ML20137W226
| ML20137W226 | |
| Person / Time | |
|---|---|
| Issue date: | 09/17/1985 |
| From: | Serbu R Office of Nuclear Reactor Regulation |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20137W182 | List: |
| References | |
| NUDOCS 8510040256 | |
| Download: ML20137W226 (5) | |
Text
sp reg Enclosure 3 y
k;, UNITED STATES NUCLEAR REGULATORY COMMISSION L z j WASHINGTON, D. C. 20555
\ **"* / SEP 17 1985 MEMORANDUM FOR: Daniel R. Muller, Assistant Director for Radiation Protection, DSI THRU: Frank J. Congel, Chief Radiological Assessment Branch, DSI Oliver D. T. Lynch, Jr. , Leader Radiation Protection Section Radiological Assessment Branch, DSI FROM: Richard J. Serbu, Task Manager Radiation Protection Section Radiological Assessment Branch, DSI
SUBJECT:
TRIP REPORT - SEPTEMBER 12, 1985 MEETING AT INP0 TO DISCUSS C0 ORDINATION PLAN ACTIVITIES On Thursday, September 12, 1985, NRC representatives met with INP0 .
representatives to discuss a variety of Coordination Plan activites being conducted under the NRC/INPO Memorandum of Agreement. As part of these discussions, activities related to Coordination Plan No. 3, " Coordination Plan for NRC/INP0 Radiological Protection Activities" were discussed from approximately 12:00 pm to 1:30 pm.
Principals in the discussions related to the Coordination Plan for Radiological Protection Activities were as follows:
NRC INP0
. William Russell, Acting Director . Pete Lyon, Director Division of Human Factors, NRR Division of Radiological Protection & Emergency
. Richard J Serbu, Task Manager Preparedness Division of Systems Integration, NRR
. William Kindley, formerly
. Dan Jones, HFPP Manager Deputy Director, DRPEP; Division of Human Factors, NRR now a staff assistant to the INP0 President
. Phil McKee, Chief Operating Reactor Programs Branch, IE . Bob Heublein, Section Manager Radiological Protection 8510040256 850927 PDR ORG EPSI i
t
D. Muller i
! Discussions centered around the following topics:
! 1. Management and working level contacts and responsibilities for Radiation l Protection in NRR following reorganization.
- 2. Revision / continuation of the Coordination Plan for Radiological Protection I i Activities.
- 3. Information exhange.
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- 4. Further actions related to Coordination Plan. ;
- 5. IliP0 concerns over "ALARA" rulemaking, R.G. 8.XX.
l A brief summary of these discussions is provided as Enclosure 1. Additionally, t
I spent approximately 1/2 hour with Bob Heublein and Tom Mitchell discussing 4 differences in data compilation which were noted during our ACRS presentations i on July 31, 1985.
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@I Richard J.
(
bu, Task Manager 6--
Radiation Protection Section j Radiological Assessment Branch i Division of Systems Integration
Enclosure:
1 As stated cc: R. Bernero W. Russell J. Sniezek
- M. Federline D.' Jones
, P. Mckee l
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ENCLOSURE 1
- 1. Manaaement and workina level contacts and responsibilities for radiation
- protection / Coordination Plan activities in NRR following reorganization
J Responsibility within NRR for Coordination Plan activities will probably shift to the Division of Human Factors Technology, and health physics ,
expertise will be provided to this group to conduct the working level i activities. The present Task Manager for Plan #3 will probably carry the j issue through to resolution, which is being revised to 11/85 from 9/85. '
- Radiation Protection activities will probably be tied into existing
! maintenance and training program efforts (in DHFS) under Hal Booher. The l history of the Coordination Plan from NRC and INP0 perspectives was also l briefly reviewed.
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- 2. Revision / continuation of the NRC/INP0 Coordination Plan for Radiological Protection Activities:
j The staff has reviewed INP0's draf t of a revised Coordination Plan #3, however, present management review of NRC relations with INP0 regarding access to and exchange of information may result in a policy decision which will affect the agreement. It appears that while the two-year l evaluation period within the body of the Plan is close to term, the plan :
itself may be extendable as is. This should be a matter for NRC management review and further discussion with INP0.
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- 3. Information exchange:
Parallels in the needs, efforts and problems of information sharing were discussed by NRC and INP0 staff members. INP0 personnel stressed the 4
need for independence from the regulatory process, while NRC stressed the need to be able to verify, on the public record, industry efforts which affect regulatory matters. Fonnality in information exchange was discussed, such as whether the INP0 ACRS presentation of July 31, 1985 constituted an on-the-record release of radiological protection data adequate for NRC decisions regarding radiation protection rulemaking.
Dan Jones (NRR/DHFS) and Phil Mckee (IE/ORPB) noted related experience under other Coordination Plans.
- 4. Further NRC actionr. related to the Coordination Plan:
The NRC Task Manager (Serbu) noted some of the remaining action plan items under Task Action Plan III.D.3.1 and outlined other actions being considered as a result of the two-year evaluation program. These included:
a) Slippage of III.D.3.1 close-out date to 11/85 b) Preparation of a Comission Paper from NRC compiled and trended data c) Current effort to compile and analyze radiological data from NRC sources
d) Pending ef fort to estaolish an NRC radiological data base e) Consideration of a revised Coordination Plan f) Assignment of radiological controls functions and responsibilities under NRR reorganization
- 5. INP0 concerns over "ALARA" rulemaking and R.G. 8.XX INP0 personnel expressed concern that even after a successful industry effort under the Coordination Plan evaluation program, that "ALARA" Rulemaking would be pursued and the implementing R.G. 8.XX issued. NRC staff noted the complex process of rulemaking and the historical events which generated the 10 CFR 20 rule in its present fonn (with the proposed "ALARA" rule), and noted that unnecessary regulation - as determined under this Coordination Plan - would probably not be pursued. INPO also noted their development of " Guidelines for Radiological Protection at Nuclear Power Stations" and indicated that NUMARC has endorsed industry efforts at further improvement in radiation protection. NRC staff will review this document in terms of " equivalency" to the NRC's R.G. 8.XX ALARA implementation form and content document.
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