IP 71124.06, Radioactive Gaseous and Liquid Effluent Treatment

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12-21-2017

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Issue Date: 12/21/17 1 71124.06

NRC INSPECTION MANUAL ARCB

INSPECTION PROCEDURE 71124 ATTACHMENT 06

RADIOACTIVE GASEOUS AND LIQUID EFFLUENT TREATMENT

Effective Date: January 1, 2018

INSPECTABLE AREA: Radioactive Gaseous and Liquid Effluent Treatment and Monitoring

Systems

CORNERSTONE: Public Radiation Safety

INSPECTION BASES:

10 CFR 20.1302 and 10 CFR 50.36a. 10 CFR 20.1302 requires

licensees take appropriate surveys of the unrestricted and

controlled areas and effluents released into these areas to

demonstrate compliance with the dose limits for individual members

of the public. 10 CFR 50.36a requires licensees to establish

Technical Specifications to keep releases of radioactive materials

ALARA and to submit yearly effluent reports. Additionally, 50.36a

provides numerical guidance via 10 CFR Part 50 Appendix I for

establishing limiting conditions for operation to ensure effluents from

light water cooled reactors are ALARA. Implementation of these

requirements is described in plant-specific Technical Specifications

and, typically, further described in licensee-controlled Offsite Dose

Calculation Manuals (ODCM). Additionally, licensees are required

by 10 CFR 20.1301(e) to comply with the U.S. Environmental

Protection Agency’s environmental radiation standards in 40 CFR

Part 190.

This inspection area verifies aspects of the Public Radiation Safety

cornerstone not fully measured by performance indicators (PI). In

Public Radiation Safety, the effluent release occurrence

performance indicator measures radioactive gaseous and liquid

releases that were above a fraction of the Technical Specification

and/or Offsite Dose Calculation Manual (ODCM) limits. Unidentified

changes to the parameters assumed in the effluent dose

calculations (e.g., process system efficiency, release points,

exposure pathways, etc.) may not be reflected in the PI reporting.

Issue Date: 12/21/17 2 71124.06

LEVEL OF EFFORT: Inspect Biennially

PROGRAM APPLICABILITY: IMC 2515 App A

71124.06-01 INSPECTION OBJECTIVES

01.01 To ensure that the gaseous and liquid effluent processing systems are maintained so

that radiological discharges are properly mitigated, monitored, and evaluated with

regard to public exposure.

01.02 To ensure that abnormal radioactive gaseous or liquid discharges and conditions,

when effluent radiation monitors are out-of-service, are controlled in accordance with

applicable regulatory requirements and licensee procedures.

01.03 To verify that the licensees’ quality control program ensures that the radioactive

effluent sampling and analysis requirements are satisfied so that discharges of

radioactive materials are adequately quantified and evaluated from all established

release points and any unmonitored and uncontrolled discharge path.

01.04 To verify the adequacy of public dose calculations and projections resulting from

radioactive effluent discharges.

01.05 To conduct a Routine Review of problem identification and resolution activities per

Inspection Procedure (IP) 71152, “Problem Identification and Resolution.”

71124.06-02 INSPECTION REQUIREMENTS

02.01 Walk Downs and Observations (1 Sample)

a. Walk down 3-5 effluent radiation monitoring systems (include at least one liquid and

one airborne system) and verify that effluent/process monitor configurations align with

ODCM descriptions. For portions of the systems that are inaccessible, review the

licensee’s material condition and surveillance records.

b. Walk down selected components of the gaseous and liquid discharge systems to verify

that equipment configuration and flow paths align with the documents reviewed during

inspection preparations and to assess equipment material condition.

c. Walk down those filtered ventilation systems whose test results will be reviewed later

during the inspection and verify that there are no conditions that would impact the

performance, or the effluent monitoring capability, of the system.

d. When possible for gaseous waste processing, observe selected portions of the routine

processing and discharge of radioactive gaseous effluent (including sample collection

and analysis). Verify that appropriate treatment equipment is used and the processing

activities align with discharge permits.

e. Evaluate any significant changes to the licensee’s effluent release points, since the last

inspection to verify they were adequately evaluated.

f. When possible for liquid waste processing, observe the routine processing and

discharge of effluents (including sample collection and analysis) to verify that

appropriate effluent treatment equipment is being used and that radioactive liquid waste

is being processed and discharged in accordance with procedure requirements and

aligns with discharge permits.

