Information Notice 2013-13, Rev.1, Deficiencies with Effluent Radiation Monitoring System Instrumentation
| ML14253A270 | |
| Person / Time | |
|---|---|
| Issue date: | 04/15/2015 |
| From: | Marissa Bailey, Camper L, Michael Cheok, Kokajko L, Mark Lombard NRC/NMSS/FCSS, NRC/NMSS/SFST, NRC/NMSS/WCD, Division of Construction Inspection and Operational Programs, Division of Policy and Rulemaking |
| To: | |
| Banic M, NRR/JLD, 415-2771 | |
| References | |
| IN-13-013, Rev 1 | |
| Download: ML14253A270 (20) | |
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
OFFICE OF NEW REACTORS
OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS
WASHINGTON, DC 20555-001 April 15, 2015 NRC INFORMATION NOTICE 2013-13, REV. 1: DEFICIENCIES WITH EFFLUENT
RADIATION MONITORING SYSTEM
INSTRUMENTATION
ADDRESSEES
All holders of and applicants for operating licenses or a construction permit for a nuclear power
reactor or a non-power reactor under Title 10 of the Code of Federal Regulations (10 CFR)
Part 50, Domestic Licensing of Production and Utilization Facilities, including those that have
permanently ceased operations and have certified that fuel has been permanently removed
from the reactor vessel.
All holders of and applicants for a power reactor early site permit, combined license, standard
design certification, or a manufacturing license under 10 CFR Part 52, Licenses, Certifications, and Approvals for Nuclear Power Plants.
All holders of and applicants for a materials license, certificate, approval, or registration, including those holders of and applicants for a specific source material license under 10 CFR
Part 40, Domestic Licensing of Source Material, including licensees involved with uranium
recovery (extraction) methods (e.g., in situ recovery facilities, conventional uranium mills, and
heap leach and ion-exchange facilities).
All holders of and applicants for a uranium enrichment facility license under 10 CFR Part 70,
Domestic Licensing of Special Nuclear Material.
All holders of and applicants for an independent spent fuel storage installation license under
10 CFR Part 72, Licensing Requirements for the Independent Storage of Spent Nuclear Fuel, High-Level Radioactive Waste, and Reactor-Related Greater Than Class C Waste.
All holders of and applicants for a gaseous diffusion plant certificate of compliance or an
approved compliance plan under 10 CFR Part 76, Certification of Gaseous Diffusion Plants.
PURPOSE
The U.S. Nuclear Regulatory Commission (NRC) is issuing this revised information notice (IN)
to inform addressees of operating experience with radioactive effluent monitoring systems. This
Revision 1 to IN 2013-13 replaces the original IN 2013-13 in its entirety, and clarifies the scope
of the monitoring program set up by licensees pursuant to 10 CFR 50.65, Requirements for
monitoring the effectiveness of maintenance at nuclear power plants (hereafter referred to as
IN 2013-13, Rev. 1 the maintenance rule). Specifically, the revision clarifies that the scope of the maintenance rule
monitoring program includes only those radiation monitoring systems (RMSs) that are relied
upon to mitigate accidents or transients or are used in plant emergency operating procedures
(EOPs) as specified in the rule, instead of all RMSs that may be used in the emergency plan.
The NRC reviewed the operating experience with RMSs based on inspection results and found
a broad range of effluent monitoring system deficiencies. The review found problems that
occurred with RMS design modifications, calibration, representative sampling, and
maintenance. These deficiencies impaired the ability of radioactive effluent monitoring systems
to monitor radioactive effluent discharges adequately; however, none of the deficiencies
identified resulted in any significant occupational or public dose.
Recipients may review the information for applicability to their facilities and to consider actions, as appropriate, to avoid similar problems. Although these examples concern nuclear power
plants, the issues raised in these examples may apply to other licensees that have radioactive
effluent monitoring programs. Suggestions contained in this IN are not NRC requirements;
therefore, no specific action or written response to this IN is required.
