ML21043A178

IMC 2600 Appendix B NRC Core Inspection Requirements

ML21043A178
Person / Time
Issue date:	02/18/2021
From:	Alayna Pearson NRC/NMSS/DFM/IOB
To:
Pearson A
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ML21043A177, ML21049A043	List:
References
CN 21-008
Download: ML21043A178 (10)

Text

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

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

SAFETY OPERATIONS Semi-Semi-annual Semi- Semi- Semi-88020 52.5 60 45 45 annual 45 - -

annual annual annual Plant 88135 Operations (Resident Annual 752 - - - - - - - - - -

Inspection Program)

Criticality Semi- Semi- Semi-88015 Semi-annual 60 30 - - 30 30 - -

Safety annual annual annual Fire 88055 Biennial 30 Biennial 60 Biennial 60 Biennial 60 Triennial 60 - -

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

Issue Date: 02/18/21 1 2600 App B

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

SAFEGUARDS Semi-Procedures as annual 60 Biennial 60 - - Biennial 60 Biennial 60 - -

in IMC 2683 MC&A MC&A Triennial 30 Triennial 30 - - Triennial 30 Triennial 30 - -

Observation Physical HEU Security Protection 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 Triennial 14 - -

81810 - - Triennial 2 Triennial 2 Triennial 2 Triennial 2 - -

Transportation Security (PS3) 81335 Triennial 4 - - - - - - - - - -

81340 Triennial 4 Triennial 8 - - Triennial 8 Triennial 8 - -

Other 96001 Triennial 360 - - - - - - - - - -

Classified 81820 Annual 2 - - - - Annual 48-160 Annual 48-160 Annual 104-120 Material (INFOSEC) and 81815 (Access

- - - - - - Annual 8-16 Annual 8-16 Annual 16 INFOSEC Authorization)

Issue Date: 02/18/21 2 2600 App B

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

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

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

Protection Control and Env.)

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

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

Emergency 88051 Preparedness (Exercise Biennial 48 Biennial 48 Biennial 48 Biennial 48 Biennial 48 - -

Observation)

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

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

(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: 02/18/21 3 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 Radioactive Waste Management - Inspection of Waste Generator Requirements of 10 CFR 84850 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 Follow-Up on Traditional Enforcement Actions Including Violations, Deviations, Confirmatory 92702 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: 02/18/21 4 2600 App B

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

N/A 04/26/07 Revised to incorporate the new inspection N/A ML070610109 CN-07-014 procedures 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 N/A ML072070181 CN-07-025 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 ML080660565 Revised to incorporate Gas Centrifuge Facility N/A N/A 03/21/08 inspections into the fuel facility inspection program CN 08-011 A N/A ML093170399 Revised to incorporate Gas Centrifuge Facility N/A N/A 01/27/10 inspections into the fuel facility inspection program.

CN 10-003 N/A ML112720197 Revised to incorporate revised hours of IP 88015 N/A ML112720208 11/07/11 and 88017.

CN 11-028 N/A ML13311A662 Significant revision to: N/A 02/07/14

• Deleted Cat III Fuel Assembly Facility Type as CN 14-005 FCSS & DFFI no longer has this type of facility in its jurisdiction.

Issue Date: 02/18/21 Att 1-1 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: 02/18/21 Att 1-2 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 Table revised to add columns for Laser Enrichment N/A ML14119A214 06/27/14 Facility and rows for Classified Material and CN 14-014 Information Security.

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, Issue Date: 02/18/21 Att 1-3 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 Editorial changes to reflect the latest revision to IMC N/A N/A 12/20/17 2681 and its associated procedures.

CN 17-030 N/A ML18099A226

• Revision includes changes to estimated N/A N/A 06/12/18 resource hours for Category I Fuel Facilities in CN 18-015 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 ML20211L835 Revision to implement the recommendations from Completed by N/A 12/14/20 the Smarter Inspection Program (ML20077L247 December 2020 CN 20-071 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.

Issue Date: 02/18/21 Att 1-4 2600 App B

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

Issue Date: 02/18/21 Att 1-5 2600 App B