ML20195H676

Draft NRC Insp Manual,Inspection Procedure 71122, Public Radiation Safety

ML20195H676
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Issue date:	04/21/1999
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References
71122, NUDOCS 9906170111
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PUBRAD.WPD NRC INSPECTION MANUAL eieB INSPECTION PROCEDURE 71122 PUBLIC RADIATION SAFETY 71122-01 INSPECTION OBJECTIVE 01.01 The objective of this procedure is to gather information to determine whether a licensee is meeting the objectives of this comerstone which are to ensure adequate protection of public health and safety from exposure to radioactive material released into the public domain as result of routine civilian nuclear reactor operations.

71122-02 INSPECTION REQUIREMENTS 02.01 Baseline inspection requirements are identified in each of the attached inspectable areas of:  !

Gaseous and Liquid Effluent Treatment Systems (Attachment 01) )

Radioactive material Processing and Shipping (Attachment 02) 4 Radiological Environmental Monitoring Program (Attachment 03) l Problem Identification and Resolution (included as part of each inspectable area) 02.02 These requirements represent the minimum inspection activity to be conducted at each reactor site at the frequencies shown in each inspectable area. l 02.03 The effectiveness of each licensee to identify and resolve problems in this comerstone area will also be inspected biannualy using the baseline inspection program procedure for evaluating licensee Problem identification and Resolution programs.

71122-03 INSPECTION GUIDANCE 03.01 The Performance Indicator in this comerstone monitors for inaccurate or increasing projected offsite doses. The Performance Indicator does not evaluate the performance of the Radiological Environmental Monitoring or transportation programs.

71122-04 INSPECTION RESOURCES 04.01 Estimates of inspection resources are identified within each inspectable area.

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ATTACHMENT 01 1

INSPECTABLE AREA: GASEGUS AND LIQUID EFFLUENT TREATMENT SYSTEMS CORNERSTONE: Public Radiation Safety INSPECTION BASES: This inspectable area verifies aspects of the Public Radiation Safety comerstone not measured by performance indicators. In Public Radiation Safety, the effluent release occurrence performance indicator measures radioactive gaseous and liquid releases that were above Technical Specification or Offsite Dose Calculation Manual limits. Radiation exposure to the public is to be below the 10 CFR 20 and 40 CFR Part 190 limits. Doses below the design objectives of Appendix 1 to 10 CFR Part 50 and 40 CFR Part 190 are ,

considered ALARA. Proper operation of the effluent treatment I system and monitors will ensure an adequate " defense-in-depth" against an unmonitored, unanticipated release of radioactivity to the  ;

environment.

l LEVEL OF EFFORT: Inspect biennially l (Estimated Hours - 30) )

l -01 INSPECTION OBJECTIVES 1

l 01.01 To ensure that the gaseous and liquid effluent processing systems are maintained so that radiological releases are properly mitigated, monitored and evaluated with respect to public exposure. Performance requirements are found in General Design Criteria 60,63 and 64 of Appendix A to 10 CFR Part 50, Radiological Effluent Technical Specifications (RETS) and the Offsite Dose Calculation Manual (ODCM).

01.02 Abnormal gaseous or liquid releases and conditions when effluent radiation monitors were out of service are conditions to be inspected in the baseline inspection program.

A PI was established to determine that releases were acceptable. In addition, effluent sample analysis Quality Control should be verified by the baseline inspection program.

-02 INSPECTION REQUIREMENTS 02.01 Insoection Plannina

a. Review the most current Annual Radiological Effluent Release Report to verify that the program was implemented as described in RETS/ODCM. Review for significance l changes in the ODCM in radwaste system design and operation. Determine whether the changes to the ODCM were made in accordance with Regulatory Guide 1.109.

Determine whether the modifications made to radwaste system design and operation increased the dose consequence to the public. Were 10CFR50.59 reviews performed when required? Have radwaste effluent radiation monitor setpoints or release concentrations increased since completion of the modifications?

b. Determine if anomalous results reported in the current Radiological Effluent Release Report were adequately resolved.

c. Review RETS/ODCM to identify the effluent radiation and flow rate monitors. Review the any effluent radiological occurrence performance indicator incidents for onsite followup. Review licensee self assessments, audits and licensee event reports that could result in unanticipated offsite releases of radioactive material.

d. Review the FSAR description of all radioactive waste systems.