DESCRIPTION OF CIRCUMSTANCES
The NRC staff reviewed industry operating experience for the period 2007 through 2012 and
found 27 instances at 20 nuclear power plants in which the effectiveness of an RMS was
degraded enough to warrant an NRC inspection finding or violation. Of particular concern was
an apparent increase in the frequency of these instances over the period. The NRC staff
evaluated these events and grouped them into the following several categories based on the
program, organization, or process affected:
- design (design changes, modifications, alterations) that impaired the system;
- calibrations and checks (primary, secondary, operability tests, etc.) that were not
technically correct;
- effluent sampling that was not representative of the effluent stream;
- backup RMSs and alternate sampling were not readily available;
- material condition of system was not maintained;
- quality assurance and quality control were deficient;
- maintenance rule was not carried out for nuclear power plants; and
- emergency planning for power plants was affected.
Example events from each of these categories are summarized below.
IN 2013-13, Rev. 1 Shearon HarrisDesignConfiguration Change Eliminates Isokinetic Sampling
In 2008, NRC staff found that the licensee did not adequately survey radioactive materials
released through the plant vent stack. Specifically, in 2000 the licensee abandoned a plant vent
stack particulate sample line booster pump because of repeated maintenance problems. As a
result, sample line isokinetic conditions (i.e., those conditions required to ensure representative
sampling of radioactive particulates) were no longer maintained. The licensee proceeded with a
modification to abandon the booster pump, assuming the plant vent stack high-efficiency
particulate air (HEPA) filtration systems would effectively remove large particulates from the flow
path upstream of the particulate sampler in the plant vent stack RMS. The licensee did not
recognize that particulates from the spent fuel pool filter backwash system were discharged into
the vent path downstream of the HEPA filtration system. With isokinetic conditions no longer
maintained in the sample line, the ability to collect a representative sample of airborne
particulates from the backwash system was degraded. This underestimated the dose to a
member of the public by up to 40 percent during periods when the spent fuel pool filter
backwash system was being operated. Corrective actions included reestablishing sample line
isokinetic conditions and entering this issue into the licensees corrective action program (CAP).
Other information appears in NRC Integrated Inspection Report 05000400/2008005, dated
January 29, 2009, Agencywide Documents Access and Management System (ADAMS)
Accession No. ML090290280.
OconeeDesign and Material ConditionMoisture in RMS Sample Chamber Impacts RMS
Response
In August 2010, NRC staff found that the licensee did not evaluate the operability of the
condenser off-gas (COG) RMSs when water was found in the sample line flow sight glass. The
licensee initially had identified the accumulation of water in the off-gas RMSs shortly after they
were installed in the 1990s. The licensee did not recognize the inoperability of the monitors, even though the detectors were requiring replacement at a much higher frequency than
expected because of water in the detection chamber that was damaging the detectors Mylar
window. Furthermore, the presence of water in the detection chamber shielded the beta
radiation detector, reduced the measuring chamber gas volume, and invalidated quantitative
measurements. The licensee entered this issue into its CAP, and corrective actions included
draining the detection chamber once per shift. It also developed plans to replace the
COG monitors with a different type of detector that is less susceptible to moisture accumulation.
Additional information appears in NRC Integrated Inspection Report Nos. 05000269/2011016,
05000270/2011016, and 05000287/2011016, dated June 23, 2011, ADAMS Accession
No. ML111751823.
BrunswickDesign and Representative SamplingSample Line Tees and Bends Can Impact
Representative Sampling
In 2010, NRC staff found that the reactor building vent effluent RMS contained mechanical tee
connections and elbows on the inlet side of the particulate sampler, potentially affecting the
ability to collect a representative sample. The NRC inspectors determined that the effect of the
configuration had not been evaluated for (1) the particle sizes likely to be encountered, (2) the
line loss through the sampling line, or (3) the potential effect on public dose estimates. This
degraded the ability to monitor radioactive effluents. The licensee entered this issue into its
CAP, and corrective actions included completing a sample line deposition study and developing
correction factors to be added to effluent release calculations. Additional information appears in
IN 2013-13, Rev. 1 NRC Integrated Inspection Report Nos. 05000325/2010002 and 05000324/2010002, dated
April 28, 2010, ADAMS Accession No. ML101180517.
Calvert CliffsDesign and Representative SamplingDesign of RMS Sampling System Dilutes
Sample
In December 2010, NRC staff found that a ventilation system did not maintain the design
negative pressure in the material processing facility (MPF), which could allow radioactive
material to bypass the RMS and escape the MPF. NRC staff review found that important
portions of the system were out of service for seven years, and the associated effluent RMS
was out of service for four years. Furthermore, the NRC staff review found that both the initial
RMS sample design, as well as the backup effluent sampler, did not supply representative
samples of the effluent stream because of sample dilution issues (e.g., deadhead flow from the
standby or alternate train). CAP actions included immediate stoppage of all work in the building
and completion of the necessary repairs before restarting work in the building. Other
information appears in NRC Integrated Inspection Report Nos. 050000317/2010005 and
05000318/2010005, dated January 28, 2011, ADAMS Accession No. ML110280097.
