Jonathan Marcano-Lozada, P.E. Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission

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Actions at Fuel Facilities Objectives of NRC Evaluation Evaluation Process Facilities Evaluated Regulatory Framework and Guidance Summary of Results Path Forward

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Information Notice 2011-08 Informed licensees of effects of the Tohoku-

Taiheiyou-Oki earthquake

Temporary Instruction (TI) 2600/015 Inspected and evaluated selected fuel facilities

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Verify adequacy of licensees’ mitigation strategies for licensing bases events

Evaluate adequacy of strategies for selected beyond licensing bases events

Collect information to determine if additional NRC regulatory actions are warranted

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Event Scenarios Considered Seismic Flooding High Winds Onsite Fires Extended Loss of Power and Water

Three Phases Review of licensing bases for each facility Inspections of licensee’s prevention/mitigation strategies Assessment of licensee’s emergency response plan for

beyond licensing basis events

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Conversion Honeywell Metropolis Works, Metropolis, IL

Enrichment Paducah Gaseous Diffusion Plant, Paducah, KY

Fuel Fabrication AREVA-Richland, Richland, WA Global Nuclear Fuel – Americas, Wilmington, NC Westinghouse – Columbia Fuels, Columbia, SC B&W Nuclear Operations Group, Lynchburg, VA Nuclear Fuel Services, Erwin, TN

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Code of Federal Regulation Parts 40, 70 and 76 Integrated Safety Analyses (ISA) required for

most facilities Systematically assess hazards (including natural

phenomena), likelihood and consequences Identify Items Relied on for Safety (IROFS) needed to

meet performance requirements Implement management measures to ensure

availability and reliability of IROFS ISAs form the foundation of licensees’ safety

program

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•10 CFR 70.61 Performance Requirements

Safety concerns related to adequacy of emergency response plan for Honeywell (NRC identified violations)

No immediate safety concerns identified to 10 CFR 70 and 10 CFR 76 licensees

Potential generic concern identified involving adherence to license conditions and regulatory requirements Unresolved Items opened Analyses/data to support certain hazard analysis and

ISA assumptions not complete or available ▪ Design calculations ▪ Consequence calculations

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TI 2600/015 Results

Potential Compliance Issues

Other Fuel Facilities Honeywell

Potential Safety Concern

Confirmatory Order Issued

Generic Letter

NRC Formal Process used to address results

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Generic Letter considerations (Directive 8.18): NRC communicates with the nuclear industry on matters

of generic applicability through its generic communications program.

Generic letter (GL) addresses a technical issue with generic applicability for which the NRC staff and the nuclear industry have interacted.

Industry involvement on the resolution of the issue ▪ Public meeting with industry August 2012 and April 2013 ▪ NEI letter, Treatment of Natural Phenomena Hazards in the

Integrated Safety Analysis, dated October 12, 2012 ▪ NRC’s letter, Response to Treatment of Natural Phenomena

Hazards in the Integrated Safety Analysis, dated March 19, 2013

Generic Letter Milestones Preparation & Coordination Complete NRC Staff Initial Concurrence In Process Draft for Public Comment Fall 2013 Resolve Public Comments Winter 2013 NRC Staff Final Concurrence Winter 2013 Issuance Spring 2014

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Generic Letter preliminary process for facility specific response: Definitions of “unlikely,” “highly unlikely,” and credible

for natural phenomena hazard (NPH) Description of the safety assessment for the

licensing/design basis for NPH Review of key characteristics of NPH events addressing

changes in the methodology used in the ISA, Address any changes in knowledge of NPH (likelihood,

magnitude) Safety Margin evaluation

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Generic Letter preliminary process for facility specific response: Address potential consequences of failures of SSCs Address the current condition of buildings and internal

structures (equipment, masonry walls, etc) by walk downs and other documented processes

Justification of how the facility provides for the adequate protection of the public health and safety under natural phenomena events

If applicable submit to the NRC proposed modifications Review of actions to mitigate NPH at the facility

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Stakeholders Involvement Public Comment Period Public Meeting after draft issuance for public

comment NRC’s staff interested in working with industry to

establish an acceptable standard methodology

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Review of licensing bases for each facility In-office review of licensee safety documentation Review hazards and mitigation for each facility: ▪ Location ▪ Hazard Level ▪ Inventory of hazardous material ▪ Prevention Strategies ▪ Mitigation Strategies ▪ Emergency Planning

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Inspections of licensee’s prevention and mitigation strategies Walk-downs with facility personnel Sampling of controls relied on to perform a safety

function for event scenarios considered Verify that controls are adequate for the safety

function and available Interviews of facility emergency response

organization (verify knowledge of procedures, training, etc.)

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Assessment of licensee’s emergency response plan for beyond licensing basis events Identify beyond licensing basis scenarios for

facility Review ability of existing prevention and

mitigation controls to perform their safety function beyond licensing basis events Interviews with county/state emergency response

organizations

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Honeywell Confirmatory Order Corrective Actions Evaluation of external events and safety basis Implementation of modifications Develop and implement quality assurance

measures for the modifications Revised Emergency Response Plan and

onsite emergency exercise Revised ISA Summary

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