IP 71124.07, Radiological Environmental Monitoring Program
https://www.nrc.gov/docs/ML1728/ML17286A291.pdf
text
Issue Date: 12/21/17 1 71124.07
NRC INSPECTION MANUAL ARCB
INSPECTION PROCEDURE 71124 ATTACHMENT 07
RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM
Effective Date: January 1, 2018
INSPECTABLE AREA: Radiological Environmental Monitoring Program
CORNERSTONE: Public Radiation Safety
INSPECTION BASES: 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 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. 10 CFR 50 Appendix I directs licensees to establish surveillance and
monitoring programs that provide data on measurable levels of
radiation and radioactive material in the environment to evaluate the
relationship between the quantities of radioactive materials released
in effluents and resultant radiation doses to individuals from
principal pathways of exposure. The scope of the REMP is
specified in 10 CFR Part 50, Appendix I, Section IV, paragraph B.
Additionally, licensees are to identify changes in the use of
unrestricted areas (e.g., for agricultural purposes) to permit
modifications in the monitoring program for evaluating doses to
individuals from principal pathways of exposure. Implementation of
these requirements is described in plant-specific Technical
Specifications and, typically, further described in licensee-controlled
Offsite Dose Calculation Manuals (ODCM).
This inspection area verifies aspects of the Public Radiation Safety
Cornerstone for which there are no performance indicators to
measure performance.
LEVEL OF EFFORT: Inspect Biennially
Issue Date: 12/21/17 2 71124.07
PROGRAM APPLICABILITY: IMC 2515 App A
71124.07-01 INSPECTION OBJECTIVES
01.01 To verify that the Radiological Environmental Monitoring Program (REMP) quantifies
the impact of radioactive effluent releases to the environment and sufficiently validates
the integrity of the radioactive gaseous and liquid effluent release program.
01.02 To verify that the REMP is implemented consistently with the licensee’s TS and/or
ODCM and to validate that the radioactive effluent release program meets the design
objectives in Appendix I to 10 CFR Part 50.
01.03 To ensure that the REMP (1) monitors noneffluent exposure pathways (e.g., onsite
spills or leaks, exposures from direct and scattered (skyshine) radiation from plant
facilities and components), (2) is based on sound principles and assumptions, and
(3) validates that doses to members of the public are within the dose limits of
10 CFR Part 20, “Standards for Protection against Radiation,” and 40 CFR Part 190,
“Environmental Radiation Protection Standards for Nuclear Power Operations,” as
applicable.
01.04 To verify that the licensee is continuing to implement the voluntary NEI/Industry Ground
Water Protection Initiative (GPI).
01.05 To conduct a Routine Review of problem identification and resolution activities per
Inspection Procedure (IP) 71152, “Problem Identification and Resolution.”
71124.07-02 INSPECTION REQUIREMENTS
02.01 Site Inspection (1 Sample)
Walk down 3-5 of the air sampling stations and 3-5 of the thermoluminescent dosimeter
(TLD) monitoring stations to determine whether they are located as described in the
ODCM and to determine the equipment material condition.
For the air samplers selected above, review the calibration and maintenance records to
verify that they demonstrate adequate operability of these components.
Review the calibration & maintenance (or volume verification) records of up to five
composite water samplers, as available.
Verify that the licensee has initiated sampling of other appropriate media upon loss of a
required sampling station.
Observe the collection and preparation of 2-4 environmental samples from different
environmental media and verify that environmental sampling is representative of the
release pathways as specified in the ODCM and that sampling techniques are in
accordance with procedures.
Issue Date: 12/21/17 3 71124.07
Based on direct observation and review of records, verify that the meteorological
instruments are operable, calibrated, and maintained in accordance with guidance
contained in the FSAR, and licensee procedures. Verify that the meteorological data
readout and recording instruments in the control room and, if applicable, at the tower
are operable
As available, evaluate the licensee’s actions in response to 3-5 events that involved a
missed sample, inoperable sampler, lost TLD, or anomalous measurement.
Review the licensee’s assessment of any positive sample results (i.e., licensed
radioactive material was detected above the lower limits of detection or LLDs).
Select 3-5 structures, systems, or components (SSCs) that involve or could reasonably
involve licensed material for which there is a credible mechanism for licensed material
to reach ground water, and verify that the licensee has implemented a sampling and
monitoring program sufficient to detect leakage of these SSCs to ground water.
Verify that records developed since the last inspection that are important to
decommissioning are retained as required.
Review any significant changes made by the licensee to the ODCM and review
technical justifications for any changed sampling locations. Verify that the licensee
performed the reviews required to ensure that the changes did not affect its ability to
monitor the impacts of radioactive effluent releases on the environment.
