ML19207A112

2019 NEI RP Forum NRC Presentation

ML19207A112
Person / Time
Issue date:	07/29/2019
From:	David Garmon-Candelaria, Kevin Hsueh NRC/NRR/DRA/ARCB
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Download: ML19207A112 (50)

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Update on NRR Radiation Protection Activities - Overview (ML19207A112)

Kevin Hsueh, Chief Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation 2019 NEI Radiation Protection Forum July 29, 2019 Memphis, TN 1

Radiation Protection & Consequence (RP&C) Branch Responsibilities

• NRR program office for radiation protection and radiological consequence assessment

• Guidance development and technical reviews of licensing applications

• NRR Reactor Oversight Process (ROP) implementation for occupational & public radiation safety cornerstones 2 2

NRC Regional Staff Present

• RI Harry Anagnostopoulos Sr. Health Physicist

• R II Bob Kellner Sr. Health Physicist

• R II Bill Pursley Health Physicist

• R III Steve Orth Acting Deputy Division Director

• R III John Cassidy Sr. Health Physicist

• R IV Bernadette Baca Health Physicist 3

Line of Management NRC Executive Director for Operations: Margaret Doane NRR Director: Ho Nieh Division of Risk Assessment Director: Mike Franovich Radiation Protection & Consequence Branch Chief: Kevin Hsueh 4 5

NRR/NRO Merger

• Merger will start in October 2019

• RP&C branch will expand its responsibility to include new reactor related licensing activities

• Ongoing cooperation and interaction with RP&C staff in NRO to ensure smooth transition 5

ROP Enhancement Initiative

• Better riskinform and performancebase the ROP

• Improve efficiency and effectiveness

• Timeline (2019)

Enhancement team formed (Jan)

Outreached to stakeholders & developed Commission (SECY) Paper (Feb May)

SECY190067 issued (June) 6 7

Inspection Procedure (IP) Update

• Periodic update of the radiation safety IP

• Timeline (2019)

IP update effort initiated (May)

Outreached to stakeholders & develop revised draft IP (May September)

Commission notification (~October)

IP revised (December) 7

ROP Related Documents Development & Update

• Screening guidance and examples of minor issues (IMC 0612, Appendixes B & E)

• Public Radiation Safety Significance Determination Process (IMC 0609, Appendix D)

• Health Physics Positions (HPPOS) (IMC 0303) Issued in July 2019 8

AccidentRange Effluent Monitors

• Accidentrange gaseous effluent monitors installed after TMI

• Share information on calibration of accidentrange gaseous effluent monitors

• Plan to revise RG 1.21 to include acceptable calibration methods 9

Regulatory Guide Updates

• Final RGs issued in 2019

- RG 1.8 on Qualification & Training of Personnel, Rev 4

- RG 4.13 on Environmental Dosimetry, Rev 2

• Draft RGs to be issued for comment in 2020

- RG 8.34 on Monitoring Criteria to Calculate Radiation Doses, draft Rev 1

- RG 1.21 on Measuring, Evaluating and Reporting Effluents and Solid Waste, draft rev 3 10

Ongoing Rulemaking Activities

• Power Reactor Decommissioning

• Part 37 Revision 11

Focus Areas Actions Ongoing

• Use Risk Insights to Focus Resources

• Knowledge Management

• Continuous Improvements/Open to Feedback 12

Update on NRR Radiation Protection Activities -

Selected Topics #1 Micheal Smith Health Physicist Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation NEI Radiation Protection Forum July 29, 2019 Memphis, TN 13

Outline

• Inspection Procedure (IP) Update Process

• IP Update Snapshot

• Procedure Formatting

• Schedule Looking Forward 14

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 Reliability

• Finalize IPs

• Train staff, as necessary Efficiency

• Issue final IPs 15

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 16

Updated Requirement Language Example IP 71124.08 Rad Waste System Walkdown 17

Looking Forward

• Revised procedures will look very different from current procedure

- Narrow requirement statements instead of broad samples with multiple line items

- More samples associated with certain requirements (e.g., instrumentation)

- Formatting changes do not impact inspection scope or effort

• Schedule

- Commission Notification (~October 2019)

- Final Procedures Published (December 2019) 18

Update on NRR Radiation Protection Activities -

Selected Topics #2 David Garmon Health Physicist Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation NEI Radiation Protection Forum July 29, 2019 Memphis, TN 19

Outline

• Reactor Oversight Process

- ROP Enhancement

- Other ROP Initiatives

• Health Physics Positions

• Regulatory Guide (RG) 1.8

• Part 37

• Operating Experience 20

ROP Enhancement

• Programwide effort to improve efficiency and effectiveness of reactor oversight

- Phase 1 (nearterm) proposal to Commission via SECY190067

- Phase 2 (midtolong term) currently being addressed through IP update

- Key industry input

• Review inspection program in light of industry performance

• Focus areas: ALARA, instrumentation and effluents and environmental monitoring

• Commission involvement

- Approval of Phase 1 items

- Notification of Phase 2 items (subject to change) 21

Other ROP Initiatives

• Updating guidance inspectors use to Performance Deficiency (i.e preventable failure to IMC 0612 - Issue Screening (Morethan determine if a performance deficiency meet requirement or standard)

