RSCS Regulatory and Technical Expertise Helps Nuclear Utility Avoid a NRC White Finding

In late 2020, RSCS was requested to assist the management of a Midwestern nuclear power plant in responding to a potential NRC inspection finding that was initially screened as White. NRC inspectors believed that during preparation of a radioactive resin shipment, plant personnel failed to meet regulatory requirements, resulting in a performance deficiency of low to moderate safety significance or White. The Nuclear Energy Institute (NEI) estimates the cost to a plant in response to a White finding is about $1 M due to necessary corrective actions and supplemental NRC inspection activities. The RSCS Team coordinated a two-prong attack on this situation.

Ellen Anderson teamed with the regulatory staff and Radiation Protection Manager (RPM) to assist in their response to NRC. She provided regulatory guidance and recommendations to plant staff based on her many years of experience in this area. She addressed the regulatory aspect by researching past NRC precedence on similar industry performance deficiencies that NRC had previously screened as Green, or low safety significance.

In addition, Nasser Rashidifard demonstrated his technical expertise by performing independent Microshield dose calculations on the resin liner in parallel with plant staff. His calculations were 100% aligned with that of the client, concluding that dose rates on the resin liner did not meet the criteria for a White finding.

Based on their independent reviews on the two perspectives, both Ellen and Nasser concluded that this performance deficiency constituted a Green finding, not a White one.  They were able to provide additional information to the client which allowed a more complete assessment of the regulatory significance.

In late January, RSCS was notified by a very pleased plant management that the final NRC screening of this finding was determined to be Green rather than White.  The RPM noted that their success in overturning the White finding was due to the of the RSCS team. Not only did this maintain the client’s regulatory margin with the NRC but also saved them a considerable expense.


Advanced Radiological Assessment Technology Demonstrated at RSCS Technology Expo for Nuclear Decommissioning Decision Makers

RSCS sponsored a Technology Expo at our Seabrook NH facility to demonstrate several high technology solutions to nuclear decommissioning decision makers who are planning for the D&D of complex non-routine nuclear sites. We have been working with several vendors of cutting-edge robotics, imaging and in-situ sampling technologies to provide a comprehensive solution for assessing high radiologically impacted areas. Our integrated technology solution combined with our years of experience in decommissioning drove impactful discussions on how to best approach some of the most difficult decommissioning projects in the USA. 

RSCS 3DCDE model of high radiation area

Our Technology Expo provided a detailed overview and full demonstration of how new technology can provide data that enhances our advanced modeling capabilities. RSCS has built powerful 3D Building Information Models (BIM) from nuclear facility designs and standard operational survey data sets and have developed dynamic and interactive asset inventories for several nuclear sites. Imaging and data collected from advanced technologies augment these complex models which are coupled to site and regional Geographic Information Systems (GIS) in one Common Data Environment (CDE), resulting in highly detailed 3D maps of radiological conditions within nuclear plants, their subsurfaces, and surrounding regions. We have harnessed the power of robotics and remote detection and sampling technologies to provide this data through radiological assessments that are ALARA and low risk. Once a remote survey is completed and data is integrated into 3DCDE models, plant management has the information they need to determine areas that are safe to perform more comprehensive manned surveys to further enhance the data set. Final models can then be used for decision making on workflow and execution. As D&D efforts proceed, the dynamic models can be routinely updated to track the removal of assets and source term and make determinations on the appropriate waste classifications and demolition sequences and strategies. RSCS experience has confirmed that detailed front-end and in-process characterizations provide the most efficient means for effective work planning, which positively impacts cost, schedule adherence, regulatory compliance and worksite safety.

FARO Trek robot with 3D mobile scanning for remote and autonomous data capture in challenging environments

Following a series of presentations, decision makers where provided with hands-on live demonstrations of the technologies discussed, which included the Trek robot that integrates LIDAR-scanning to provide comprehensive 3D models of an area, and the WARP robot that provides radiological dose rates, air sampling, smear data and gamma distribution and isotopic identification, imaging and mapping using H3D’s CZT detectors. Finally, our WARP was equipped with a Viridian Scope laser extraction system that sampled the surface layer of concrete for radioactive contamination. These remotely operated robots and assessment technologies can safely enter high radiation areas to provide data on the current conditions inside the impacted areas. This assessment solution provides our clients with the ability to investigate areas with ambient dose rates up to 100 R/h that are impractical to characterize using traditional techniques.

