ML20040G412

Summary of Speech Entitled Radiation Protection Plans for Nuclear Power Plants, Presented at ANS 811129-1204 Winter Meeting in San Francisco,Ca

ML20040G412
Person / Time
Issue date:	11/29/1981
From:	Kreger W NRC
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NUDOCS 8202120287
Download: ML20040G412 (6)

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TITLE:

Radiation Prokction PlMLlorJiuclear. Tcuer_ Plante AttrilOR(S):(List authors in the proper order and nacil>

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William E. Kreger

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U.S. Nuclear Regulatory Comission

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IOR IN VITED

SUMMARY

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Radiation Protection Plans for thsclear Power Plant:

William L. Ereger U. S. Nuclear Regulatory Comission Washington, D. C.

20555 NRC regulatory staff practice regarding radiation protection at nuclear power plants before the T!!!-2 accident concerned itself primarily with careful review of applicant propose,d design aspects at the CP 1. censing stage, careful review of applicant proposed operating aspects at the OL licensing stage, followed by relatively infrequent inspections at operating plants structured and directed towards compliance with regulations and legal-ly binding regulatory requirenents.

These requirements have been well known and documented particularly in 10 CFR Part 20. Regulatory Guide 8.8, and the Standard Review plan.

The applicant / licensee commitments to a radiation pro-tection progran are documented in Chapter 12 of the FSAR and in the Technical Specifications of the licer.se.

The accident at Three Mile Island, and subsequent investigations of the accident by numerous groups, including one special inquiry directed specifi-j i

i cally at the TMI radiation protection program, identified serious concerns i

involving several aspects of the radiation protection program fof that plant.

I Some of the concerns involved areas which were not addressed by regulations i

or facility technical specifications. This led to the additional concern that similar problems might exist at other operating power reactor facilities.

Following the accident, the NRC ordered operating power reactor licensees to initiate corrective actions for a number of generic deficiences which came to light from the accident, including several involving radiological protection l

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.i t e.hi c ht n.y of prira ry coolant ' <- linq l ieu,

inadequate sanpling proa.:uret, for at i bient level coolant sar.ple;; inchility to obtain air samples fron containment; and lack of capability to detect the presence of radiciodines in the presence of high noble gas activity. These deficiencies were studied by the fMC staf f and requirements for corrections were claterated in fiUREG-0660, Vol. I (tlay 1930) "flRC Action Plan Developed as a Result of the Till-2 Accident."

lhese requirements were further clari-fied in fiUREG-0737 (flov.1980) " Clarification of THI Action Plan Requirements."

The utilities have been backfitting these requirements and numerous inter-actior's with the staff have further refined appropriate acceptance criteria for these items, which are being incorporated in an_ ongoing revision of the Standard Review plan (to be issued early fall,1981).

In addition to the cencern about the above mentioned generic deficiences, the concern about radiation orotection areas not specifically addressed by regulations has led to another response at the imC.

The Office of Inspec-tion and Enforcement (IE) initiated in calendar year 1980, a najor effort to evaluate the effectiveness of health physics (radiation protection) pro-

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grams at all currently operating nuclear power facilities.

This effort was d

called the Health Physics Appraisal program (HPAP) and it was structured to facilitate an integrated look at the total health physics progran, including natters for which explicit regulatory requirements did not exist,and empha-sized evaluation of capability and perfomances rather than compliance with regulations.

Each plant was visited for several weeks by teams of health physicists from IE and NRR and a contractor, and a comprehensive report was written on the results of each appraisal which took a total'of six weeks to l

perform.

The llPAp inspections used a rodified Management Oversight and Risk 3

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applica ble que'.t ions ter rat h t ret 1h f.eal t h phy' irs prograri w. view

! a consisting of seven uajor parts:

(1) Ladiation Protection Organization.aJ l'anagement; (2) Personnel Selection, Qualification and Training; (3) Exposure Control; (4) Radioactive k'aste Management; (5) ALAPA Program; (6) facilities and Equipment; and (7) Emergency Response Capabilities.

The findings of the appraisals identified dif f erent weaknesses at different facilities.

Significant weaknesses were found in virtually every part of the HP program, but all of the prograns were judged to be acceptable for con.

tinued operations while significant findings were being corrected.

In order of the above listed rajor program parts, the weaknesses were:

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Lack of managenent support failure to conduct performance audits of HP staff Shortage of HP staff.

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Failure to develop and use appropriate personnel selection criteria Poorly defined or impicmented training progran.

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Failure to recognize need for extrenity monitoring Poor calibration of instrunents, especially for monitoring betas and neutrons I

Inadequate dose verification Poor personnel nonttoring practices Inadequate air sanpling practices and failure to correlate results with personnel intales.

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4 Failure to perform adequate reviews of nadtfied liquid waste processing systens d

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Lact of a formal ALAnA Progran Misunderstanding of what ALARA neans.

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ftarginally adequate tarilities for offices, decontamination activities, respirator maintenance and contaminated tool storage Limited supplies of special equ'ipment.

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Lack of emergency response training of personnel Lack of capability to make measurements at action levels Inattention to calibration and maintenance of equipment Inadequate in areas identified by NUREG-0578 (discussed above relative to f;UREGs-0660 and 0737).

!!ost of the weaknesses and deficiencies involved aspects of the radiation protection progran that required nanagement attention.

In NRR, there has:

been under developnent for over a year, the description of a Radiation Pro-tection Plan that should he implenented at operating reactors.

The plan description was issued in NUREG-0761, Radiation Protection Plans (RPP) for i

Nuclear Power Reactor Licensees, March 1981 (see 46 FR 21285 of April 9, 1 981). This plan is structured to provide the elenents to be included in s

the comprehensive radiation protection program that the PLAN for each plant describes. Many of the elements of the program address specific deficien-cies found in the HPAP, and it is believed that the implementation and understanding of the program will 93 a long ways toward correcting the identified deficiencies, since it presents standard procedural guidance to be carried out at all plants durjng the life of the plant.

It specifically

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. thi innttm oi re t e. ~ e a n.c ent at :< m u,n tu tim istuc. ni r.ntiat ien prot n t ico.

,to so t il.+ r i t. no:. fou + '

s.4 n t in constrain a licensee or cpplis.mt ' inn, writing an p.Pp and developing a pro-gram that is nost appropriate f or the facility and organization being addres-sed. The practical gaal of the f;RC in requiring a PLAN which nects the intent of the report (f;UP.EG-0761) is to assure that each facility has a strong, self-improving radiat ion ~ protection program with. full active partici-pation on the part of each in;lividuhl, facility managers and super ~ visors at all icvels, and the radiation protection organization.

Conments on this docunent have been requested from the public, and from the nuclear power industry, as well as fron several specific organizations such as the ANS, HPS, AIF, EEI, NCRp, EPA, INPO, EPRI, etc. ' By the time this talk is presented it will be possible to summarize the reaction from these -

sources, as well as what the f;RC staff has done to respond to the cornents.

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