Note: For items 02.01.a and 02.01.b above, do not duplicate inspection effort of IP 71124.08, Section 02.02.

02.02 Calibration and Testing Program (Process and Effluent Monitors) (1 Sample)

a. Select 2-3 effluent monitor instruments (at least one of each type, such as gaseous,

liquid, etc.). Verify that channel calibration and functional tests are performed

consistent with radiological effluent technical specifications (RETS/ODCM); that (a) the

licensee calibrates its monitors with National Institute of Standards and Technology

(NIST) traceable sources; (b) if a primary calibration, it adequately represents the plant

nuclide mix; (c) if a secondary calibration, it verifies the primary calibration; and (d) the

channel calibrations encompass the instrument’s alarm set points.

b. Verify that effluent monitor alarm set points are established as provided in the ODCM

and station procedures.

c. For changes to effluent monitor set points, evaluate the basis for changes to ensure

that an adequate justification exists.

02.03 Sampling and Analyses (1 Sample)

a. As available, for 3-5 effluent sampling activities, verify that adequate controls have been

implemented to ensure representative samples are obtained.

b. As available, for 1-3 effluent discharges made with inoperable effluent radiation

monitors, verify that controls are in-place to ensure compensatory sampling is

performed consistent with the ODCM and that those controls are adequate to prevent

the release of unmonitored liquid and gaseous effluents.

c. Determine whether the facility is routinely relying on the use of compensatory sampling

in lieu of adequate system maintenance, based on the frequency of compensatory

sampling since the last inspection.

02.04 Instrumentation and Equipment (1 Sample)

a. Effluent Flow Measuring Instruments.

Review the methodology the licensee uses to determine the effluent stack and vent flow

rates. Verify that the flow rates are consistent with the ODCM or FSAR values, and that

differences between assumed and actual stack and vent flow rates do not affect the

results of the projected public doses.

b. Air Cleaning Systems.

Verify that surveillance test results for ventilation effluent discharge systems meet

Technical Specifications requirements.

c. High-Range Effluent Monitoring Instrumentation.

1. Select up to two high-range effluent monitors or other effluent/process monitors that

are relied on by the licensee in its emergency operating procedures (EOPs) as a

basis for triggering emergency action levels (EALs) and subsequent emergency

classifications, or to make protective action recommendations (PARs) during an

accident.

a) Verify these instruments are calibrated and available.

b) Review licensee’s methodology for calculating EAL thresholds (e.g. instrument

response factor determination) associated with system modifications since the

last inspection

c) As feasible, observe electronic and radiation calibration of these instruments to

verify conformity with the licensee’s calibration and test protocols.

2. Verify that the licensee has the capability to collect and analyze high-range, postaccident iodine and particulate effluent samples.

02.05 Dose Calculations (1 Sample)

a. For significant changes in reported dose values compared to the previous Radiological

Effluent Release Report, evaluate the factors which may have resulted in the change. If

the change was not explained as being influenced by operational issues independently

assess the licensee’s offsite dose calculations.

b. Review 1-3 radioactive liquid and 1-3 gaseous waste discharge permits. Verify that the

projected doses to members of the public are accurate and based on representative

samples of the discharge path.

c. Evaluate the methods used to determine the isotopes that are included in the source

term to ensure all applicable radionuclides are included; within detectability standards.

Review the current Part 61 analyses to ensure hard-to-detect radionuclides are

included in the source term.

d. Review changes in the licensee’s offsite dose calculations since the last inspection.

Verify the changes are consistent with the ODCM and Regulatory Guide 1.109. Review

meteorological dispersion and deposition factors used in the ODCM and effluent dose

calculations to ensure appropriate factors are being used for public dose calculations.