Verify that the appropriate detection sensitivities are used for counting samples to
satisfy TS/ODCM required LLDs.
Review quality control charts for maintaining radiation measurement instrument status
and actions taken for degrading detector performance.
If the licensee uses a vendor laboratory to analyze REMP samples, verify that the
vendor’s quality control program, including inter-laboratory comparison programs, is
adequate.
Review the results of the licensees’ inter-laboratory comparison program to verify the
adequacy of environmental sample analyses performed by the licensee. If applicable,
review the licensee’s determination of any bias to the data and the overall effect on the
REMP.
02.02 GPI Implementation (1 Sample)
Verify that the licensee is continuing to implement the voluntary NEI/Industry Ground Water
Protection Initiative (GPI). Since the last inspection:
Review monitoring results of the GPI to determine if the licensee has implemented its
program as intended, and to identify any anomalous results. For anomalous results or
missed samples, determine if the licensee has identified and addressed deficiencies
through its corrective action program.
Issue Date: 12/21/17 4 71124.07
If applicable, document observations of incomplete or discontinued elements of the
licensee’s implementation of the GPI in the inspection report in Section 4OA5. [C1]
If the licensee is not implementing the minimization of contamination and survey
aspects of the GPI, review licensee methods of meeting the Decommissioning Planning
Rule requirements.
Review identified leakage or spill events and entries made into 10 CFR 50.75 (g)
records. Review evaluations of leaks or spills, and review any remediation actions
taken for effectiveness. Review onsite contamination events involving contamination of
ground water (Lessons Learned Task Force (LLTF recommendation #17). Assess
whether the source of the leak or spill was identified and mitigated.
Note: Limited, defined documentation of the review of abnormal or unplanned
radioactive discharges (e.g., leaks and spills) should be provided in the inspection
reports (see also IMC 0612) (LLTF recommendation #19)
For unmonitored spills, leaks, or unexpected liquid or gaseous discharges, ensure that
an evaluation was performed to determine the type and amount of radioactive material
that was discharged.
1. Assess whether sufficient radiological surveys were performed to evaluate the
extent of the contamination and the radiological source term. Verify that a
survey/evaluation has been performed to include consideration of hard-to-detect
radionuclides.
Determine whether the licensee completed offsite notifications; as provided in its GPI
implementing procedures
Review the evaluation of discharges from onsite surface water bodies that contain or
potentially contain radioactivity, and the potential for ground water leakage from these
onsite surface water bodies. Determine if the licensee is properly accounting for
discharges from these surface water bodies as part of its effluent release reports.
Verify that on-site ground water sample results and a description of any significant onsite leaks/spills into ground water for each calendar year are documented in the Annual
Radiological Environmental Operating Report (AREOR) for REMP or the Annual
Radiological Effluent Release Report (ARERR).
For significant, new effluent discharge points (such as significant or continuing leakage
to ground water that continues to impact the environment if not remediated), determine
if the ODCM was updated to include the new release point and includes the bases for
all new assumptions and parameters used in dose calculations.
02.03 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.
Issue Date: 12/21/17 5 71124.07
71124.07-03 INSPECTION GUIDANCE
Inspection Planning
Review the annual radiological environmental operating reports and the results of any
licensee assessments since the last inspection enable to verifying that the REMP was
implemented in accordance with the TS and ODCM. Review the report for changes to
the ODCM with respect to environmental monitoring, commitments in terms of sampling
locations, monitoring and measurement frequencies, land use census, inter-laboratory
comparison program, and analysis of data. Guidance on the proper location of
environmental monitoring stations is in NUREG-1301, “Offsite Dose Calculation
Guidance: Standard Radiological Effluent Controls for Pressurized Water Reactors,”
issued April 1991. Also, refer to the NRC Branch Technical Position, Revision 1, “An
Acceptable Radiological Environmental Monitoring Program (ADAMS Accession No.
ML010710060),” for additional information.
Review the ODCM to identify locations of environmental monitoring stations.
Review the final safety analysis report (FSAR) for information regarding the
environmental monitoring program and meteorological monitoring instrumentation.
Review quality assurance audit results of the program to assist in choosing inspection
“smart samples.” If the licensee uses a vendor laboratory to analyze the REMP
samples, review any audits and technical evaluations performed on the vendor’s
program.
Review the annual effluent release report and the 10 CFR Part 61, “Licensing
Requirements for Land Disposal of Radioactive Waste,” report, to determine if the
licensee is sampling, as appropriate, for the predominant and dose-causing
radionuclides likely to be released in effluents.
