ML19189A035
| ML19189A035 | |
| Person / Time | |
|---|---|
| Issue date: | 07/19/2019 |
| From: | Garmon D, Matthew Smith NRC/NRR/DRA/ARCB |
| To: | |
| Michael Smith | |
| References | |
| Download: ML19189A035 (26) | |
Text
2020 Inspection Procedure 71124 Update Micheal Smith, Health Physicist NRR/DRA/ARCB micheal.smith@nrc.gov David Garmon, Health Physicist NRR/DRA/ARCB david.garmon@nrc.gov July 23, 2019 ML19189A035
Agenda
- Background - Radiation Safety Cornerstones Inspection Procedure
- Inspection Procedure (IP) Update Process
- IP Update Snapshot
- Focus Areas
- ALARA - Oversight of Part 37
- Instrumentation - Inspection Planning
- Effluents and Environmental Monitoring - Procedure Formatting
- Schedule Looking Forward
- Feedback/Discussion
- Comments and input from the public 2
Radiation Safety Cornerstones 3
Baseline Inspection Procedures IP Title (%PRS/%ORS)* Nominal Hours Inspection Samples Number 71124 Radiation Safety-Public Occupational N/A N/A 71124.01 Radiological Hazard Assessment and Exposure Controls (0%/100%) 36 +/- 4 (annual) 6 71124.02 Occupational ALARA Planning and Controls (0%/100%)** 46 +/- 14 (biennial) 4 71124.03 In-Plant Airborne Radioactivity Control and Mitigation (0%/100%) 16 +/- 4 (biennial) 3 71124.04 Occupational Dose Assessment (0%/100%) 20 +/- 4 (biennial) 4 71124.05 Radiation Monitoring Instrumentation (20%/80%) 32 +/- 4 (biennial) 2 71124.06 Radioactive Gaseous and Liquid Effluent Treatment (100%/0%) 35 +/- 4 (biennial) 5 71124.07 Radiological Environmental Monitoring Program (100%/0%) 29 +/- 4 (biennial) 2 71124.08 Radioactive Solid Waste Processing and Radioactive Material 34 +/- 4 (biennial) 5 Handling, Storage and Transportation (80%/20%)
- PRS = Public Radiation Safety Cornerstone; ORS = Occupational Radiation Safety Cornerstone
- Staff has proposed retiring this procedure (with transfer of some of its contents) as part of the ROP Enhancement effort 4
Inspection Procedure (IP) Revision Process
- Identify which IPs need to be revised based on:
Independence
- Inspection experience
- Stakeholder feedback Clarity
- Programmatic reviews
- Develop revised procedures through internal collaboration Openness
- Provide external stakeholders an opportunity to preview significant changes (July 23, 2019 public meeting) Reliability
- Finalize IPs
- Train staff, as necessary Efficiency
- Issue final IP 5
IP 71124 Update - Snapshot Focus Areas Proposed Action ALARA Inspections Retire dedicated inspection procedure; however, continue performance-based inspection during other inspection efforts
- Pending Commission decision Instrumentation Inspections No changes Effluent and Environmental Inspections Shifting frequency from biennial to triennial; however, maintaining scope, Clarifying intent of groundwater protection program inspections Oversight of Part 37 Including Part 37 oversight within existing radioactive material control and transportation inspection effort Inspection Planning Considering applicability of situational inspections to radiation safety procedures (similar to adverse weather inspections)
Inspection Procedure Format Procedures will be reformatted to more clearly communicate inspection activities with public and to support streamlining inspection reports 6
ALARA Considerations
- Persistent downward trend in collective radiation exposure (CRE) per reactor
- CRE is used to facilitate risk-informed oversight
- A measure of the challenges a program faces
- Dose limits apply to individual doses not collective doses
- Industry performance as reflected through a combination of inspection outcomes and CRE
- Staff position that baseline inspections in the ALARA area can be reduced from a risk-informed, performance-based perspective 7
ALARA Inspections - Proposal Pending Commission approval
- Proposal to retire focused baseline inspection procedure
- Focuses finite inspection resources in a risk-informed manner
- Leverages other inspection efforts for performance-based inspection of ALARA
- New approach will emphasize performance
- Observations of radiation workers
- Evaluation of licensee planning associated with significant radiological work
- Evaluation of licensee assessments of discrepancies between planned and actual doses 8
Instrumentation - Considerations and Proposal
- Considerations
- Advancements in technology and instrument design have improved radiation detection capability albeit with some added complexity
- Radiation detection instrumentation is fundamental to radiation protection
- NRC uses licensee data for oversight
