ML19339H351
| ML19339H351 | |
| Person / Time | |
|---|---|
| Issue date: | 12/05/2019 |
| From: | Garmon D, Matthew Smith NRC/NRR/DRA/ARCB |
| To: | |
| References | |
| Download: ML19339H351 (32) | |
Text
Updates to Radiation Safety Cornerstones David Garmon, Health Physicist Micheal Smith, Health Physicist NRR/DRA/ARCB December 18, 2019 ML19339H351
Agenda
- Background
- Reactor Oversight Process
- Inspections
- Changes to Radiation Safety Cornerstones
- Changes to ALARA Inspections
- Changes to Radiological Effluents and Environmental Monitoring Inspections
- Implementation of Inspection Guidance Applicable to 10 CFR Part 37
- Part 37 Background
- Overview of Inspection Guidance
- More-than-Minor Screening Examples
- SDP Revisions
- Looking Forward to 2020 2
Why Change?
- Part of continuous self-assessment process Independence that is fundamental to the ROP
- ROP Enhancement provided excellent Clarity opportunity for program improvement
- Apply lessons from regulatory and Openness operating experience
- Maintain focus on those issues having the Reliability most impact on public health and safety Efficiency Staff Actions are Guided by the Principles of Good Regulation 3
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Background===
4
5 What is an NRC Inspection?
- Examination of the licensees activities to assist in determining
- Whether the licensee is meeting the cornerstone objectives, and
- If further engagement by the NRC is necessary before the objectives of the cornerstones are compromised
- Trained and qualified inspectors
- Review key licensee documentation
- Observe licensee activities
- Evaluate licensee actions An NRC inspector observes a licensee technician during an environmental monitoring inspection Inspection is a Key Input in Verifying Reasonable Assurance of Adequate Protection of Public Health and Safety 6
Inspection Finding Process Start End Interactions with Licensee
__ = Changes introduced or being introduced in the near future 7
More-than-Minor Screening
- Allows NRC to direct minor issues to the licensee for resolution
- Licensee addresses issues in a prioritized manner using NRC-inspected corrective action programs
- Process:
Minor (Address with CAP)
No Screening Yes Yes Inspection Finding Performance Criteria (use SDP)
Deficiency (>Minor?)
Key Point - All Violations of NRC Requirements Must be Corrected 8
Significance Determination
- Process used to determine the significance of the inspection finding
- Yields a color input for consideration during overall performance assessment Red Significance Inspection Yellow Determination Finding Process White Green 9
Changes within Radiation Safety Cornerstones 10
Summary of Changes - Updates to Inspection Manual
- Inspection Procedures
- 1. Recommended retiring ALARA inspections*
- 2. Changed frequency of radioactive effluents and environmental monitoring inspections from biennial to triennial
- 3. Added guidance on how to inspect new requirements for the protection of radioactive material
- Inspection Manual Chapters
- 1. Clarified more-than-minor screening guidance and added examples
- 2. Near-future: will update significance determination process documents
- Pending Commission approval, per SECY-19-0067 11
Changes to ALARA Inspections (Pending Commission Approval)
- Persistent downward trend in dose per reactor
- Low safety significance associated with findings
- Staff observation that baseline inspections in the ALARA area can be reduced from a risk-informed, performance based perspective
- Discussed in detail during February 28, 2019 public meeting (ML19046A069)
Retiring ALARA-Focused Inspections and Continuing Oversight using Already Existing Inspections of Plant Work 12
Changes to Radiological Effluent and Environmental Monitoring Inspections*
- Considerations
- Nuclear power plant effluents contribute negligibly to public dose
- Since the advent of the ROP, nuclear power plant effluents have decreased or remained at very low levels
- 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
- Changing the frequency of inspection from biennial to triennial
- Inspection of effluent monitoring instrumentation will remain at biennial frequency Scope of Effluent and Environmental Monitoring Inspections is Unchanged
- Discussed in detail during July 23, 2019 public meeting (ML19189A035) 13
Part 37 Oversight Framework for Power Reactor Licensees 14
Background for 10 CFR Part 37
- Provides requirements for physical protection of category 1 or category 2 quantities of radioactive material (i.e. Part 37 material)
- Specific guidance applicable to power reactors
- Radioactive materials are categorized based on risk
- Initial reactor inspections completed in January 2018
- Inspections revealed no risk-significant safety or security issues associated with licensee implementation of programs
- Staff has concluded that implementation of the requirements of Part 37 at reactors is adequate Radioactive Material is Secure at U.S. Nuclear Power Plants 15
16 Considerations in Developing Part 37 Oversight Framework
- 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
- Appropriately risk-informing inspection and significance determination
- Accounting for specifics of power plant materials, for example:
- Physical form of material
- Risk mitigation from Part 73 features in OCA Risk Communications to Stakeholders Should be Consistent with Current Reactor SDP 17
Selection of Public Radiation Safety Cornerstone
- Two options considered
- Physical Security
- Focuses on protection of special nuclear material
- Significant changes to cornerstone required
- Concerned with protecting the public health from exposures to radioactive material that result from routine reactor operations
