. Based on the above, the team is recommending a 15 percent range be added to the resource estimate in IP 60855.

4. RECOMMENDATIONS While the self-assessment team concluded that the ISFSI Inspection Program is effective, the team developed seven recommendations that when implemented will further enhance the program. The recommendations have been added to the ISFSI program tracker.

1. The team recommends moving the justification for cross-qualification to the actual qualification journal, IMC 1246B03, Training Requirements and Qualification Journal for Independent Spent Fuel Storage Installation Inspector.

2. The team recommends that further guidance be given for inspectors to, a) use the 10 additional hours for follow-up inspection allotted in IP 60855 and, b) account for the time in the HCM Time and Labor system. Furthermore, staff believes that the allowance of 10 additional hours for follow-up inspection between onsite inspections should be included in IP 60858 so that this can also be used to follow-up on any activities at AFR licensees.

3. The team recommends that the staff retire IP 60857 and relocate the specific guidance to a different document (i.e., other inspection procedures or an Appendix to the IMC).

Additionally, the team recommends regular training sessions be held that highlight 10 CFR 72.48 reviews.

4. The team recommends that a self-assessment of the ISFSI Inspection Program be conducted at the end of each triennial period. A procedure should be developed to assist in conducting these recurring self-assessments.

5. The team recommends that guidance be developed and incorporated into IMC 2690 and that training be provided to ensure that expectations for estimating time being charged to the procedures is being done consistently across the spent fuel storage program.

6. The team recommends revising IP 60855 to include a 15 percent range to the resource estimate.

7. The team recommends the staff continue to monitor the inspection hours and if the actual level of effort continues to be less than the estimated resources after the corrective actions have been implemented, the staff should explore if there is a need to change the resource estimate.

5. CONCLUSIONS

The results of the self-assessment show that the ISFSI Inspection Program is effective in achieving its program goals. Further, the enhancements made to the program through the 2020 Enhancement Initiative had the direct benefit of creating a more risk-informed, comprehensive, and consistent inspection program across the NRC. The staff will conduct the next ISFSI program self-assessment at the end of the CY 2023 - CY 2025 triennial period.

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