ML23335A167
| ML23335A167 | |
| Person / Time | |
|---|---|
| Issue date: | 12/06/2023 |
| From: | David Garmon-Candelaria, Veunephachan S NRC/NRR/DRA/ARCB |
| To: | |
| References | |
| Download: ML23335A167 (1) | |
Text
Reactor Oversight Process David Garmon Health Physicist - USNRC Storm Veunephachan Health Physicist (Inspector) - USNRC ADAMS Accession No. ML23335A167 INPO - New RPM Seminar December 6, 2023
Objectives
- Overview of the NRC
- Overview of the Reactor Oversight Process
- Overview of Inspection Program and Performance Indicators 2
What is the NRC ?
The NRC is an independent agency headed by five* Commissioners appointed by the President and confirmed by the Senate for staggered, five-year terms. One of them is designated by the President to be the Chairman and official spokesperson of the Commission.
The NRC is not associated with a federal department and does not report to a cabinet or secretary.
Who are the NRCs stakeholders?
Objective: Overview of NRC 3
History of the NRC Atomic Energy Act of 1946 created a government monopoly of nuclear technology and emphasized secrecy and weapons development. It established the Atomic Energy Commission (AEC).
Atomic Energy Act of 1954 ended the government monopoly and made the peaceful, commercial uses of nuclear technology an urgent priority. The AEC was then tasked with promoting and regulating peaceful applications of nuclear technology.
Energy Reorganization Act of 1974 separated the AEC into what became the DOE and the NRC. NRC began operation in 1975.
Follow-on legislation Objective: Overview of NRC 4
To license and regulate the nations civilian use of byproduct, source, and special nuclear materials to ensure adequate protection of public health and safety, promote the common defense and security, and protect the environment.
Objective: Overview of NRC 5
NRC Mission
6 NRR Letter dated October 15, 2019: https://www.nrc.gov/docs/ML1926/ML19260E683 NRC Values: https://www.nrc.gov/about-nrc/values.html Objective: Overview of NRC
The NRC Regulates Nuclear Reactors - commercial power reactors, research and test reactors and new reactor designs Radioactive Materials - nuclear reactor fuel, radioactive materials for medical, industrial and academic use Transportation, Storage and Disposal - of nuclear material and waste, decommissioning of nuclear facilities Nuclear Security - physical security of nuclear facilities from sabotage or attacks and materials from theft and diversion Objective: Overview of NRC 7
8 Objective: Overview of NRC NRC Regions
Regulatory Hierarchy Atomic Energy Act and Other Applicable Legislation Plant-Specific Licensing Basis
- Title 10 of the Code of Federal Regulations
- Operating License
- Technical Specifications High Radiation Area Controls (HRA/LHRA/VHRA)
REMP / ODCM Certain plant procedures (see RG 1.33)
Qualifications for certain positions
- Design Basis, FSAR, Certain Commitments etc.
9 Objective: Overview of NRC
10 Objective: Overview of NRC Key Day-to-Day Functions
11 Oversight Activities Inspection - Identify and disposition issues in a risk-informed manner Assessment - Evaluate and communicate licensee performance info Enforcement - NRCs response to noncompliances Investigations
- NRC OI vs. NRC OIG Allegations Objective: Overview of NRC Allegation - a declaration, statement or assertion of impropriety or inadequacy associated with NRC-regulated activities, the validity of which has not been established NRC Form 3 NUREG/BR-0240, Rev 8
12 Objective: Overview of ROP Reactor Oversight Process
13 Objective: Overview of ROP Assessment of Performance
Increasing Safety Significance Green White Yellow Red Inspection Findings / Performance Indicators Assessment of Performance - Action Matrix Columns Licensee
Response
Regulatory
Response
Degraded Performance Multiple/Repetitive Degraded Cornerstone Unacceptable Performance Increasing Safety Significance, Inspection, Management Involvement and Regulatory Action Communicating Significance to the Public and Licensee 14 Objective: Overview of ROP
Radiation Safety Cornerstone Performance Indicators Occupational Radiation Safety
- Keep occupational dose to individual workers below the limits specified in 10 CFR Part 20 Subpart C and
- Use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational doses that are ALARA per (20.1101(b))
- To assess the performance of the radiological effluent control program
Reference:
RIS 2000-08, IMC 0308, NEI 99-02, Rev 7 15 Objective: Overview of Inspection and PIs
Occupational Radiation Safety PI
- Occupational Radiation Safety Indicator Definition Technical Specification high radiation area occurrences Very high radiation area occurrences Unintended exposure occurrences Occupational Radiation Safety Performance Indicator Threshold: White Threshold: Yellow Threshold: Red Increased Regulatory Response Band Required Regulatory Response Band Unacceptable Performance Occupational Exposure Control Effectives
> 2
> 5 Not Applicable 16 Objective: Overview of Inspection and PIs
- Public Radiation Safety Indicator Definition Sum of release occurrences per reactor unit that exceed the following:
Liquid: 1.5 mrem/qtr (whole body) or 5 mrem/qtr (organ) or Gaseous: 5 mrads/qtr (gamma) or 10 mrads/qtr (beta) or 7.5 mrem/qtr (organ dose from I-131, I-133, H-3 and particulates)
