ML20290A462
| ML20290A462 | |
| Person / Time | |
|---|---|
| Issue date: | 10/21/2020 |
| From: | Garmon D NRC/NRR/DRA/ARCB |
| To: | |
| David Garmon (301) 415-3512 | |
| References | |
| Download: ML20290A462 (18) | |
Text
Update to Radiation Safety Significance Determination Process October 21, 2020 David Garmon Health Physicist NRR/DRA/ARCB ADAMS Accession No. ML20290A462
Agenda
- Meeting preliminaries
- Principles of Good Regulation
- Background of Significance Determination Process (SDP)
- Why is this update required?
- Updates being considered
- Discussion
- Questions/Feedback 2
NRR Letter dated October 15, 2019: https://www.nrc.gov/docs/ML1926/ML19260E683 NRC Values: https://www.nrc.gov/about-nrc/values.html 3
Radiation Safety Cornerstones 4
5
Significance Determination Process
- How the NRC categorizes inspection findings
- Purposes
- Determine and Communicate Risk
- Guide inspection resources 6
Documents we will be discussing
- 3. IMC 0308, Attachment C - Technical Basis for Occupational Radiation Safety SDP
- 5. IMC 0308, Attachment D - Technical Basis for Public Radiation Safety SDP https://www.nrc.gov/reading-rm/doc-collections/insp-manual/manual-chapter/
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Why are we updating the SDP?
- To address situations where incorrect packaging is used in transport
- To incorporate Part 37
- To clarify guidance for certain transportation findings
- To update basis documents 8
Review of recent activity
- Published draft revision to App D in 2018 (ML18178A100)
- Added guidance for addressing use of incorrect packages in transport
- Refined regulatory basis statements
- Refined process for package breaches during transport
- Received comments from NEI (ML18264A305)
Independence Clarity Openness Reliability Efficiency 9
Updates being considered
- Using the 2018 draft as a starting point
- Incorporation of Part 37 into the SDP
- Addition of guidance to help dispositioning transportation inspection findings
- Additional background information in basis documents Independence Clarity Openness Reliability Efficiency 10
Review of 2018 Draft
- Refer to ML18178A100 and ML18264A305
- Highlights
- Clarifies when findings involving excepted material shipments should be dispositioned in SDP
- Addition of guidance for incorrect packaging of material, how to comply with survey requirements and package breach scenarios 11
Part 37 12
- Provides reasonable assurance of the security of category 1 or category 2 quantities of radioactive material by protecting these materials from theft or diversion
- Rule provides defense-in-depth and redundancy
- Power reactor-specific considerations
- RIS 2015-15 Cat.
1 or 2
Security zone/monitoring Access control processes 1
Material Detection 2
Part 37 Subpart A, B or C Finding?*
Green White Yellow Red Access by individual who is not Trustworthy and Reliable?
Actual Loss of Material?**
> Category 2?
Yes Yes Yes No Yes No No
- Failures to conduct an investigation or notify the NRC when required by Part 37 shall be dispositioned IAW the NRC Enforcement Policy
- Consult with NRC Office of Investigations prior to dispositioning findings associated with actual cases of theft, diversion or sabotage of radioactive materials Deficient Security Zone?
Deficient Material Detection Capability?
Yes No No Draft Part 37 SDP Diagram (1 of 2) 13
Part 37 Subpart D Finding*
Preplanning and Coordination Issue?
Licensee demonstrates no impact on material security?
White Yellow Red Green Actual Loss of Material Material delivered to unlicensed entity?
Material Returned?
> Cat 2?
Physical Protection in Transit Issue?
Yes Yes Yes Yes Yes Yes Yes No No No No No No No
- Failures to conduct an investigation or notify the NRC when required by Part 37 shall be dispositioned IAW the NRC Enforcement Policy No Yes Loss of Comms and Tracking?
License Verification Issue?
No Yes Draft Part 37 SDP Diagram (2 of 2) 14
Still Under Development
- Part 37
- Guidance for findings that occur in the PA
- How/if to incorporate other licensee processes that control access (e.g., general building security, areas controlled for radiation safety purposes etc.)
- Additional transportation guidance to ensure that outcomes accurately communicate significance
- Basis language
- As low as is reasonably achievable (ALARA)
- Radioactive effluents (failure to implement effluent program) 15
Looking Ahead
- Continue development and vetting with staff
- Continue providing updates and receiving external feedback through monthly ROP public meetings
- Considering another focused public meeting in December/January Independence Clarity Openness Reliability Efficiency November 2020 December 2020/January 2021 February 2021
- Internal comment/resolution
- Publish for February implementation
- Commission notification
- SDP Effective 16
Discussion 17
Questions/Feedback David Garmon david.garmon@nrc.gov 18