ML23180A241

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IMC 2600 Appendix B, NRC Core Inspection Requirements
ML23180A241
Person / Time
Issue date: 07/27/2023
From: Chris Speer
Division of Fuel Management
To:
Shared Package
ML23180A239 List:
References
CN 23-021
Download: ML23180A241 (1)
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NRC INSPECTION MANUAL NMSS/DFM INSPECTION MANUAL CHAPTER 2600 APPENDIX B NRC CORE INSPECTION REQUIREMENTS Effective Date: 07/27/2023

IMC 2600 Appendix B: NRC Core Inspection Requirements Tables 1, 2, and 3 PURPOSE:

This appendix identifies the NRC core and resident inspection requirements for each type of fuel facility by inspection procedure.

Table 1: Fuel Fabrication Facilities 1 Category I Fuel Category II Fuel Fabrication Facility Category III Fuel Fabrication Facility Fabrication Facility Function/Program Procedure or Inspection Estimated Inspection Frequency Estimated Resources per IP (hrs) Inspection Estimated Areas Procedure Suite Frequency Resources Frequency Resources per IP per IP (hrs)

(hrs)

SAFETY OPERATIONS Plant Operations 88020 Semi-annual 52.5 Semi-annual 60 Semi-annual 60 88135 (Resident Annual 752 - - - -

Inspection Program)

Criticality Safety 88015 Semi-annual 60 Semi-annual 45 Semi-annual 30 Fire Protection 88055 Biennial 30 Biennial 60 Biennial 60 SAFEGUARDS MC&A Procedures as Semi-annual 60 Annual 60 Biennial 60 in IMC 2683 MC&A Triennial 20 Quadrennial 20 Quadrennial 20 Observation Physical Protection HEU Security Measures (PS1) 81700.01 Biennial 18 - - - -

81700.02 Annual 27 - - - -

81700.04 Biennial 40 - - - -

1 The details related to the distribution of inspection hours will be described in the licensee's inspection scheduling letter.

Issue Date: 07/27/23 1 2600 App B

Category I Fuel Category II Fuel Fabrication Facility Category III Fuel Fabrication Facility Fabrication Facility Function/Program Procedure or Inspection Estimated Inspection Frequency Estimated Resources per IP (hrs) Inspection Estimated Areas Procedure Suite Frequency Resources Frequency Resources per IP per IP (hrs)

(hrs) 81700.05 Triennial 70 - - - -

81700.06 Triennial 20 - - - -

81700.07 Biennial 25 - - - -

81700.08 Triennial 24 - - - -

81700.11 Annual 8 - - - -

LEU Security Measures (PS2) 81421 - - Triennial 24 - -

81431 - - - - Triennial 14 81810 - - Triennial 2 Transportation Security (PS3) 81335 Triennial 4 Triennial 8 - -

81340 Triennial 4 - - - -

Other 96001 Triennial 360 - -

Classified Material 818202 Annual 2 Annual 48-160 - -

and INFOSEC (INFOSEC) 81815 (Access - - Annual 8 - -

Authorization RADIOLOGICAL CONTROLS Radiation 88030 Biennial 60 Biennial 60 Biennial 60 Protection Environmental 88045 (Effluent Triennial 30-60* Triennial 30-60* Triennial 30-60*

Protection Control and Env.)

Transportation 86740 Triennial 30-60* Triennial 30-60* Triennial 30-60*

FACILITY SUPPORT Emergency 88050 Biennial 30 Biennial 30 Biennial 30 Issue Date: 07/27/23 2 2600 App B

Category I Fuel Category II Fuel Fabrication Facility Category III Fuel Fabrication Facility Fabrication Facility Function/Program Procedure or Inspection Estimated Inspection Frequency Estimated Resources per IP (hrs) Inspection Estimated Areas Procedure Suite Frequency Resources Frequency Resources per IP per IP (hrs)

(hrs)

Preparedness 88051 (Exercise Biennial 48 Biennial 48 Biennial 48 Observation)

Plant Modifications 88070 Annual 30-90* Annual unless 88072 is 30-90* Annual unless 30-90*

(Annual) unless performed 88072 is 88072 is performed performed Plant Modifications 88072 Triennial 90* Triennial 90* Triennial 90*

(Triennial)

Corrective Action 88161 - - - - - -

Plan 1

The details related to the distribution of inspection hours will be described in the licensees inspection scheduling letter.

