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
To:
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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

Meeting Logistics 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 2

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Background===

  • 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
Overview, cont.
  • Created three new inspection procedures
  • Revised six existing inspection procedures
  • 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
  • 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

IMC 2602, cont.

  • Defines and describes independent inspection effort
  • Provides overview of NRC Memorandum of Understanding (MOU) with 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

- 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

Overview for Core Procedures Updated existing procedures One core procedure per each modality

- IP 87104 - complex materials

- IP 88104 - fuel cycle

- IP 87654 - uranium recovery Core procedure for surveys

- 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

IP 88104 -

Fuel Cycle Shifted Inspection Requirements to Risk Modules

- Observation of Decommissioning Activities

- Occupational Radiation Protection

- Security and Control of Radioactive Material

- Waste Generation, Storage, and Transportation

- Public Dose, Effluent Releases, and Environmental Monitoring

- Management Organization and Controls

- Final Status Radiological Surveys 17

IP 88104 -

Fuel Cycle

  • Updated Inspection Guidance

- Parallel new Risk Modules

- Align with updates to IMC 2600

- Overall guidance more concise

  • No change to inspection resources estimate
  • Previous Appendices A & B consolidated to single Appendix A

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

IP 87654 -

Uranium Recovery Decommissioning

  • Applicable to decommissioning of uranium mills or In-Situ Recovery (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

IP 83890 -

Closeout Inspection and Survey

  • Can be used with IMCs 2602 and 2801
  • Ensures effective decommissioning IAW all license and regulatory requirements
  • All actions have been taken to 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 Procedures, cont.

Discretionary IPs include:

Radiation Protection

Groundwater Monitoring

Management and Organization 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

IP 87305 -

Management and Organization Used to ensure licensee management monitors and manages decommissioning

- Verify the organization meets license requirements

- Ensure proper oversight by licensee management, including changes to procedures, conduct of audits, and review of QA programs

- Review safety committee activities, especially any changes since the last inspection 29

IP 89060 -

DOE Observational Site Visits

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

- DOE-Legacy Management is responsible for long term surveillance and maintenance 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:

31 IMC 2602 Decommissioning Fuel Cycle, Uranium Recovery, and Materials Inspection Program ML22010A141 IP 83822 Radiation Protection ML22010A147 IP 83890 Closeout Inspection and Survey ML22010A145 IP 84900 Low-Level Radioactive Waste Storage ML22010A148 IP 87104 IP 87300 IP 87305 Decommissioning Inspection Procedure for Materials Licensees Groundwater Monitoring Management and Organization ML22010A142 ML22010A146 ML22010A149 IP 87654 Uranium Mill, In-Situ Recovery, and 11e.(2)

Byproduct Material Disposal Site Decommissioning Inspection ML22010A144 IP 88104 Decommissioning Inspection Procedure for Fuel Cycle Facilities ML22010A143

Questions 32

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