ML20211L834

IMC 2600 Appendix B NRC Core Inspection Requirements

ML20211L834
Person / Time
Issue date:	12/14/2020
From:	Alayna Pearson NRC/NMSS/DFM/IOB
To:
Pearson A
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ML20211L831, ML20349A009	List:
References
CN 20-071
Download: ML20211L834 (9)

Text

NRC INSPECTION MANUAL NMSS/DFM INSPECTION MANUAL CHAPTER 2600 APPENDIX B NRC CORE INSPECTION REQUIREMENTS Effective Date: 01/01/2021

Issue Date: 12/14/20 1

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

This appendix identifies the NRC Core and Resident inspection requirements for each type of Fuel Facility by Inspection Procedure.

Table 1 Category I Fuel Facility Category III Fuel Fabrication Facility Uranium Conversion Facility Gas Centrifuge Facility Laser Enrichment Facility Function/

Program Areas Procedure or Procedure Suite Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Approved CAP Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

SAFETY OPERATIONS Plant Operations 88020 (OPR)

Annual (2 per year) 105 Annual (2 per year) 120 Annual (2 per year) 90 Annual (2 per year) 90 Annual (2 per year) 90 88135+

(Resident Inspection Program)

Annual 752 Criticality Safety 88015 Annual (2 per year) 120 Annual (2 per year) 60 Annual (2 per year) 60 Annual (2 per year) 60 Fire Protection 88055 (FPB)

Biennial 30 Biennial 60 Biennial 60 Biennial 60 Triennial 60

+Resident inspection activities are conducted over the course of the year at the frequency and in the manner described in the relevant inspection procedure. The hours listed are for planning purposes and may vary by +10%. If variance is more than 10%, the difference must be explained and the hours reviewed

Issue Date: 12/14/20 2

2600 App B Category I Fuel Facility Category III Fuel Fabrication Facility Uranium Conversion Facility Gas Centrifuge Facility Laser Enrichment Facility Function/

Program Areas Procedure or Procedure Suite Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

SAFEGUARDS MC&A Procedures as in IMC 2683 Annual 120 Biennial 60 Biennial 60 MC&A Observation Triennial 30 Triennial 30 Triennial 30 Physical Protection HEU Security Measures (PS1) 81700.01 Biennial 18 81700.02 Annual 27 81700.04 Biennial 40 81700.05 Triennial 70 81700.06 Triennial 20 81700.07 Biennial 25 81700.08 Triennial 24 81700.10 Triennial 6

81700.11 Annual 8

LEU Security Measures (PS2) 81431 Triennial 14 Triennial 22 Triennial 14 81810 Triennial 2

Triennial 2

Triennial 2

Transportation Security (PS3) 81335 Triennial 4

81340 Triennial 4

Triennial 8

Triennial 8

Other 96001 Triennial 360 Classified Material and INFOSEC 81820 (INFOSEC)

Annual 2

Annual 48-160 Annual 104-120 81815 (Access Authorization)

Annual 8-16 Annual 16

Issue Date: 12/14/20 3

2600 App B Category I Fuel Facility Category III Fuel Fabrication Facility Uranium Conversion Facility Gas Centrifuge Facility Laser Enrichment Facility Function/

Program Areas Procedure or Procedure Suite Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

Approved CAP Frequency Estimated Resources per IP (hrs)

Inspection Frequency Estimated Resources per IP (hrs)

RADIOLOGICAL CONTROLS Radiation Protection 88030 (RP)

Biennial 60 Biennial 60 Biennial 60 Biennial 60 Triennial 60 Environmental Protection 88045 (Effluent Control and Env.)