2 This IP is only applicable to facilities with a classified materials program and the hours and frequency listed reflect the estimated resources for those facilities with a classified materials program.

Issue Date: 07/27/23 3 2600 App B

Table 2: Other Fuel Facilities Uranium Conversion Gas Centrifuge Facility Laser Enrichment Facility Facility Function/Program Procedure or Inspection Estimated Inspection Estimated Approved CAP Estimated Inspection Estimated Areas Procedure Frequency Resources Frequency Resources Frequency Resources Frequency Resources Suite per IP per IP per IP per IP (hrs) (hrs) (hrs) (hrs)

SAFETY OPERATIONS Plant Operations 88020 Semi- 45 Semi-annual 45 Semi-annual 45 - -

annual 88135 - - - - - - - -

(Resident Inspector Program)

Criticality Safety 88015 - - Semi-annual 30 Semi-annual 30 - -

Fire Protection 88055 Biennial 60 Biennial 60 Triennial 60 - -

SAFEGUARDS MC&A Procedures as - - Biennial 60 Biennial 60 - -

in IMC 2683 MC&A - - Quadrennial 20 Quadrennial 20 - -

Observations Physical HEU Security Protection Measures (PS1) 81700.01 - - - - - - - -

81700.02 - - - - - - - -

81700.04 - - - - - - - -

81700.05 - - - - - - - -

81700.06 - - - - - - - -

81700.07 - - - - - - - -

81700.08 - - - - - - - -

81700.10 - - - - - - - -

81700.11 - - - - - - - -

LEU Security Measures (PS2) 81431 Triennial 22 Triennial 14 Triennial 14 - -

81810 Triennial 2 Triennial 2 Triennial 2 - -

Issue Date: 07/27/23 4 2600 App B

Uranium Conversion Gas Centrifuge Facility Laser Enrichment Facility Facility Function/Program Procedure or Inspection Estimated Inspection Estimated Approved CAP Estimated Inspection Estimated Areas Procedure Frequency Resources Frequency Resources Frequency Resources Frequency Resources Suite per IP per IP per IP per IP (hrs) (hrs) (hrs) (hrs)

Transportation Security (PS3)

Other 96001 - - - - - - - -

Classified 81820 - - Annual 48-160 Annual 48-160 Annual 104-120 Material and (INFOSEC)

INFOSEC 81815 - - Annual 8-16 Annual 8-16 Annual 16 (Access Authorization)

RADIOLOGICAL CONTROLS Radiation 88030 Biennial 60 Biennial 60 Triennial 60 - -

Protection Environmental 88045 Triennial 30-60* Triennial 30-60* 5 Years 30-60* - -

Protection (Effluent Control &

Env.)

Transportation 86740 Triennial 30-60* Triennial 30-60* 5 Years 30-60* - -

FACILITY SUPPORT Emergency 88050 Biennial 30 Biennial 30 Biennial 30 - -

Preparedness 88051 Biennial 48 Biennial 48 Biennial 48 - -

(Exercise Observation)

Plant 88070 Annual 30-90* Annual unless 30-90* - -

Modifications unless 88072 is performed (Annual) 88072 is performed Plant 88072 Triennial 90* Triennial 90* Triennial 90* - -

Modifications (Triennial)

Corrective Action 88161 - - - - Triennial 90* - -

Program

  • Note: The actual planned inspection hours will depend on information developed from routine inspections, changes to the ISA Summary, discussions with Project Inspectors, Project Managers, and staff, etc.