Public Radiation Safety Performance Indicator Threshold: White Threshold: Yellow Threshold: Red Increased Regulatory Response Band Required Regulatory Response Band Unacceptable Performance RETS/ODCM Effluents
> 1
> 3 Not Applicable 17 Objective: Overview of Inspection and PIs
Types of Inspections Baseline inspections Supplemental inspections Generic safety issue, special and infrequent inspections Reactive Inspections (Management Directive 8.3, IMC 0309) 18 Objective: Overview of Inspection and PIs
Inspection Program Objectives To obtain factual information providing objective evidence that power reactor facilities are operated safely, and licensee activities do not pose an undue risk to public health and safety To determine the causes of declining performance before such performance reaches a level that may result in undue risk to public health and safety To identify those safety significant issues that may have generic applicability Baseline: provide sufficient examination, along with PIs, that licensees are meeting the objectives of the ROP cornerstones 19 Objective: Overview of Inspection and PIs
Regulations Design Basis Licensing Basis Licensing Process Licensee Performance Inspection Process Compliance Adequacy Other Agency Processes (e.g., assessment, generic issues)
Risk-Informed Licensing Basis and Inspections 20 Objective: Overview of Inspection and PIs
Occupational Radiation Safety Cornerstone Baseline Inspection Procedures (IPs)
IP 71124.01 - Radiological Hazard Assessment and Exposure Controls (12 months)
IP 71124.02 - Occupational ALARA Planning and Controls (24 months)
IP 71124.03 - In-Plant Airborne Radioactivity Control and Mitigation (24 months)
IP 71124.04 - Occupational Dose Assessment (24 months)
IP 71124.05 - Radiation Monitoring Instrumentation (24 months) 21 Objective: Overview of Inspection and PIs
Public Radiation Safety Cornerstone Baseline Inspection Procedures (IPs)
IP 71124.06 - Radioactive Gaseous and Liquid Effluent Treatment (36 months)
IP 71124.07 - Radiological Environmental Monitoring Program (36 months)
IP 71124.08 - Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation (24 months)
IP 71152 - Performance Indicators (12 months for Occupational and Public RS Cornerstones) 22 Objective: Overview of Inspection and PIs
Key Inspection Process Terminology Issue of Concern: A well-defined observation or collection of observations potentially impacting safety or security which may warrant further inspection, screening, evaluation or regulatory action Performance Deficiency: Licensees (1) failure to satisfy one or more regulatory requirements or self-imposed standards where such failure was (2) reasonably foreseeable and (3) preventable.
Inspection Finding: A performance deficiency determined to be more-than-minor Significance Determination Process: Process applied to a finding to determine its safety and security significance (i.e. Green, White, Yellow or Red)
Licensee-Identified: Identified as a result of deliberate observation by licensee personnel; and entered into licensee CAP 23 Objective: Overview of Inspection and PIs
Inspection Finding Process 24 Objective: Overview of Inspection and PIs
Is the PD More-Than-Minor?
If the answer to any of the following questions is yes, then the performance deficiency is More-than-Minor and is a finding.
- 1) Could the performance deficiency reasonably be viewed as a precursor to a significant event?
- 2) If left uncorrected, would the performance deficiency have the potential to lead to a more significant safety concern?
- 3) Is the performance deficiency associated with one of the cornerstone attributes and did the performance deficiency adversely affect the associated cornerstone objective?
Inspectors should also consider using IMC 0612, Appendix E, Examples of Minor Issues, when answering the screening questions listed above.
25 Objective: Overview of Inspection and PIs
Occupational RS Cornerstone Objective and Attributes 26 Objective: Overview of Inspection and PIs
Public RS Cornerstone Objective and Attributes 27 Objective: Overview of Inspection and PIs
Significance Determination Objectives Characterize safety significance of inspection findings using best available info.
Provide an objective common framework for communicating significance Provide a basis for timely assessment and enforcement actions Provide inspectors with risk information for use in risk-information activities 28 Objective: Overview of Inspection and PIs Occupational Rad Safety SDP ALARA Overexposure Substantial potential for overexposure Compromised ability to assess dose Public Rad Safety SDP Rad Material Control Effluents and REMP Transportation Part 37 Land Disposal of Rad Waste
Example Finding #1 - Failure to follow procedures with an improper entry to an HRA
- Operator received dose rate alarm as they entered a HRA
- Worker had not been made aware or had been briefed prior to entry
- PD: The failure to follow a licensees procedural requirements for entry into a high radiation area 29 Objective: Overview of Inspection and PIs
Occupational SDP Flowpath
- Finding identified:
Failure to follow procedures with an improper entry to a HRA
- ALARA Planning or Work Controls? No, move to next figure 30 Objective: Overview of Inspection and PIs
Occupational SDP Flowpath Continued
- Was it an Overexposure?
