ML020420052

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Regulatory Conference - January 23 2002
ML020420052
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 02/05/2002
From: Gody A
Division of Reactor Safety IV
To: Terry C
TXU Electric
References
Download: ML020420052 (75)
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February 5, 2002 Mr. C. L. Terry TXU Electric Senior Vice President & Principal Nuclear Officer ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION, UNITS 1 AND 2 -

REGULATORY CONFERENCE - JANUARY 23, 2002 Dear Mr. Terry This refers to the meeting conducted in the Region IV Office, Arlington, Texas, on January 23, 2002. As you are aware, the purpose of this meeting was for you to provide information that would assist in our assessment of your ability to prevent the release of licensed radioactive material to an unrestricted area that could cause a radiation dose to members of the public. The attendance list and the licensees presentation are enclosed (Enclosures 1 and 2).

Additionally, during this meeting, you provided us one additional corrective action document (SMF-2001-002621), which we had not previously reviewed.

In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its enclosures will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRCs document system (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).

Sincerely,

/RA/

Anthony T. Gody, Chief Operations Branch Division of Reactor Safety Dockets: 50-445; 50-446 Licenses: NPF-87; NPF-89

Enclosures:

1. Attendance List
2. Licensee Presentation

TXU Electric cc w/o enclosures:

Roger D. Walker Regulatory Affairs Manager TXU Generation Company LP P.O. Box 1002 Glen Rose, Texas 76043 George L. Edgar, Esq.

Morgan, Lewis & Bockius 1800 M. Street, NW Washington, D.C. 20036 G. R. Bynog, Program Manager/

Chief Inspector Texas Department of Licensing & Regulation Boiler Division P.O. Box 12157, Capitol Station Austin, Texas 78711 County Judge P.O. Box 851 Glen Rose, Texas 76043 Chief, Bureau of Radiation Control Texas Department of Health 1100 West 49th Street Austin, Texas 78756-3189 John L. Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711-3189

TXU Electric Electronic distribution from ADAMS by RIV:

Regional Administrator (EWM)

DRP Director (KEB)

DRS Director (ATH)

Senior Resident Inspector (DBA)

Branch Chief, DRP/A (DNG)

Senior Project Engineer, DRP/A (KMK)

Staff Chief, DRP/TSS (PHH)

RITS Coordinator (NBH)

R:\_CPSES\2001\cp1-23-01ms-mps.wpd SHP:PSB C:OB MPShannon/lmb ATGody

/RA/ /RA/

01/24/02 2/05/02 OFFICIAL RECORD COPY T=Telephone E=E-mail F=Fax

ENCLOSURE 1 MEETING: TXU / COMANCHE PEAK STATION

SUBJECT:

Control of Radioactive Material Identified in NRC Inspection 2001-07 DATE: January 23, 2002 ATTENDANCE LIST (Please Print Clearly)

NAME ORGANIZATION POSITION/TITLE Lance Terry TXU Energy Sr. V.P. & Principal Nuc. Off.

Daniel Wilder TXU CPSES Rad & Ind Safety Mgr John R. Curtis TXU CPSES RPM Roger D. Walker TXU CPSES Regulatory Affairs Manager Scott E. Bradley TXU CPSES Health Physics Supervisor Michael P. Shannon NRC Senior Health Physicist Ellis Merschoff NRC Regional Administrator Arthur T. Howell NRC Director, Division of Reactor Safety Gail M. Good NRC Chief, Plant Support Branch Anthony T. Gody NRC Chief, Operations Branch David Graves NRC Chief, Project Branch A Gary Sanborn NRC Director, ACES Chris Nolan NRC Enforcement Specialist Scott Schwind NRC Resident Inspector - CPSES Don Allen NRC Senior Resident Inspector - CPSES Karla Smith NRC Regional Counsel Larry Ricketson NRC Senior Health Physicist Thomas Klug NRC Physical Security Inspector Bernadette Baca NRC Health Physicist Joseph L. Taylor NRC DRS Reactor Inspector Eddy L. Crowe NRC

