ML19331A686

ISFSI Inspection Program Enhancement Initiative Overview Presentation

ML19331A686
Person / Time
Issue date:	12/02/2019
From:	Jeremy Tapp NRC/NMSS/DFM/IOB
To:
JETapp NMSS/DFM/IOB 415.8047
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Download: ML19331A686 (15)

Text

ISFSI Inspection Program Enhancement Initiative Overview Jeremy Tapp Division of Fuel Management, NMSS December 2, 2019

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Background===

NRC Transformation Team established in early 2018 Internal feedback received to improve program efficiency and consistency 27 ROP recommendations provided to NRR by NEI (September 19, 2018)

- Recommendation 1H: Eliminate Materials Inspections of ISFSI In response to all feedback the staff committed to assess the ISFSI program

ISFSI Enhancement Team

• A team of 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

- Aging Management

- 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

• 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

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

• 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 Teams Assessment - Option 2

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