Confirm that in-plant dilution factors and dilution factors applied beyond the point of

discharge into unrestricted areas are appropriately used in dose calculations for liquid

effluents.

e. Review the results of the latest Land Use Census and verify that changes have been

factored into the dose calculations.

f. For the radioactive liquid and gaseous waste discharges reviewed in (b) above, verify

that the calculated doses (monthly, quarterly, and annual dose) are within the 10 CFR Part 50, Appendix I and Technical Specification dose criteria.

g. Select, as available, 1-3 records of any abnormal gaseous or liquid tank discharges and

verify the abnormal discharge was monitored by the discharge point effluent monitor. If

discharges were made with inoperable effluent radiation monitors, or if unmonitored

leakage occurred, verify that an evaluation was made of the discharge to satisfy the

survey requirements of 10 CFR 20.1501.

02.06 Problem Identification and Resolution

For each sample, conduct a routine review of problem identification and resolution

activities using Inspection Procedure (IP) 71152, “Problem Identification and

Resolution.”

71124.06-03 INSPECTION GUIDANCE

Inspection Planning.

To the extent that can be reasonably accomplished, perform in-office preparation before the

inspection, and complete the remaining inspection planning and follow-up actions during the

onsite aspects of the inspection.

a. Event Reports and Effluent Report Reviews.

Ensure that docketed reports since the previous inspection are included in the current

inspection (e.g., annual radioactive effluent release reports, special 30 day reports,

supplemental monitoring reports, offsite dose calculation manual revisions). Consider

scheduling this inspection soon after the annual radiological environmental report has

been submitted such that recent data can be compared between the effluent report and

the environmental reports.

1. Review the Annual Radiological Effluent Release Report(s) issued since the last

inspection. Determine if the reports were submitted as required by the

ODCM/Technical Specifications. Note any anomalous results, unexpected

trends or abnormal releases identified by the licensee for further inspection to

determine if they were evaluated, were entered in the corrective action program

and were adequately resolved.

2. Identify radioactive effluent monitor operability issues reported by the licensee as

provided in effluent release reports. Review these issues during the onsite

inspection, as warranted, given their relative significance. Determine if the

issues were entered into the corrective action program and adequately resolved.

b. ODCM and FSAR Reviews.

1. Review FSAR descriptions of the radioactive effluent monitoring systems, treatment

systems, and effluent flow paths so they can be verified during inspection walkdowns.

Issue Date: 12/21/17 6 71124.06

2. Review changes to the ODCM made by the licensee since the last inspection.

If differences are identified, review the technical basis or evaluations of the change

during the onsite inspection, to determine whether they were technically justified

and maintain effluent releases ALARA.

Changes to the ODCM are provided in the latest Annual Radiological Effluent

Release Report.

Review changes against the guidance in the following documents:

a) NUREG-1301, “Offsite Dose Calculation Manual Guidance: Standard

Radiological Effluent Controls for Pressurized Water Reactors,”

b) NUREG-1302, “Offsite Dose Calculation Manual Guidance: Standard

Radiological Effluent Controls for Boiling Water Reactors,”

c) NUREG-0133, “Preparation of Radiological Effluent Technical Specifications

for Nuclear Power Plants,”

d) Regulatory Guide (RG) 1.109, Calculation of Annual Doses to Man from

Routine Releases of Reactor Effluents for the Purpose of Evaluating

Compliance with 10 CFR 50, Appendix I,”

e) RG 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in

Liquid and Gaseous Effluents and Solid Waste,”

f) RG 4.1, “Radiological Environmental Monitoring for Nuclear Power Plants,”

and

g) RG 4.15, “Quality Assurance for Radiological Monitoring Programs (Inception

through Normal Operations to License Termination)—Effluent Streams and

the Environment.”

3. If applicable, evaluate the licensee’s management of non-radioactive systems that

have become contaminated since the last inspection. Determine if any of the newly

contaminated systems have an unmonitored effluent discharge path to the

environment, whether any required ODCM revisions were made to incorporate

these new pathways and whether the associated effluents were reported as

required.