WARP robot with Viridian Scope laser extraction sampling for in-situ analysis of surface contamination

The robotic platforms demonstrated are industrial strength, can withstand harsh environments, fit into confined and constrained spaces, and navigate successfully around obstacles. The Trek robot was designed and built to perform complex navigational operations such as walking up stairs. WARP performs diverse analytical operations using a custom designed and built payload management system that allows for efficient room or cubicle entries. To test and demonstrate the capabilities of these robotic platforms and technologies, a full scale realistic shielded equipment room was built including components, radiological conditions and entry challenges. The mock-up environment provided an ideal backdrop for demonstrating the power and capacity of this next generation integrated technology solution.

RSCS is proud to offer this state-of-the-art technology to the nuclear decommissioning industry.  After our participants observed several full-scale live demonstrations, they were convinced of the readiness and utility of this technology for their sites and are already envisioning new ways to use this assessment technology to benefit their decommissioning efforts. RSCS looks forward to deploying this fully integrated and functioning capability and incorporating future technologies to our platforms to adapt to the needs of our clients across our industries.

Live Demo Videos:

MARSSIM Training Provided to Nuclear Professionals

Recently, RSCS delivered our first MARSSIM class in Omaha NE to fifteen experienced nuclear professionals. Our instructors Eric Darois and Heath Downey conducted the course and were able to relay their first-hand experiences in implementing the MARSSIM processes for characterization and final status surveys in support of decommissioning projects. 

One of everyone’s favorite topics, ‘Statistics’, was covered in great detail.  We hope that this module was able to help demystify some of the more confusing concepts. In addition, the course presented details on using specific statistical software products as well as some helpful tips on using EXCEL for data manipulation. 

Our team had a great week in Omaha and unexpectedly enjoyed some great seafood! Thanks to All in Attendance!

Ellen Anderson Appointed to HPS Power Reactor Section Board

Ellen Anderson - RSCSRSCS Director of Radiological Services, Ellen Anderson, was recently appointed to the board of the Power Reactor Section (PRS) of the Health Physics Society. This appointment recognizes Ellen’s extensive experience with the nuclear power industry in the areas of radiation protection, emergency preparedness, regulatory affairs, nuclear oversight and security, including a ten-year tenure as the Director of Radiation Safety and International Liaison for the Nuclear Energy Institute’s (NEI).

The PRS was formed in 1982 with the goal of exchanging technical, regulatory, and business practice information amongst professionals in the nuclear power industry. Over the years, the mission of the board has expanded to include outreach and educational materials on radiation science and nuclear plant electric power generation for educators. In addition, the section provides scholarships to students pursuing two and four-year degrees in radiation science.

Congratulations Ellen on this appointment to the board of the Power Reactor Section!

RSCS Staff Receives the ANL Board of Governors James B. Porter, Jr. Team Award for Outstanding Safety Performance

Building 350 - RSCSRSCS is proud to announce that our staff member, Michael Grimes, was awarded the Argonne National Laboratory Board of Governor’s James B. Porter, Jr. Team Award for Outstanding Safety Performance. This award is given annually to recognize a team of laboratory employees who promote and demonstrate the principles of integrated safety management. Michael’s team is recognized for contributing to the creation and sustenance of a positive safety culture and a commitment to excellence in workplace safety.

Our staff have been working for several years at the Argonne National Laboratory to support the Building 350 Legacy Project. Building 350 was commissioned in 1959 to fabricate plutonium fuels. At the time the building was dedicated, it was one of the worlds largest and most advanced facilities which produced fast-reactor fuel elements and fuel plates for fast reactor core configuration proof of concept designs, including the ZPR-6 and ZPR-9 assemblies. The laboratory was closed down in 1973, and was decommissioned between 1978-1983. The Building 350 Legacy Project is now focused on recycling thousands of Certified Reference Materials for use at other DOE facilities, and preparing the structure for reuse as a radiological facility.

We are glad to recognize Michael Grimes for this prestigious award. His performance reflects our core commitment to work place safety while conducting radiological consulting and project management services for our clients. Congratulations Michael!

RSCS Deploys Wide Application Robotics Platform – WARP – for Remote Measurement Applications

WARP -  RSCSRSCS has developed a Wide Application Robotics Platform – WARP – to support remote measurement applications. This platform is based upon a robot design manufactured by RADeCO, and offers several advantages for remote survey applications. Features include a small footprint of 20″x 17″x 17″, a carryload of 20 lbs, easily removed tires for contamination control, 4 hour runtime batteries that can be swapped out in the field, onboard lighting in all directions, front and rear cameras and an open air range of 200 meters plus for data transfer. WARP has the ability to carry a payload of detectors and access confined spaces with ease through remote wireless operation.