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.02.02 Onsite insoection

a. Walkdown the gaseous and liquid release systems (including monitors) to observe current system configuration with respect to the FSAR, ongoing activities, and equipment material condition,

b. Observe the routine processing and release of several batches of liquid radioactive waste to determine whether appropriate treatment equipment is used and that liquid waste is processed and released in accordance with procedure requirements.

c. When possible, observe the routine processing of a batch of radioactive gases to determine appropriate treatment equipment is used and the radioactive gas is processed and released in accordance with ODCM/RETS procedure requirements.

d. Review about 5 examples of abnormal releases or releases made with inoperable monitors. Review licensee treatment of these releases to ensure an adequate defense-in-depth was maintained against an unmonitored, unanticipated release of radioactivity to the environment. For example, was appropriate compensatory sampling and radiological analyses conducted at the ODCM or RETS required frequency when effluent monitors were declared out-of-service for extended periods of time?

e. Review any significant changes made by the licensee to the ODCM as well as to the liquid or gaseous radwaste system design, procedures, or operation since the last inspection. For each system modification that impacted effluent monitoring or release controls, determine whether processing equipment changes could result in increasing the amount of radioactMty released to the environment and whether changes made to monitoring instrumentation resulted in a non-representative monitoring of effluents as a result. For significant changes (factor of 2) to dose values reported in the Annual Radiological Effluent Release Report, independently assess the licensee's offsite dose calculations utilizing the NRC PC-DOSE computer code or equivalent method.

Agreement should be within a factor of 2.

f Review each effluent release PI to determine if any quarterly RETS (or ODCM) limits were exceeded or if any 10CFR50 Appendix I levels were exceeded.

g. Review ventilation system surveillance test results to ensure that system flows remain consistent with ODCM/RETS or FSAR values. Ventilation flow rates may affect certain ODCM and EP dose calculations.

h. Review calibration records developed since the last inspection for each effluent radiation and flow rate monitor. Review each effluent radiation monitor current alarm setpoint value and system modifications made since the last inspection with respect to ODCM or RETS requirements.

i. Inspect calibration records of counting room laboratory instrumentation associated with effluent monitoring and release activities. Review quality control charts for maintaining counting room instrument status and actions taken for degrading detector performance.

J. Review licensees interlaboratory comparison results to verify the quality of effluent l sample analyses performed by the licensee. Review licensee's quality control evaluation of the interlaboratory comparison tost and associated corrective actions for any deficiencies identified. If applicable, determine the extent of the identified bias and evaluate the overall effect on licensee dose projections.  ;

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02.03 Identification and Resolution of Problems .

a. Review licensee self assessments, audits, Licensee Event Reports, and Special l Reports with respect to the effluent release program since the last inspection.

l Determine if identified problems are entered into the corrective action program for resolution. 1

b. Review Problem Reports affecting effluent sampling, sample analysis, or effluent ,

radiation monitoring instrumentation. Review incidents involving potential or unmonitored release paths (e.g., piping tunnels, roll up doors, spills to storm drains).

l Interview staff and review documents to determine if the following activities are being conducted in an effective and timely manner commensurate with their importance to safety and risk:

1. Initial problem identification, characterization, and tracking.

l 2. Disposition of operability /reportability issues.

l 3. Evaluation of safety significance / risk and priority for resolution.

4. Identification of repetitive problems.

' S. Identification of contributing causes. j

6. Identification and implementation of corrective actions which will achieve lasting 4 l results. I

7. Resolution of non-cited violations (NCVs) tracked in corrective action system (s). i

8. Implementation / consideration of risk significant operational experience feedback.

Emphasis should be placed on ensuring problems are identified, characterized, J prioritized, entered into a corrective action, and resolved. j

c. For repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified above, determine if the licensee's self-assessment activities are also identifying and addressing these deficiencies. j l

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V ATTACHMENT O2 INSPECTABLE AREA: Radioactive Material Processing and Shipping CORNERSTONE: Public Exposure l INSPECTION BASIS: This inspectable area verifies manarda of the Public Exposure comerstone for which there are no indicators to measure performance. To guard against unplanned public exposure during transportation of radioactive material. Although there is a low frequency of industry events, the actual exposure consequence to g the public is potentially high. In addition, the program that prevents '

the unrestricted release of contaminated material will be verified to limit exposures to the public.