John M. Mateychick NRC Reactor Inspector Daniel R. Carter NRC Health Physicist R. La Vonn TXU Media Jerry Lee TXU Community Relations Mitch Lucas TXU Nuclear Overview Manager Bob Kidwell TXU Reg. Affairs Douglas W. Snow TXU Reg. Affairs Alan Hall TXU Nuclear Overview Don Woodlan TXU Reg. Affairs Ralph Andersen NEI Health Physicist Shari Mosty TXU RP Technician Tim Woods TXU RP Technician Joe Rincon TXU RP Technician Karl Warkentin Retired Rana McGaughy TXU Nuclear Overview

ENCLOSURE 2 TXU PRESENTATION

TXU Energy Comanche Peak Steam Electric Station Public Radiation Safety Regulatory Conference January 23, 2002

Public Radiation Safety - Regulatory Conference Introduction Lance Terry Senior Vice President and Principal Nuclear Officer Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Radiation Protection Program Detailed and Conservative Procedures

  • Used cotton glove liners are not allowed outside the RCA Aggressive System Health Program
  • RadWorker practices self-identified in 1999 as not meeting expectations Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Radioactive Material Control Program Most of these examples were of such low-level activity that these items could have been surveyed and released from the RCA using the instruments normally used for RCA egress.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Radioactive Material Control Program These items were self-identified and entered into our Corrective Action Program to preclude more significant events.

Many of these items were found by processes put in place in response to prior events.

Previous corrective actions are producing positive results.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Licensee Position All of the examples should screen out as MINOR ISSUES using the Group 1 questions of IMC-0610*

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Licensee Position Even if all the examples are considered GREATER THAN MINOR, the final risk significance should be determined to be GREEN per IMC-0609, App. D Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Concerns

  • No credit given for the Defense-In-Depth built into our program
  • Survey standards based on a sites capabilities
  • Possible negative incentive to document issues at a low threshold Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Agenda

  • Timeline D. Wilder
  • CPSES Radioactive Material D. Wilder Control Program
  • Discussion of Individual Events D. Wilder
  • Event Risk(s) in Perspective D. Wilder
  • CPSES Position on Issue Significance R. Walker
  • Summary and Closing L. Terry Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Timeline Danny Wilder Radiation and Industrial Safety Manager Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CY 1999 17 SMFs related to radworker practices in first 6 months provided indications of an adverse trend. The following corrective actions were taken in response:

  • RP Department met with contractor personnel to emphasize proper radworker practices.
  • RP Department instituted searches of modesty clothing prior to laundry RP and Nuclear Overview (NOD) Departments performed a combined assessment of radworker practices during the FALL refueling outage (1RF07). (NOD Eval #1999-043)
  • Several specific areas (training, equipment, awareness, etc) were identified for further evaluation to address adverse trend
  • Negative observations were not limited to any one group of workers
  • Initiated SMF #1999-3100 to document the combined program assessment and capture corrective actions RP Program Health report for 4th Qtr 1999 was rated UNACCEPTABLE due to trend Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference SMF 1999-3100 Corrective Actions

  • Human Performance Day materials developed to specifically address radiation worker practices
  • Initiated revision of Radiation Worker Training (RWT) materials to include current radiation worker issues
  • Reinstated the RWT dressout practical demonstrations
  • Specific training for RP Techs on radiation worker issues, management expectations for SmartForm generation, and radiation worker coaching techniques Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference RADIOLOGICAL PRACTICES Error Reporting by Organization End of 1999 End of 2000 End of 2001 RP Dept RP Dept RP Dept 17% 50% 77%

others others others 83% 50% 23%

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CY 2000 2 SMFs in first 9 months (no refueling outage) concerning low-level radioactive materials outside the RCA.

In June, INPO performed a scheduled E&A visit. Prior to this visit, TXU self-identified Radworker Practices as a potential area for improvement.

INPO concurred with both the characterization and our plan of action at the end of their E&A visit.

RP and NOD performed a combined reassessment of RadWorker practices during the FALL refueling outage (2RF05). (NOD Eval #2000-043)

  • Improvements noted in some areas of radiation worker performance
  • Continued challenges with control of low-level radioactive materials
  • Initiated SMF #2000-3185 to document the combined program assessment and capture corrective actions Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference SMF 2000-3185 Corrective Actions Total of 10 recommendations for improvement in radiation worker performance and contamination controls.