No
- Was There a Substantial Potential? No
- Was the Ability to Assess Dose Compromised? No
- Green 31 Objective: Overview of Inspection and PIs
Example #2 - Failure to Comply with the Terms of the CoC for a Package Delivered to a Carrier for Transport
- Spent fuel pool cleanup campaign failed to identify all irradiated hardware
- Inaccurate load plans lead to control rod blades being shipped that were not planned
- Additional 1300 Ci of Co-60 placed in shipment
- PD: Licensees failure to comply with the terms of the CoC for a package delivered to a carrier for transport 32 Objective: Overview of Inspection and PIs
Example #3 - White Finding
- Finding: Licensee failed to appropriately identify and assess the radiological hazards when retracting a source range monitor
- Two contract workers stationed in sub pile room to retract SRM detector cable
- RP techs present. Positioned outside the carousel area and in keyway 33 Objective: Overview of Inspection and PIs
White Finding Continued
- Work plan instructed workers to retract SRM cable until radiation level rises/or there was approximately 30 feet of cable left in drive tube
- Workers manually withdrew approximately 22ft instead of desired 9ft-12ft of detector cable.
- SRM detector and ~7 1/2 ft of activated cable withdrawn outside reactor vessel
- Increased radiation fields from 2 Rem/hr to >1000 Rem/hr in open area of the carousel work platform 34 Objective: Overview of Inspection and PIs
White Finding Continued
- Workers immediately left the area once notified by RP
- In order leave the sub-pile floor and undervessel area, workers had to climb a ladder and crossover a handrail that was adjacent to the SRM drive tube
- Several industrial hazards present including cords, ropes, and un-barricaded open pit with a nominal 6-foot fall
- No physical barriers that would have prevented access to the source during work activities
- Highest dose recorded was 98 mRem
White Finding Continued
- PD: Licensees failure to appropriately identify and assess the radiological hazards associated with retracting the highly irradiated SRM-C from the reactor vessel.
- More than minor? Yes, because it could be viewed as a precursor to a significant event 36 Objective: Overview of Inspection and PIs
White Finding SDP Flowpath
- Route through IMC 0609 Appendix C Occupational Radiation Safety SDP
- Finding identified
Occupational SDP Flowpath Was it an overexposure? No Was there a substantial potential? Yes SDE/DRP Exposure? No Was it a whole-body Exposure in a VHRA? No White CCA: Decision making, Human Performance (H.1.b) 38 Objective: Overview of Inspection and PIs
Inspection Readiness Clearly state the problems and regulatory significance in condition reports if you understand it Be forthcoming on issues that arise during inspections Open communication with inspector onsite (when jobs are happening, pre-job briefings)
Contact your inspector if significant issues come up or issues where potential willfulness is involved Ensure program changes are thoroughly reviewed against FSAR, ODCM, and TRM requirements and perform adequate justification for changes Availability of program owners or subject matter experts during inspection 39 Objective: Overview of Inspection and PIs
Follow On Activities 40 Objective: Overview of Inspection and PIs
Key References IMC 0305 - Operating Reactor Assessment Program: Overview of the assessment process/performance reviews, explanation of the Action Matrix IMC 0308 - ROP Basis Document: Detailed background information several ROP programs, SDP, Assessment, Enforcement, (Att 3, App C and D apply to occupational and public radiation safety SDPs)
IMC 0309 - Reactive Inspection Decision Basis for Reactors: Describes criteria for reactive inspections (e.g., SIT)
IMC 0608 - Performance Indicator Program (RIS 01-025 & NEI 99-02):
Description of PIs, FAQ process etc.
IMC 0609 - Significance Determination Process: SERP process, process for appeal of characterization of findings, SDPs for occupational and public radiation safety IMC 0612 - Issue Screening: Guidance for dispositioning of NRC findings, more-than-minor examples IMC 2515 - Light Water Reactor Inspection Program Operations Phase Federal Register Notices associated with key regulations 41
Contacting the NRC Report an emergency
- (301) 816-5100 (call collect)
Report a non-emergency safety concern (identity is protected unless ordered otherwise by court or you reveal yourself as the source)
- (800) 695-7403
- Allegation@nrc.gov NRC Inspector General (fraud, waste, abuse or misconduct)
- (800) 233-3497
- nrcoig.oversight.gov General information or questions
- www.nrc.gov
- david.garmon@nrc.gov Health Physicist, NRR 42