ML23209A533

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2023 NEI RP Forum - NRC Presentation
ML23209A533
Person / Time
Issue date: 07/28/2023
From: Meena Khanna
NRC/NRR/DRA/ARCB
To:
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Download: ML23209A533 (1)
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Highlights on NRC Activities (ADAMS Accession No. ML23209A533)

Meena Khanna, Deputy Division Director Division of Risk Assessment Office of Nuclear Reactor Regulation 2023 NEI Radiation Protection Forum August 1, 2023 1

NRC Attendees Meena Khanna, Deputy Division Director (NRR)

Kevin Hsueh, Branch Chief (NRR)

Steve Garry, Sr. Health Physicist (NRR)

Dave Garmon, Health Physicist (NRR)

Bill Rautzen, Health Physicist (NRR)

Storm Veunephachan, Health Physicist (RI)

Bob Kellner, Sr. Health Physicist (RII)

John Cassidy, Sr. Health Physicist (RIII)

Bernadette Baca, Health Physicist (RIV)

Dominic Antonangeli, Health Physicist (RIV) 2

NRC Strategic Goals Ensure the Safe and Secure Use of Radioactive Materials Continue to Foster a Healthy Organization Inspire Stakeholder Confidence in the NRC 3

Nuclear Reactor Safety Program Priorities

  • Nuclear Safety Issues
  • Hiring/Staffing
  • Operating Reactor Licensing and Oversight
  • Vogtle 3 and 4
  • Digital Instrumentation and Control
  • New Reactor/Advanced Reactor Licensing Activities
  • NRR Risk Activities 4

Ongoing Rulemakings

  • Appendix I to Part 50, Cost Benefit Analysis

Our People Are Our Strength 6

Importance of Good Communication

  • Building/Maintaining trust among your community and other stakeholders
  • Increasing positive stakeholder interactions 7

Update on NRR Radiation Protection Activities - Overview Kevin Hsueh, Chief Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation 2023 NEI Radiation Protection Forum August 1, 2023 8

Radiation Protection and Consequence Branch NRR program office for radiation protection and radiological consequence analyses Guidance development and technical reviews of licensing actions NRR Reactor Oversight Process (ROP) implementation for occupational and public radiation safety cornerstones 9

Recent Radiation Protection Inspection Guidance Updates

- Updated guidance for dispositioning findings associated with the transportation of radioactive materials

- Added guidance to address inspection findings involving 10 CFR Part 37

  • Refinement of inspection procedures based on regulatory experience (71124.01, January 2022)

- Retired 71124.02 ,Occupational ALARA Planning and Controls

- Supplemented IP 71124.01, Radiological Hazard Assessment and Controls 10

Recent Regulatory Guide Updates

  • RG 1.21 on Measuring, Evaluating and Reporting Effluents and Solid Waste, Rev. 3

- Includes guidance on calibration of accident-range radiation and effluent monitors

- RG 1.21 Rev. 3 issued in September 2021

  • RG 8.34 on Monitoring and Calculating Dose, Rev. 1

- Includes guidance on dose calculations and prospective dose evaluations

- RG 8.34 Rev. 1 issued in August 2022 11

Areas of Continued Interest

  • Accident-Range Radiation Monitoring

- Multiple White findings associated with calibration and maintenance of radiation monitors in recent years

- IP 71124.05, Radiation Monitoring Instrumentation, provides inspection guidance

- Public version of NRC Staff Training on Radiation Monitors (ML21327A271)

- Increased interactions between NRC RP and EP staff and look for opportunities to better risk inform NRCs oversight efforts

  • HP Staffing and Knowledge Management

- Radiological controls

- Extensions of calibration frequencies

- Effective communications 12

Focus Areas - Actions Ongoing

  • Level of Efforts Informed by Safety Significance and Risk Insights
  • Supporting NRC Rulemaking Activities
  • Staffing and Knowledge Management
  • Continuous Improvements/Open to Feedback 13

Update on NRR Radiation Protection Activities Specific Topics David Garmon, Health Physicist Steven Garry, Sr. Health Physicist 2023 NEI Radiation Protection Forum August 1, 2023 14

Specific Topics Open communications with stakeholders Prospective Evaluations Inspection Experience Insights Accident-Range Radiation Monitoring 15

Specific Topics - Communications

  • Rev 1 of NEI 07-07, 2019, Objective 2.1 Stakeholder Briefing
  • Focused Stakeholder Briefings on the initial briefing Maintaining Open from site to State/Local officials Communications with
  • Removed periodic briefings from committed actions of Stakeholders is the initiative Essential
  • Recent inspection experience indicates that periodic briefings may be still helpful in mitigating concerns about groundwater contamination
  • NRC processes for dispositioning oversight issues relies in part on licensee openness and willingness to respond to information requests
  • Recent inspection experience showed that NRC/licensee communications-missteps leads to inefficiencies in dispositioning inspection findings 16

Specific Topics - Prospective Evaluations No Prospective Evaluation Required Monitoring Required recording and reporting Yes Prospective Evaluation Likely to exceed monitoring criteria? Yes Yes Dose Dose No Surveys/

results > investigation Voluntary No No monitoring outside Voluntary recording monitoring criteria bounds of and reporting prospective evaluation 17

Specific Topics - Prospective Evaluations Observations Monitoring after unplanned, Need unintended exposure

- Do you have a Prospective Evaluation? Is it up to date?