Shearon HarrisCalibrationsSecondary Calibration Source Not Traceable to the Primary
Calibration
In 2012, NRC staff found that a radioactive chlorine-36 source, used for secondary calibration of
the plant vent stack monitor, was not traceable to the primary calibration. Specifically, when the
original secondary source developed a leak and had to be replaced, an inadequate engineering
calculation was performed to evaluate the suitability of the new source. The evaluation
compared the sources activities and Mylar thicknesses, but it did not address geometry
differences between the two sources (i.e., point source vs. 2.5-centimeter (1-inch) diameter
active area). Thus, traceability of the new chlorine-36 source to the National Institute of
Standards and Technology traceable primary calibration was not established adequately. The
licensee entered this issue into its CAP and evaluated corrective actions and extent of condition.
The licensee performed a supplemental evaluation which showed that the geometry differences
between the old source and new source had only minimal effect on detector response. Other
information appears in NRC Inspection Report No. 05000400/2012003, dated July 26, 2012, ADAMS Accession No. ML12208A231.
KewauneeCalibrationSources Not Appropriate for Secondary Calibration
As part of an event follow-up for LER 2006-010-00, in 2009, NRC staff evaluated and closed an
issue involving radioactive sources used for calibration of effluent RMSs. The secondary
calibration sources used for the liquid radioactive waste RMS and the steam generator
blowdown liquid RMS were not of sufficient strength to meet channel calibration requirements of
the Offsite Dose Calculation Manual (ODCM) and technical specifications (TS). Subsequent
testing, with sources of sufficient strength, determined that one of the instruments did not
perform as predicted in the range in which the alarm was required, thus rendering the
instrument inoperable. The licensee entered this into its CAP. The licensee immediately
declared the instrument inoperable and began the required compensatory sampling. Other
maintenance corrected the condition, and subsequent secondary calibrations were appropriately
completed. Other information appears in NRC Integrated Inspection Report
No. 05000305/2009003, dated August 5, 2009, ADAMS Accession No. ML092180061.
IN 2013-13, Rev. 1 Prairie IslandMaintenanceRMSs Not Scoped in the Maintenance Rule
Per 10 CFR 50.65(b)(2)(i), the scope of the maintenance rule includes nonsafety-related
structures, systems, and components that are relied upon to mitigate accidents or transients or
are used in the EOPs. On September 30, 2011, NRC staff found that the licensee failed to
include all plant RMSs used in the EOPs. In addition, the licensee was not demonstrating that
the performance or the condition of these RMSs was being controlled effectively through the
performance of preventive maintenance. As a result, the performance of some RMSs was not
being assessed against licensee-established goals to offer reasonable assurance that the
monitors were capable of fulfilling their intended functions. Without the appropriate monitoring
and maintenance priority, RMSs may remain out of service for long periods of time. The
licensee entered this into its CAP. Corrective actions included scoping the applicable RMSs
into the licensees maintenance rule program. Other information appears in NRC Integrated
Inspection Report Nos. 05000282/2011004 and 05000306/2011004, dated October 23, 2011, ADAMS Accession No. ML112980240.
Peach BottomRepresentative Sampling and Quality AssuranceProcedures Lack Detail To
Ensure Representative Sampling
In 2007, NRC staff found that the licensee did not establish adequate quality assurance for
monitoring radioactive particulates from the main plant stack. Specifically, the procedures for
effluent monitoring were inadequate to detect and prevent non-representative sampling of
particulates by the main plant stack RMS. Particulates were bypassing the O-ring around the
particulate filter, resulting in underreporting of radioactive effluents. The NRC staff determined
that a contributing factor was the lack of adequate training of personnel to recognize sample
bypass. The licensee entered this issue into its CAP. Corrective actions included reevaluating
affected radioactive effluent dose assessments for 2006 and 2007 to ensure no TS dose limits
were exceeded, restoring representative sampling by correcting the cause of sample bypass, and evaluating extent-of-condition for both the Unit 2 and Unit 3 plant vent stack B train
sampling systems. Other information appears in NRC Integrated Inspection Report Nos.
