[APPENDIX A]{.underline}

GUIDANCE FOR CONDUCTING FUEL CYCLE INSPECTIONS

PART I

FUEL CYCLE FACILITY TERMINOLOGY

A. PURPOSE

This part describes the types of facilities and systems covered by the
fuel facility inspection program and various terms used in the program.

B. TYPES OF FACILITIES

The following types of facilities are included in the fuel cycle
facility inspection program.

1\. [Category I Fuel Fabrication Facility]{.underline}. A facility
licensed under 10 CFR Part 70 to use or possess strategic special
nuclear material (Category I formula quantities of high enriched uranium
or plutonium) in processing, recovery, fuel fabrication, or research and
development activities and operations.

2\. [Category II Fuel Fabrication Facility]{.underline}. A facility
licensed under 10 CFR Part 70 to use or possess special nuclear material
of moderate strategic significance (Category II formula quantities of
high enriched uranium or plutonium) in processing, recovery, fuel
fabrication, or research and development activities and operations.

3\. [Category III Fuel Fabrication Facility]{.underline}. A facility
licensed under 10 CFR Part 70 to use or possess special nuclear material
of low strategic significance (Category III quantities of low enriched
uranium or plutonium) in processing, recovery, fuel fabrication, or
research and development activities and operations.

4\. [Category III Fuel Assembly Facility]{.underline}. A facility
licensed under Part 70 to use or possess special nuclear material of low
strategic significance (Category III quantities of low enriched uranium
or plutonium) in loading finished fuel pellets into fuel assemblies.

5\. [Uranium Conversion Facility]{.underline}. A facility licensed under
10 CFR Part 40 to produce uranium hexafluoride (UF~6~) from concentrated
uranium oxides (yellowcake) or to produce uranium tetrafluoride (UF~4~)
from UF~6~.

6\. [Uranium Enrichment Facility]{.underline}. A facility licensed or
certified under 10 CFR Part 70 or 76, respectively, to increase the
ratio of the isotope U-235 to the isotope U-238 in uranium. Enriched
uranium may also be downblended at these facilities by mixing it with
natural or lower enriched quantities of uranium. (Downblending can also
be accomplished at some fuel fabrication facilities.)

C. SAFETY SYSTEMS

Variability among the different types of facilities as well as in the
processes that are employed in similar facilities does not lend itself
to generic inspection planning. The specific risk significant systems in
a facility that should be addressed by each inspection procedure (IP)
depend on the type of facility and the processes used. Guidance on
selection of risk-significant systems is provided in each inspection
procedure. For some facilities, the term Asafety systems@ may be defined
more narrowly in facility documents than would serve the purposes of the
safety inspection program. For example, the term may refer to items
relied on for safety (IROFS) or alternatively only to systems designed
to prevent major offsite releases. The inspectors should rely on the
Integrated Safety Analysis (ISA), Safety Analysis Report (SAR), or
license application to identify risk-significant systems. Discussions
with the Branch Chief and Project Inspector are also useful in
determining inspection priorities.

The purpose of the following descriptions is to describe some of the
safety systems that typically are found at fuel cycle facilities without
necessarily limiting the applicability of the designation Asafety
system@ to other process elements within the plant.

1\. [Plant Protection System]{.underline}. A function of plant
protection systems is to initiate the operation of controls important to
safety. The plant protection system encompasses all electrical and
mechanical devices and circuitry, from sensors to actuation device input
terminals, involved in generating signals associated with the detection
of off-normal conditions and events that could threaten safety. It may
also automatically trigger responses to maintain the continued safe
condition of the plant. Functioning of the plant protection system may
serve to actuate one or more of those systems described in the following
paragraphs.

2\. [Mechanical Process Systems]{.underline}. These systems include
receiving, storing, handling, transferring, and forming fissile material
in fuel fabrication plants and other plants for plutonium and uranium
processing. There may be important subsystems or components encompassed
by these systems that will be subject to inspection. Examples include
provisions for cleanups, maintaining assemblies in subcritical
conditions, crane operations, fuel pellet pressing, uranium dioxide
transfer and blending, pellet grinding, and handling or lifting
liquid-filled UF~6~ casks or fuel elements.

3\. [Chemical Process Systems]{.underline}. These systems may involve
changes in the physical or chemical composition of nuclear materials
contained in them (e.g., UF~6~ vaporization, filtering, centrifugation,
solvent extraction). The intended and unintended changes in physical or
chemical composition of the nuclear material or moderating material in
these systems are of particular safety significance, especially with
respect to nuclear criticality.

These processes often require sophisticated instrumentation for
monitoring and processing control, especially when they contain fissile
material. The actual form of the fissile material at any point in such a
process may be subject to rapid and undetected change if required
process parameters cannot be maintained. Such undesirable changes in
chemical composition could greatly increase the risk of a radiological
event.

Chemical process systems also include those for producing chemicals
containing no nuclear material, but which are needed to feed processes
that do involve nuclear materials elsewhere in the plant. Such processes
can also pose risks to the safe control of nuclear material. Upset
conditions associated with the system could lead to radiological
consequences in neighboring systems that do contain nuclear material.

4\. [Process Offgas Systems]{.underline}. Process offgas systems are
designed to confine hazardous chemical or radioactive materials that may
be generated during process operations or radioactive waste storage.
They are also designed to reduce the concentrations of these materials
in gaseous process effluents. Usual components of process offgas systems
are gas collection systems, scrubbers, condensate removal systems,
sampling systems, chemical monitoring systems, and control and
instrumentation systems.