- How do you demonstrate compliance with monitoring criteria? Voluntary vs. Required Monitoring Monitoring Scope

- Does it include an evaluation of the likelihood of exceeding each Validate Demonstrating of the dose limits? e.g., TEDE, TODE, SDE, LDE assumptions in compliance prospective with

- Does it clearly state whether these dose quantities are being dose occupational monitored and, if so, under what conditions (e.g., normal ops or evaluation dose limits outage)?

Voluntary Monitoring

- Important to NRC (but not a requirement, but important to NRC!)

- Important to know when its no longer voluntary 18

Specific Topics - Prospective Evaluations Guidance/References RG 8.34, Rev 01, dated August 2022

- Task Interface Agreement (TIA), dated February 2016 ML15187A388

- TIA Follow-up, dated June 2016 ML16137A098 Rulemaking Summaries (aka Statement of Consideration)

- (10 CFR 19.12) take into consideration assigned activities which can reasonably be expected to occur during the life of the facility

- Part 19 (60FR36039): likely to receive includes spills of coolant, sudden increases in external radiation, loss of control of rad material resulting in high airborne radioactivity (note different context [i.e., rad worker training] than Part 20 monitoring criteria but analogous language)

Part 20 Q&As (NUREG/CR-6204 ML12166A179)

- #43 (voluntary monitoring), #44 (error in evaluation), #212 (voluntary monitoring), #214/215/420 (prior employers), #465 (monitoring only part of a year), #486 (when to evaluate) 19

Inspection Experience

  • Human Performance
  • 45% NRC ID
  • 24 Plants
  • All 4 NRC Regions 20

Inspection Experience - Takeaways

- Generally, two types of issues:

  • Individual performance vs. program implementation

- Work scope changes not fully evaluated (e.g., RWP requirements changed without proper review/approval)

  • Contamination Controls

- Use of operating experience and latest survey information

- Airborne areas: unposted, improperly surveyed (alpha controls)

- Procedures/checklists/hold points

  • Radiation Monitoring Calibration

- Changes to calibration frequency not vetted by RP 21

Accident Monitoring Instrumentation

  • Item II.F.1 is Additional Accident-Monitoring Instrumentation

- Item II.F.1 Noble gas effluent monitoring

- Item II.F.1 Iodine and particulate sampling and analysis

- Item II.F.1 Containment high range radiation monitoring

  • Tables II.F.1-1, II.F.1-2, and II.F.1-3 establish specifications for radiation monitoring equipment 22

NUREG-0737, Item II.F.1-1 Noble Gas Effluent Monitoring

  • Calibrate effluent monitoring instruments to Xe-133 for gamma or Sr-90 for beta
  • Describe procedures for converting instrument readings to release rates, considering radionuclide spectrum distribution as a function of time after shutdown 23

NUREG-0737, Item II.F.1-2 Iodine and Particulate Monitoring

  • Real time monitoring is not required
  • Iodine and particulate sampling & analysis is required
  • Licensees must develop procedures for collection and analysis of onsite samples without exceeding 5 rem
  • Note: Iodine release rates can be calculated based on partitioning (scaling) factors to noble gas (RG 1.21) 24

NUREG-0737, Item II.F.1-3 Containment High Range Monitors (CHRMs) 25

Potential Errors in Calibrations

  • Using wrong calibration geometry
  • Using wrong efficiency factors

- Assuming 1 efficiency factor fits all detectors

- Replacing detectors and not updating software efficiency factors (particularly General Atomics CdTe(Cl) solid state detectors)

- Not correcting RMS output to a mix of radionuclides (incorrectly only apply Xe-133 efficiency factors) 26

Plant Staff and RP Staff Responsibilities

  • Need to know:

- which department(s) are in charge and who is the subject matter expert

- what equipment is installed and how equipment works

- vendor manuals and calibration summary reports

- how calibration checks are performed and whether checks meet calibration tolerances

- the basis for instrument response factors

- how the monitor output interfaces with dose assessment codes 27

Accident-Range Radiation Monitor Presentations

Questions & Discussion

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