During the onsite inspection, review any event reports, ODCM entries and 10 CFR 50.59 evaluations that have been performed for systems that have been identified

as contaminated since the last inspection. Determine if any of the newly

contaminated systems have an unmonitored effluent discharge path to the

environment, whether any required ODCM revisions were made to incorporate

these new pathways and whether the associated effluents were reported in

accordance with Regulatory Guide 1.21, as applicable. IE Bulletin 80-10 provides

guidance on contaminated systems not originally designed to be contaminated.

c. Procedures, Special Reports, and Other Documents

1. Review LERs, event reports and/or special reports related to the effluent program

issued since the previous inspection. Identify any additional focus areas for the

inspection based on the scope/breadth of problems described in these reports.

2. Review effluent program implementing procedures, particularly those associated

with effluent sampling, effluent monitor set point determinations and dose

calculations.

3. Review copies of licensee and third party (independent) evaluation reports of the

effluent monitoring program since the last inspection for insights into the

licensee’s program and to aid the inspector in selecting areas for review (smart

sampling). Such reports include Quality Assurance (QA) reports and reports

describing the results of the inter-comparison program with third party analytical

laboratories.

d. Post-Accident High Range Effluent Monitors.

Identify instrumentation and associated technical requirements for high range effluent

radiation monitoring instrumentation, including those instruments used for remote

emergency assessment. Review FSAR commitments and technical specification

requirements for these instruments.

Post-accident monitoring instrumentation includes high range effluent monitors (System

Particulate Iodine and Noble Gas (SPING)) and any other effluent or process monitors

that are relied on by the licensee in its Emergency Operating Procedures (EOPs), or to

issue protective action recommendations (PARs) during an accident

Note: Do not repeat any NRC inspection activity for any radiation monitor

instrumentation that is included under the Maintenance Rule program.

03.01 Walk Downs and Observations

a. Focus on any flow measurement devices and all accessible point-of-discharge liquid

and gaseous effluent monitors of the selected systems. Look for monitor degradation

and out-of-service tags. For effluent sampling systems (e.g., SPINGs), look for

indications of non-representative sampling such as severe bends in sample line tubing,

non-isokinetic sampling, or lack of heat tracing in areas where temperature extremes

could have an impact (causing condensation and plate-out). Additionally, be alert to

degraded ventilation system connections (e.g., flexible duct connectors) that could

contribute to releases. Guidance on sampling systems is contained in ANSI N13.1-

1969, “Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities,” and

ANSI N13.10-1974/ANSI N42.18-2004, “Specification and Performance of Onsite

Instrumentation for Continuously Monitoring Radioactivity in Effluents.”

b. Be alert for potential unmonitored release points (such as open roof vents in BWR

turbine decks, temporary structures butted against turbine, auxiliary or containment

buildings), building alterations which could impact airborne, or liquid, effluent controls,

and ventilation system leakage that communicates directly with the environment.

Evaluate how the licensee is quantifying gaseous and liquid discharges and is calculating the associated doses. Review the licensee’s assessment of the source term

used, including all radionuclides discharged, within detectability standards. Be aware of

system contamination that may have impacted otherwise non-contaminated systems

(e.g., PWR turbine sumps, plant boilers, RHR heat exchangers, etc.).

c. Guidance on the performance of ventilation charcoal and filter banks is provided in

ASME N510-1989. Conditions that may impact ventilation system performance include

degraded HEPA/charcoal banks, improper alignment, or system installation issues

d. No inspection guidance.

e. In general, discharge points that are secondary dispersion/dilution points (i.e., those

originating from authorized effluent discharges such as rain-out into storm drains or

drainage from equipment condensation, including freezers) do not need further

evaluation (see RIS 2008-03). However, the discharge of radioactive material from

unusual discharge points (e.g., pumping of water from cable trays) needs an evaluation

prior to discharge. This evaluation can be a bounding evaluation for less significant

release points (see RG 1.21, Rev. 2). Some changes may require a 10 CFR 50.59

review, or prior NRC approval (e.g., burning contaminated oil in an auxiliary boiler).

Consider if changes are subject to 10 CFR 50.59 reviews or NRC approval (e.g.,

alternate discharge points).

f. No inspection guidance.