05000277/2007002 and 05000278/2007002, dated May 15, 2007, ADAMS Accession
No. ML071350471.
Oyster CreekMaterial Condition and Representative SamplingSample Line Integrity Impacts
Representative Sampling
In December 2010, NRC staff found that the licensee did not maintain the required continuous
representative sampling of the main plant stack effluent. The main plant stack effluent sample
line, supplying the main plant stack effluent RMS, was found to be separated at a tube fitting by
several inches resulting in a non-representative sample of stack effluents. Subsequent
inspection of main stack RMS effluent radioactivity trends showed a long-term decreasing trend
from 2006 to 2010. Also, some radionuclides that were typically present in main stack samples
in 2006 were absent in 2010 analysis results. Furthermore, NRC staff found that the licensee
did not promptly report the degraded sample capability for impact on the emergency
preparedness (EP) program and did not carry out timely compensatory sampling for certain
functions of the system that supported the EP program. The licensees ultimate corrective
actions included revising site procedures to offer for an alternate sampling plan, starting
compensatory monitoring, repairing the stack sample line, conducting bounding dose
calculations, evaluating extent-of-condition, and entering information into the CAP. Other
information appears in NRC Integrated Inspection Report No. 05000219/2010003, dated
IN 2013-13, Rev. 1 August 9, 2010, ADAMS Accession No. ML102210111; and NRC Integrated Inspection Report
No. 05000219/2010005, dated February 8, 2011, ADAMS Accession No. ML110390509.
ColumbiaEmergency PlanningIncorrect RMS Response Factors Used as Part of the
Emergency Plan
In 2012, NRC staff determined that the licensee used inappropriate parameters for the reactor
building RMS in the emergency plans dose projection software. In the event of a real
emergency, using inaccurate radio-gas calibration and xenon-equivalency factors in dose
projection software would affect the assessment of a radiological release. This condition
existed between April 2000 and December 2011. The licensee entered this into their CAP.
Corrective actions included correcting the erroneous values used in the emergency plan. Other
information appears in NRC Inspection Report No. 05000397/2012502, dated July 26, 2012, ADAMS Accession No. ML12208A379.
Oyster CreekMaintenance and Emergency PlanningLoss of RMS Sampling System Can
Impact Emergency Planning
In 2009, NRC staff found that the licensee did not carry out timely corrective or compensatory
actions when the main stack effluent monitoring system automatic cartridge sampling system
was taken out of service from November 2006 through March 2009. The automatic system
collected high-activity, post-accident cartridge effluent samples. After the automatic sampling
system was placed in manual, to allow for manual collection of the cartridges, the chemistry
staff did not document the loss of automatic sampling capability in the corrective action
program, nor were the concerns forwarded to the EP group for an analysis about potential effect
on the emergency plan. The licensee did not repair the system in a timely manner, nor evaluate
the manual compensatory sampling measures to ensure high activity samples could be handled
and analyzed without excessive personnel radiation exposure. Corrective actions included
replacing solenoid valves in the automatic sampling system and returning the automatic
sampling system to service. Other information appears in NRC Inspection
Report 05000219/2009002, dated May 5, 2009, ADAMS Accession No. ML091250078.
BACKGROUND
For all licensees, the regulatory basis for effluent RMSs includes the requirements of
10 CFR 20.1501(a), which requires all NRC licensees to make surveys that are necessary
and reasonable to evaluate the magnitude and extent of radiation levels, concentrations or
quantities of residual radioactivity, and the potential radiological hazards of the radiation levels
and residual radioactivity detected. Additionally, 10 CFR 20.1501(c) requires licensees to
ensure that instruments used for quantitative radiation measurements (e.g., dose rate and
effluent monitoring) are calibrated periodically for the radiation measured.
The regulatory basis for nuclear power reactor effluent RMSs includes the following:
- A design requirement for nuclear power plants to monitor effluent discharge paths for
radioactivity released from nuclear power plants as provided in Criterion 64, Monitoring
Radioactivity Releases, of Appendix A, General Design Criteria for Nuclear Power
Plants, to 10 CFR Part 50.
IN 2013-13, Rev. 1 * A design requirement for nuclear power plants that instrumentation be supplied to
monitor variables and systems over their anticipated ranges for accident conditions, as
appropriate, to ensure adequate safety is included in Criterion 13, Instrumentation and
Control, of Appendix A to 10 CFR Part 50.