2 of these recommendations were related to the problems with inadvertent releases of low-level radioactive materials and were addressed by:

  • Modesties without pockets were acquired and implemented
  • Disposable glove liners were acquired and implemented Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CY 2001 NOD performed a followup assessment of RadWorker practices during the Spring refueling outage (1RF08). (NOD Eval #2001-013)

  • Noted improvement in radiation worker practices and release of material, but problems have not been completely solved.
  • Pocket-less modesties and disposable gloves a success
  • RP needs to move beyond these barrier-type improvements and address underlying worker behavior issues to keep getting better During the FALL 2001 NOD Annual RP program evaluation, several aspects of RPs corrective action program were identified for improvement. (NOD Eval #2001-039)
  • Corrective actions were being taken in response to SMF issues, but these actions were not always addressing the human performance aspects.
  • RP needs to work on addressing generic impacts and performance by groups outside the RP Department.
  • Initiated SMF #2001-2186 to document the program evaluation and capture corrective actions Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference SMF 2001-2186 Corrective Actions

  • Performed a self-assessment of human performance within the RP Dept.
  • Published human performance expectations to RP Dept.
  • Initiated tracking of any negative trends, noted during monthly trend analysis, by entry into the SMF database
  • Consolidated RP corrective action documentation under the Health Physics Supervisor for consistency
  • Reformed the RP Program Health (Station) Team with members from departments outside RP.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference NRC Inspection Reports 50-445;446/01-04:

  • 2 licensee-identified violations related to the improper release of radioactive materials from the RCA 50-445;446/01-07:
  • verbal exit cited 3 additional licensee-identified events with a potential for public exposure
  • initially characterized as GREEN finding
  • CPSES initiated SMF #2001-2621 to document preliminary findings, evaluate causes, and capture corrective actions
  • Scope includes all events
  • Formed inter-disciplinary task team to perform a complete programmatic evaluation; including root cause analysis
  • Action plan still being formulated Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Corrective Actions The 3 programmatic SmartForms (1999-3100 / 2000-3185 / 2001-2186) although not tied to any individual event, were opened to address the global issues concerning not only radioactive material controls, but also the larger issue of RadWorker practices.

The 11 individual event SmartForms documented in IR 01-07 were trended to these 3 programmatic SmartForms to determine the effectiveness of past corrective actions.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference QUESTIONS?

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Radioactive Material Control Program The guidance of NRC IE Circular 81-07 has been used extensively as a basis for our radioactive material control program.

This document provides guidance for operational detection levels which will provide reasonable assurance that contaminated materials are properly controlled and disposed of while at the same time providing a practical method for the uncontrolled release of materials from the restricted area.

Based on providing adequate survey techniques and equipment (friskers) to be able to detect:

  • 5000 dpm/100 cm2 total and
  • 1000 dpm/100 cm2 removable beta/gamma contamination Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Radioactive Material Control Program We believe that 8 of the 11 examples from IR 50-446;446/01-07 were of such low-level activity, or the activity was so situated, that these items could realistically have been surveyed and released from the RCA.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Monitoring Equipment

  • Frisker (and GM-type probes)
  • Primary Survey Instrument
  • Used for surface contamination and smear counting Beta-Gamma radiation
  • Lower Limit of Detection is 100 counts above background, approximately 5000 DPM / 100 cm2
  • Accuracy dependant on rate at which probe is moved, distance to the object, and background
  • Most widely-used instrument and the accepted standard in the industry for survey and release of materials
  • Only instrument which NRC has provided guidance (IE 81-07).

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Monitoring Equipment

  • Personnel Contamination Monitor (PCM2)
  • Primary personnel contamination detection device
  • Gas-flow proportional detectors (34 total)
  • Detects both point and distributed Alpha-Beta
  • Alarms at 5000 DPM per zone or 30,000 DPM summation (Beta)
  • Insensitive to Gamma
  • Alpha-Beta sources may be shielded by clothing
  • Accurate only for Alpha-Beta surface contamination
  • More dependable and consistent than frisking for distributed contamination Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Monitoring Equipment

  • Final check of personnel & hand carried items
  • Plastic scintillation detectors
  • Gamma sensitive
  • Detects approximately 100 nCi total activity
  • Accuracy and dependability limited by geometry
  • Final check for gross contamination & internal contamination
  • Demonstrated to detect less than 1% of Annual Limit of Intake (ALI)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Monitoring Equipment