03.02 Calibration and Testing Program (Process and Effluent Monitors)

a. Focus on point of discharge effluent monitors and others, if time permits. Guidance on

calibration program requirements is in Regulatory Guide 1.21, “Measuring, Evaluating,

and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste”;

Regulatory Guide 4.15, “Quality Assurance for Radiological Monitoring Programs

(Inception through Normal Operations to License Termination)—Effluent Streams and

the Environment”; ANSI Standard N13.1-1969, “Sampling Airborne Radioactive

Materials in Nuclear Facilities”; and Health Physics Positions (HPPOS) 040 and 229 in

NUREG/CR-5569, Revision 1, “Health Physics Positions Data Base,” dated

May 1, 1992. If an instrument is not calibrated correctly, determine generic applicability

and actual and potential exposure impact, and assess the impact with respect to control

or emergency preparedness. Deficiencies should be entered into the licensee’s

corrective action program. Notify regional EP inspector if any issues are found with

effluent monitors found in the licensee’s approved emergency action level scheme.

b. No inspection guidance.

c. Determine if the set points are based on an appropriate effluent radionuclide (noble

gas) mix so as not to exceed the effluent dose limits in 10 CFR Part 20 and the design

constraints in 10 CFR Part 50, Appendix I, “Numerical Guides for Design Objectives

and Limiting Conditions for Operation to Meet the Criterion ‘As Low as is Reasonably

Achievable’ for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor

Effluents.” The radionuclide mix used in the calculation should be the same as or more

conservative (lower average energy) than the licensee’s actual source term mix.

Issue Date: 12/21/17 9 71124.06

03.03 Sampling and Analyses

a. Evaluate potential sampling system configurations or situations that may impact

representative sampling (e.g., media by-pass, humidity, line loss, heat trace, sample

line flushing, vessel recirculation, composite samplers etc.). Guidance for review of

reasonableness and consistency of sample data is covered in R.G. 4.15, Rev 1,

Section C. 8. For those licensees committed to Rev.2 of R.G. 4.15, guidance is

included in Section C.7 for quality assurance, Section C.8 for verification and validation,

and Section 10 for preventive and corrective action. In general, the licensee’s program

in this area should be sufficient to detect anomalous data indicative of potential

deficiencies in sample collection or analysis. For example, if the licensee’s sample line

for a system (e.g., stack) has lost integrity resulting in non-representative samples,

would the program provide a means of detecting the deficiency?

b. No inspection guidance.

c. No inspection guidance.

03.04 Instrumentation and Equipment

a. Effluent Flow Measuring Instruments.

Guidance on the maintenance of flow measurement devices (e.g., pitot tubes) and filter

testing is contained in ANSI N42.18-2004, “Specification and Performance of On-Site

Instrumentation for Continuously Monitoring Radioactivity in Effluents.”

If available, review historical trends in vent/stack flow rates to determine if substantial

variability exists, potentially indicating flow restrictions in the measuring device or fan

motor problems.

b. Air Cleaning Systems.

Guidance on performance testing of Technical Specification required ventilation

systems is provided ASME N510-1989, “Testing of Nuclear Air Treatment Systems.”

Systems to consider include the Standby Gas Treatment System (BWRs) and the

Containment/Auxiliary Building Ventilation System (PWRs). Coordinate with the

resident inspectors before inspecting safety-related (accident scenario) ventilation

systems to avoid duplication of effort.

c. High-Range Effluent Monitoring Instrumentation.

1. Refer to the licensee’s FSAR, technical specification requirements, and

NUREG-0737, “Clarification of TMI Action Plan Requirements,” issued

November 1980, for guidance on post-accident monitoring instrumentation. Note:

Since these monitors may be used for PARs, ensure that the regional EP staff is

aware of any monitoring issues that could impact the monitors’ function.

A detailed review of EAL threshold calculations is not intended, nor desired.

Inspectors should interview plant personnel who conduct, or a responsible for, these

calculations to qualitatively review the licensee’s performance in this area.

Issue Date: 12/21/17 10 71124.06

Significant questions or issues in this area should be referred to the program office

for further guidance.