- An operational requirement for nuclear power plants in 10 CFR 50.36a(a) to: (1) keep
radioactive materials released to the unrestricted area as low as is reasonably
achievable, (2) have TS that will ensure compliance with the applicable provisions of
10 CFR 20.1301, Dose limits for individual members of the public, (3) provide
procedures for effluent control and for the operation and maintenance of the radioactive
waste system; and (4) submit an annual report to the NRC describing radioactive
effluents released to unrestricted areas.
The TS and associated ODCM of 10 CFR 50 licensees requires the maintenance of specified
RMSs for radioactive effluents through calibration, testing, operational requirements, and
maintenance procedures. The alarm and trip set-points associated with effluent RMSs identified
therein must be set and adjusted in accordance with the TS and ODCM. Effluent RMS alarm
and trip set-points can offer adequate assurance that the public radiation dose limits set forth in
10 CFR 20.1301 and that the design objectives of 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, are not exceeded.
Other considerations concerning nuclear power plant effluent RMSs include:
- The monitoring requirements set forth in 10 CFR 50.65, Requirements for monitoring
the effectiveness of maintenance at nuclear power plants. Per 10 CFR 50.65(b)(2)(i),
the scope of the monitoring program specified in 10 CFR 50.65(a)(1) shall include RMSs
that are relied upon to mitigate accidents or transients or are used in plant EOPs. As
discussed in 10 CFR 50.65(a)(2), monitoring as specified in 10 CFR 50.65(a)(1) is not
required where it has been demonstrated that the performance or condition of a
structure, system, or component is being effectively controlled through the performance
of appropriate preventive maintenance, such that the structure, system, or component
remains capable of performing its intended function.
- The emergency response plan requirements in paragraphs (b)(4) and (b)(9) of NRC
regulation 10 CFR 50.47, Emergency plans, for a standard emergency classification
and action level scheme, the bases of which include facility system and effluent
parameters, and for adequate methods, systems, and equipment for assessing and
monitoring actual or potential offsite consequences of a radiological emergency
condition. Other information on using RMSs in an emergency plan is discussed in
IN 2013-01, Emergency Action Level Thresholds outside the Range of Radiation
Monitors.
- Nuclear power plant licensees may use some RMSs as part of the steam generator tube
integrity program that is contained in their TS and current licensing basis.
- Nuclear power plant licensees are required, via the TS and ODCM, to report, after
30 days of inoperability of RMSs, the inoperability to the NRC in the next annual
IN 2013-13, Rev. 1 radioactive effluent release report (in accordance with their licensing basis) and carry out
any ODCM required compensatory actions. Compensatory actions for the inoperable or
nonfunctional monitors typically involve sampling effluents from the affected plant
systems on some routine interval (e.g., once per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />) or starting backup sampling
equipment.
The regulatory bases for materials license effluent RMSs include the following:
- Those persons holding licenses under 10 CFR Part 40, Domestic Licensing of Source
Material, must comply with the requirements of 10 CFR 40.63, Tests. Subsection
40.63(c) requires all 10 CFR Part 40 licensees to perform, or permit the NRC to perform, tests of radiation detection and monitoring instruments. Licensees engaged in uranium
milling, uranium hexafluoride production, or uranium enrichment activities are required to
report radioactive effluents, and such other information that the NRC may require, in
accordance with 10 CFR 40.65, Effluent monitoring reporting requirements. Paragraph
40.65(a)(1) also states that the NRC may require licensees to take appropriate actions
based upon these reports. In addition, Criteria 7, 7A, 8, and 8A of 10 CFR Part 40,
Appendix A, require monitoring of effluents and a concomitant corrective action program
for those 10 CFR Part 40 licensees engaged in uranium or uranium milling activities and
the disposition of tailings or waste resulting from such milling activities.
- Those persons holding licenses under 10 CFR Part 70, Domestic Licensing of Special
Nuclear Material, must comply with the requirements of 10 CFR 70.56, Tests.
Paragraph 70.56(c) requires tests of radiation detection and monitoring instruments.
Licensees authorized to possess and use special nuclear material for processing and
fuel fabrication, scrap recovery, conversion of uranium hexafluoride, or in a uranium
enrichment facility are required to report radioactive effluents, and such other information
that the NRC may require, in accordance with 10 CFR 70.59, Effluent monitoring
reporting requirements. Section 70.59 also states that the NRC may require licensees
to take appropriate actions based upon these reports.