  • Small Articles Monitor (SAM-9)
  • Qualitative check of hand carried items
  • Gamma-sensitive plastic scintillation detectors
  • Detectors are summed for an effective alarm value of 3820 DPM
  • Monitors the entire article, not just the surface, for a VOLUME activity.
  • Insensitive to Alpha-Beta radiation
  • Limited use to small items
  • SAM set up for maximum sensitivity (a qualitative go/no-go) vs. quantitative accuracy Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Monitoring Equipment Detection Capability Comparison Frisker SAM-9 Hood 100 ncpm Alarm 1,000 dpm 18,300 dpm Hood 90 ncpm Alarm 900 dpm 14,400 dpm Hood 40 ncpm Alarm 400 dpm 11,100 dpm Velcro 110 ncpm Alarm Strap 1,100 dpm 12,050 dpm Velcro 80 ncpm Alarm Strap 800 dpm 6770 dpm NOTE: None of these articles were above the alarm setpoints of the PCM-2 or the PM-7.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Defense In Depth Measures All hand-carried items (with certain specific exceptions) are surveyed by a SAM-9 prior to release from the RCA Survey of all trash dumpsters, daily during outage and prior to disposal during non-outage periods Searches of all modesty clothing prior to laundry Survey of areas outside the RCA, schedule varies with plant conditions Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference QUESTIONS?

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Discussion of Events Date Corrective Description Discovered by Followup Activity Hypothetical 1 - PM-7 Frisker Survey? Determined by: Dose 2 - Modesty search Action 3 - Awareness Yes / No 1 - frisker (mRem) 4 - Routine survey If Yes, then give 2 - SAM-9 SMF # 3 - MCA 5 - SAM-9 net cpm 2

01/24/00 SMF 2000-0187 Reusable cotton PC glove liner 2 Y - <100 2.09E-09 Ci 4.00e-05 1

04/11/00 SMF 2000-1080 Safety harness, Warehouse C 1 Y - 1000 4.50E-09 Ci 4.30e-05 2

09/25/00 SMF 2000-2380 Extension cord, cold tool room 3 Y - <100 1.30E-09 Ci 9.60e-06 2

09/30/00 SMF 2000-2445 Reusable cotton PC glove liner 2 N 7.30E-09 Ci 4.20e-05 1

10/01/00 SMF 2000-2458 Temporary power pack 3 Y - 100 4.50E-09 Ci 2.60e-05 3

10/12/00 SMF 2000-2740 Oily rags found in dumpster 4 N 1.00E-06 Ci 3.40e-03 2

11/03/00 SMF 2000-3122 Reusable cotton PC glove liner 3 Y - <100 1.30E-09 Ci 2.20e-05 03/27/01 SMF 2001-0630* Air fitting in tool bag 5 Y - 2000 9.00E-09 Ci1 3.80e-05 2

04/06/01 SMF 2001-0850 Velcro straps & yellow masslin 2 Y - <100 4.90E-09 Ci 2.80e-05 1

04/11/01 SMF 2001-0968 Individual wearing velcro straps 3 Y - 160 7.30E-10 Ci 4.20e-06 05/24/01 SMF 2001-1352* Tool alarmed PM-7 monitor at AAP 1 Y - 7000 3.15E-08 Ci1 5.90e-04

