ML19060A128

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Summary of NRC Public Meeting to Discuss ROP Enhancement-Related Changes to the Radiation Safety Cornerstones
ML19060A128
Person / Time
Issue date: 04/04/2019
From: Garmon D
NRC/NRR/DRA/ARCB
To: Kevin Hsueh
NRC/NRR/DRA
Garmon-Candelaria D
References
Download: ML19060A128 (4)


Text

K. Hsueh 1 April 4, 2019 MEMORANDUM TO: Kevin Hsueh, Chief Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation FROM: David Garmon, Health Physicist /RA/

Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation

SUBJECT:

SUMMARY

OF NUCLEAR REGULATORY COMMISSION PUBLIC MEETING ON FEBRUARY 28, 2019 TO DISCUSS ROP ENHANCEMENT-RELATED CHANGES TO THE RADIATION SAFETY CORNERSTONES On February 28, 2019, NRC staff conducted a category 2 public meeting (ADAMS Accession No. ML19050A455) to discuss ROP Enhancement-related changes to the radiation safety cornerstones. Enclosure 1 contains the meeting attendance list Purpose Communicate the staffs preliminary recommendations with respect to enhancements to the Radiation Safety Cornerstones of the Reactor Oversight Process.

Background

The ROP remains a sound and effective framework for regulation of commercial nuclear facilities; however, NRC staff can make improvements to the program, in line with the Principles of Good Regulation, to achieve a more risk-informed and performance-based program. By letter dated September 19, 2018 (ADAMS Accession No. ML18262A322), the staff received two major recommendations from industry that apply to the Radiation Safety Cornerstones of the ROP:

1) Review radiation protection inspections to apply lessons learned from the Engineering Inspections Working Group to streamline them (following the stakeholder engagement process employed with engineering inspections); include credit for self-assessments.

CONTACT: David Garmon, NRR/DRA/ARCB 301-415-3512 david.garmon@nrc.gov

K. Hsueh 2

2) The philosophy setting the policy for the EP SDP above should be applied to all deterministic SDPs as much as practical.

NRC staff solicited external participation to inform its analysis of the recommendations. During a public meeting on November 15, 2018 (ADAMS Accession No. ML18348B256), the staff agreed to focus on four areas during the ROP Enhancement effort: (1) Oversight in the area of As Low as is Reasonably Achievable (ALARA) performance; (2) Oversight of Radiological Instrumentation; (3) Oversight of Radioactive Effluents; and (4) An increased reliance on licensee self-assessments as a means of assessing plant performance in the these areas.

During a public meeting on December 14, 2018 (ADAMS Accession No. ML18345A396 and ML18352A984) industry representatives were provided with an opportunity to provide prepared remarks and information pertaining to industry performance in the focus-areas of this analysis.

Meeting Summary On February 28, 2019 (ADAMS Accession No. ML19060A128 and ML19046A069), the staff held a public meeting to discuss the preliminary conclusions of its analysis of the industrys recommendations. During the meeting, the staff reviewed fundamental information regarding the Radiation Safety Cornerstones; described its approach toward evaluating the industrys recommendations; provided perspectives on the application of self-assessments in the oversight of licensee radiation protection programs and presented its proposed recommendations to the Commission. The staff also solicited feedback from external stakeholders for inclusion in its SECY input.

Public Comments External stakeholders asked several clarifying questions regarding the draft recommendations.

Additionally, one member from the industry inquired about the status of the draft IMC 0609, Appendix D (ADAMS Accession No. ML18178A100) and if industry would be allowed to provide input on how industry comments to the draft would be resolved (ADAMS Accession No. ML18264A305). The staff placed the effort to update IMC 0609, Appendix D on hold while the ROP Enhancement effort was being initiated in case changes from the ROP Enhancement effort would have to be incorporated into IMC 0609, Appendix D. The staff intends to resume efforts to publish the updated IMC 0609, Appendix D in the spring of 2019. This effort will include a presentation during an ROP Monthly meeting where the staff will discuss how it resolved comments to the draft document. Details of the meeting will be included in the corresponding ROP Monthly meeting announcement.

Enclosure:

Attendance List

ML19092A145 (*email concurrence)

OFFICE NRR/DRA/ARCB NRR/DRA/ARCB NAME DGarmon KHsueh DATE 4/2/19* 4/4/19*

Meeting Attendance List:

Ellen Anderson NEI Mary Anderson NRC Rich Clement NRC Steven Dolley S&P Global Platts David Garmon NRC George Gellrich Exelon Heather Gepford NRC Russ Gibbs NRC Willie Harris Exelon Kevin Hsueh NRC Greg Ferrigno South Texas Project Ken Heffner Certrec Ben Hirner Callaway Elizabeth Langille TVA Jonah Morgan South Texan Project Jennifer Rowland Millstone Laura Schwartz International Technology and Trade Associates Inc.

Daniel J. Shannon Kewaunee Jim Slider NEI Clayton Stone South Texas Project Steve Taylor Southern Nuclear Co.

Samuel A. Wender First Energy Tony Zimmerman Duke Energy Enclosure