02.01 |
Inspection Planning and In-Office Inspection |
|
a. |
Review the most current Annual
Environmental Monitoring Report and
licensee assessment results to verify that
the REMP was implemented as required by
TS and the ODCM. Review the report for
changes to the ODCM with respect to
environmental monitoring, commitments in
terms of sampling locations, monitoring
and measurement frequencies, land use
census, interlaboratory comparison
program, and analysis of data. (Refer to
the NRC Branch Technical Position,
Revision 1, "An Acceptable Radiological
Environmental Monitoring Program," for
additional information) |
|
b. |
Review the ODCM to identify
environmental monitoring stations.
Review licensee self assessments, audits,
licensee event reports, and interlaboratory
comparison program results. |
|
c. |
Review FSAR for information regarding
the environmental monitoring program and
meteorological monitoring instrumentation. |
|
d. |
Review the scope of the licensee's audit
program to verify that it meets the
requirements of 10 CFR 20.1101(c). |
02.02 |
Onsite Inspection |
|
a. |
Walk-down between 20 and 30 percent of
the air sampling stations and 5 and 10
percent of the thermoluminescence
dosimeter (TLD) monitoring stations to
determine whether they are located as
described in the ODCM and to determine
the equipment material condition. |
|
b. |
Observe the collection and preparation of a
variety of environmental samples (e.g.,
ground and surface water, milk, vegetation,
sediment, and soil). Verify that
environmental sampling is representative of
the release pathways as specified in the
ODCM and that sampling techniques are in
accordance with procedures. |
|
c. |
Based on direct observation and review of
records, verify that the meteorological
instruments are operable, calibrated, and
maintained in accordance with guidance
contained in the FSAR, NRC Safety Guide
23, and licensee procedures. Verify that
the meteorological data readout and
recording instruments in the control room
and at the tower are operable. Compare
readout data (i.e., wind speed, wind
direction, and delta temperature) in the
control room and at the meteorological
tower to identify if there is any line loss
differences. |
|
d. |
Review each event documented in the
Annual Environmental Monitoring Report
which involved a missed sample,
inoperable sampler, lost TLD, or
anomalous measurement for the cause and
corrective actions. Conduct a review of the
licensee's assessment of any positive
sample results (i.e., licensed radioactive
material detected above the lower limits of
detection (LLDs). Review the associated
radioactive effluent release data that was
the likely source of the released material. |
|
e. |
Review any significant changes made by
the licensee to the ODCM as the result of
changes to the land census or sampler
station modifications since the last
inspection. Review technical justifications
for any changed sampling locations.
Verify that the licensee performed the
reviews required to ensure that the changes
did not affect its ability to monitor the
impacts of radioactive effluent releases on
the environment. |
|
f. |
Review the calibration and maintenance
records for up to 5 air samplers and
composite water samplers. |
|
g. |
Review calibration records for the
environmental sample radiation
measurement instrumentation (i.e., count
room). Verify that the appropriate
detection sensitivities with respect to
TS/ODCM are utilized for counting
samples (i.e., the samples meet the
TS/ODCM required LLDs). Review
quality control charts for maintaining
radiation measurement instrument status
and actions taken for degrading detector
performance. If the licensee uses a vendor
laboratory to analyze the REMP samples,
review the results of the vendor's quality
control program including the
interlaboratory comparison program to
verify the adequacy of the vendor's
program. Review any audits and technical
evaluations the licensee performed on the
vendor's program. |
|
h. |
Review the results of the licensees'
interlaboratory comparison program to
verify the adequacy of environmental
sample analyses performed by the licensee.
Review the licensee's quality control
evaluation of the interlaboratory
comparison program and the corrective
actions for any deficiencies. If applicable,
review the licensee's determination of any
bias to the data and the overall effect on the
REMP. |
|
i. |
Review QA audit results of the program to
determine whether the licensee met the
TS/ODCM requirements. |
02.03 |
Unrestricted release of material from the Radiologically Controlled Area (RCA) |
|
a. |
Observe several locations where the
licensee monitors potentially contaminated
material leaving the RCA, and inspect the
methods used for control, survey, and
release from these areas. When possible,
observe the performance of personnel
surveying and releasing material for
unrestricted use to verify that the work is
performed in accordance with plant
procedures. |
|
b. |
Verify that the radiation monitoring
instrumentation is appropriate for the
radiation types present (reference DAW
radio-chemical analysis results obtained in
Section 02.03) and was calibrated with
appropriate radiation sources. |
|
|
NOTE: 10 CFR Part 20 does not contain
release limits for the release of
contaminated material to unrestricted areas;
thus, the licensee's criteria should be that
no detectable licensed radioactive material
(radioactive gaseous and liquid effluents
excepted) is released for unrestricted use or
as waste into an unrestricted area. |
|
d. |
Review the licensee's equipment to ensure
the radiation detection sensitivities are
consistent with the NRC guidance
contained in IE Circular 81-07 and IE
Information Notice 85-92 for surface
contamination and HPPOS-221 for
volumetrically contaminated material. If
applicable, as discussed in HPPOS-250,
verify that the licensee performs radiation
surveys to detect radionuclides that decay
via electron capture. |
|
e. |
Review the licensee's procedures and
records to verify that the radiation detection
instrumentation is used at its typical
sensitivity level based on appropriate
counting parameters (i.e., counting times
and background radiation levels). Verify
that the licensee has not established a
"release limit" by altering the instrument's
typical sensitivity through such methods as
raising the energy discriminator level or
locating the instrument in a high radiation
background area. |
02.04 |
Identification and Resolution of Problems |
|
a. |
Review the licensee's Licensee Event
Reports, Special Reports, audits, and self
assessments related to the radiological
environmental monitoring program
performed since the last inspection.
Determine if identified problems are
entered into the corrective action program
for resolution. |
|
b. |
Review corrective action reports affecting
environmental sampling, sample analysis,
or meteorological monitoring
instrumentation. Interview staff and
review documents to determine if the
following activities are being conducted in
an effective and timely manner
commensurate with their importance to
safety and risk:
- Initial problem identification,
characterization, and tracking.
- Disposition of operability/reportability
issues.
- Evaluation of safety significance/risk
and priority for resolution.
- Identification of repetitive problems.
- Identification of contributing causes.
- Identification and implementation of
effective corrective actions.
- Resolution of non-cited violations
(NCVs) tracked in corrective action
system(s).
- Implementation/consideration of risk
significant operational experience
feedback.
Emphasis should be placed on ensuring
problems are identified, characterized,
prioritized, entered into a corrective action,
and resolved. |
|
c. |
For repetitive deficiencies or significant
individual deficiencies in problem
identification and resolution identified
above, determine if the licensee's self-assessment activities are also identifying
and addressing these deficiencies. |
The estimated hours to complete this procedure ranges from a minimum of 30 hours to a maximum of 35 hours, with a base of 32
hours.