Focus should be given to those monitors in which the EAL threshold is based on

public dose and for which changes to the thresholds have been made since the

previous inspection. NEI 99-01 provides guidance on establishing EALs.

Consider if monitor operation is appropriate for the setpoint value (e.g., the setpoint

is not affected by the monitor switching from mid-range to high-range or a purge

function that actuates upon shifting of ranges).

2. No inspection guidance.

03.05 Dose Calculations

a. Consider dose values that change by a factor of 5, or that increase such that they

approach Appendix I Criterion. Factors that may result in changes to dose values

include fuel integrity, recent changes in coolant chemistry, extended outage, or major

decontamination efforts. Review the licensee’s dose calculation methods. If any

concerns arise, use available NRC computer codes (agreement should be within a

factor of 2) to verify dose values, perform manual calculation, or review the licensee’s

dose calculation methods.

b. No inspection guidance.

c. No inspection guidance.

d. No inspection guidance.

e. Consider significant increases or decreases to population in the plant environs,

changes in critical exposure pathways, the location of nearest member of the public, or

critical receptor, etc.

f. No inspection guidance.

g. Consider discharges resulting from misaligned valves and valve leak-by, etc.

03.06 Problem Identification and Resolution

Per IP 71152, it is expected that routine reviews of PI&R activities should equate to

approximately 10 to 15 percent of the resources estimated for the associated baseline

cornerstone procedures, this is a general estimate only based on the overall effort

expected to be expended in each strategic performance area. It is anticipated that the

actual hours required to be expended may vary significantly from attachment to

attachment, depending on the nature and complexity of the issues that arise at the

particular facility. Overall, an effort should be made to remain within the 10 to 15

percent estimate on a strategic performance area basis. Inspection time spent

assessing PI&R as part of the baseline procedure attachments should be charged to

the corresponding baseline procedure.

71124.06-04 RESOURCE ESTIMATE

For planning purposes it is estimated to take 35 hours4.050926e-4 days <br />0.00972 hours <br />5.787037e-5 weeks <br />1.33175e-5 months <br />, on average (with a range of 31 to 39

hours) to perform the requirements of this attachment.

71124.06-05 COMPLETION STATUS

Inspection of the minimum sample size will constitute completion of this procedure in the RPS.

The minimum sample size for this attachment is five, defined as the completion of the activities

contained in sections 02.01 through 02.05.

If any of the sample inspection requirements cannot be completed, the procedure should be

closed in accordance with IMC 0306, “Planning, Tracking and Reporting of the Reactor

Oversight Process (ROP).” For example, if certain steps could not be completed due to sample

unavailability, the procedure attachment should be declared “Complete – full sample not

available” with a comment addressing the specific steps or activities that could not be

completed.

71124.06-06 REFERENCES

10 CFR Part 20, “Standards for Protection against Radiation,”

10 CFR 50.34a, “Design Objectives for Equipment to Control Releases of Radioactive Material

in Effluents—Nuclear Power Reactors,”

10 CFR Part 50, Appendix A, “General Design Criterion for Nuclear Power Plants,” Criterion 60,

“Control of releases of radioactive materials to the environment,”

10 CFR Part 50, Appendix A, “General Design Criterion for Nuclear Power Plants,” Criterion 64,

“Monitoring radioactivity releases,”

ANSI N13.1-1969, “Guide to Sampling Airborne Radioactive Materials in Nuclear Facilities,”

ANSI N13.10-1974, “Specification and Performance of On-site Instrumentation for Continuously

Monitoring Radioactivity in Effluents,”

ANSI N42.18-2004, “Specification and Performance of Onsite Instrumentation for Continuously

Monitoring Radioactivity in Effluents,”

ASME N510-1989, “Testing of Nuclear Air Treatment Systems,”

Generic Letter 89-01, “Implementation of Programmatic and Procedural Controls for

Radiological Effluent Technical Specifications,”

Inspection and Enforcement (IE)Bulletin 80-10, “Contamination of Nonradioactive System and

Resulting Potential for Unmonitored, Uncontrolled Release to Environment,”

