ML23019A012

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Inspection Manual Chapter 2602 and Associated Inspection Procedures Awareness Training for NRC & Agreement State Inspectors
ML23019A012
Person / Time
Issue date: 01/19/2023
From: Maurice Heath
Office of Nuclear Material Safety and Safeguards
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Download: ML23019A012 (1)
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Inspection Manual Chapter 2602 and Associated Inspection Procedures Awareness Training Decommissioning Fuel Cycle, Uranium Recovery & Materials Inspection Program January 19, 2023

  • Participants are in listen-only mode until the question portion of the meeting
  • Send short questions via Teams Chat and facilitator will read them aloud
  • The presentation is being recorded to use for training purposes Meeting Logistics 2
  • Commissioners issued a policy statement mandating the use of risk assessment in regulatory activities (60 FR 42622)
  • Revision to IMC 2602 to risk-informed, performance-based inspection in accordance with the policy statement 3

Working Group Members

  • Rob Evans, Region IV, Chair
  • Orysia Masnyk Bailey, Region I
  • Jenni Dalzell, Region III

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
  • Created three new inspection procedures
  • Revised six existing inspection procedures
  • Worked with IMC 2800 WG and Overview, Very Low Safety Significance Issue cont. Resolution (VLSSIR) WG on consistent language
  • Implemented consistent reporting and tracking of inspection results 7
  • Established minimum inspection frequency of one year
  • Clarified timeliness of inspections
  • Ensure all IPs included recommended inspection hours Overview,
  • Added a definition of completion cont. for each IP
  • Revised to facilitate use by Agreement States 8

IMC 2602 Overview

  • New definitions

- Risk modules, risk-informed inspection, performance-based inspection, Be riskSMART, VLSSIR, 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

- 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) 11

  • Updated existing procedures
  • One core procedure per each modality

- IP 87104 - complex materials

- IP 88104 - fuel cycle

- IP 87654 - uranium recovery Overview for

  • Core procedure for surveys Core Procedures - IP 83890 - confirmatory 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 12

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 13

IP 87104 - Materials

  • Inspection Procedure includes 7 risk modules:

- Observation of decommissioning activities

- Occupational Radiation Program

- Security and control of radioactive materials

- Waste generation, storage and transportation

- Public Dose, Effluent Releases and Environmental Monitoring 14

IP 87104 - Materials

  • Risk Modules, cont.

- Management Organization and Controls

- Final status surveys

  • Refer to IP 83890, Closeout Inspection and Survey
  • Appendix provides field notes inspector can use to assist in planning, performance, and documentation of inspection 15

IP 88104 - Fuel Cycle Decommissioning

  • Added additional Inspection Objective

- Verify facility meets unrestricted release and license termination criteria 16

  • Shifted Inspection Requirements to Risk Modules

- Observation of Decommissioning Activities

- Occupational Radiation Protection

- Security and Control of Radioactive IP 88104 - Material

- Waste Generation, Storage, and Fuel Cycle Transportation

- Public Dose, Effluent Releases, and Environmental Monitoring

- Management Organization and Controls

- Final Status Radiological Surveys 17

  • Updated Inspection Guidance

- Parallel new Risk Modules

- Align with updates to IMC 2600

- Overall guidance more concise

  • No change to inspection resources IP 88104 - estimate Fuel Cycle
  • Previous Appendices A & B consolidated to single Appendix A

- Changes checklist from IMC 2600 Inspection Procedures to new Risk Modules 18

IP 87654 -

  • Applicable to decommissioning of uranium mills or In-Situ Recovery Decommissioning (ISR) Sites 19

IP 87654 - Uranium Recovery

  • Applicable to decommissioning of uranium mills or In-Situ Recovery (ISR) Sites
  • Sites not subject to 10 CFR 20 Subpart E but must meet 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.

20

  • Can be used with IMCs 2602 and IP 83890 - 2801
  • Ensures effective decommissioning Closeout IAW all license and regulatory requirements Inspection and
  • All actions have been taken to Survey support license termination 21

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, divided into Risk Module inspection items 22

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 23

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 24

Discretionary IPs include:

Radiation Protection

Groundwater Monitoring

Management and Discretionary Procedures, Organization cont.

25

IP 83822 - Radiation Protection

  • Used to evaluate the licensees radiation protection program

- Review licensee procedures and implementation

- Verify equipment is adequate and properly calibrated

- Verify appropriate use of exposure monitoring and controls, i.e. dosimetry and air monitoring

- Review and observe surveys 26

IP 84900 - Low Level Waste Storage

  • Used to ensure safe storage of low-level waste pending disposal

- Evaluate the adequacy of the storage area, including protective features for the storage area and access controls

- Ensure waste is properly labeled and stored in packaging that is appropriate and intact

- Review plans and strategies for disposition of various waste streams 27

IP 87300 - Groundwater Monitoring

  • Used to evaluate licensee efforts to monitor and remediate groundwater contamination

- Observe groundwater monitoring or remediation activities

- Review licensee radiation protection performance

- Ensure safe storage and control of and radioactive materials resulting from groundwater programs, including proper disposal 28

  • Used to ensure licensee management monitors and manages decommissioning IP 87305 - - Verify the organization meets license Management requirements

- Ensure proper oversight by licensee and management, including changes to procedures, conduct of audits, and review of QA programs Organization - Review safety committee activities, especially any changes since the last inspection 29

- New procedure to capture OSV for Title I and Title II sites managed under the Uranium Mill Tailings Radiation Control IP 89060 - Act (UMTRCA)

DOE - DOE-Legacy Management is Observational responsible for long term surveillance and maintenance Site Visits for sites where mill tailings are stored

- Operate under a general license issued by NRC to DOE

- NRC is responsible for oversight of DOE activities at these sites 30

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 31

Questions 32

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