  • Indicates item captured as a NCV in prior NRC Inspection Report (50-445/01-04; 50-446/01-04)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-0187
  • Cotton Glove Liner
  • Found in bag of dirty modesties being searched prior to laundering
  • Item did not leave the Protected Area
  • Less Than 100 net counts per minute with frisker
  • Hypothetical Dose - 4 E-5 mrem
  • Assumed it left RCA in modesty pocket
  • Based on testing, item would NOT have alarmed PCM-2 or PM-7 Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-1080
  • Safety Harness
  • Found at Alternate Access Point (AAP) PM-7
  • Item had been outside Protected Area
  • 1000 net counts per minute with frisker
  • Hypothetical Dose - 4.3 E-5 mrem
  • The harness was obtained at Warehouse C (RAM storage area) and stored on the motorized personnel lift
  • Inadequate survey of items on the motorized personnel lift Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-2380
  • Extension Cord labeled Radioactive
  • Found on MSC Cold Tool Room Counter
  • Item did not leave the Protected Area
  • < 100 net counts per minute with frisker
  • 1.3 E-03 µCi (estimated from SAM alarm)
  • Hypothetical Dose - 9 E-6 mrem
  • Unknown how cord left the RCA Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-2445
  • Cotton Glove Liner
  • Found in bag of dirty modesties being searched prior to laundering
  • Item did not leave the Protected Area
  • No frisker survey
  • Hypothetical Dose - 4.2 E-5 mrem
  • Assumed it left RCA in modesty pocket
  • Based on testing, item would NOT have alarmed PCM-2 or PM-7 Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-2458
  • Temporary Power Pack
  • Discovered adjacent to the MSC
  • Item did not leave the Protected Area
  • 100 net counts per minute on a large area smear counted with frisker
  • Hypothetical Dose - 2.6 E-5 mrem
  • Was incorrectly surveyed for release from the RCA Yard Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-2740
  • Oily Rags
  • Found using MicroR meter in trash dumpster during routine survey
  • Item did not leave the Protected Area
  • Hypothetical Dose - 3.4 E-3 mrem
  • The origin of the rags could not be determined
  • Actions Taken:
  • Dumpster tagged and taken into the RCA
  • Followup survey of all dumpsters and temp trailers
  • Frequency of dumpster surveys increased to daily during outages Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2000-3122
  • Cotton Glove Liner
  • Discovered on a gas bottle rack outside the RCA
  • Item did not leave the Protected Area
  • Less Than 100 net counts per minute with frisker
  • Hypothetical Dose - 2.16 E-5 mrem
  • Assumed it left RCA in modesty pocket
  • Based on testing, item would NOT have alarmed PCM-2 or PM-7 Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2001-0630
  • Chicago fitting
  • Alarmed the SAM-9 at RCA Yard Exit
  • Item had been outside Protected Area
  • 2000 net counts per minute with frisker
  • Hypothetical Dose - 3.8 E-5 mrem
  • The fitting had been previously located at Warehouse C
  • Single spot of fixed contamination located inside the fitting
  • SAM-9 monitor installed for use in Whse C Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2001-850
  • Velcro Straps & Masslin
  • Found in bag of dirty modesties being searched prior to laundering
  • Items did not leave the Protected Area
  • <100 net counts per minute with frisker
  • Hypothetical Dose - 2.8 E-5 mrem
  • Assume individual wore the straps and masslin was in modesty pockets
  • Based on testing, items would NOT have alarmed PCM-2 or PM-7 Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2001-968
  • Velcro Straps
  • RP Technician noticed individual wearing straps outside the RCA
  • Items came from outside the Protected Area
  • 160 net counts per minute with frisker
  • Hypothetical Dose - 4.2 E-6 mrem
  • Individual stated he had the straps from another plant and been through the portals
  • Based on testing, items would NOT have alarmed PCM-2 or PM-7 Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

  • SMF 2001-1352
  • Channel Lock Pliers
  • Alarmed the PM-7 at the Alternate Access Point (AAP)
  • Items did not leave the Protected Area
  • Checked out of the Cold Tool Room
  • 7000 net counts per minute with frisker
  • Hypothetical Dose - 5.9 E-4 mrem
  • Suspect the tool came from the RCA Yard Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference HYPOTHETICAL RISK associated with this material Total hypothetical dose from all 11 items

= 0.0043 mrem (4.3E-6 Rem)

The risk associated with this level of dose is not significant.

< 0.1% of the SDP individual event decision block

< 0.005% of the public dose limit of 10CFR20.1301

< 0.02% of the operational dose standards of 40CFR190.10

< 1% of the Negligible Individual Dose of NCRP-116.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Perspective on Hypothetical Risk Significance

  • Total activity of all items is conservatively estimated to be : 1 µCi
  • An uptake of this amount of activity would not require individual monitoring
  • Assuming the CPSES DAW Nuclide mix, the uptake would be less than 1% of an ALI Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference QUESTIONS?

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Issue Significance Determination Roger Walker Regulatory Affairs Manager Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Issue Significance All potential findings must be screened first using the NRCs Inspection Manual Chapter 0610*, Reactor Inspection Reports Appendix B Thresholds for Documentation prior to being evaluated by the actual Significance Determination Process (SDP) of IM 0609.