Triennial 30-60 Triennial 30-60 Triennial 30-60 Triennial 30-60 5 Years 30-60 Transportation 86740 (T)

Triennial 30-60 Triennial 30-60 Triennial 30-60 Triennial 30-60 5 Years 30-60 FACILITY SUPPORT Emergency Preparedness 88050 (EP)

Biennial 30 Biennial 32 30 Biennial 32 30 Biennial 32 30 Biennial 30 88051 (Exercise Observati on)

Biennial 48 Biennial 48 Biennial 48 Biennial 48 Biennial 48 Plant Modifications (Annual) 88070 Annual unless 88072 is performed 30-90*

Annual unless 88072 is performed 30-90*

Annual unless 88072 is performed 30-90*

Annual unless 88072 is performed 30-90*

Plant Modifications (Triennial) 88072 Triennial 90*

Triennial 90*

Triennial 90*

Triennial 90*

Triennial 90**

Corrective Action Program 88161 Triennial 90

• 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: 12/14/20 4

2600 App B Table 2 As Needed Inspection Procedures IP Number Title 40100 Independent Safety Culture Assessment Follow-up 71152 Problem Identification and Resolution 71153 Follow-up of Events and Notices of Enforcement Discretion 84850 Radioactive Waste Management - Inspection of Waste Generator Requirements of 10 CFR Part 20 and 10 CFR Part 61 88003 Reactive Inspection for Events at Fuel Cycle Facilities 88005 Management Organization and Controls 88010 Training 88071 Configuration Management Programmatic Review 88075 Event Follow Up 88161 Corrective Action Program (CAP) Implementation at Fuel Cycle Facilities 92701 Follow up 92702 Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory Action Letters, and Orders 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 93001 OSHA Interface Activities 93100 Safety-Conscious Work Environment Issue of Concern Follow up 93800 Augmented Inspection Team 93812 Special Inspection 95003.02 Guidance for Conducting an Independent NRC Safety Culture Assessment END

Issue Date: 12/14/20 Att 1-1 2600 App B Revision History Table for IMC 2600 Appendix B Commitment Tracking Number Accession Number Issue Date Change Notice Description of Change Description of Training Required and Completion Date Comment Resolution and Closed Feedback Form Accession Numbers (Pre-Decisional, Non-Public)

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

N/A ML070610109 N/A ML072070159 08/15/07 CN-07-025 Remove OFFICIAL USE ONLY - SENSITIVE INTERNAL 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 ML072070181 N/A ML080660565 03/21/08 CN 08-011 Revised to incorporate Gas Centrifuge Facility inspections into the fuel facility inspection program A

N/A N/A N/A ML093170399 01/27/10 CN 10-003 Revised to incorporate Gas Centrifuge Facility inspections into the fuel facility inspection program.

N/A N/A N/A ML112720197 11/07/11 CN 11-028 Revised to incorporate revised hours of IP 88015 and 88017.

N/A ML112720208 N/A ML13311A662 02/07/14 CN 14-005 Significant revision to:

• Deleted Cat III Fuel Assembly Facility Type as FCSS & DFFI no longer has this type of facility in its jurisdiction.

N/A

Issue Date: 12/14/20 Att 1-2 2600 App B

• 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

Issue Date: 12/14/20 Att 1-3 2600 App B new material included in the inspection procedure revision. The inspection frequency has been reduced to biannual, from annual 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 06/27/14 CN 14-014 Table revised to add columns for Laser Enrichment Facility and rows for Classified Material and Information Security.

N/A ML14119A214 N/A ML15070A286 09/24/15 CN 15-018 Revision includes:

Removed reference to GDP from Table 1.

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, None ML15070A287

Issue Date: 12/14/20 Att 1-4 2600 App B 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 12/20/17 CN 17-030 Editorial changes to reflect the latest revision to IMC 2681 and its associated procedures.

N/A N/A N/A ML18099A226 06/12/18 CN 18-015 Revision includes changes to estimated resource hours for Category I Fuel Facilities in the areas of Plant 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 N/A N/A ML20211L835 12/14/20 CN 20-071 Revision to implement the recommendations from the Smarter Inspection Program (ML20077L247 and ML20073G659). Deleted waste management and maintenance and surveillance IPs and incorporated risk significant elements into other IPs to reduce overlaps in the inspection guidance.

Complete by December 2020 N/A