Review reported groundwater monitoring results, and changes to the licensee’s written
program for identifying and controlling contaminated spills/leaks to ground water.
Review changes to the plan and program since last inspection to identify changes that
have decreased effectiveness and scope.
03.01 Site Inspection
Consistent with smart sampling, the air sampling stations should be selected based on
the locations in the downwind sectors with the highest concentration per unit release
rate (X/Q), and highest deposition per unit release rate (D/Q), and thermoluminescence
dosimeters (TLDs) should be selected based on the most risk-significant locations (e.g.,
those that have the highest potential for public dose impact). Shifts in wind sectors with
the highest X/Q and D/Q may be detected by comparing several years of the licensee’s
meteorological data.
No inspection guidance.
No inspection guidance.
Issue Date: 12/21/17 6 71124.07
Consider the following media ground and surface water, milk, vegetation, sediment, and
soil. Guidance on sample collection and preservation is provided in NUREG-1576,
“Multi-Agency Radiological Laboratory Analytical Protocols Manual” (MARLAP), issued
July 2004. Also, refer to the NRC Branch Technical Position, Revision 1, “An
Acceptable Radiological Environmental Monitoring Program,” for guidance on sampling
other appropriate media upon loss of a required sample location.
No inspection guidance.
Compare readout data (i.e., wind speed, wind direction, and delta temperature) in the
control room and at the meteorological tower to identify any differences that would
indicate that inaccurate data are being used for dose determination.
Note that most 10 CFR Part 50 licensees will not be committed to Regulatory
Guide 1.23, “Meteorological Monitoring Programs for Nuclear Power Plants,” but may
be committed to Safety Guide 23, “Onsite Meteorological Programs,” (1972).
Review missed and or anomalous environmental samples to identify if they should be
reported in the annual environmental monitoring report. Review the licensee’s
assessment of any positive sample results (i.e., licensed radioactive material detected
above the lower limits of detection (LLDs). Review the associated radioactive effluent
release data that was the source of the released material. Ensure that the licensee has
addressed any positive indications in the environmental monitoring samples and has
adjusted the effluent monitoring program and dose modeling, as appropriate to ensure
the accuracy of the models. (See Section 6.8 in NUREG-1301, “Offsite Dose
Calculation Manual Guidance: Standard Radiological Effluent Controls for Pressurized
Water Reactors,” and in NUREG-1302, “Offsite Dose Calculation Guidance: Standard
Radiological Effluent Controls for Boiling Water Reactors,” issued April 1991.)
No inspection guidance.
Some examples of SSCs are outdoor refueling water storage tanks, spent fuel pools,
spent fuel pool leak detection systems, outdoor tanks, outdoor storage of contaminated
equipment, buried piping, retention ponds, basins, or reservoirs, and steam lines.
Some examples of leak detection methods for the SSCs are ground water monitoring,
operator rounds, engineering walk downs or inspections, leak detection systems, or
periodic integrity testing.
Licensees should document significant contamination resulting from leaks and spills, as
required by 10 CFR 50.75, “Reporting and recordkeeping for decommissioning
planning,” paragraph (g).
Changes may be made in response to changes to the land census, long-term
meteorological conditions (3-year average), or modifications to the sampler stations
since the last inspection.
No inspection guidance.
If the licensee uses a vendor laboratory to analyze the REMP samples, review the
results of the vendor’s quality control program, including the inter-laboratory comparison
program, to verify the adequacy of the vendor’s program.
Issue Date: 12/21/17 7 71124.07
No inspection guidance.
RG 1.33, 1.21 and 4.15 provide guidance for licensees participating in an intralaboratory and inter-laboratory comparison program to verify the quality of analyses.
03.02 GPI Implementation
Monitoring results are provided in the licensee’s Annual Radiological Effluent Release
Report or the Annual Radiological Environmental Operating Report.
For Part 50 licensees, adequate implementation of the NEI-GPI provides one
acceptable method of implementing the Decommissioning Planning Rule requirements
in 10 CFR 20.1406 and 10 CFR 20.1501 in accordance with RG 4.22,
“Decommissioning Planning during Operations.” If the licensee chooses other methods
of implementing these requirements, review those methods of implementation.
For 10 CFR Part 52 licensees, in addition to complying with 10 CFR 20.1406, licensees
are committed to implementing the GPI as part of their licensing basis, including use of
the NEI 08-08A, “Generic FSAR Template Guidance for Life-Cycle Minimization of
Contamination” as implemented in design features and operational programs.
Decommissioning planning rule requirements are found in 10 CFR 20.1406
(minimization of contamination) (see Regulatory Guide 4.22, “Decommissioning
Planning during Operations”) and 10 CFR 20.1501, “General” for requirements on
subsurface surveys.