Regulatory Guide (RG) 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in

Liquid and Gaseous Effluents and Solid Waste,”

Issue Date: 12/21/17 12 71124.06

RG 1.109, “Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for

the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I,”

RG 1.21, “Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous

Effluents and Solid Waste,”

RG 4.1, “Radiological Environmental Monitoring for Nuclear Power Plants,”

RG 4.15, “Quality Assurance for Radiological Monitoring Programs (Inception through Normal

Operations to License Termination)—Effluent Streams and the Environment,”

RIS 2008-03, “Return/Re-use of Previously Discharged Radioactive Effluents,”

NUREG-0133, “Preparation of Radiological Effluent Technical Specifications for Nuclear Power

Plants,”

NUREG-0737, “Clarification of TMI Action Plan Requirements,”

NUREG-1301, “Offsite Dose Calculation Guidance: Standard Radiological Effluent Controls for

Pressurized Water Reactors,”

NUREG-1302, “Offsite Dose Calculation Guidance: Standard Radiological Effluent Controls for

Boiling Water Reactors,” and

NUREG/CR-5569, Revision 1, “Health Physics Positions Data Base.”

END

Attachment 1: Revision History for IP 71124.06

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion

Date

Comment Resolution

and Closed Feedback

Form Accession Number

(Pre-Decisional, NonPublic Information)

N/A 12/02/09

CN 09-030

Conducted four year search for commitments

and found none.

This new procedure is being issued as a result

of the 2009 ROP IP Realignment. It

supersedes inspection requirements in IP 71121 and 71122.

Yes

09/09/2009

ML092810414

C1 Reference:

SRM-SECY-11-

019 (August 15,

2011)

Senior

Management

Review of

Overall

Regulatory

Approach to

Groundwater

Protection

ML12321A387

06/06/13

CN 13-013

This revision directs the inspection staff to

document observations of incomplete or

discontinued implementation of the NEI/industry

ground water protection Initiative (GPI). The

revision also instructs inspection staff that if the

licensee is not implementing the GPI, to review

the adequacy of the licensee’s implementation

of the Decommissioning Planning Rule under

10 CFR 20.1406(c) and 10 CFR 20.1501,

including Part 52 licensee requirements to

implement the GPI and NEI-08-08A.

N/A ML13085A201

ML13129A076

N/A ML15345A054

04/01/16

CN 16-010

Revisions to the IP 71124.06 procedure

attachment were made in response to the 2013

ROP Enhancement Project.

The revision changed how inspection samples

are counted, moved the sections on ground

water inspections from 71124.06 to 71124.07.

It incorporates effluent monitoring

instrumentation from 71124.05 into 71124.06.

N/A IP revised only to include

new sample sizes.

There is no valid

comment resolution at

this time.

Issue Date: 12/21/17 Att1-2 71124.06

Commitment

Tracking

Number

Accession

Number

Issue Date

Change Notice

Description of Change Description of

Training Required

and Completion

Date

Comment Resolution

and Closed Feedback

Form Accession Number

(Pre-Decisional, NonPublic Information)

N/A ML17286A290

12/21/17

CN 17-031

Major editorial revision of IP 71124.06.

Inspection Bases was updated to reference

applicable regulations. Guidance added to

address sample quality assurance in response

to ROPFF 71124.06-1639.

Section 02 was audited and modified to move

guidance to Section 03 and to concisely state

actions necessary to complete each

requirement

Modified 02.04 to add requirement for

inspectors to review rad monitor calculations

used to establish EAL thresholds in response to

ROPFF 71124.06-2237. Reduced 02.02.a to 2-

3 from 3-5.

Moved requirement to review results of inter-lab

comparison to 71124.05 (02.02.a.2).

PI&R was transitioned from an independent

sample to a requirement that would be

completed as part of each sample. Guidance

section updated to reflect resource estimates

for routine review of PI&R activities per IP 71152 Section 04.01.

Verbal discussion

of changes during

2017 HP

Counterpart

meeting,

09/06/2017

ML17300A475

Closed FBFs:

71124.06-1639

ML17300B385

71124.06-1743

ML17300B383

71124.06-2237

ML17300B384