LEVEL OF EFFORT: Inspect Biennially (Estimated Hours - 40)

-01 INSPECTION OBJECTIVES 01.01 This inspection will verify that the radioactive material processirs and shipping program complies with the requirements of 10CFR Parts 20 and 71 and DOT regulations 49CFR Parts 170-189. Radioactive material intended for burial must also comply with 10CFR61.55 - 61.57 waste classification, stability, and marking requirements.

01.02 A minimum of .5 significant radioactive material shipments (greater than excepted-package shipments) should be reviewed to include actual observation of at least 1 such shipment and at least 1 radioactive material processing actuty (e.g., resin liner dowatering, waste packaging, waste sorting). Radioactive material survey methods will be reviewed as well as detection sensitivity levels with respect to the Final Rule on

- Radiological Criteria for License Termination, Nov 1998 (63FR222ps 64132-64134).

INSPECTION REQUIREMENTS:

i 02.01 Insoection plannino 4

When possible, coordinate the inspection schedule with the licensee to coincide with a Type B shipment or other non-excepted package shipments. Review the solid radwaste system description in the FSAR.

02.02 ~ Radwaste system walk down Walk down the liquid-to-solid radwaste processing systems with respect to the FSAR 4 and process control program.

a. Take note of any abandoned equipment and ensure all such vessels are drained and isolated from operating systems.  ;

b. Determine if current liquid radwaste processing configuration and operations are consistent with the FSAR. .

c. Review current processes for transferring radwaste resin and sludge discharges into

• shipping / disposal containers to determine if appropriate waste stream mixing and/or -

sampling procedures provide representative samples of the waste product for the purposes of waste classification as specified in 10CFR61.55 for waste disposal.

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02.03 Waste characterization and classification Review each radioactive waste stream for current radio-chemical sample analysis results. Review licensee's use of scaling factors and calculations used to account for difficult-to-measure radionuclides. Review the dry active waste (DAW) radio-chemical sample analysis results against the basis for contamination monitoring instrumentation utilized for the unrestricted release of materials (Section 02.07).

02.04 Shioment orecaration

a. Obsewe shipment packaging, surveying, labeling, marking, placarding, vehicle checks, emergency instructions, disposal manifest, shipping papers provided to the driver, and licensee verification of shipment readiness. Ensure requirements of any applicable transport cask ~ Certificate of Compliance have been met. Ensure the receiving licensee is authorized to receive the shipment packages.

b. Observe radiation workers during the conduct of radwaste processing and radioactive material shipment preparation activities. Determine if the shippers are knowledgeable of the shipping regulations and whether shipping personnel demonstrate adequate skills to accomplish the package preparation requirements for public transport with respect to Bulletin 79-19 and 49CFR172 Subpart H.

02.05 Shippina Records Sample at least 5 previously unreviewed non-excepted package shipment (LSA 1,11, lil, SCO 1,11, Type A, or Type B) records. Review these records with respect to NRC and DOT requirements.

02.06 Unrestricted release of material from the Radioloaically Controlled Area (RCA)

a. Observe several locations where the licensee monitors material leaving the RCA and inspect the methods used for control, survey, and release from these areas. When possible, observe the performance of qualified personnel surveying and releasing material for unrestricted use. Determine if the contamination monitoring instrumentation is appropriate for the radiation types present (reference DAW radio-chemical analysis results) and were calibrated with appropriate sources at appropriate energy levels.

b. Determine the criteria used for unrestricted release and ensure the detection sensitivity of contamination monitoring instruments is maximized and meets the levels indicated in the following table (derived from the Final Rule on Radiological Criteria for License Termination, Nov 1998 (63FR222ps 64132-64134)). The values in this table represent surface contamination concentrations that represent 25 mrem / year TEDE (based on conservative assumptions). Although the regulations prohibit the uncontrolled release .

of any licensed material, lower levels than those found in the table would not be considered dose-significant. Higher detection sensitivities than indicated in the table may represent a significant potential to release contaminated material resulting in significant dose to the public and may result in a significant inspection finding.

