ML23355A245
| ML23355A245 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 01/05/2024 |
| From: | Shana Helton Division of Fuel Management |
| To: | Masters A NRC/RGN-II/DFFI |
| References | |
| Download: ML23355A245 (3) | |
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MEMORANDUM TO: Anthony D. Masters, Director Division of Fuel Facility Inspection Region II FROM: Shana R. Helton, Director Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
TRISO-X RESIDENT INSPECTOR DECISION On April 5, 2022, the U.S. Nuclear Regulatory Commission (NRC) received an application for a construction and operating license for the TRISO-X fuel fabrication facility located in Oak Ridge, Tennessee (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22101A200). The staff has decided not to place a resident inspector at the TRISO-X Category II fuel facility during initial construction or operations.
Prior to 2023, the NRC had only authorized fuel facility licensees to possess Category I and Category III quantities of special nuclear material (SNM), and an inspection program had been developed for these types of facilities. With several facilities expressing interest in possessing and using Category II quantities of SNM, the Office of Nuclear Material Safety and Safeguards (NMSS) and Region II formed a working group to ensure the Category II core inspection procedures were up to date. A part of this effort involved determining whether Category II facilities should be required to have a resident inspector.
Currently, only the facilities with Category I quantities of SNM have a resident inspector. This includes the Nuclear Fuel Services facility in Erwin, TN, and the BWXT Nuclear Operations Group, Inc., located in Lynchburg, VA. The fuel facilities licensed to possess Caterogry III quantities of SNM do not have resident inspectors. The fuel facilities licensed to possess Category II quantities of SNM are evaluated on a case-by-case basis to determine if a resident inspector is needed.
Inspection Manual Chapter (IMC) 2600, Fuel Cycle Facility Operational Safety and Safeguards Inspection Program, states that resident inspectors are assigned to certain fuel cycle facilities that require such oversight because of their complexity of operation, risk, or other significant factors. To make the decision regarding whether Category II facilities should require a resident inspector, the staff evaluated the rationale supporting resident inspector presence at Category I facilities versus Category III facilities. Also, the staff considered the circumstances around the decisions to place or not to place resident inspectors at the Mixed Oxide facility, a Category I CONTACT: Briana DeBoer, NMSS/DFM 301-415-5043January 5, 2024 Signed by Helton, Shana on 01/05/24
A. Masters 2
plutonium processing and fuel fabrication plant during construction activities, the Paducah Gaseous Diffusion Plant during operation activities, and the Louisiana Energy Services Gas Centrifuge Facility during construction and operation activities. The staff considered factors such as safety and safeguards risks, oversight requirements that would be needed based on the risk factors of the facility, and cost effectiveness for completing those oversight activities. Safety considerations included criticality, fire, chemical, and other radiological hazards anticipated at these types of facilities. Further, staff considered the anticipated number of items relied on for safety (IROFS) at each facility. Safeguard considerations included physical security, information security, and material control and accounting anticipated at these types of facilities. Given the variations between facilities (i.e. fissionable material composition and enrichment, size of facility, processes of facility, etc.), the staff ultimately determined that each fuel cycle facility will be evaluated independently to determine whether the facility should have a resident inspector during initial construction and/or operation activities.
Staff considered all the above factors for the planned Category II TRISO-X facility in Oak Ridge, Tennessee, and found that the greatest safety risk was inadvertent criticality. Despite the higher enrichment limit of under 20 percent Uranium-235 for the TRISO-X facility compared to the Category III facilities, the overall risk of a criticality accident at TRISO-X is closer in magnitude to the existing Category III fuel fabrication facilities than for a Category I type facility. Therefore, not placing a resident inspector at TRISO-X is consistent with the current level of oversight at fuel fabrication facilities.
Given the risk profile and anticipated IROFS at the proposed TRISO-X facility, the staff determined that facility oversight is most effectively and efficiently performed by resources held in the regional office. IMC 2600, appendix B, identifies the core inspection requirements for each type of fuel facility. The core inspection procedures identified for Category II fuel fabrication facilities cover the performance areas of safety operations, safeguards, radiological controls, and facility support, which are the same performance areas in the resident inspector program. Therefore, each Category II fuel facility will be inspected in the safety operations, safeguards, radiological controls, and facility support areas on a set periodicity, utilizing approximately 0.31 full-time employee equivalent (FTE) per year. Category I and III fuel facilities are inspected in the same performance areas utilizing approximately 1 FTE per year and 0.26 FTE per year respectively. Considering all the above factors, the staff decided not to place a resident inspector at the TRISO-X fuel fabrication facility for construction or operation activities.
The decision to not place a resident inspector at the TRISO-X facility during construction or operation activities is based on factors as NRC knows them at this time and is subject to change should conditions and oversight requirements change.
Docket No. 07007027
cc:
M. Bartlett, NMSS S. Poy, NMSS S. Lav, NMSS A. Rivera-Varona, NMSS E. Michel, R-II C. Taylor, R-II A. Masters 3
SUBJECT:
TRISO-X FUEL FACILITY RESIDENT INSPECTOR DECISION DATED DISTRIBUTION:
Public ADAMS Accession Number: ML23355A245 *via email OFFICIAL RECORD COPYOFFICE NMSS NMSS NMSS RII NAME BDeBoerWWheatley ELove for ARivera-VaronaEMichel DATE 12/21/2023 12/26/2023 12/26/2023 01/02/2024 OFFICE NMSS RII NMSS NAME SLav AMasters SHelton DATE 01/02/2024 01/03/2024 01/05/2024January 5, 2024