ML20094C407
| ML20094C407 | |
| Person / Time | |
|---|---|
| Issue date: | 11/24/1975 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NUREG-75-087, NUREG-75-087-12.1, NUREG-75-87, NUREG-75-87-12.1, SRP-12.01, NUDOCS 9511020202 | |
| Download: ML20094C407 (5) | |
Text
- _ _ _ _ _ _ _ _ _
NUREG 75/087 a re f
'o U.S. NUCLEAR REGULATORY COMMISSION
^
j g
STANDARD REVIEW PLAN i
g%.....+
OFFICE OF NUCLEAR REACTOR REGULATION SECTION 12.1 ASSURING THAT OCCUPATIONAL RADIATION EXPOSURES ARE AS LOW AS 15 REASONABLY ACHIEVABLE REVIEW RESPONSIBILITIES Primary - Radiological Assessment Branch (RAB)
Secondary - None I.
AREAS OF REVIEW The following areas of the applicant's safety analysis report (SAR) related to assuring that occupational radiation exposures (ORE) will be as low as is reasonably achievable (ALARA) are reviewed:
1.
POLICY CONSIDERATIONS Management policy with respect to designing and constructing the plant (preliminary a.
safety analysis report. PSAR) and with respect to operating the plant (final safety analysis report. FSAR) and the planned organizational structure (PSAR).
b.
The applicable activities carried on by the individuals in management having responsibility for radiation protection (PSAR).
Information describing the implementation of policy, organizational, training, c.
and design review guidance or requirements provided in Regulatory Guide 8.8 Regulatory Guide 8.10. Regulatory Guide 1.8, and in 10 CFR Part 20. Information describing alternatives. if such are proposed (PSAR and update in FSAR).
2.
DESIGN CONSIDERATIONS Facility and equipment design considerations (PSAR) (but not design features, as a.
inSARSection12.3).
b.
The description of the use of dose assessment (SAR Section 12.4) and the resultant man-rem doses associated with various work functions for evaluating the facility design relative to assuring that ORE will be ALARA (PSAR).
The description of how experience from past designs, from various design guidelines, c.
such as Regulatory Guide 8.8. and from operating plants is used to develop improved radiationprotectiondesigns(PSAR).
d.
Information describing the implementation of the design guidelines of Aegulatory Guide 8.8 and other industry developed design guidance that includes the ALARA Criteria. Infonnation describing alternatives. if such are proposed (PSAR and update in FSAR).
USNRC STAND ARD REVIEW PLAN 1"O'."O*a"*""!.".':*f",*". " *'O.."%','.""'*" ","*'"."".*,,.7*,.'"c".'"J.*.".,*.* '," *,*,"0 *d ",*, ".'."* ",*.'""'."u*' '"
- "," "*",:', ".'0.,*.'.::".rt.:". ".".,*". 1.'O. "*',~ 0".*.0".',"=",',".==1".*"". *,:*."r l."::,"*"l,r;'.
I e.-,.,.......--...n.,,
c
. v. =,, a
,, e
. oen..
I m
e.e leo.W Nn.t
. O C. 2 555
/75 9511020202 751124 PDR NUREG 75/087 R PDR
~_..
. ~ - ~.
- -- ~_-
3.
OPERATIONAL CONSIDERATIONS The techniquas and methods that will be used for daveloping detailed op1 rational a.
plans and procedures (PSAR).
b.
The description of how procedures for operation may impact on and interact with the plant design and on the design process (PSAR).
The use of operating plant experience in planning the operational considerations c.
for new plant designs (PSAR).
d.
The criteria and conditions under which various exposure reduction procedures and techniques are implemented (FSAR).
Information describing the implementation of radiatior, protection programs, and e.
operational guidance of Regulatory Guide 8.8 and Regulatory Guide 8.10.
Infor-mation describing alternatives, if such are proposed (PSAR and update in FSAR).
II.
ACCEPTANCE CRITERIA The descriptive information in the SAR is considered to be sufficient if it meets the minimum information needs set forth in Section 12.1 of the " Standard Format and Contents of Safety Analysis Reports for Nuclear Power Plants," Revision 2.
hpecific acceptance criteria for these areas of review are as follows:
1.
POLICY CONSIDERATIONS Acceptability will be based on evidence in the PSAR that a policy for assuring that ORE will be ALARA has been formulated, described, displayed, and will be implemented in accordance with Regulatory Guide 8.8, Regulatory Guide 8.10, C.1, and Regulatory Guide 1.8.
This includes designating and assigning a specific individual responsibility and authority for implementing ALARA policy. Alternative proposed policies will be evaluated on the basis of a comparison with the Regulatory Guides and industry standards.
2.
DESIGN CONSIDERATIONS Acceptability will be based on evidence that the design methods, approach, and inter-actions are in accordance with Regulatory Guide 8.8, including incorporation of:
measures for reducing the need for maintenance is required; measures to improve the accessibility to components requiring periodic maintenance or inservice inspection; measures to reduce the production, distribution and retention of activated corrosion products throughout the primary system; reviews of the design by competent radiation protection personnel; instructions to designers and engineers regarding ALARA design; feedback of experience from operating plants and past designs; and continuing facility design reviews. Alternative proposed design policies will be evaluated on the basis of a comparison with the Regulatory Guide.
