ML20066L232

ISFSI Inspection Program Enhancement Webinar

ML20066L232
Person / Time
Issue date:	03/09/2020
From:	Jeremy Tapp NRC/NMSS/DFM/IOB
To:
TLTerry NMSS/DFM/IOB 415.1488
References
Download: ML20066L232 (15)

Text

ISFSI Inspection Program Enhancement Initiative Overview Jeremy Tapp Office of Nuclear Materials Safety and Safeguards Division of Fuel Management March 9, 2020

Background

• Internal feedback to provide a more risk-informed independent spent fuel storage installation (ISFSI) inspection program

• The Nuclear Energy Institute submitted one recommendation in their letter on Reactor Oversight Process enhancements (September 19, 2018) regarding ISFSI inspection

• Initiated a proactive review to enhance the ISFSI inspection program in June 2019

ISFSI Enhancement Working Group A working group of NRC regional ISFSI inspectors and NRC Headquarters staff was formed to evaluate and enhance the NRCs existing ISFSI inspection program by developing a clearer, more risk-informed, comprehensive, and consistent approach to ISFSI inspections across the four regions that focuses on those areas most important to safety

• Working Group Charter, Agencywide Documents Access and Management System (ADAMS) Accession No. ML19155A273

ISFSI Enhancement Scope

• Oversight of ISFSI operations:

- Onsite component construction

- Dry runs

- Loading

- Monitoring

• Not in scope of review:

- Transportation

- Vendor Inspections

- Aging Management

- Security

Focus Areas of ISFSI Program The working group identified five safety focus areas:

• Occupational dose,

• Public dose/exposure,

• Fuel damage,

• Confinement/canister integrity, and

• Impact to plant operation

Areas Reviewed for Potential Enhancement

• Application of risk insights (methodology) o Frequency of inspections o Level of effort

• Qualification and training

Methodology

• Holistic approach to develop a more risk-informed, performance-based ISFSI program that takes into account information from o Probabilistic models ISFSI pilot probabilistic risk assessmentNUREG-1864 Materials systems risk analysisNUREG/CR-6642 o Operating experience o Subject matter expertise

• Evaluated all ISFSI inspection procedures and ranked the risk of each inspection activity according to the five safety focus areas o Risk prioritization tool to help inspectors identify and focus inspections on the most risk-significant items

Key Considerations

• A comprehensive and objective review to develop a more risk informed inspection program to focus on those areas most important to safety

• Increase in inspection for risk-significant activities and decrease in other activities

• Greater flexibility to perform inspections during more risk significant ISFSI operations

• Recommendations considered varied stakeholder feedback

Working Group Recommendations Inspection Frequencies

• Informed by operating experience, subject matter expertise, and risk insights, which included the fixed radiographic installation and irradiator facility inspection frequencies

- Proposed Program

• Routine inspections - triennial cycle

• Extended loading campaign - quarterly until complete

• All other inspection frequencies - as needed

- Current Program

• Routine inspections - every 2 years, not to exceed 3 years

• All other inspection frequencies - as needed

Working Group Recommendations Formal qualification and training specific for ISFSI inspectors

• Applicable to regional or resident inspectors

• Cross-qualification program developed for reactor inspectors already fully qualified as a resident or regional engineering inspector

• Partial qualification table developed for those resident or regional engineering inspectors who only perform routine loading inspections

• No recommendation on who performs inspection

Working Group Recommendations 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 triennial cycle for routine loading inspections

• 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> every quarter during extended loading campaign

• 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every triennial cycle (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, not to exceed 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 2 years, not to exceed 3 years, (includes Away From Reactor ISFSIs) for routine monitoring inspections

Working Group Recommendations Inspection Effort (cont.)

• Preoperational and initial loading inspections

- Based revised risk-informed inspection procedures and taking account actual resource expenditures

- Proposed Program

• Preoperational inspection (Inspection Procedure (IP) 60854) - 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br />

• Review of 10 CFR 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

• Preoperational inspection (IP 60854) - 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />

• Review of 10 CFR 72.212 evaluations (IP 60856) - 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />

- No change to ISFSI construction inspection (IP 60853) - 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br />

Additional Areas for Consideration

• The working group 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

- Review possible efficiency gains and overall improvement related to the creation of a Center of Expertise for ISFSI oversight activities

- Develop a routine assessment of the ISFSI inspection program

Recommendation Development

• Issued a memorandum with the working groups initial assessment and recommendations on October 2, 2019 (ADAMS Accession No. ML19277G895) o Includes two enclosures (ADAMS Accession Nos.

ML19277G878 and ML19277G879) with recommendations

• Solicited internal and external feedback on the initial recommendations o Includes public meetings that provided an opportunity for feedback from stakeholders in various geographic areas

• Updated the working groups recommendations to incorporate feedback (ADAMS Accession No. ML20045D870)

Status and Next Steps

• The NRC will make a final decision and issue a tasking memorandum to the regions with the final recommendations report

• Program documents will be updated, as needed, based upon final decision

- New technical basis document

- Revisions to Inspection Manual Chapters and inspection procedures

• Implementation planned for start of calendar year 2021