ML23012A230
| ML23012A230 | |
| Person / Time | |
|---|---|
| Issue date: | 01/12/2023 |
| From: | Maurice Heath Office of Nuclear Material Safety and Safeguards |
| To: | |
| References | |
| Download: ML23012A230 (1) | |
Text
Inspection Manual Chapter 2602 and Associated Inspection Procedures Public Meeting Decommissioning Fuel Cycle, Uranium Recovery & Materials Inspection Program January 17, 2023
- Participants are in listen-only mode until the public comment portion of the meeting
- Send short questions and comments via Teams Chat and facilitator will read them aloud
- Meeting will be recorded/transcribed to allow NRC staff to review questions and comments at later date
- Presentation slides are available for Meeting Logistics download from ADAMS at ML22XXXXXX 2
Working Group Members
- Rob Evans, Region IV, Chair
- Marti Poston, NMSS
- Orysia Masnyk-Bailey, Region I
- Roland Womack, Region II
- Jenni Dalzell, Region III
- Joe Power, New Jersey 3
- Commissioners issued a policy statement mandating the use of risk assessment in regulatory activities (60 FR 42622)
- Mandate and path forward to achieve the mandate detailed in Background SECY-98-144 (ML003753601)
- Revision to IMC 2602 to risk-informed, performance-based inspection in accordance with the policy statement 4
Agenda
- Overview
- Changes to the program
- Core Inspection procedures
- Discretionary inspection procedures 5
Overview
- Updated to reflect current decommissioning practices
- Adopted risk-informed, performance-based inspection philosophy and use of risk modules
- Combine all non-reactor modalities in one IMC 6
Overview, cont.
- Created three new inspection procedures
- Revised six existing inspection procedures
- Worked with IMC 2800 WG and Very Low Safety Significance Issue Resolution (VLSSIR)
WG on consistent language
- Implemented consistent reporting and tracking of inspection results 7
Overview, cont.
- Established minimum inspection frequency of one year
- Clarified timeliness of inspections
- Ensure all IPs included recommended inspection hours
- Added a definition of completion for each IP
- Added guidance during pandemics/epidemics
- Revised to facilitate use by Agreement States 8
IMC 2602 Overview
- New definitions
- Risk modules, risk-informed inspection, performance-based inspection, Be riskSMART, Decommissioning Planning Rule (DPR), program adjustment
- Modified to align with revised responsibilities
- Established standard inspection frequency and criteria to adjust based on site activities 9
- Defines and describes independent inspection effort
- Provides overview of NRC IMC 2602, Memorandum of Understanding (MOU) with cont. other federal agencies related to decommissioning
- Established seven distinct risk modules for decommissioning 10
Risk modules
- Defined in IMC 2602 and used in the IPs
- Program areas that present higher risk or expected to effectively reduce risk to health, safety and security that are identified in each inspection procedure in order to focus inspection efforts on these particular program areas.
11
Risk Modules, Cont.
- Observation of decommissioning activities
- Occupational radiation protection
- Security and control of licensed material
- Waste generation, storage, and transportation
- Public dose, effluent releases, and environmental monitoring
- Management organization and controls
- Final status/confirmatory surveys (as needed) 12
- Updated existing procedures
- One core procedure per each modality
- IP 87104 - complex materials
- IP 88104 - fuel cycle
- Core procedure for surveys Overview for - IP 83890 - confirmatory Core Procedures surveys
- Applicable to all decommissioning inspections not just those needing a significant decommissioning effort or decommissioning plan
- Performance-based inspection with emphasis on risk-significant activities 13
IP 87104 - Materials Decommissioning
- Updated existing procedure 87104
- Applicable to all decommissioning inspections not just those needing a significant decommissioning effort or decommissioning plan
- Describes performance-based inspection with emphasis on risk-significant activities
- No change to recommended inspection resources 14
IP 88104 - Fuel Cycle Decommissioning
- Added additional Inspection Objective
- Verify facility meets unrestricted release and license termination criteria 15
- Updated Inspection Guidance
- Align with updates to IMC 2600 Fuel Cycle Facility Operational Safety and Security Inspection Program
- Overall guidance more concise IP 88104 -
- No change to inspection resources Fuel Cycle estimate
- Previous Appendices A & B consolidated to single Appendix A
- Changes checklist from IMC 2600 Inspection Procedures to new Risk Modules 16
IP 87654 -
- Updated existing IP 87654
Decommissioning Sites
- Shift from compliance based to risk-informed, performance-based inspections 17
- Sites not subject to 10 CFR 20 Subpart E but must meet decommissioning requirements associated with Appendix A of 10 CFR 40
- Field notes in Appendix of IP for the pre-decommissioning, active decommissioning and post-decommissioning inspection processes 18
IP 83890 -
- Can be used with IMCs 2602 and 2801 Closeout
- Ensures effective decommissioning in accordance with all license and Inspection and regulatory requirements
- Ensure all actions have been taken Survey to support license termination 19
IP 83890 - Closeout Inspection and Survey
- Emphasis on conducting inspections that are risk-informed, performance-based; utilizing direct observation and confirmatory surveys
- Added a resource estimate, and what constitutes procedure completion
- Appendix A updated to be used as a field notes checklist 20
IP 83890 - Closeout Inspection and Survey
- Inspection Guidance section provides expanded details on:
When confirmatory surveys should be conducted Use of a contractor to perform confirmatory surveys FSS review items What constitutes adequate evidence that site can be released What constitutes adequate evidence that the license can be terminated Uranium Recovery decommissioning and survey requirements 21
Overview of Discretionary Procedures
- Discretionary IPs can be used to supplement core procedures and have no required frequency
- There are no risk modules associated with the discretionary procedures
- One IP created to address DOE observational site visits 22
Discretionary Procedures, cont.
- Discretionary IPs include:
IP 83822 - Radiation Protection IP 84900 - Low Level Waste Storage IP 87300 - Groundwater Monitoring IP 87305 - Management and Organization 23
How to Find the Documents:
IMC 2602 Decommissioning Fuel Cycle, Uranium Recovery, ML22010A141 and Materials Inspection Program IP 83822 Radiation Protection ML22010A147 IP 83890 Closeout Inspection and Survey ML22010A145 IP 84900 Low-Level Radioactive Waste Storage ML22010A148 IP 87104 Decommissioning Inspection Procedure for ML22010A142 Materials Licensees IP 87300 Groundwater Monitoring ML22010A146 IP 87305 Management and Organization ML22010A149 IP 87654 Uranium Mill, In-Situ Recovery, and 11e.(2) ML22010A144 Byproduct Material Disposal Site Decommissioning Inspection IP 88104 Decommissioning Inspection Procedure for Fuel ML22010A143 Cycle Facilities 24
Questions 25