ML24215A344
| ML24215A344 | |
| Person / Time | |
|---|---|
| Issue date: | 08/06/2024 |
| From: | Meena Khanna NRC/NRR/DRA |
| To: | |
| References | |
| Download: ML24215A344 (1) | |
Text
1 Highlights on NRC Activities (ADAMS Accession No. ML24215A344)
Meena Khanna, Acting Division Director Division of Risk Assessment Office of Nuclear Reactor Regulation 2024 NEI Radiation Protection Forum August 6, 2024
2 NRC Attendees
Meena Khanna, Acting Division Director (NRR)
Kevin Hsueh, Branch Chief (NRR)
Steve Garry, Sr. Health Physicist (NRR)
Dave Garmon, Health Physicist (NRR)
Bill Rautzen, Health Physicist (NRR)
Jack Bell, Health Physicist (RII)
Valerie Myers, Sr. Health Physicist (RIII)
John ODonnell, Sr. Health Physicist (RIV)
3 NRC Strategic Goals Ensure the Safe and Secure Use of Radioactive Materials Continue to Foster a Healthy Organization Inspire Stakeholder Confidence in the NRC
4 Items of Interest
- Increased Enrichment of Conventional and Accident Tolerant Fuel Designs for Light-Water Reactors
- Palisades Restart
- NuScale Standard Design Approval
5 Advance Act Clear sign from Congress and President that the NRC must find more efficient ways to meet its important safety and security mission.
Provisions include:
Update to mission statement - consideration of efficiency and the benefit of nuclear energy technology to society Leveraging Risk-Informed Decision-making and process efficiencies Budgeting flexibilities Develop strategies (e.g., micro-reactors, fusion technology)
International cooperation Reporting requirements to Congress More
6 For your Consideration
- Topics of Interest
- Accident-Range Radiation Monitoring
- Supplemental RP Tech Shortage
- Improved Communications
- Importance of the RPM and Succession Planning
- Key position as it relates to radiation safety
- Requires investment by the site to develop
- Independence from operational pressures
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
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 NRC Staff Training
- HP staff training on Supplemental Inspection Guidance, Inspection Procedure (IP) 71124.07 - Environmental Monitoring, Analysis of Environmental Dosimetry (ML23341A123)
- HP staff training on Supplemental Inspection Guidance, IP 71124.04 - Dose Assessment Evaluation of EPD vs. TLD/OSL dosimetry programs (ML23237B473)
10 Areas of Continued Interest
- Accident-Range Radiation Monitoring
- HP Staffing and Knowledge Management
- Radiological controls
- Dose assessments
- Extensions of calibration frequencies
- Effective communications
- RPM Qualifications
11 Focus Areas - Actions Ongoing
- Level of Effort Informed by Safety Significance and Risk Insights
- Supporting NRC Rulemaking Activities
- Staffing and Knowledge Management
- Continuous Improvements/Open to Feedback
12 Update on NRR Radiation Protection Activities Specific Topics David Garmon, Health Physicist Steven Garry, Sr. Health Physicist
13 Specific Topics NRC Position on RPM Qualifications Performance Indicator Program Review NRC Staff Site Access Inspection Experience Insights Radiation Monitor Calibration Frequency Recent NRC Staff Training
14 NRC Position on RPM Qualifications
- Requirements
- 20.1101 - Develop, document and implement a radiation protection program commensurate with scope of licensed activities and sufficient to ensure compliance
- Standard TS
- Sufficient organizational independence from operating pressures
- Meet or exceed RG 1.8, Rev 2
- Guidance and NRC Positions
- RG 1.8, Multiple Revs
- HPPOS (018, 020, 217)
15 NRC Position on RPM Qualifications (contd)
- Individual accountable for the program required by 10 CFR Part 20
- Onsite staff member
- Education and Experience
- Bachelor Degree
- HPPOS - 020
- 5 years experience
- Inclusive of 3 yr nuclear &1 yr management
- Additional experience specifications
16 Performance Indicator Program Review Inspection Manual IMC 0608, Program Description IMC 0308, Att 1, Bases IP 71151 PI Verification IP 71150 PI Discrepancies Occupational Radiation Safety Public Radiation Safety Aggregation of certain issues that wouldnt be aggregated as findings Reporting is up to licensees per NEI 99-02 (being updated now to Rev 8)