- Those persons holding specific licenses under 10 CFR Part 72, Licensing
Requirements for the Independent Storage of Spent Nuclear Fuel, High-level
Radioactive Waste, and Reactor-Related Greater than Class C Waste, must comply
with the requirements of subsection (d) of 10 CFR 72.44, License conditions.
Specifically, 10 CFR 72.44(d)(1) requires maintenance of the equipment in an
independent spent fuel storage installations (ISFSI) radioactive waste treatment system
to meet the effluents requirements of 10 CFR 72.104, Criteria for radioactive materials
in effluents and direct radiation from an ISFSI or MRS. In addition, 10 CFR 72.44(d)(2)
requires the establishment of an environmental monitoring program to ensure
compliance with the technical specifications for effluents. Specific licensees are required
to report radioactive effluents, and such other information that the NRC may require, in
accordance with 10 CFR 72.44(d)(3).1 Paragraph 72.44(d)(3) also states that the NRC
may require licensees to take appropriate actions based upon these reports.
- Those persons holding specific licenses or general licenses under 10 CFR Part 72 are
subject to subsection (c) of 10 CFR 72.126, Criteria for radiological protection, which
1 Licensees holding a general license under 10 CFR Part 72 would make a similar report in accordance with
IN 2013-13, Rev. 1 requires that a means for measuring the amounts of radionuclides in effluents must be
provided for in an ISFSIs handling and storage system. Paragraph 72.126(c)(2) also
requires that areas containing radioactive materials must be provided with systems for
measuring the direct radiation levels in and around such areas. Subsection 72.126(d)
specifies that ISFSIs must be designed to offer means to limit effluents. Also, systems
designed to monitor the release of radioactive materials must have means for calibration
and testing their operability.
- With respect to those entities subject to 10 CFR Part 76, Certification for Gaseous
Diffusion Plants, subsection (g) of 10 CFR 76.35 requires that the application for a
certificate of compliance must include a compliance status report that includes
environmental and effluent monitoring data. In addition, those entities subject to
10 CFR Part 76 must comply with the requirements of subsection (c) of 10 CFR 76.123, Tests, which requires testing of radiation detection and monitoring instruments.
To carry out the regulations listed above, licensees take actions to maintain RMSs in an
operable or functional condition. When an effluent RMS fails, licensees are required to take
actions to ensure that radioactive effluents continue to be adequately monitored. Although
simple solutions can return an RMS to an operable or functional status, if the issue becomes
repetitive, some licensees conduct a more detailed evaluation to reveal the causal factors which
can sometimes reveal more permanent solutions. Some of these solutions may include
replacing aging RMSs, or prioritizing the equipments maintenance based on the input from
plant RMS users (e.g., Operations, Chemistry, and Radiation Protection staff). Other solutions
may involve enhanced training or improved interdepartmental coordination so that all individuals
conducting work, maintenance, or calibration of the systems have a common understanding of
the importance of proper operation of the system and what constitutes a fully operable or
functional system.
The following NRC generic communications relate to effluent RMSs:
- NRC Generic Letter (GL) 79-003, Offsite Dose Calculation Manual, 1979. This GL
informed the addressees of additional guidance on the content of the ODCMs, including
the procedural details of the regulatory requirements for effluent RMSs.
- NRC GL 79-006, Contents of the Offsite Dose Calculation Manual, 1979. This GL
informed the addressees of the importance of the ODCM and technical specifications in
carrying out 10 CFR 50.36a and other Federal regulations.
- NRC IN 82-49, Correction for Sample Conditions for Air and Gas Monitoring, 1982.
This IN informed the addressees of potential errors in radioactive gaseous effluent
monitoring.
- NRC IN 83-52, Radioactive Waste Gas System Events, 1983. This IN informed the
addressees of inadvertent releases because of valve mispositioning and other problems.
In some events, plant staff failed to recognize the resulting unusual radiation monitor
responses.
- NRC IN 86-30, Design Limitations of Gaseous Effluent Monitoring Systems, 1986.
This IN informed the addressees of issues related to the Eberline SPING-4 monitors.
