ML19151A753

NEI Slides for NRC Public Meeting May 30 2019_Final

ML19151A753
Person / Time
Site:	Nuclear Energy Institute
Issue date:	05/31/2019
From:	Anderson E Nuclear Energy Institute
To:	Office of Nuclear Reactor Regulation
Smith M
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Download: ML19151A753 (15)

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NRC Public Meeting: 2020 Inspection Procedure 71124 Ellen Anderson Director, Radiation Safety May 30, 2019

©2019 Nuclear Energy Institute

Overview Industry views pertinent to the NRC review Industry performance relevant to the eight RP inspection procedures

©2019 Nuclear Energy Institute 2

Industry performance is strong Industry RP program performance remains strong

• 92% of RP findings between May 2015 and May 2019 are very low safety significant (green)

RP programs are mature and robust; best practices, including operational experience, are widespread and freely shared.

Technology employed in RP programs has improved since the ROP began

• Instruments and dosimetry can detect much lower levels of radiation and exposure than ever before

©2019 Nuclear Energy Institute 3

Industry performance warrants comprehensive rethinking of RP inspections Inspection frequencies should be extended and inspection sample sizes should be reduced.

NRC review should use similar approach to that used for review of Engineering inspection suite

• Various aspects of Electronic Alarming Dosimeters (EADs) are inspected in the 4 attachments (01, 02, 04, 05);

• RP-related PI&R is inspected multiple times: all attachments, by Sr. Resident inspectors, and the Biennial PI&R Team Inspection Rethink the meaning of samples in RP inspection procedures; current use is not a good proxy for the actual level of effort involved.

©2019 Nuclear Energy Institute 4

RP Inspection Findings May 2015 - May 2019 60 RP Inspection Findings May 2015 - May 2019 50 92% green 40

1. Findings 30 20 10 0

1 2 3 4 5 6 7 8 Inspection Procedure Attachments green findings, blue = no color findings, white findings

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IP 71124.01 Radiological Hazard Assessment and Exposure Controls Technological innovation and industrys use of improved instrumentation have assisted station RP staff & workers in early identification of unauthorized high radiation area (HRA) entries. For example:

• Use of on Electronic Alarming Dosimeters (EADs) and the establishment of low dose and dose-rate set points have cautioned workers about unanticipated radiological conditions due to:

Entry into unauthorized areas Changed radiological conditions Workers responded to set point alarms from these non-regulatory, ALARA tools by immediately leaving the areas and reporting to RP.

Worker response to this technology has resulted in minimal radiation exposure.

47% of the overall findings for the 4-year period

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Inspection Planning Burdensome

• Onerous document requests To reduce licensee burden, consider requesting only risk significant items

• Grouping of several inspection areas using a team inspection approach

• Time-consuming and distraction to RP staff to support inspections -

especially during outages Feedback from RP Managers:

• Region I: Roy Miller, PSEG

• Region II: Steve Taylor, Southern Nuclear

• Region III: Willie Harris, Exelon

• Region IV: Johann Geyer, Ameren

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Conclusions Most findings are already captured in licensees corrective action programs.

NRC should use this unique moment to comprehensively, holistically review the RP inspection suite.

• Do this right. Take the time to do a quality review.

A properly reformed RP inspection suite should help:

• Leverage licensees strong RP program performance and advances in technology to optimize RP oversight;

• Reduce the burden on NRC and licensees for inspection planning and preparation;

• Reduce the impacts on licensees during outages; and

• Focus NRC resources on the most risk significant aspects during the most risk significant period of time.

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IP 71124.02 Occupational ALARA Planning and Controls Trends in collective radiation dose, as shown in NUREG-0713, continue to demonstrate strong and effective ALARA performance and philosophies ALARA program controls are defined in licensee procedures.

Inspections of industry ALARA programs resulted in six green or low-safety significant finding and one no-color finding.

7% of the overall findings for the 4-year period.

©2019 Nuclear Energy Institute 9

IP 71124.03 In-Plant Airborne Radioactivity Control and Mitigation In the 4-year period, NRC identified nine low-safety significance (green) findings:

• Licensees failed to maintain or adequately follow station procedures.

• 8% of the overall findings for the 4-year period.

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IP 71124.04 Occupational Dose Assessment In the 4-year period, NRC identified two low-safety significance (green) & three no-color findings:

• Licensees failed to follow station procedures.

• 5% of the overall findings for the 4-year period.

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IP 71124.05 Radiation Monitoring Instrumentation Technological innovation and industrys use of improved instrumentation have assisted station RP staff in the accurate detection of radiation and radioactive material:

• New instrument designs have eliminated moving parts and other similar factors that were prone to failure, converting to digital components that are rugged and reliable.

• New instrument employ self-diagnostics software to continuously assess instrument performance and take appropriate actions to ensure measurement quality, including placing itself out of service.

• Mature industry procedures and practices have resulted in sustained program excellence, experiencing very low instrument failure rates (0.27%, EPRI 0421207).

In the 4-year period, NRC identified seven findings: six low-safety significance (green) and one no-color finding for instrument calibration issues.

7% of the overall findings for the 4-year period.

©2019 Nuclear Energy Institute 12

IP 71124.06 Radioactive Gaseous and Liquid Effluent Treatment As a result of improved radioactive effluent control programs, the amount of activity of gaseous & liquid radioactive effluents has steadily decreased over time. In the last decade:

• noble gas effluent radioactivity from PWRs has decreased by a factor of ten and BWRs have decreased by a factor of five; and

• mixed fission and activation product radioactivity in liquid effluents has also decreased nearly ten times at BWRs and one-half at PWRs.

In the 4-year period, there were eight very low safety significant (green) findings; one no-color and one low-to-moderate safety significant (white) finding for a legacy instrument issue.

9% of the overall findings for the 4-year period. ©2019 Nuclear Energy Institute 13

IP 71124.07 Radiological Environmental Monitoring Program In the 4-year period, NRC identified six findings:

• 4 low-safety significant (green) findings and

• 2 no-color findings.

All findings were station procedure non-compliances.

5% of the overall findings for the 4-year period.

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IP 71124.08 Radioactive Solid Waste Processing and Radioactive Material Handling, Storage, and Transportation In the 4-year period, NRC identified thirteen findings:

• 12 low-safety significant (green) findings and

• 1 no-color finding.

All findings were diverse in cause and did not jeopardize public health and safety.

12% of the overall findings for the 4-year period.

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