- Inspections and event response
- Measurements serve as the basis for risk-informed decisions in oversight and enforcement
- Proposal
- No change recommended at this time 9
Effluent and Environmental Monitoring - Considerations
- Nuclear power plant effluents contribute a negligible amount to overall public dose
- Since the advent of the ROP, nuclear power plant effluents have decreased
- NRC inspections verify adequacy of licensee processes in tracking effluents and environmental monitoring
- Licensees report outcomes to NRC annually (posted to our web site)
- Performance Indicator tracks effluent performance 10
Effluent and Environmental Inspections - Proposal
- Shift inspections of effluents and environmental monitoring from biennial to triennial while maintaining the scope of these inspections the same
- Clarify intent of groundwater protection initiative (GPI) inspections
- Per Commission direction NRC staff is to monitor GPI implementation at licensees and document incomplete or discontinued elements of the program NRC will continue inspections of radiological effluents and environmental monitoring in a risk-informed, performance-based manner 11
Part 37 - Considerations
- Part 37 protects against high consequence, low likelihood events
- Loss of category 1 or 2 material through theft or diversion
- Observations from 34 site inspections
- Inspection hours
- 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br /> (median)
- Dependent on licensee preparedness
- Issues
- Key control/custody
- RP and security interface requires investment Category 1 and category 2 material is secure at U.S. nuclear power plants 12
Part 37 - Proposal
- Risk-informed, performance-based approach includes limited inspection
- Inspection guidance includes:
- Consideration of category 1 and 2 material during inspections
- Consideration of personnel granted unescorted access to category 1 and 2 material versus list of trained personnel
- Review of licensees annual access control program review
- Review of licensees annual security program review
- Review of shipping documentation describing preplanning and coordination
- Consideration of license verification requirements prior to shipping material 13
Part 37 - Associated Activities
- Mechanisms for dispositioning performance deficiencies under the ROP
- More-than-Minor guidance
- Significance Determination Process
- Inspector Training
- Rulemaking Effort 14
Inspection Planning
- Guidance in IP 71124
- Emphasize long-term nature of inspection planning and risk-informing when to disposition issues
- Guidance on when inspection requirements should be completed (outage, non-outage); however, inspectors ultimately have discretion on when to complete inspections
- Exploring application of situational inspection construct similar to IP 71111.01 15
Updated Requirement Language Example IP 71124.08 Rad Waste System Walkdown 16
Proposed Baseline Inspection Procedures Changes in red IP Number Title (%PRS/%ORS)* Nominal Hours Minimum Inspection Inspection Revised Minimum Samples Requirements Inspection Samples 71124 Radiation Safety-Public Occupational N/A N/A N/A N/A 71124.01 Radiological Hazard Assessment and Exposure Controls 36 +/- 4 (annual) 6 6 10 (0%/100%)
71124.02 Occupational ALARA Planning and Controls (0%/100%)** 0 N/A N/A 0 71124.03 In-Plant Airborne Radioactivity Control and Mitigation 16 +/- 4 (biennial) 3 4 4 (0%/100%)
71124.04 Occupational Dose Assessment (0%/100%) 20 +/- 4 (biennial) 4 4 4 71124.05 Radiation Monitoring Instrumentation (20%/80%) 32 +/- 4 (biennial) 2 2 15 71124.06 Radioactive Gaseous and Liquid Effluent Treatment 35 +/- 4 (triennial) 5 5 11 (100%/0%)
71124.07 Radiological Environmental Monitoring Program 29 +/- 4 (triennial) 2 3 3 (100%/0%)
71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage and Transportation 34 +/- 4 (biennial) 5 5 8 (80%/20%)
- PRS = Public Radiation Safety Cornerstone; ORS = Occupational Radiation Safety Cornerstone
- Staff has proposed retiring this procedure (with transfer of some of its contents) as part of the ROP Enhancement effort 17
Looking Forward
- IP 71124 Procedure Revision
- Commission Notification (October 2019)
- Final Procedures Published (December 2019)
- ROP Enhancement SECY (June 2019)
- Currently under consideration by Commission 18
Discussion/Feedback 19
Questions/Comments?
Micheal Smith, Health Physicist NRR/DRA/ARCB micheal.smith@nrc.gov (301) 415 - 3673 David Garmon, Health Physicist NRR/DRA/ARCB david.garmon@nrc.gov (301) 415 - 3512 20
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