Initially, RSCS will deploy WARP configured with ISOCS detectors, low and high dose Radeye detectors, GPS modules for gamma walkovers, air sampling equipment and smear collection magazines. We envision expanding the capabilities of WARP by incorporating gamma spectroscopy detectors including CZT and mini HPGe, gamma cameras, Lidar survey equipment and thermal imaging technology.

RSCS has embraced cutting edge robotics technology for complex decommissioning work for decades. This new WARP system will expand our field technician’s ability to perform accurate surveys in high radiation areas efficiently and safely.

New Research Evaluates Anthropogenic Fossil Carbon Dioxide and Claims of Its Dominance and Role in Global Warming

Skrable article - RSCSAs many of you may know, the three owners of RSCS are all alumni of the University of Massachusetts – Lowell’s radiological health program. Their college mentors, Ken Skrable, George Chabot and Clay French, performed an exhaustive and compelling analysis of the potential cause (or lack-thereof) of global warming and prepared a scientific article that details their conclusions (links below). 

Most people believe that global warming is due to increases of CO2 released to the atmosphere from the burning of fossil fuels by humans (i.e. anthropogenic CO2). Here are a few things you may not know.

  1. ‘Most’ carbon in the environment contains a radioactive isotope of carbon (carbon-14) at low but measurable levels. This is formed by nuclear reactions in the upper atmosphere from radiation emitted by the sun at a very constant level over the eons. We use this fact to do carbon-dating of old bones and other old organic matter. The exception to this is fossil fuels, which has virtually no C-14 remaining because of its age and the 5,730 year half-life of C-14.
  2. NOAA has been conducting air sampling at 2 mountain-top locations since 1959 where they measure CO2 and C-14 in the atmosphere.

If burning fossil fuels were the culprit for increasing CO2 levels then we would see a predictable decrease of C-14 specific activity, as the lack of C-14 in fossil fuels would dilute the predictable C-14 in the atmosphere. As indicated in the Figure above, as the anthropogenic component increases, the specific activity of carbon-14 decreases in a very predictable way as a result of the dilution of the initial specific activity in 1750 by the anthropogenic fossil component. In 2020 (i.e. 270 y since 1750), the specific activity is 13.81 dpm/gC, and the anthropogenic fossil component is 51.07 ppm, which is 12.4% of the total carbon dioxide of 411.36 ppm (not shown in Figure). Thus, carbon dioxide present in the atmosphere in 2020 from the burning of fossil fuels does not dominate the total, and it cannot be the primary cause of global warming.

Attempts to present this analysis to NOAA with the hope of obtaining a review and constructive criticism of the approach and methodologies taken have not been successful. We believe the research conducted by Ken Skrable, George Chabot and Clay French provides an unbiased analysis that has scientific merit. While the conclusions provided may be contrary to what many believe, we are presenting this research as it may have significant implications on the issue of global warming, its world-wide cost, and global politics.

Three separate documents describing this issue in detail are available for review; a synopsis of the research, an essay “Anthropogenic-fossil and Non Fossil Components of Mauna Loa and Niwot Ridge Annual Mean Carbon Dioxide”, and the article “Anthropogenic Fossil Carbon Dioxide and Claims of Its Dominance and Role in Global Warming“.



RSCS deploys J.L. Shepherd Model 81 Cs-137 Beam Calibrator

J.L. Shepherd Model 81 Cs-137 Beam CalibratorThis week, RSCS performed our first instrument calibrations using a newly acquired J.L. Shepherd Model 81 Cs-137 open beam calibrator.  This dual source calibrator has an exposure rate range of 100 microR/h to 4 R/h, increasing the laboratory’s ability to provide open beam calibrations at higher exposure rates. By bringing the Model 81 calibrator on-line, we have significantly increased our laboratory’s throughput capacity which will have a positive impact on our turn times for gamma detection instrument calibrations.

The Model 81 calibrator is a fully automated system that is controlled remotely using a control panel to set the distance to the source along a rail assembly, apply attenuators and actuate the sources.  In addition, exposures can be set using timers to remove operator error when calibrating integrated dose instruments.  Finally, the Model 81 has several safety features that will automatically shield the sources, including an optical sensor that detects movement into the beam area, and a SCRAM button.   