Minor questions and examples) becomes an inspection finding (IMC 0612, Apps B and E)

• Revising Public Radiation Safety SDP (IMC Minor Violation (must be documented in CAP Morethanminor =

0609, App D) and corrected in INSPECTION FINDING prioritized manner)

- More comprehensively address transportation findings

- Clarify how to disposition significant REMP Significance Color of Finding (Green, Determination Process findings (SDP)

White, Yellow or Red)

- Add process to disposition Part 37 findings 22

Health Physics Positions (HPPOS)

• Program reinstituted through Inspection Manual Chapter 0303 (ML18344A103)

• HPPOS are summaries and clarifications of NRC positions, policies and requirements applicable to radiation protection

• Purpose

- Knowledge management

- Facilitate efficiency and consistency

• Cannot be used to establish NRC positions (other programs exist for that purpose)

• How do HPPOS relate to other NRC documents? Risk Informed NRC provides oversight to requirements as described in plant licensing basis 23

RG 1.8

• RPM is part of onsite staff

• Person responsible for implementation of the RP program that is required by Part 20

• Time on site

- No prior experience as RPM = 6 months

- Prior experience = Up to licensee

• Experience supervising RP ops

• Temporary fills not to exceed 1 year

• HPPOS019 position revised to define one year of experience as 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> of work with no expectation of minimum time to accrue 24

Part 37

• Limited inspection as part of radioactive material and transportation inspection

• Focus on protection/control of the material

• Riskinformed: Focus on material stored outside the PA

• Transportation

• Developing morethanminor guidance and significant determination process

• Rulemaking update

- Included as part of the Integrated Source Security and Accountability Rulemaking

- Seeking approval to develop Regulatory Basis document

- Consideration of nonrulemaking solutions 25

Operating Experience

• HRA controlsrelated issues comprise the predominant contributor to RP findings

• Use of dated survey information for briefing radiation work

• Transitioning selected radiation monitors to runtofailure vice maintaining calibration per Part 20

• Spent fuel pool cleanup plans should be comprehensive

• Adequate control of complex work

• Knowledge management

• Supplemental RP tech management 26

Update on NRR Radiation Protection Activities -

Selected Topics #3 Steven Garry Sr. Health Physicist Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation NEI Radiation Protection Forum July 29, 2019 Memphis, TN 27

Outline

• Regulatory Commitments

• Regulatory Guides

• H3 in Oil

• AccidentRange Effluent Monitoring

• Very LLW Alternate Disposals

• Proposed Decomm Rulemaking 28

Regulatory Commitments

• Licensing basis commitments

- Commitment to Regulatory Guides

- Commitments to RGs may be listed in UFSARs

• Cited violations

- Cited violations - response letter to NRC

• NEI 9904 Managing Commitments

• SECY20000045, Acceptance of NEI 9904 29

RG 4.13 Environmental Dosimetry

• Rev. 2 has been issued, endorses ANSI/HPS N13.37

• Provides less stringent dosimeter performance criteria

• Provides an NRC approved method of determining facility related direct radiation dose

• Can be used in the demonstration of compliance with 10 CFR 20.1302 and 40 CFR 190 30

Environmental Dosimeter Performance Specifications

• Rev. 1 of RG 4.13

• Reproducibility criteria = +/- 3% on 10 dosimeters

• 25 mR spike @ 3% = 25 mR +/- 0.75 mrem (avg) acceptable range = 24.25 to 25.75 mrem

• Rev. 2 of RG 4.13

- Reproducibility criteria = +/- 7.5% on 10 dosimeters

- 25 mR spike @ 7.5% = 25 mR +/- 1.87 mrem (avg) acceptable range = 23.11 - 26.87 mrem 31

10 CFR 20.1301 and 10 CFR 20.1302

• 10 CFR 20.1301(e) EPAs 40 CFR 190 dose limit is 25 mrem whole body dose (not 100 mrem TEDE)

• 10 CFR 20.1302 Demonstrating compliance with public dose limits

- Specific requirement to perform surveys in controlled areas and unrestricted areas

- Surveys include the calculations of levels of radiation

- ANSI N13.37 provides acceptable data analysis method 32

Draft RG 8.34 Monitoring & Calculating Dose

• Issues under consideration:

- Revised TEDE definition and new term EDEX

- Prospective evaluations & the need to monitor

- Monitoring likely & unlikely exposures

- Assessing dose when dosimetry results are inconsistent with electronic dosimetry or surveys

• RG Periodic Reviews 33

H3 in Oil

• There are no free release criteria

• 10 CFR 20.1501 requires surveys reasonable under the circumstances

• No specific LLD is required

• 1984 petition (49 FR 36653) for rulemaking on disposal of waste oil

• 1992 new rule in 10 CFR 20.2004 that allows onsite incineration 34

AccidentRange Effluent Monitors

• Effluent monitors were initially calibrated to lowenergy gammas from Xe133 and Kr85 beta