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Radionuciufe Acceptable screenina level for Unrestricted release (dom /100 cm8)

Hydrogen-3 (tritium) 1.2E+08 Carbon-14 3.7E+06 Sodium-22 9.5E+03

' Sulfur-35 1.3E+07 Chlorine-36 5.0E+05 Manganese-54 3.2E+04 Iron-55 4.5E+06 Cobalt-60 7.1 E+03 Nickel 1.8E+06 Strontium-90 8.7E+03 Technetium-99 1.3E+06  ;

lodine-129 3.5E+04 ,

Cesium-137 2.8E+04 Iridium-192 7.4E+04 ]

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Any detectable alpha above MDA may be dose-significant and will have to be l evaluated on a site-specific basis. Other radionuclides that are not listed in the table ]

may be evaluated separately (contact NMSS, Low-Level Waste and Decommissioning j Projects Branch). For multiple radionuclides, use of the sum-of-the-fractions rule is )

appropriate. The above values should be used as a screening tool.

02.07 Identification and Resolution of Prebiems

a. Problem identification and resolution. Review audits and self-assessrnents for the radwaste transportation program since the last inspection. Determine if identified problems are entered into the corrective action program for resolution.

b. Review transportation and release of radioactive material corrective action reports written since the previous inspection in this area. Interview staff and review documents to determine if the following activities are being conducted in an effective and timely manner commensurate with their importance to safety and risk:

1. Initial problem identification, characterization, and tracking.

2. Disposition of operability /reportability issues.

3. Evaluation of safety significance / risk and priority for resolution.

4. Identification of repetitive problems.

5. Identification of contributing causes.

6. Identification and implementation of corrective actions which will achieve lasting results. l

7. Resolution of non-cited violations (NCVs) tracked in corrective action system (s).

8. Implementation / consideration of risk significant operational experience feedba,ck.

Emphasis should be placed on ensuring problems are identified, characterized, prioritized, entered into a corrective action, and resolved.

c. For repetitive deficiencies or significant individual deficiencies in problem identification and resolution identified above, determine if the licensee's self-assessment activities are also identifying and addressing these deficiencies.

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-03 INSPECTION GUIDANCE 03.02 Radwaste system walk down if solid waste streams are not appropriately sampled, determine if variability is greater than a factor of 10. If so, would there be any previous waste disposal shipments that should have been designated at a higher waste classification?

03.03 Waste Characterization and Classification if scaling factors used are incorrect, determine if the error is greater than a factor of 10.

If so, what affect would this have on waste classification? Identify any waste disposal shipments that were misclassified.

03.04 Shioment preparation if discrepancies were noted, identify them to the licensee for correction. If safety i' significant, discuss with regional management to determine if correction to the shipment is needed before the shipment leaves site. Ensure the licensee incorporates the discrepancies in the corrective action program as appropriate.

03.05 Shiooina Records if improper shipping records or shipment violations were reported by a consignee, determine what was the exposure consequence to the public (based on dose rates or contamination levels above DOT limits).

03.06 Unrestricted release of material from the Radioloaically Controlled Area (RCA)

If detection capability is deficient, based on actual plant radionuclide mixture, determine potential or actual radioactivity released. Determine dose consequence (licensee or NRC (Resrad, DandD)). If greater than 5 mrem /yr it may result in a significant finding.

Incidents involving the release of contaminated material should be investigated by the licensee and documented in the problem identification and resolution program. The investigation should include a specific exposure pathway analysis and a dose estimate.

Incidents resulting in >5 mrem / year should be documented as a significant inspection finding.

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- ATTACHMENT 03 INSPECTABLE AREA: RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM (REMP)

CORNERSTONE: Public Exposure INSPECTION BASES: This inspectable area verifies aspects of the Public Exposure comerstone for which there are no indicators to measure performance. The REMP supplements the effluent monitoring program by verifying that the measurable concentrations of radioactive materials and levels of radiation in the environment are as predicted by the effluent measurements and modeling of effluent pathways.

LEVEL OF EFFORT: Inspect biennially (Estimated Hours - 10)

-01 INSPECTION OBJECTIVES 01.01 To ensure that the REMP reasonably measures the effects of radioactive releases to the environment and sufficiently validates the integrity of the gaseous and liquid effluent release program.