RSCS developed and implemented a detailed training program on the use of the Model 81 for our laboratory technicians and have added this calibrator to our ISO/IEC 17025:2017 Scope of Accreditation provided by ANAB.  Providing accredited calibrations using the Model 81 demonstrates our on-going commitment to providing fast, cost effective and high quality instrument calibrations to our clients.

RSCS Providing Essential Services During the COVID-19 Outbreak

RSCS at TMIOver the past several weeks, RSCS has been providing essential services to our customers at medical facilities, nuclear power plants and government agencies. We are proud to be able to continue to support the nation’s critical infrastructure during this time of unparalleled disruption.

Anticipating the implications of the COVID-19 outbreak earlier in the year, RSCS revised our Business Continuity Plans to address the unique risks that this novel virus posed to the safety of our employees and customers and to ensure we could provide essential services without interruption. As most of the States in the country enacted suspension of non-essential services, we were prepared with plans to protect our workforce to ensure the consistent delivery of services to our clients. As this situation has progressed, we have adopted the evolving guidance in our workplaces to prevent the spread of COVID-19. These plans and protocols have kept our workers healthy, and have allowed us to supply our services to the medical, energy and government sectors on time and with the same level of quality that our customers have come to expect from RSCS.

RSCS Cal instrumentsPatients requiring nuclear medicine procedures cannot wait for the COVID-19 outbreak to subside. Hospitals providing these services depend upon us for instrument calibration and repair services to ensure that their equipment used to survey hospital facilities are in tolerance. As more workers are telecommuting, and children have substituted remote learning for classroom education, the need for electrical power to support these operations is critical. Our project management services at operating nuclear plants have been delivered without interruption to ensure that the power grid is stable. Hazardous conditions at various nuclear sites and at government cleanup sites cannot be left unattended while we await the return to the new normal. These sites require that the efforts to safely remediate them stay on track. First responders and government agencies rely on us to maintain various instruments in the highest level of readiness for them to use. Our dedicated workers have stayed on the job, using best practices to stay healthy while performing this important work.

As the COVID-19 outbreak is contained and mitigated, we will continue to do our part to provide essential services at sites throughout the country and at our headquarters and laboratory in NH. We look forward to the day when our country is back open, but until then, we will do our part to help support our critical infrastructure.



RSCS COVID-19 Response Plans

covid-19 - RSCSIn response to the COVID-19 viral outbreak, RSCS has updated our Business Continuity Plan, which includes requirements for responding to an outbreak of contagious disease.  This plan details several measures to protect our workers, minimize business disruptions and respond to worsening conditions as they are identified by Local / Federal Government.  Specifically, our plan details the following:

  • Personal hygiene measures
  • Enhanced cleaning / disinfecting of work areas
  • Use of PPE for contamination control
  • Increased on-hand inventory of consumables / parts
  • Staff training on health & safety precautions, use of cloud-based file storage/sharing systems for remote work, implementation of response plans
  • Social distancing, split shifts and remote work schedules
  • Safe handling of incoming / outgoing packages
  • Travel restrictions
  • Quarantine measures and temporary office closures if ordered by Local / Federal Government or if in-company outbreak detected
  • Notification to customers / vendors

RSCS plans to minimize the impact of this emerging COVID-19 outbreak through the following measures:

  • Defense in depth – Staff in the Business Services Group and Calibration Laboratory are cross trained, health physicists and engineering staff working on projects have a similar knowledge base, pool of available radiological technicians typically exceeds staffing needs, staff substitutions are available in the case of illness.
  • Escalating levels of response based on changing conditions

    Initial response plan calls for social isolating as much as possible through use of remote work for corporate and projects staff and split shifts for Calibration Laboratory to allow for increased distancing of staff during the work-day.

    If conditions worsen, or in-house staff contract the illness, then the next level of response includes isolation of ill staff and quarantine and monitoring of staff who had close contact with ill staff.  As the majority of our staff can work remotely, quarantines should have minimal impact on the delivery of services to clients.  Calibration Laboratory staff can substitute for each other minimizing the impact of absenteeism on instrument calibration turn times.  Staff who work at client sites have substitutes available from our bench of health physicists, engineers and radiological technicians to ensure schedules can be maintained.

If mandatory quarantines, travel bans or other Local / Federal Government orders are imposed, then RSCS will comply as required and will resume projects and calibrations once orders are lifted.  While we have no control over this contingency, we commit to supporting our customers through work that can be accomplished remotely as much as possible. 

We will continue to monitor this situation closely and will update information on our webpage on our response plans if they should change in the future.