IN 2013-13, Rev. 1 * NRC IN 86-42, Improper Maintenance of Radiation Monitoring Systems, 1986. This IN
informed the addressees that valve tag outs, temporary electrical jumpers, incorrect
valve line ups, and procedure noncompliance can affect RMS instrumentation.
- NRC IN 86-43, Problems with Silver Zeolite Sampling of Airborne Radioiodine, 1986.
This IN informed the addressees of the hazards of silver zeolite as an ignition source
when hydrogen is present.
- NRC GL 89-01, Implementation of Programmatic and Procedural Controls for
Radiological Effluent Technical Specifications in the Administrative Controls Section of
the Technical Specifications and the Relocation of Procedural Details of Radiological
Effluent Technical Specifications (RETS) to the Offsite Dose Calculation Manual or to
the Process Control Program, 1989. This GL informed the addressees how to keep the
radioactive effluent technical specifications in the technical specifications and relocate
procedural details of RETS to the ODCM. At the same time, the NRC staff emphasized
that its intent is not to reduce the level of radiological effluent controls, including the
controls for effluent RMSs.
- NRC IN 2013-01, Emergency Action Level Thresholds outside the Range of Radiation
Monitors, 2013. This IN informed addressees of failures to properly evaluate the effect
of site equipment changes on the emergency plan when radiation monitors were not
properly evaluated in conjunction with changes made to emergency action level (EAL)
thresholds for emergency classifications.
The following NRC guidance and information documents are related to RMSs:
- Regulatory Guide (RG) 1.21, Measuring, Evaluating, and Reporting Radioactive
Material in Liquid and Gaseous Effluents and Solid Waste, Revision 1, 1974, and
Revision 2, 2009. This guidance document contains details about reporting RMS
failures in annual effluent reports to the NRC.
- RG 4.15, Quality Assurance for Radiological Monitoring Programs (Inception through
Normal Operations to License Termination)Effluent Streams and the Environment, Revision 1, 1979, and Revision 2, 2007. This guidance document outlines basic but
important programmatic controls that form a basis for reliable operation of RMSs. Many
licensees have committed to at least parts of this regulatory guide in their licensing basis
documents.
- NUREG-0737, Clarification of TMI Action Plan Requirements, 1980. The information in
this NUREG contains insights about the performance of RMSs in high radiation fields
and emergency situations.
- RG 1.97, Criteria for Accident Monitoring Instrumentation for Nuclear Power Plants, Revision 3, 1983, and Revision 4, 2006. This guidance document discusses the
performance of RMSs in high radiation fields and emergency situations.
IN 2013-13, Rev. 1 * NUREG/CR-4757, Line-Loss Determination for Air Sampler Systems, 1991. This
NUREG describes how analysis results may be biased by plate-out of particulates and
iodine on sample lines.
- NUREG-1301, Offsite Dose Calculation Manual Guidance: Standard Radiological
Effluent Controls for Pressurized Water Reactors, 1991. This NUREG outlines the
default, minimum-acceptable effluent control and environmental monitoring programs for
pressurized-water reactors.
- NUREG-1302, Offsite Dose Calculation Manual Guidance: Standard Radiological
Effluent Controls for Boiling Water Reactors, 1991. This NUREG outlines the default, minimum-acceptable effluent control and environmental monitoring programs for
boiling-water reactors.
DISCUSSION
Effluent RMSs can serve multiple purposes such as monitoring radioactive effluents, monitoring
for primary-to-secondary leakage (e.g., such as at nuclear power plants), and for use in
conjunction with emergency action levels in the emergency plan. Maintaining an operable or
functional RMS may involve personnel in the following departments: maintenance, work control, operations, chemistry, health physics, emergency planning, system engineering, design
engineering, and instrumentation and control.
Several of the operational experience examples in this IN occurred because of challenges to
effective coordination between these numerous groups and the lack of sensitivity to, or
awareness of, the deficiencies that were reasonably within the licensees ability to detect and
correct. In many instances, once deficiencies were identified, RMSs remained out of service for
extended periods of time. In some cases, when the RMS was out of service, the backup or
alternate sampling requirements were not always adequately fulfilled or were unreasonably
delayed. Some operational experience involved poor maintenance of effluent monitor
design-basis documents (e.g., primary calibration records, calibration source documentation, and vendor manuals) as part of the overall effluent quality assurance (QA) program. Licensee
procedures used to service, maintain, and use RMS instrumentation can have a significant
effect on the reliable operation of RMS instrumentation.