01.02 To verify that the REMP is implemented consistent with the licensee's technical specifications (TS) to validate that the effluent release program meets the dose limits of Appendix i to 10CFR50.

7 INSPECTION REQUIREMENTS 02.01 Inspection Plannina  !

a. Review the most current Annual Environmental Monitoring Report and licensee j assessment results to verify that the REMP was implemented as required by TS and the 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, and analysis of data.

b. Review the ODCM to identify environmental monitoring stations. Review licensee self assessments, audits, licensee event reports, and interlaboratory comparison program results.

c. Review FSAR for information regarding the environmental monitoring program and meteorological monitoring instrumentation. I 02.02 Onsite Inspection  ;

a. Walkdown about 5 air sampling and 5 TLD monitoring stations to determine if they are located as described in the ODCM and to determine the equipment material condition. )

b. Observe the collection and preparation of a variety of samples (e.g., liquid, milk, vegetation, sediment, and soil). Verify that environmental sampling is representative of the release pathways as specified in the ODCM and that sampling techniques utilized I are in accordance with procedures.  !

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c. Based on dir:ct observation end r:vi:w of r: cords, dat:rmins il tha control room end I r: mots tow r m:trorologicalinstrum:nts cro operabia, calibrat:d cnd maintain:d with respect to FSAR, Regulatory Guide 1.23, and licensee procedures.

d. Review the cause and corrective actions taken for each event documented in the l Annual Environmental Monitoring Report involving a missed sample, inoperable sampler, lost TLD, or anomalous measurement. Conduct a thorough review for any positive sample results (above background) and compare with applicable effluent releases,

e. Review offsite dose calculations (dose to the public). Where appropriate, perform independent calculations to verify the doses are valid.

f. Review any significant changes made by the licensee to the ODCM as the result of I changes to the land census or sampler station modifications since the last inspection.

g. Review the calibration and maintenance records for about 5 samplers.

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h. Review calibration records for the environmental sample laboratory counting instrumentation. Ensure appropriate detection sensitivities with respect to RETS/ODCM are utilized for counting samples. Review quality control charts for 1 maintaining counting room instrument status and actions taken for degrading detector performance. .

i. Review licensees' interlaboratory comparison results to verify the adequacy of environmental sample analyses performed by the licensee. Review licensee's quality control evaluation of the interlaboratory comparison test and associated corrective actions for any deficiencies identified. If applicable, determine the extent of the identified bias and evaluate the overall effect on licensee dose projections.

2.03 Identification and Resolution of Problems

a. Review licensee self assessments, audits, Licensee Event Reports, and Special Reports with respect to the environmental monitoring program since the last inspection. Determine if identified problems were entered into the corrective action program for resolution.

b. Review problem reports affecting environmental sampling, sample analysis, or meteorological monitoring instrumentation. Interview staff and review documents to determine if the following activities are being conducted in an effective and timely manner commensurate with their importance to safety and risk:

1. Initial problem identification, characterization, and tracking.

2. Disposition of operability /reportability issues.

3. Evaluation of safety significance / risk and priority for resolution. .

4. Identification of repetitive problems.

5. Identification of contributing causes.

6. Identification and implementation of corrective actions which will achieve lasting results.

7. Resolution of non-cited violations (NCVs) tracked in corrective action system (c).

8. Implementation / consideration of risk significant operational experience feedback.

Emphasis should be placed on ensuring problems are identified, characterized, prioritized, entered into a corrective action, and resolved.

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l c. For repetitiva defici:nci:s or significant individu;.1 d:ficienci:s in probl:m id:ntification and resolution identified above, determine if the licensee's self-assessment activities are also identifying and addressing these deficiencies.

-03 lNSPECTION GUIDANCE ,

03.02 Onsite insoecti90 if there are any positive sample results (i.e., above background), this may indicate an environmental impact from plant operations and should be investigated thoroughly.

Determine if there was a redundant sample taken to verify the positive results. Ensure measurement analytical procedures were properly conducted. If we verify that the sample results are positive, involve regional management and the licensee in continued review. Other areas to review include historical environmental data to detect l l any trends that may indicate a time period and pathway of concem. Based on this l review, investigate the corresponding effluent release data for corroboration or '

explanation.

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