• Source term - noble gas from core melt is a highenergy gamma mix

• Calibrations based only on lowenergy gammas from Xe 133 are not representative of a mix of highenergy gamma emissions from noble gases 35

AccidentRange Effluent Monitors (contd)

• NRC is reviewing information on existing calibration methods in NUREG0737 and HPPOS001

• NRC is considering simpler calibration methods consistent with current calibration methods

• Emergency classifications and protective actions are primarily based on plant conditions (temperatures, pressure & highrange containment monitor readings)

• Licensees should understand their current calibration methods & departmental ownership of effluent monitors 36

Very LLW Disposals

• 20.2002 Proposed Waste Disposal

• Regulatory Issue Summary 201611

- Requires NRC approval for power plants

- Agreement States have given some approvals

• NRC inspection identified a minor violation

• NRC is reevaluating the approval process 37

Proposed Decomm Rulemaking

• SECY18055 Proposed Decomm Rule

- Submitted to Commission May 7, 2018

- Aligns license requirements to lower levels of radiological risk

- Reduces need for license amendments and exemption requests 38

Proposed Decomm Rulemaking (contd)

Four levels of decommissioning:

1) permanent cessation of operations and removal of all fuel from the reactor vessel,

2) sufficient decay of fuel in the spent fuel pool such that it would not reach ignition temperature within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> under adiabatic heatup conditions,

3) transfer of all fuel to dry storage, and

4) removal of all fuel from the site.

39

Proposed Decomm Rulemaking (contd)

• Affected areas

- Drug and alcohol testing

- Cyber security

- Foreign ownership

- Emergency Preparedness

• 4 levels of emergency planning standards

• Gradual reduction of risk during decomm

- Physical security

- Certified fuel handler

- Use of decomm funds

- Environmental considerations reviews and reporting 40

Proposed Decomm Rulemaking (contd)

• Radiation Protection Aspects

- Proposed decomm rule does NOT directly affect radiation protection

- 10 CFR 20 remains unchanged

- Effluent & environmental monitoring programs can be reduced appropriately 41

Proposed Decomm Rulemaking (contd)

• Indirect Radiological Aspects

- Emergency Planning Reductions

- LLW Transportation

• 45 day receipt notifications (vs. 20 days) 42

Questions?

43

Backup Slides 44

1988 Decommissioning (Decomm) Rulemaking

• General criteria 53 FR 24051

- 50.75g record keeping

- Cost estimating formula

- Decomm within 60 years

- Submitting applications for license termination

- Supplements to the environmental report 45

1997 Decomm Rulemaking

• Radiological Criteria 62 FR 39058

• Radiological criteria for decomm

• 25 mrem/yr plus ALARA for unrestricted release

• 100 mrem/hr plus ALARA for restricted release with institutional controls

• Meet drinking water protection - EPA 40 CFR 141

• Minimization of contamination (for applicants) 46

2011 Decomm Rulemaking

• Decomm Planning Rule

- Operating facilities to minimize contamination into the site (10 CFR 20.1406(c))

- Requires subsurface (groundwater) surveys

- Report decommissioning costs estimates for decommissioning and spent fuel management

- RG 4.22 on Decomm Planning 47

New Proposed Decomm Rule

• Six power reactors shut down since 2012

• Twelve additional reactors may shut down between 20182025

• NRC has received requests for license amendments and regulatory exemptions

• NRC staff issued a Lessons Learned Report (ML16085A029)

• New rulemaking for shutdown reactors

• NRC staff has prepared a proposed rule 48

Proposed PostShutdown Emergency Plan (PSEP)

• Maintain the effectiveness of the emergency plan (EP)

- EP that meets of the requirements of App E to 10 CFR 50 and

- EP planning standards of Section 50.47(b)

- Allows changes to their EPs related to staffing, the Emergency Response Data System (ERDS), emergency action levels (EALs), annual dissemination of public information, evacuation time estimates (ETEs)

- Follow 10 CFR 50.54(q)(8) when making initial EP changes to comply with the requirements of 10 CFR 50.200(a)

- Licensees must submit these plan changes to the NRC at least 60 days prior to implementation per 10 CFR 50.4 49

Proposed Decomm Rule Related Regulatory Guides

• New RG - Emergency Planning for Decommissioning Nuclear Power Reactors (DG1346)

(ML17311B018)

• Draft RG 1.184, Rev. 2 Decommissioning of Nuclear Power Reactors (DG1347) (ML17347A794)

• Draft RG 1.159, Rev. 3 Assuring the Availability of Funds for Decommissioning Nuclear Reactors (DG1348) (ML17348B485)

• Draft RG 1.185, Rev. 2, Standard Format and Content for PostShutdown Decommissioning Activities Report (DG1349) (ML17353A727)

• NUREG0586, Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (2002) 50