Issue Date: 07/27/23 5 2600 App B

Table 3: As Needed Inspection Procedures IP Number Title Management Measures 71152 Problem Identification and Resolution 88071 Configuration Management Programmatic Review 88161 Corrective Action Program (CAP) Implementation at Fuel Cycle Facilities Enforcement Follow-Up on Traditional Enforcement Actions Including Violations, 92702 Deviations, Confirmatory Action Letters, and Orders Follow-Up Inspections for Any Severity Level I or II Traditional Enforcement 92722 Violation or For Two or More Severity Level III Traditional Enforcement Violations in a 12-Month Period Follow-Up Inspection for One Severity Level III and Two Severity Level IV 92723 Traditional Enforcement Violations or for Three or More Severity Level IV Traditional Enforcement Violations in the Same Area in a 12-Month Period Event Response 88003 Reactive Inspection for Events at Fuel Cycle Facilities 88075 Event Follow Up 93800 Augmented Inspection Team 93812 Special Inspection Team Safety Culture 40100 Independent Safety Culture Assessment Follow-up 93100 Safety-Conscious Work Environment Issue of Concern Follow up 95003.02 Guidance for Conducting an Independent NRC Safety Culture Assessment Strike Preparation/Recovery 92709 Contingency Plans for Licensee Strikes or Lockouts 92711 Implementation of Licensee Contingency Plans During a Strike/ Lockout 92712 Resumption of Normal Operations After a Strike/Lockout 81700.10 Protection of Safeguards Information at Category I Fuel Cycle Facilities END Issue Date: 07/27/23 6 2600 App B

Attachment 1: Revision History Table for IMC 2600 Appendix B Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Number Issue Date Required and Feedback Form Change Notice Completion Accession Numbers Date (Pre-Decisional, Non-Public)

N/A 04/26/07 Revised to incorporate the new inspection procedures N/A ML070610109 CN-07-014 developed to address changes to 10 CFR Part 70 and to reflect enhancements made to the fuel facility inspection program.

N/A 08/15/07 Remove OFFICIAL USE ONLY - SENSITIVE INTERNAL N/A ML072070181 CN-07-025 INFORMATION designation from entire manual chapter to make publicly available.

(1) Revised to correct estimated resources per year for Plant Operations [Cat. III and Uranium Conversion], MC&A [Cat I],

and Radiation Protection [Cat. I]; (2) Revised to delete Procedure 84900, Low Level Waste. The procedure was combined into Procedure 88035, Waste Management.

N/A ML080660565 Revised to incorporate Gas Centrifuge Facility inspections into N/A N/A 03/21/08 the fuel facility inspection program A CN 08-011 N/A ML093170399 Revised to incorporate Gas Centrifuge Facility inspections into N/A N/A 01/27/10 the fuel facility inspection program.

CN 10-003 N/A ML112720197 Revised to incorporate revised hours of IP 88015 and 88017. N/A ML112720208 11/07/11 CN 11-028 Issue Date: 07/27/23 Att1-1 2600 App B

N/A ML13311A662 Significant revision to: N/A 02/07/14

  • Deleted Cat III Fuel Assembly Facility Type as FCSS &

CN 14-005 DFFI no longer has this type of facility in its jurisdiction.

  • Revised to include adjustment to Gaseous Diffusion Plant resident inspection hours as described in ML12284A329.
  • Revise to make total core hours for Gaseous Diffusion Plant consistent with the core hours described in ML12284A329.
  • Removed Operator Training hours and made it as needed.
  • Changed MC&A hours to reflect the sum of estimated hours in the IPs.
  • Removed Management Organization and Controls hours and frequency as inspections requirements were transferred to other IPs. Made this IP as needed.
  • Updated IP 88054 and 88055 inspection hours. All inspection hours will be charged to the triennial procedure every three years. The triennial inspection hours have been increased to reflect that 88055 will not be charged during this 3rd year.
  • Reduced the Radiation Protection (88030) inspection hours to be performed at the Category 1 fuel facilities. This reduction allows for the same resource allocation as the Category 3 and Conversion facilities. The evaluation for this change included the safety significance of the facilities and the radiation protection evaluations included in 88135.
  • Added new Corrective Action Programs for Fuel Cycle Facilities inspection procedure.
  • The Environmental Protection, 88045, inspection hours were increased to correspond to the new material included in the inspection procedure revision.
  • The Waste Management (88035) inspection hours were increased to correspond with the new material included in the inspection procedure revision. The inspection frequency has been reduced to biannual, from annual Issue Date: 07/27/23 Att1-2 2600 App B

Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Number Issue Date Required and Feedback Form Change Notice Completion Accession Numbers Date (Pre-Decisional, Non-Public) inspections, due to the amount of waste management activities at the site.

