ML23356A124
| ML23356A124 | |
| Person / Time | |
|---|---|
| Site: | 07007004 |
| Issue date: | 01/26/2024 |
| From: | Shana Helton Division of Fuel Management |
| To: | Masters A NRC/RGN-II/DFFI |
| References | |
| Download: ML23356A124 (3) | |
Text
January 26, 2024 MEMORANDUM TO: Anthony D. Masters, Director Division of Fuel Facility Inspection Region II Signed by Helton, Shana FROM: Shana R. Helton, Director on 01/26/24 Division of Fuel Management Office of Nuclear Material Safety and Safeguards
SUBJECT:
AMERICAN CENTRIFUGE PLANT RESIDENT INSPECTOR DECISION On June 11, 2021, the U.S. Nuclear Regulatory Commission (NRC) approved operation of sixteen centrifuges to demonstrate production of High-Assay Low-Enriched Uranium (HALEU) for the American Centrifuge Plant (ACP) fuel fabrication facility located in Piketon, Ohio (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21138A827). The staff has decided not to place a resident inspector at the ACP Category II fuel facility during 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 Category 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 CONTACT: Briana DeBoer, NMSS/DFM 301-415-5043
A. Masters 2 decisions to place or not to place resident inspectors at the Mixed Oxide facility, a Category I 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 and the current size of the HALEU demonstration program at the ACP in Piketon, Ohio. The ACP facility is licensed to possess and use Category II quantities of material. The HALEU demonstration program involves a relatively small number of operating centrifuges (16) with a relatively small production capacity (about 900 kg of HALEU in the form of UF6 per year). In addition, the safety and safeguards risks associated with the ACP operations are expected to be similar to or less than those associated with other Category III fuel cycle facilities such as the Urenco National Enrichment Facility in New Mexico, which consists of thousands of operating centrifuges, and the three Category III fuel fabrication facilities. Since the risk profile at ACP is lower than the Category III enrichment and fuel fabrication facilities, and the NRC had determined that these Category III facilities do not warrant a resident inspector, the staff determined that a resident inspector is not warranted for the ACP facility at this time. However, this decision will be revisited as the ACP operations authorized by the NRC change and expand over time.
Given the risk profile and anticipated IROFS at the proposed ACP 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 ACP fuel fabrication facility for construction or operation activities.
The decision to not place a resident inspector at the ACP facility during construction or operation actives was based on factors as they were known at the time of the decision and is subject to change should conditions and oversight requirements change.
Docket No. 07007004
A. Masters 3
SUBJECT:
AMERICAN CENTRIFUGE PLANT RESIDENT INSPECTOR DECISION DATED January 26, 2024 DISTRIBUTION:
Public ADAMS Accession Number: ML23356A124 *via email OFFICE NMSS NMSS NMSS RII JGoodridge for NAME BDeBoer ARivera-Varona RWilliams WWheatley DATE 12/28/2023 12/29/2023 01/04/2024 01/16/2024 OFFICE NMSS RII NMSS NAME SLav AMasters SHelton DATE 01/19/2024 01/23/2024 01/26/2024 OFFICIAL RECORD COPY