NRC Inspection Manual Chapter 0609, Significance Determination Process (SDP) Appendix D, Public Radiation Safety addresses Radioactive Material Control related issues.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Issue Significance Process Flow Path Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Excerpt from IMC 0610* dated 02/27/01 B. Minor Issues/Violations (group 1 questions)

If the answers to all of the group one questions is "No", the issue may be considered minor. However, the inspector should also determine whether the issue has extenuating circumstances that warrant documenting the issue in the inspections report by reviewing group 3 questions. Additional guidance and examples can be found in the NRC Enforcement Manual, Guidance Documents, Guidance for Classifying Violations as Minor Violations.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Excerpt from IMC 0610* dated 02/27/01 (1) Does the issue have an actual or credible impact on safety?

(2) Could the issue be reasonably viewed as a precursor to a significant event?

(3) If left uncorrected, would the same issue under the same conditions become a more significant safety concern?

(4) Does the issue relate to collecting or reporting performance indicators that would have caused a PI to exceed a threshold?

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference NRC Inspection Report From NRC IR 50-445/01-07; 50-446/01-07 section 40a2c(2):

The events were more than minor because the failure to properly survey radioactive material has a credible impact on safety, in that, an inadvertent release of radioactive material and an unplanned exposure could occur to occupational workers and members of the public. (Emphasis added)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Position IMC 0610* defines CREDIBLE as: A scenario offering reasonable grounds for being realistic (given a set of existing conditions postulating a scenario with no more than one if ). (emphasis added)

Since the potential impact on safety (significance) of these items is inadvertent dose to the public, the only applicable variables are:

  • Time of exposure; Or
  • Activity (dose rate)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Position Varying time of exposure If all items were assumed to aggregate together and expose an individual 24 hr/day for 365 days, the maximum calculated exposure would still be < 0.005 Rem.

A more realistic, but still conservative calculation of the collective exposure would be about three orders of magnitude less.

0.0043 mRem (4.3E-6 Rem)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Position Varying activity of items released We believe 9 of the 11 examples from IR 50-446;446/01-07 were surveyed and could have been no more than 10X their actual activity without detection by either a PCM or PM7 monitor.

This would change the dose estimate from these materials to only 4.3E-5 Rem. Still a very small fraction of the public dose limits.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference NRC IM Chapter 0610*

Do the issues have an actual or credible impact on safety?

Actual impact on safety?

NO Credible impact on safety?

NO Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Position When the issue is assessed via SDP,

  • this issue should screen out as a minor issue using the Group 1 questions of IMC-0610*

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference NRC IM Chapter 0610*

Group 2 Questions Radiation SafetyPublic (1) Does the issue involve an occurrence in the licensee's radiological effluent monitoring program that is contrary to NRC regulations or the licensee's TS, Offsite Dose Calculation Manual (ODCM), or procedures?

(2) Does the issue involve an occurrence in the licensee's radiological environmental monitoring program that is contrary to NRC regulations or the licensee's TS, ODCM, or procedures?

(3) Does the issue involve an occurrence in the licensee's radioactive material control program that is contrary to NRC regulations or the licensees procedures?

(4) Does the issue involve an occurrence in the licensees radioactive material transportation program that is contrary to NRC or Department of Transportation (DOT) regulations or licensee procedures?

CPSES agrees that the answer would be yes to question #3 for any of the examples noted in the inspection report, because they each relate to conditions contrary to our procedures. As such, any example that is determined to be more than minor would be reviewed under the 0609 SDP.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Public Radiation Safety SDP From IMC 0609, Appendix D:

Radioactive Material Control Program Objective This branch of the logic diagram focuses on the licensees radioactive material control program. It assesses the licensees ability to prevent the inadvertent release of licensed radioactive material to an unrestricted area that can cause a radiation dose to members of the public. (emphasis added)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Public Radiation Safety SDP From IMC 0609, Appendix D:

Radioactive Material Control Program Basis 10 CFR Part 20 contains the requirements for the control and disposal of licensed radioactive material. At a licensees facility, any equipment or material that came into contact with licensed radioactive material or that had the potential to be contaminated with radioactive material of plant origin and are to be removed from the facility must be surveyed for the presence of licensed radioactive material. This is because NRC regulations, with one exception in 10 CFR 20.2005, provide no minimum level of licensed radioactive material that can be disposed of in a manner other than as radioactive waste or transferred to a licensed recipient.