To ensure reliable service in the event of postulated accidents, offgas
systems are generally equipped with redundant components to maintain the
availability of critical functions. For example, redundant exhaust
blowers may be installed. These may be designed to automatically switch
to emergency power systems upon loss of normal electrical supply to
ensure plant ventilation.

5\. [Confinement Barriers and Systems]{.underline}. Confinement barriers
or systems are used to control the release of radioactive materials to
the environment or into areas normally occupied by plant personnel. They
can be used either singly, or in combination, to improve effectiveness
or add redundancy.

Primary confinement barriers include glove boxes, walls of process
vessels, tankage, piping, and storage containers whose failure could
result in releases of substantial quantities of radioactive materials.

Final confinement barriers include exterior structure housing features,
ventilation intake filters, or suitable intake dampers. The portion of a
building=s exhaust ventilation system consisting of final filtration
equipment and equipment used to maintain a negative building pressure
can also be considered to serve as a confinement barrier system.

Absolute barriers are fabricated of impermeable material that can be
expected to prevent penetration of all confined material without regard
to the material=s physical or chemical nature. Examples include pipe and
vessel walls, and walls of buildings and structures.

Selective barriers, such as mass-transfer devices or filters, are
usually employed to remove selected chemical or particulate matter from
a process or ventilation stream, while allowing the bulk amount of the
stream to pass through. Examples of selective barriers are adsorbers,
scrubbers, distillation units, and particulate filters.

6\. [Ventilation Systems]{.underline}. A principal risk to health and
safety is the release and dispersal of radioactive materials. The
prevention of such releases and dispersal is an important function of
ventilation systems. They serve as principal confinement barriers in a
multiple confinement barrier system that guards against the release of
radioactive or other potentially dangerous materials during normal or
abnormal conditions.

7\. [Emergency Utility Services]{.underline}. Included are:

a\. [Electrical supply system]{.underline} with power supply and
distribution networks to maintain the following: final confinement
barrier and related systems associated with maintenance of its
functional integrity; fire protection systems; and safety‑related
monitoring and alarm systems, including those concerned with security,
criticality, combustible gases, effluents, and maintenance of pressure
differential between the ambient atmosphere and the plant interior
atmosphere.

b\. [Water supply systems]{.underline} intended for fire protection,
chemical dilution, or required equipment cooling, each with appropriate
capacity and distribution capability.

c\. [Compressed air supply systems]{.underline} intended to serve
safety‑related instruments and controls (with appropriate capacity and
distribution capability), and spargers.

d\. [Lighting systems]{.underline} to illuminate vital process
operations and security areas and aid in personnel egress and reentry.

e\. [Steam supply systems]{.underline} intended for process operations,
maintenance of critical temperatures in processes, and operation of
jet‑eductors used for transfer of process and waste solutions, etc.

8\. [Fire Protection Systems]{.underline}. These include fire alarm and
fire suppression systems. They are significant to nuclear safety in at
least two ways. First, by limiting the consequences of fires through
early detection and automatic suppression, they enable plant personnel
to maintain safe control of nuclear material. Second, the use of water
or other hydrogenous materials to suppress fire may inadvertently
provide sufficient moderation to cause inadvertent criticality. In areas
where sufficient quantities of special nuclear material exist, fire
suppression systems and techniques must be limited to prevent this from
occurring.

9\. [Other Safety Communications and Alarms Systems]{.underline}. These
include emergency communications systems, monitoring and alarm systems
for plant security, nuclear criticality, combustible gases, effluents,
and pressure differential across confinement barriers. Some of the
monitoring and alarm systems may be integral parts of the plant
protection systems.

END

ATTACHMENT 1

[Revision History for IMC 2600, Appendix A]{.underline}

+--------+--------+------------------------+-----+-------+-------------+
| Comm   | Issue  | Description of Change  | Tr  | Tra   | Comment     |
| itment | Date   |                        | ain | ining | Resolution  |
| Tr     |        |                        | ing | Compl | Accession   |
| acking |        |                        | Nee | etion | Number      |
| Number |        |                        | ded | Date  |             |
+--------+--------+------------------------+-----+-------+-------------+
| N/A    | 04     | Revised to incorporate | N   | N/A   | ML070600575 |
|        | /26/07 | the new inspection     | one |       |             |
|        |        | procedures developed   |     |       |             |
|        | CN-    | to address changes to  |     |       |             |
|        | 07-014 | Part 70 and to reflect |     |       |             |
|        |        | enhancements made to   |     |       |             |
|        |        | the fuel facility      |     |       |             |
|        |        | inspection program.    |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
| N/A    | 08     | Remove AOFFICIAL USE   | N   | N/A   | ML072070424 |
|        | /15/07 | ONLY - SENSITIVE       | one |       |             |
|        |        | INTERNAL INFORMATION@  |     |       |             |
|        | CN     | designation from       |     |       |             |
|        | 07-025 | entire manual chapter  |     |       |             |
|        |        | to make publicly       |     |       |             |
|        |        | available.             |     |       |             |
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|        |        |                        |     |       |             |
+--------+--------+------------------------+-----+-------+-------------+
|        |        |                        |     |       |             |
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