Assess whether sufficient radiological surveys were performed to evaluate the extent of
the contamination and the radiological source term. Verify that a survey/evaluation has
been performed to include consideration of hard-to-detect radionuclides. Note that the
use of scaling factors can be used in bounding calculations. 10 CFR 50.75(g) files (or
corrective action program files referencing 50.75(g) files) should contain a description of
the leak or spill (isotopes and quantities), location and size of the impacted area, cross
reference to survey results, and results of any remediation performed if undetected
leakage has occurred or is suspected and insufficient monitoring/remediation actions
have been taken by the licensee, discuss this issue with your supervisor. If assistance
in assessing the adequacy of the licensee’s onsite/offsite monitoring activities is needed
and/or site hydrologic characteristics are not clearly defined, the program office should
be consulted.
No inspection guidance.
No inspection guidance.
Surface water bodies include: ponds, retention basins and lakes.
No inspection guidance.
Guidance on new release points is provided in Regulatory Guide 1.21 and Lessons
Learned Task Force (LLTF) recommendation #17.
Issue Date: 12/21/17 8 71124.07
Note: In accordance with Regulatory Guide 1.109, a significant new exposure pathway
exists if a conservative evaluation yields an additional dose increment equal to or more
than 10 percent of the total from all exposure pathways considered in Regulatory Guide 1.109.
03.03 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.
71124.07-04 RESOURCE ESTIMATE
For planning purposes, it is estimated to take 29 hours3.356481e-4 days <br />0.00806 hours <br />4.794974e-5 weeks <br />1.10345e-5 months <br />, on average (with a range of 25 to
33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />) to perform the requirements of this attachment.
71124.07-05 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 two, defined as the completion of the
activities contained in sections 02.01 and 02.02.
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.
71124.07-06 REFERENCES
10 CFR Part 50, Appendix A, “General Design Criteria for Nuclear Power Plants,” Criterion 64,
“Monitoring radioactivity releases,”
10 CFR 50.34a, “Design Objectives for Equipment to Control Releases of Radioactive Material in
Effluents—Nuclear Power Reactors,”
10 CFR 50.75, “Reporting and recordkeeping for decommissioning planning,”
IMC 0612, “Power Reactor Inspection Reports,”
Issue Date: 12/21/17 9 71124.07
Inspection Procedure 71152, “Problem Identification and Resolution,”
NEI 07-07, “Industry Ground Water Protection Initiative (GPI),”
NEI 08-08A, “Generic FSAR Template Guidance for Life-Cycle Minimization of Contamination,”
NRC, “Lessons Learned Task Force (LLTF) Report,” ADAMS ML062650312
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,”
NUREG-1576, “Multi-Agency Radiological Laboratory Analytical Protocols Manual,”
Regulatory Guide (RG) 4.22, “Decommissioning Planning During Operations,”
RG 1.23, “Meteorological Monitoring Programs for Nuclear Power Plants,”
RG 4.22, “Decommissioning Planning During Operations,” and
Safety Guide 23, “Onsite Meteorological Programs.”
END
Issue Date: 12/21/17 Att1-1 71124.07
Attachment 1: Revision History for IP 71124, Attachment 07
Commitment
Tracking
Number
Accession Number
Issue Date
Change Notice
Description of Change Description of
Training Required and
Completion Date
Comment and
Feedback Resolution
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
C1
Reference:
SRM-SECY11-019
(August 15,
2011)
Senior
Management
Review of
Overall
Regulatory
Approach to
Groundwater
Protection
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
Issue Date: 12/21/17 Att1-2 71124.07
Commitment
Tracking
Number
Accession Number
Issue Date
Change Notice
Description of Change Description of
Training Required and
Completion Date
Comment and
Feedback Resolution
Accession Number
(Pre-Decisional, NonPublic Information)
N/A ML15345A067
04/01/16
CN 16-010
Revisions to the IP 71124.07 procedure
attachment were made in response to the
2013 ROP Enhancement Project.
This revised procedure includes
groundwater monitoring inspection
requirements transferred in from IP 71124.06.
The revision changed the way samples are
counted.
N/A IP revised only to
include new sample
sizes. There is no valid
comment resolution at
this time.
N/A ML17286A291
12/21/17
CN 17-031
Major editorial revision of IP 71124.07.
Section 02 was audited and modified to
move guidance to Section 03 and concisely
state actions necessary to complete each
requirement
Modified Inspection Bases to reference
applicable regulations. Adjusted guidance
in response to ROPFF 71124.06-1743.
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
Closed FBF 71124.06-
1743