  • The Transportation inspection procedure (IP 86740) was not revised. The change in hours reflect the current recommendation in hours from the Resource Estimate section of the inspection procedure. The frequency of the IP was changed to biennial, from annual, to keep the total number of inspection hours consistent with the current level of risk for this activity. This change addresses an audit finding which stated that the App B hours should be consistent with the recommended hours of the inspection procedure.

The column headings were revised to simplify the chart and to decrease the number of footnotes applicable.

N/A ML14119A212 Table revised to add columns for Laser Enrichment Facility N/A ML14119A214 06/27/14 and rows for Classified Material and Information Security.

CN 14-014 Issue Date: 07/27/23 Att1-3 2600 App B

Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Number Issue Date Required and Feedback Form Change Notice Completion Accession Numbers Date (Pre-Decisional, Non-Public)

N/A ML15070A286 Revision includes: None ML15070A287 09/24/15

  • Removed reference to GDP from Table 1.

CN 15-018

  • Inspection procedures 88015, 88016, and 88017 were merged into one procedure. The chart was updated and hours adjusted accordingly.
  • Table 2, As Needed Inspection Procedures, was added to appendix. NRR communicated that listing inspection procedures in the IMC was essential for administratively including IPs in RPS.
  • As needed Inspection Procedures 88005, 88010, 88161, and 92702 were removed from Table 1 and included in Table 2.
  • The table which included the resident inspection hours for GDP and Category 1 facilities was deleted and information consolidated in Table 1.
  • Resident inspection responsibilities for Gaseous Diffusion Plant were removed. The inspection procedures removed from the IMC are 88100, 88102, 88103, and 88105.
  • 88135 inspection hours for NFS was reduced from 1504 to 752 hour0.0087 days <br />0.209 hours <br />0.00124 weeks <br />2.86136e-4 months <br />s/year. This corresponds with the NRC staffing change at the facility; from two resident inspectors to one.

N/A ML17299B292 Editorial changes to reflect the latest revision to IMC 2681 and N/A N/A 12/20/17 its associated procedures.

CN 17-030 Issue Date: 07/27/23 Att1-4 2600 App B

Commitment Accession Description of Change Description of Comment Resolution Tracking Number Training and Closed Number Issue Date Required and Feedback Form Change Notice Completion Accession Numbers Date (Pre-Decisional, Non-Public)

N/A ML18099A226

  • Revision includes changes to estimated resource hours N/A N/A 06/12/18 for Category I Fuel Facilities in the areas of Plant CN 18-015 Operations and Fire Protection to reflect a transfer of hours from IPs 88020 and 88055 to IP 88135 (Resident Inspector Program).
  • Revised to include changes to 88070 and 88072 regarding annual implementation versus triennial.

Added 3 inspection procedures to Table 2: 40100, 71153, and 84850 N/A ML20211L835 Revision to implement the recommendations from the Smarter Completed by N/A 12/14/20 Inspection Program (ML20077L247 and ML20073G659). December CN 20-071 Deleted waste management and maintenance and 2020 surveillance IPs and incorporated risk significant elements into other IPs to reduce overlaps in the inspection guidance.

N/A ML21043A178 Revised to clarify inspection frequency for Plant Operations, N/A N/A 02/18/21 Criticality Safety, and MC&A inspections. Added columns on CN 21-009 page 2 for facilities with approved CAP to be consistent with the rest of the table.

N/A ML23180A241 Updated Category II Fuel Fabrication Facility inspection N/A N/A 07/27/23 frequencies and estimated resources. Split up Table 1 into CN 23-021 separate tables for fuel fabrication facilities and enrichment facilities.

Issue Date: 07/27/23 Att1-5 2600 App B

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