ML19331A686
ML19331A686 | |
Person / Time | |
---|---|
Issue date: | 12/02/2019 |
From: | Jeremy Tapp NRC/NMSS/DFM/IOB |
To: | |
JETapp NMSS/DFM/IOB 415.8047 | |
References | |
Download: ML19331A686 (15) | |
Text
ISFSI Inspection Program Enhancement Initiative Overview Jeremy Tapp Division of Fuel Management, NMSS December 2, 2019
Background
- NRC Transformation Team established in early 2018
- Internal feedback received to improve program efficiency and consistency
- Recommendation 1H: Eliminate Materials Inspections of ISFSI
- In response to all feedback the staff committed to assess the ISFSI program
ISFSI Enhancement
- A team ofTeam Regional ISFSI inspectors and headquarters staff was created to assess the ISFSI program
- Develop recommendations for a more effective and efficient ISFSI inspection program
- (Team Charter, ADAMS Accession No. ML19155A273)
ISFSI Enhancement Initiative Scope
- Oversight of ISFSI operations:
- On-site component construction
- Dry-runs
- Loading
- Monitoring
- Not in Scope of Review:
- Transportation
- Vendor Inspections
- Security
Focus Areas of ISFSI Program The team identified five safety focus areas:
- Occupational Dose,
- Public Dose/Exposure,
- Fuel Damage,
- Confinement/Canister Integrity, and
- Impact to Plant Operation
Areas of Potential Enhancement
- Application of Risk insights (Methodology)
- Frequency of Inspections
- Qualification and training
- Level of Effort
Teams Assessment - Option 1
- Methodology
- More risk-informed, performance-based ISFSI program that takes into account information from:
- Probabilistic Models
-ISFSI Pilot PRA - NUREG/CR-1864
-Materials Systems Risk Analysis - NUREG/CR-6642
- Operating Experience
- Subject Matter Expertise
- Risk prioritization tool to help inspectors identify the most risk significant items
Teams Assessment - Option 1
- Inspection Frequencies
- Informed by risk insights, specifically the fixed radiographic installation and irradiator facility inspection frequencies
- Proposed Program
- Routine inspections - triennial;
- All other inspection frequencies - as needed
- Current Program
- Routine inspections - biennial
- All other inspection frequencies - as needed
- Routine monitoring inspections at Away From Reactor ISFSIs subject to change based on aging management inspection results
Teams Assessment - Option 1
- Formal qualification and training specific for ISFSI inspectors
- Applicable to regional or resident inspectors
- Interim qualification table developed for routine loading inspections performed by resident or regional engineering inspectors
- No recommendation on who performs inspection
Teams Assessment - Option 1
- Inspection Effort
- Routine inspections
- Level of effort assessed by performing line by line review of hours needed for the risk-significant inspection activities
- Welding, Heavy Loads, Fuel Loading activities
- Proposed Program
- 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> every 3 years for routine loading inspections
- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every 3 years (includes Away From Reactor ISFSIs) for routine monitoring inspections
- Current Program
- 132 hours0.00153 days <br />0.0367 hours <br />2.18254e-4 weeks <br />5.0226e-5 months <br /> every 2 years for routine loading inspections
- 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every 2 years (includes Away From Reactor ISFSIs) for routine monitoring inspections
Teams Assessment - Option 1
- Inspection Effort (cont.)
- Pre-operational and initial loading inspections
- Based on actual resource expenditures and activities in revised risk informed inspection procedures
- Proposed Program
-Pre-operational inspection (IP 60854) 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />
-Review of 72.212 evaluations (IP 60856) 160 hours0.00185 days <br />0.0444 hours <br />2.645503e-4 weeks <br />6.088e-5 months <br />
- Current Program
-Pre-operational inspection (IP 60854) 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />
-Review of 72.212 evaluations (IP 60856) 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />
Teams Assessment - Option 2
- The scope of the program requirements for inspection of the five safety focus areas primarily informed by pilot PRA study.
- Inspection Frequencies consistent with Option 1
- Inspector Qualification and Training
- Provides training alternatives dependent on the inspector implementing the program
- E.g., A qualified ROP resident inspector, for oversight of routine loading activities, would complete applicable modules of the new ISFSI inspector training course
- Region-based ISFSI program support available from qualified specialized inspectors
- E.g., Radiological and welding/NDE
Teams Assessment - Option 2
- Inspection level of effort
- Proposed Routine loadings: 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> every 3 years
- Option 2 level of effort is based on consideration of the risk profile and approach for implementation of the program
- Option 1 Routine loadings: 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> every 3 years
- Level of effort for all other inspection activities is consistent with Option 1
Additional Areas for Consideration
- The team also recommended the following:
- Assess and provide recommendations for enhancement in the areas of inspection readiness for
- Transportation of spent nuclear fuel
- Consolidated Interim Storage Facilities (CISFs)
- Review possible efficiency gains and overall improvement related to the creation of a Center of Expertise for ISFSI oversight activities
- Development of a self-assessment process for the ISFSI oversight program
Status and Next Steps
- Internal review of evaluation and recommendations
- Public feedback on proposed recommendations being accepted through December 20
- Consideration and assessment of feedback on team recommendations/options and final report submitted for decision
- Upon decision, program documents will be updated
- New technical basis document
- Revisions to Inspection Manual Chapters and Inspection Procedures
- Goal for implementation in Fiscal Year 2021