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.