3.
OPERATIONAL CONSIDERATIONS Acceptability will be based on evidence that the applicant has a program to develop plans and procedures in accordance with Regulatory Guide 8.8, which can incorporate the experiences obtained in facility operation into facility and equipment design and into operations planning and which will implement specific exposure control techniques. In the FSAR, acceptance of criteria and conditions under which various exposure reduction procedures and techniques are implemented will also be based on Regulatory Guides 8.8 12.1-2 11/24/75 os
-e
and 8.10 C.2.
Alternative proposed plans and procedures will be evaluated on tha basis of a comparison with the Regulatory Guides.
111.
REVIEW PROCEDURES The information furnished in the SAR is reviewed for completeness in accordance with the
" Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants " Revision 2.
v RAB. reviews the management policy and the planned organizational structure to determine how the guidance given in Regulatory Guides 8.8, 8.10 and 1.8 will be implemented or whether alternatives have been proposed. The organizational structure review includes determining if the individuals responsible for the radiation protection program are on a level in manage-ment that will assure implementation of management's commitment for assuring that ORE will be ALARA. Any problems concerning the review of organizational structure, as related to the radiation protection manager will be communicated to Quality Assurance Branch, which has primary review responsibility for this item, in Chapter 13. The reviewer uses ANSI N18.7-1972 for additional guidance on acceptable operating organizations.
The reviewer evaluates information in this section to determine if the organizational structure provides a mechanism for the radiation protection manager and his organization interacting with design groups to assure that mJthods and techniques for reducing ORE will be incorporated in the design of the plant. Where the future plant radiation protection f
manager has not been selected, design review should be accociplished in accordance with the guidance of Regulatory Guide 8.8, or a proposed alternative. For those applicants that have operating reactors the reviewer determines that a review of the proposed plant design is conducted by appropriate personnel from the operating plant. The reviewer determines from infonnation furnished by the applicant that he has incorporated previsouly accepted design features and has used operating experience to improve on the design of the plant with regard to assuring that ORE will be ALARA. The reviewer compares the material in this section with the requirements of 10 CFR Part 20 and the guidelines of Regulatory Guides 8.8 and 8.10.
Based on the review RAB may request additional information or request the applicant to modify his submission in order to meet the acceptance criteria given in Section !!.
IV.
EVALUATION FINDINGS The staff's review should verify that adequate and sufficient information is contained in the SAR and amendments to arrive at conclusions of the following type, which are to be included in the staff's Safety Evaluation report. The report will include a sumary of the applicant's coverage, the staff's basis for review and acceptance criteria, and the findings of the review. The following is a brief representation of the evaluation findings:
"12.1 Assuring that ORE are ALARA.
"This section of the applicant's SAR has been reviewed to determine the policy, design, and operational considerations related to assuring that occupational radiation exposures (ORE) will be as low as is reasonably achievable (ALARA). The review covered the descrip-tion of the applicant's management policy are eganizational structure regarding radiation protection, the design considerations that a o used to apply experience from past designs 12.1-3 11/24/75 J
q e
=
m-.-
m-
and operating experfince torard achieving improved designs, and the methods and tech-niques used fgr dsveloping plans and procadures for assuring that ORE will be ALARA.
The review included analysis of the manner by which the applicant's policy, design, and operational considerations confonn to the guidelines of Regulatory Guides 8.8, 8.10, and 1.8 or provide acceptable alternatives.
"The basis for acceptance has been conformance of the management policy, design, and E*
n operational considerations with established guidelines, criteria, and good practice at licensed nuclear plants, including those provided in Regulatory Guides 8.8. 8.10, and s
1.8.
The management policy and individual responsibilities are appropriately imple-mented both with regard to the design process and with regard to developing and con-sidering operational procedures.
"It is concluded that the policy considerations, design considerations, and operational considerations related to assuring that ORE will be ALARA conform to the Comhsion's Regulations and to the appropriate Regulatory Guides and industry standards and are considered acceptable."
V.
REFERENCES 1.
Regulatory Guide 8.8 "Information Relevant to Maintaining Occupational Radiation Exposures As Low As Practicable (Nuclear Reactors)."
2.
10 CFR Part 20. " Standards for Protection Against Radiation."
3.
Regulatory Guide 8.10 " Operating Philosphy For Maintaining Occupational Radiation Exposures As Low As Practicable."
4.
Regulatory Guide 1.8, " Personnel Selection and Training."
5.
Regulatory Guide 1.70, " Standard Format and Contents of Safety Analysis Reports for Nuclear Power Plants," Revision 2.
6.
ANSI N18.7-1972, " Administrative Control for Nuclear Power Plants," American National StandardsInstitute(1972).
12.1-4 11/24/75 s
d
__a Q__
O 3RP
/ 2
?-