ML18338A488
| ML18338A488 | |
| Person / Time | |
|---|---|
| Issue date: | 04/24/2019 |
| From: | Aron Lewin NRC/NRR/DIRS/IRIB |
| To: | |
| Lewin A, 415-2259, NRR/DIRS | |
| References | |
| Download: ML18338A488 (3) | |
Text
Inspection Procedure Assessment Summary and Outline of Proposed Changes Inspection Procedure (IP): IP 71124 Radiation Safety - Public and Occupational (see additional summaries for attachment-specific information)
Inspector Procedure Lead: David Garmon Estimated Hours to Complete Review: 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Date Review Completed: 12/7/2018
- 1. Results and assessment of review of IMC 0308, ROP basis document review IMC 0308 Att 2 was updated in January 2018 to address inconsistencies between the IPs and the inspection program basis.
- 2. Results and assessment of review of any applicable changes to PIs A three year review by the PI lead did not identify any significant changes to PIs that would result in a reduction or unintended gap in the key safety attributes of each safety cornerstone.
- 3. Results and assessment of review of any applicable changes to Rules and STSs Not applicable
- 4. Results and assessment of review of recent Operating Experience Not applicable for 71124; however, individual attachments to this IP may require revision based on Operating Experience
- 5. Results and assessment of review based on RRPS data Expended hours align with estimated hours. See breakdown below Period: 2016-2017 71124.01* 71124.02 71124.03 71124.04 71124.05 71124.06 71124.07 71124.08 Avg Hours; Range 36; 32-40 46; 32-60 16; 12-20 20; 16-24 32; 28-36 35; 31-39 29; 25-33 34; 30-38
- Sites** Total Hrs Hrs Per Site Total Hrs Hrs Per Site Total Hrs Hrs Per Site Total Hrs Hrs Per Site Total Hrs Hrs Per Site Total Hrs Hrs Per Site Total Hrs Hrs Per Site Total Hrs Hrs Per Site Region I 16 584.0 36.5 695.0 43.4 359.0 22.4 261.0 16.3 546.0 34.1 572.0 35.8 479.0 29.9 573.0 35.8 Region II 18 646.0 35.9 748.0 41.6 308.0 17.1 335.0 18.6 510.0 28.3 546.0 30.3 459.0 25.5 475.0 26.4 Region III 15 558.0 37.2 778.0 51.9 248.0 16.5 279.0 18.6 501.0 33.4 485.0 32.3 459.0 30.6 511.0 34.1 Region IV 13 428.0 32.9 618.0 47.5 242.0 18.6 202.0 15.5 380.0 29.2 403.0 31.0 337.0 25.9 385.0 29.6
- For 71124.01 IP the Total Hrs is the 2017 hours0.0233 days <br />0.56 hours <br />0.00333 weeks <br />7.674685e-4 months <br /> since this procedure is a 1 year procedure
- The number of sites may have changed over the period considered; however, the impact on hours per site is negligible
- 6. Feedback Forms Form No. Date Summary of Issue Status Potential Submitted Relevant IMC Docs 71124.01- 10/9/2013 ROP inspection In 2018, NRR IP 71124 1942 procedures are not committed to develop IMC 0308 consistent with materials an oversight IMC 0612 inspection program framework for because they do not security of radiative require inspectors to material under Part review the safety and 37 at power reactor
security of licensees. This FBF irradiators/calibrators at will be considered nuclear power plants as during the is done as part of the development of that materials inspection framework.
program 71124.05- 10/3/2014 The current procedure In 2018, NRR IP 71124 2096 does not address Parts committed to develop IMC 0308 37 and 73 requirements an oversight IMC 0612 for quantities of framework for radioactive material of security of radiative concern. material under Part 37 at power reactor licensees. This FBF will be considered during the development of that framework.
71124.08- 10/3/2014 The current procedure In 2018, NRR IP 71124 2095 does not address Parts committed to develop IMC 0308 37 and 73 requirements an oversight IMC 0612 for quantities of framework for radioactive material of security of radiative concern. material under Part 37 at power reactor licensees. This FBF will be considered during the development of that framework.
- 7. Other Considerations The summarized results of the assessment for all IP 71124 attachments is included in this document. However, individual statistics related to inspection hours and other attachment-specific information is included in the assessment summary for that specific attachment.
- 8. Results of discussions with regions Inspectors contacted:
- Ron Rolph (RI)
- Harry Anagnostopoulos (RI)
- Jonathan Rivera (RII)
- Adam Nielsen (RII)
- Carmen Dykes (RII)
- Natasha Greene (RIV)
- Louis Carson (RIV)
Potential changes to consider:
- Consider developing an outage inspection procedure. This procedure would include samples that were only appropriate for completion during outage periods and would mimic what inspectors already do as a result of the inspection planning process.
- Even after the changes that were recently published in January 2018, there is still some redundancy in the .01 and .02 attachments.
- Certain areas can benefit from a focused assessment: ALARA (too much time, not enough significance) and Effluents and Rad Monitoring (too little time, hard to get done with allotted time)
- Some inspectors are interested in having flexible inspection time while on site. Perhaps the amount of time can be based on plant performance
- When evaluating changes to the inspection procedures, consider the licensee staff that inspection personnel will be interacting with during the onsite portion of inspections.
There may be some efficiency gains in moving requirements to match-up with licensee resources.
- Consider incorporating Part 37 into the inspection program because security of radiological material was already part of the regulations via 20.1801 and 20.1802.
Recommendations
- Conduct an assessment focusing on ALARA, effluent and rad monitoring inspections as part of the ROP Enhancement effort. During this assessment, be sure to consider licensee staff support to the inspection process in determining the most efficient means to execute inspection requirements.