- The impact of deficiencies in licensee performance fall within the cornerstone description (i.e., potential impact to public through exposures)
- Material control is already part of the public radiation safety cornerstone
- Already existing material security requirements stemming from 10 CFR Part 20
- Health physics inspectors are most qualified to identify material 18
IP 71124.08 Revision Part 37 Inspection Guidance (Material Security)
- Inspection guidance* includes:
- Consideration of category 1 and 2 material during inspections
- Consideration of events where unauthorized personnel are granted unescorted access to category 1 and 2
- Training of personnel who have Part 37 responsibilities
- Review of licensees annual access control program review for certain deficiencies occurring outside of the security protected area
- Review of licensees annual security program review for certain deficiencies occurring outside of the security protected area
- Inspection issues that potentially impact Part 73 security plan will be turned over and dispositioned by NRC security inspectors Risk-Informed, Performance-Based Approach Includes Inspection of Selected Areas
- Discussed during July 23, 2019 public meeting (ML19189A035) and July 29, 2019 industry conference (ML19207A112) 19
IP 71124.08 Revision Part 37 Inspection Guidance (Transportation)
- Inspection guidance* includes:
- Observations of actual shipment preparation when possible
- Review of shipping preplanning and coordination
- Different requirements for category 1 and category 2 materials
- Consideration of license verification requirements prior to shipping material An NRC inspector verifies radiation levels from a radioactive material shipment being prepared for transport Risk-Informed, Performance-Based Approach Includes Inspection of Selected Areas
- Discussed during July 23, 2019 public meeting (ML19189A035) and July 29, 2019 industry conference (ML19207A112) 20
More-Than-Minor (MTM) Screening Guidance
- The screening process involves consideration of several factors (i.e., screening questions) to determine if a performance deficiency is more-than-minor
- The revision to the guidance
- Clarifies how examples relate to the screening questions
- Adds examples based on stakeholder feedback
- For example, allows conservative use of alarming dosimeters to be considered during screening
- Adds a section to address performance deficiencies concerning Part 37 21
Significance Determination Process Updates 22
SDP - Radiation Protection Cornerstones
- Two SDPs
- Occupational Radiation Safety SDP
- An SDP is a risk-informed process for determining safety significance of inspection findings
- Objectives of an SDP
- Characterize significance using best available risk insights
- Provide an objective and common framework for communicating significance
- Provide basis for timely assessment and enforcement
- Used to risk-inform the inspection program NRC uses SDPs to Communicate Risk to Stakeholders 23
SDP - Updates Needed
- Administrative updates to reflect current program
- Administrative updates to reflect current program
- Transportation SDP does not address the possibility of incorrect packaging being used for radioactive material shipments
- Assumption that correct packaging is used and then a performance deficiency occurs
- Leads to undesired reliance on IMC 0609 Appendix M (Qualitative Criteria) to determine significance
- Update to address issues pertaining Part 37-related inspection findings 24
Notional SDP Thresholds for Part 37 Category 1 material Red Finding Category 2 material Yellow Finding Performance Deficiency Contributes to Actual Theft and Diversion Event Not establishing, or maintaining required program elements in effect, and other risk-significant issues (e.g., White Finding significant failure to protect mobile material)
Deficiencies in implementation of required program elements Green Finding
- - - Actual Green/White threshold to be developed with stakeholder input in CY2020 25
Process for Updating SDP
- Described in IMC 0609
- Similar to the original development of the SDP
- Input considered from multiple stakeholders
- NRC Staff
- Public
- Licensees
- Participation will be primarily through internal workshops, public meeting(s) and letters
- Leverage ROP Monthly meeting for efficiency 26
Looking Forward to 2020
- Inform Commission of changes to radiological effluents, environmental monitoring and Part 37 inspections
- Inspection procedure attachments 01 - 04
- Publish in early Jan 2020
- Inspection procedure attachments 05 - 08
- Publish 14 days after Commission notification (per MD 8.13)
- More-than-Minor Guidance
- Publish in early January 2020
- Provide inspector training on Part 37 inspections
- Start dialog during February ROP Monthly
- Goal to publish by summer 2020 27
Questions/Comments?
David Garmon, Health Physicist NRR/DRA/ARCB david.garmon@nrc.gov (301) 415 - 3512 Micheal Smith, Health Physicist NRR/DRA/ARCB micheal.smith@nrc.gov (301) 415 - 3763 28
References
- IP 71124, Radiation SafetyPublic and Occupational
- IP 71124.01, Radiological Hazard Assessment and Exposure Controls
- IP 71124.02, Occupational ALARA Planning and Controls
- IP 71124.03, In-Plant Airborne Radioactivity Control and Mitigation
- IP 71124.04, Occupational Dose Assessment
- IP 71124.05, Radiation Monitoring Instrumentation
- IP 71124.06, Radioactive Gaseous and Liquid Effluent Treatment
- IP 71124.07, Radiological Environmental Monitoring Program
- IP 71124.08, Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation
- IMC 0308 Attachment 3, Appendix C, Technical Basis for Occupational Radiation Safety Significance Determination Process
- IMC 0308 Attachment 3, Appendix D, Technical Basis for Public Radiation Safety Significance Determination Process
- IMC 0612 Appendix E, Examples of Minor Issues 29
31 Part 37 Material 32