(emphasis added)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Public Radiation Safety SDP SDP determination process Is there a finding in the licensees radiological material control program that is contrary to NRC regulations? If yes, the question is what is the dose impact (as calculated by the licensee) of the event? If the dose impact was not more than 0.005 rem total effective dose equivalent (TEDE) and there were not more than 5 of these events in the inspection period, then the SDP classification is GREEN.

If the dose impact was greater than 0.005 rem TEDE or there were more than 5 occurrences that were not above 0.005 rem TEDE in the inspection period (two years), then the SDP classification is WHITE. If the dose impact is greater than 0.1 rem TEDE (exceeds 10 CFR Part 20 public dose limit), the SDP classification is YELLOW. If the dose impact was greater than 0.5 rem TEDE, the SDP classification is RED.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Definitions From 10 CFR 20.1003 RESTRICTED AREA - an area, access to which is limited by the licensee for the purpose of protecting individuals against undue risks from exposure to radiation and radioactive materials.

CONTROLLED AREA - An area, outside of a restricted area but inside the site boundary, access to which can be limited by the licensee for any reason.

UNRESTRICTED AREA - Unrestricted area means an area, access to which is neither limited nor controlled by the licensee.

From CPSES ODCM CONTROLLED AREA - A CONTROLLED AREA means an area outside of a restricted area, as defined in 10 CFR20.1003, but inside the SITE BOUNDARY, access to which can be limited by the licensee for any reason.

UNRESTRICTED AREA - An UNRESTRICTED AREA means any area beyond the SITE BOUNDARY.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Radioactive Material Control Program CPSES area boundaries taken from CPSES FSAR, Figure 2.1-2 RED annotations added to the original Unrestricted Area Unrestricted Area Controlled Area Unrestricted Area Unrestricted Area Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference NRC Inspection Report From NRC IR 50-445/01-07; 50-446/01-07 We note that none of the material was released from the owner-controlled property and that the potential public exposure associated with these items was less than 5 millirem, a small fraction of NRC limits. (emphasis added)

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Public Radiation Safety SDP What should be counted as an event / occurrence?

One interpretation could be that any violation of your Rad Material Control Program counts an event.

However, CPSES believes that to count as event / occurrence, and be consistent with the objective and basis of the SDP, that there must be an occurrence of an inadvertent release of licensed radioactive material to an unrestricted area that can cause a radiation dose to members of the public.

If the material has not been released to an unrestricted area it should not count as an event.

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference CPSES Position on SDP Significance Since none of these events involve a release of radioactive materials to an unrestricted area (as defined by CPSES ODCM), this issue should be considered to have zero examples that fall within the scope of IM 0609 App D as an event / occurrence, and the significance would be Green Even if the Protected Area boundary, because of the portal monitors, is conservatively used as defining the Unrestricted Area for SDP purposes, then only 3 of the events should be counted.

  • SMF 2000-1080; Safety Harness from WHSE C
  • SMF 2001-0630; Chicago air fitting from WHSE C
  • SMF 2001-0968; Velcro Straps In either case, the number is still less than 5 and therefore Green Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Significance Conclusion CPSES believes that even if the examples are considered greater than minor, the finding should be characterized as GREEN per IMC-0609, App. D This is because:

  • no event had a dose impact > 5.0 mrem
  • there are < 5 events that could have exposed members of the public in an unrestricted area Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference QUESTIONS?

Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference Summary Lance Terry Senior Vice President and Principal Nuclear Officer Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

SUMMARY

RP Management at Comanche Peak:

  • self-identified the concerns with the program
  • took conservative actions to ensure no loss of control of radioactive materials
  • documents issues at a low threshold
  • is still aggressively working to eliminate these low-level items Comanche Peak Steam Electric Station TXU Energy

Public Radiation Safety - Regulatory Conference

SUMMARY

Additionally;

  • Each of these items should screen out as minor issues
  • These items clearly do not represent a low to moderate risk
  • No threat to the public
  • None of the items left the Owner-Controlled Area at CPSES
  • Only 3 items left the Protected Area
  • Total hypothetical dose significantly less than 0.005 REM Comanche Peak Steam Electric Station TXU Energy
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