Observations Occupational Radiation Safety PI Public Radiation Safety PI
17 NRC Staff Site Access
- 10 CFR 19.12 rad worker training satisfied by initial site access training and 5-year refresher training for NRC staff
- Federal identification badge (HSPD-12 PIV, CAC) badge number can be used instead of SSN for dose records
18 Inspection Experience Insights
- Instrument Calibration
- Changes in calibration frequency
- Known issues with equipment (alert status with no action)
- HRA/LHRA Controls
- Worker zigged when they were told to zag (or should have been told)
- Change in operational conditions (relying on old survey data/brief)
- Contamination Control/Internal Dose Assessment
- Delays in evaluating air sample information
- Understanding radiological hazard
- Bioassay protocols
19 Inspection Reports with RP Findings (Jul 23-Jul 24)
ML23122A163 - Failure to calibrate primary drywell and containment high range area radiation monitors in accordance with 10 CFR 20.1501(c)
ML23201A014 - Failure to Adequately Secure Radioactive Shipment to Prevent Shifting During Transport ML23202A186 -
Failure to Follow Procedure for Proper Storage of SCBA Respirator Facepieces Failure to Follow Procedures in Performing Internal Dose Assessments ML23221A301 - Failure to Perform Air Sampling Analysis Resulting in Two Uptakes ML23221A327 - Improper entry into a high radiation area ML23293A193 - Inadvertent Entry Into an Overhead High Radiation Area ML23310A032 - Failure to perform a radiation survey in accordance with 10 CFR 20.1501(a) to ensure occupational doses were controlled within regulatory limits ML23310A315 - Failure to follow procedures resulting in an unanticipated dose rate alarm and unplanned exposure to a crane operator ML23312A183 - Failure to periodically calibrate radiation monitors ML23312A351 - Failure to comply with RWP requirements for entry into HRA ML23317A081 - Failure to perform performance response check for instrumentation ML24024A192 - Failure to Secure a Lock High Radiation Area to Prevent Unauthorized Access ML24036A290 - Failure to Adequately Control Radiological Work ML24038A256 - Failure to follow radiological control procedures with two examples ML24043A263 - Failure to Implement Adequate Procedure Results in Unexpected Change in Radiological Conditions Requiring Locked High Radiation Area Controls ML24079A169 - Failure to Comply with the Terms of the Certificate of Compliance for a Package Delivered to a Carrier for Transport ML24107A927 - Failure to Operate the Hatch Unit 2 Radwaste Area HVAC System as described in the FSAR Design Bases ML24131A141 - Failure to Evaluate Radiological Conditions Following the Transfer of Radioactive Sludge to a Shipping Liner ML24141A101 - Failure to follow ALARA planning and control procedures resulting in unplanned dose
20 Radiation Monitor Calibration Frequency
- Some licensees have extended calibration frequencies, without adequate evaluations or internal coordination
- Frequencies have been extended beyond 1 year and beyond vendor recommendations
- Run-to-Failure is a maintenance strategy, not a calibration frequency
21 Applications of Grace Period Concept
- NRC does not formally use the term Grace Period
- Standard Tech Specs use the term extension with respect to surveillances such as for a calibration frequency
- An extension of a calibration frequency should be based on an analysis of instrument stability
- Frequency should be based on the initial calibration cycle, not be continually extended based on the most recent calibration date
22 Regulatory Requirements 10 CFR 20.1501(c ) requires periodic calibration as follows:
(c) The licensee shall ensure that instruments and equipment used for quantitative radiation measurements (e.g., dose rate and effluent monitoring) are calibrated periodically for the radiation measured NUREG-1736 recommends inherently stable instruments be calibrated every 12 months or more frequently for less stable instruments or instruments used in rugged environments
23 ANSI Standard N323AB-2013 - Portable Instrumentation
- Calibrate at a frequency required to maintain an acceptable accuracy
- Frequency should not exceed one year, except:
- More frequent calibrations for extreme conditions (hard usage, multi-shift use)
- Before changing calibration frequencies, conduct an analysis:
- If as-found responses are out of calibration acceptance range, consider increasing calibration frequency
- If as-found results indicate consistent reliable performance, the calibration interval can be extended
24 ANSI N323D - 2002 - Installed Instrumentation
- Calibration Frequency
-Frequency depends on stability of the instrument
-Stability is determined based on routine response checks
- If results are within +/- 10%, no recalibration is required
- If results are within +/- 10% to +/- 20%, annual recalibration is required
25 ANSI Standard 42.33 -2019 - Portable Exposure Rate Meters For Homeland Security
- Calibration based on design and reliability history of the instrument
- Recalibration should not exceed one year or as recommended by the manufacturer
- Sources used for all calibrations should be traceable to NIST (see ANSI N42.22 and N42.23)
26 Standard Technical Specification (STS)
Radiological Instrumentation STS typically require specific periodic calibration frequencies (18 months) or in accordance with the Surveillance Frequency Control Program PWR STS NUREG-1431 Radiological Instrumentation:
STS 3.3.3 Containment high area radiation monitors (CHARMS)
STS 3.3.6 Containment purge and exhaust monitors STS 3.3.7 Control Room air and air intake monitors STS 3.3.8 Fuel Building gas and particulate monitors STS 3.4.15 RCS leak detection system gas and particulate monitors BWR STS NUREG-1434 Rad Monitors STS 3.3.3.1 Primary containment monitors STS 3.3.6.2 Secondary containment isolation instrumentation STS 3.3.7 Control Room ventilation particulate and gas monitors NUREG-1430 Standard Technical Specifications Babcock and Wilcox Plants NUREG-1431 Standard Technical Specifications Westinghouse Plants NUREG-1432 Standard Technical Specifications Combustion Engineering Plants NUREG-1433 Standard Technical Specifications General Electric Plants (BWR/4)
NUREG-1434 Standard Technical Specifications General Electric BWR/6 Plants
27 Surveillance Frequency Control Programs
- STS sometimes defer to frequencies as specified in the licensees Surveillance Frequency Control Program
- Calibration frequencies that deviate from frequencies recommended in regulatory guidance or industry standards should have an analysis or justification
- Analysis or justification should be based on instruments as-found performance and stability characteristics
- When needed, increase calibration frequency to assure reliable instrument performance
28 Recent NRC Staff Training - Environmental Dosimetry
- Supplemental Inspection Guidance, Inspection Procedure (IP) 71124.07 - Environmental Monitoring, Analysis of Environmental Dosimetry (ML23341A123)
- Some observations of 2023 environmental reports:
- background radiation measurements
- analyses of background radiation levels and plant dose
- storage of control dosimeters
- transit dose calculation
29 Recent NRC Staff Training - Environmental Dosimetry
- Element 3 and 4 readings were reported as 0.0 to 2.3 mrem, and location mean value is reported as 1.0 mrem
- Background should be about 12 - 25 mrem
- Storage of control dosimeters 29
30
- HP staff training on Supplemental Inspection Guidance, IP 71124.04 - Dose Assessment Evaluation of EPD vs. TLD/OSL dosimetry programs (ML23237B473)
- How to evaluate discrepancies
- Plot/graph individual EPD vs TLD/OSL readings
- Use INPO or empirical acceptance bands
- Identify outliers Reasons for some discrepancies Identify causes of discrepancies Recent NRC Staff Training - Dose Assessment Evaluation
31 Example Trend Chart Mismatch 0
50 100 150 200 250 0
50 100 150 200 250 EPD (mrem)
TLD/OSL (mrem)
A positive EPD bias would be seen as a trend above the tolerance band at high doses.
At EPD doses > 50 mrem, TLD/OSL may be more accurate.
At doses < 50 mrem, if the TLD/OSL doses are higher than EPDs, it is possible that BWR workers are receiving N-16 or ISFSI dose outside the RCA while not wearing EPDs Are EPDs trending high?
Are TLD/OSLs trending low?
It could be either one!!
Green and Red lines represent tolerance bands
Questions & Discussion