A working group of staff at the Nuclear Regulatory Commission has recommended downshifting the standard schedule for inspections of spent reactor fuel storage pads from roughly every two years to three years.
That was the No. 1 recommendation in the draft final version of Independent Spent Fuel Storage Installation (ISFSI) Inspection Enhancement Initiative, issued on March 6.
As of April 2019, the NRC counted 80 general and site-specific ISFSIs, nearly all built on-site for dry storage of used fuel at operational or retired nuclear power plants. They are spread across 35 states and together contain more than 80,000 metric tons of the radioactive waste.
Inspections are conducted on a “two-year, not to exceed three years,” schedule for monitoring and recurring loading operations, and more frequently during construction, preoperational testing, and first loading, the final draft says.
“The working group used operating experience and subject matter expertise to review inspection results from inspections completed both every two years and every three years, as is currently allowed by the program,” according to the report. “The results did not show an increase of issues or violations for those inspections completed on the three-year periodicity versus the typical two-year frequency.”
The NRC currently allocates 132 hours every two years for routine loading inspections, and 24 hours every two years for routine monitoring inspections. The proposed cuts would trim routine loading inspections to 96 hours every three years and routine monitoring inspections to 24 hours every three years.
“We are trying to improve our inspection program by making it more consistent across the regions and by focusing our inspection efforts on the most risk significant activities and aspects of (dry storage facility operations,” NRC spokesman David McIntyre said by email. The NRC plans to increase the time devoted to pre-operational activities — making sure a licensee has the proper procedures, training and personnel in place, he wrote.
The working group also recommended setting a specific quarterly schedule for inspections of extended loading campaigns, rather than the current “as necessary” guideline. Extended loading campaigns generally are conducted after a power plant is permanently retired and the operator moves all remaining spent fuel from cooling ponds into dry storage.
Routine inspections examine dry-storage casks for cracks, along with evaluating their overall operational security and protection, according to McIntyre. Prior to loading, inspectors examine a site’s preparations, personnel training, radiation protections, and other safety measures. During actual loading, the agency wants to confirm procedures are properly carried out.
The ISFSI inspections review began in June 2019, following input on the issue from staff, the NRC inspector general, and external stakeholders. That included the Nuclear Energy Institute, the trade group for the nuclear industry, which in September 2018 urged the full termination of used-fuel pad inspections.
The working group, consisting of staff from NRC headquarters in Rockville, Md., and the agency’s regional offices, studied the frequency of inspections, training and qualifications, level of effort, and program resources. Other topics, such as security and transportation, were deemed outside the scope of the review. Input was collected from both internal and external stakeholders.
The final decision on the recommendations will be made by the director of the NRC’s Division of Fuel Management. With approval, the new inspection program would be in fully place by next year.
The report includes five recommendations in total, including establishing a “cross-qualification” program for personnel already rated for reactor inspections. Spent-fuel storage inspectors not qualified for reactor work would continue to be qualified under ISFSI training and qualification programs.
Some resident inspectors at nuclear power plants are qualified in specific components of ISFSI inspections and conduct oversight of fuel-loading programs, the report notes. For those reactor-qualified inspectors, the working group recommended a “partial qualified” option for reactor inspectors who would carry out normal ISFSI loading or monitoring inspections.
“This provides an efficiency to enable staff who will only perform these limited inspections to have requisite expertise and training that aligns with the activities inspected and supplements the training, qualification, and experience those fully qualified reactor inspectors have obtained,” according to the report.
Training resident inspectors for the work would reduce the number of inspectors that would have to be sent from NRC headquarters or its four regional offices, McIntyre said.
A total number of inspectors was not available, but each NRC region has at least two
In addition, the working group recommended placing funding for inspections fully under the NRC’s Spent Fuel Storage and Transportation business line. That business currently splits costs with the Operating Reactor business line.
That system creates certain bureaucratic complications, the working group found. “For example, it is a challenge to receive and discern the funding from the Operating Reactor business line for ISFSI inspections at the regional level as ISFSI inspection [full-time equivalent employees] are combined into the funding for several other operating reactor inspections. In addition, having the program funded through two business lines makes it more challenging to Enclosure coordinate the budget implications of program changes made by the SFST business line. It is also a challenge for inspection staff to charge time under two dockets, using two different inspection procedures.”
The NRC requested $28.1 million for its spent fuel storage and transportation budget in the upcoming 2021 federal fiscal year, compared to $22.9 million in fiscal 2020.
The working group identified several inspection-related issues that should be addressed in the future. These include potential improvements to inspections pertaining to the transportation of spent nuclear fuel. Also, the group recommended planning for inspecting consolidated interim storage facilities for used fuel, such as proposed for southeastern New Mexico and western Texas.