In summary, the NRC found a broad range of effluent monitoring system deficiencies in its
review of operating experience. The review found that deficiencies associated with the following
factors can degrade the effectiveness of effluent RMSs:
- Routine and preventive maintenance of RMSs and associated ventilation systems.
- Evaluation of the effect of RMS design modifications on representative sampling.
- Advanced planning to ensure any required backup monitoring or compensatory sampling
is promptly initiated when effluent RMSs are out-of-service.
IN 2013-13, Rev. 1 * Advanced planning to ensure necessary actions are taken in response to RMS alarm
conditions, including reporting and controlling releases. This advanced planning may be
particularly applicable when back-out criteria or administrative action levels are used in
conjunction with temporary or backup radiation monitors.
- Calibration of effluent monitors using appropriate radioactive sources for primary and
secondary calibrations, including the use of correction factors in various applications, such as emergency planning dose-projection software.
- QA to find deficiencies in the sampling and measurement process and to establish
confidence in the results. QA practices may include: (1) trending and tracking of RMS
performance and maintenance (e.g., by reviewing trends for significant changes in
radioactive effluents or observing unexpected changes in sample appearance); (2)
verifying representative sampling following RMS maintenance or design modifications;
and (3) maintaining and using RMS design-basis documents, such as primary
calibration records, calibration source documentation, and vendor manuals.
- Training for plant personnel concerning RMS functions and ODCM requirements.
- Coordination and communication among numerous, different plant groups whose
activities may affect RMS functions with respect to radioactive effluent monitoring and
the emergency plan.
Licensees can carry out corrective actions, such as those described in this document, to
address the factors that are known to degrade the effectiveness of RMSs.
IN 2013-13, Rev. 1
CONTACT
This IN requires no specific action or written response. Please direct any questions about this
matter to the technical contact listed below or to the appropriate Office of Nuclear Reactor
Regulation project manager.
/RA/ /RA/
Larry W. Camper, Director Mark D. Lombard, Director
Division of Decommissioning, Division of Spent Fuel Management
Uranium Recovery Office of Nuclear Material Safety
and Waste Programs and Safeguards
Office of Nuclear Material
Safety and Safeguards
/RA/ /RA/
Michael C. Cheok, Director Marissa G. Bailey, Director
Division of Construction Inspection Division of Fuel Cycle Safety, Safeguards, and Operational Programs and Environmental Review
Office of New Reactors Office of Nuclear Material Safety
and Safeguards
/RA/
Lawrence E. Kokajko, Director
Division of Policy and Rulemaking
Office of Nuclear Reactor Regulation
Technical Contacts:
Ronald Nimitz, Region I/DRS/PSB2
610-337-5267 E-mail: ronald.nimitz@nrc.gov
Adam Nielsen, Region II/DRS/PSB1
404-997-4660
E-mail: adam.nielsen@nrc.gov
Note: NRC generic communications may be found on the NRC public Web site, http://www.nrc.gov/reading-rm/doc-collections/, under Document Collections.
- by email TAC MF4768 OFFICE NROR/DSEA/RPAC NRR/DIRS/IRIB R1/DRS/PSB2 RII/DRS/PSB1 NAME RConatser* ALewin* RNimitz * ANielsen*
DATE 10/7/14 10/7/14 10/7/14 9/25/14 OFFICE Tech Editor NRR/DRA/AHPB NRR/DRA NRR/DPR/PROB
NAME JDougherty* UShoop* JGitter (SLee for) KHsueh*
DATE 9/18/14 9/25/14 10/7/14 10/6/14 OFFICE FSME/DWMEP/DURLD/RDB NRR/DPR/PGCB NRR/DPR/PGCB NRR/DPR/PGCB
NAME BWatson* MBanic CHawes CMH SStuchell
DATE 10/1/14 10 / 29 /14 10/24/14 10 / 27 /14 OFFICE NMSS/ FCSE NRO/DCIP NMSS/SFM NMSS/DURWP
NAME MBailey* MCheok MLombard* LCamper
DATE 9/30/14 11 / 10 /14 9/30/14 11 / 3 /14 OFFICE NRR/DPR NRR/PGCB/LA OGC NRR/DPR
NAME AMohseni ELee APessin* LKokajko
DATE 11 /14 /14 4/10/15 3/26/15 (NLO) 4/15/15