ML20151J001

Advises That NUREG-0801, Evaluation Criteria for Detailed Control Room Design Reviews, Will Be Issued in Final Form, Incorporating Public Comments & Consistent W/Requirement of NUREG-0737,Suppl 1

ML20151J001
Person / Time
Issue date:	04/25/1984
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO)
Shared Package
ML20151C834	List: ML20151C832 ML20151C859 ML20151C868 ML20151C882 ML20151C904 ML20151J001 ML20151K338 ML20151S856 ML20154L830 ML20154L836 ML20195F797 ML20195F813
References
FOIA-87-714, RTR-NUREG-0737, RTR-NUREG-0801, RTR-NUREG-737, RTR-NUREG-801 NUDOCS 8405160276
Download: ML20151J001 (2)

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\,,,, April 25,1984 MEMORANDUM FOR: William J. Dircks Executive Oirector  ;

for Operations '

FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation

SUBJECT:

PUBLICATION OF NUREG-0801, "EVALUATION CRITERIA FOR DETAILED CONTROL ROOM DESIGN REVIEWS' l We met with CRGR on Thursday, March 15 to discuss publication of a document that had been previously issued in draft fonn, NUREG-0801, "Evaluation

• Criteria for Detailed Control Roorn Design Reviews." l CRGR has reviewed NUREG-0801 and does not object to publication provided that I a number of specific cocments are addressed, that ELD conduct a review to screen and revise.the NUREG language so as to make it unambiguously clear )

that the document contains no regulatory requirements, and that the staff include its views and positions as to the value/ validity of existing industry guidance (e.g.. NUTAC reports). CRGR further requested that our reasons or i arguments to support publication of NUREG-0801 as an exception to agency policy regarding use of NUREGs as a means to set forth licensee guidance or 1 generic requirements be included as part of the CRGR record.

Subsequent to the CRGR meeting ELD has reviewed the NUREG and their corments

~ k. . . and revisions have been incorporated. In addition, the technical editors s have reviewed and corrected the report. We have also addressed CRGR's specific coceents. Industry's NUTAC documents for detailed control roca design review have been evaluated and our connents transmitted to the industry Chaiman. A meeting is being scheduled to discuss our conclusions.

Following this meeting, our evaluations will be surnarized and included as an appendix to NURIG-0801.

We agree with CAGR that NUREG documents should not be used by the staff as a vehicle for generating / establishing generic requirements. However NUREG-0801 was originally issued as a draft for public cocnent on October 1981 and the staff was comitted to resolution of coments and issuance in final fom.

HUREG-0737, Supplement I was issued on December 17, 1981 and it presented the requirements for a Detailed Control Room Design Review as well as describing the extent of staff review. NRR proposes to. issue NUREG-0801 in final fonn incorporating public coments and consistent with the requirement of NUREG-0737, Supplement 1. NUREG-0801 has been extensively reviewed to ensure that it does not generate / establish new gencric requirements.

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William J. Dircks 1 .

At the time the comitment was made to develop this document it was noted that this and a companion document NUREG-0835, "Human Factors Review Guidelines for the SPDS." would be the last NUREGs of this type that NRR would issue and that future guidance would be disseminated by way of '

Regu17 tory Guides or Standard Review Plan Revisions. The delay in issuing this document has resulted from efforts to incorporate public coments and modifications to ensure ccnsistency with NUREG-0737 Supplement 1.

NUREG-0801 has been reviewed and cocinented on by the ACRS in addition to having undergone substantial staff, public and industry review and coment.

This extensive review process formed part of the justification for "grandf athering" this NUREG report. The impact of issuing it as a Regulatorp' Guide or as part of the Standard Review Plan would be an eighteen month to two year delay and a repetition of most of the review and coment process

, which already took place. . e Nf' -

Harold R. Denton, Director Office of Nuclear Reactor Regulation .

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OCT 101986 MEMORANDUM FOR: Robert M. Bernero, NRR Richard W. Starostecki, IE Richard E. Cunningham, NMSS Denwood F. Ross, RES Clemens J. Heltemes, Jr., AE00 Joseph Scinto, OGC THRU: John E. Zerbe, Director Regional Operations and Generic Requirements Staff FROM: Ronald R. Bellamy Regional Operations and Generic Requirements Staff

SUMMARY

AND ISSUE IDENTIFICATION FOR CRGR MEETING NO. 98 Enclosed for your information and use is the ROGR statf sumary associated with the proposed rule change that would require personnel dosimetry processors be accredited through the National Voluntary Laboratory Accreditation Program .

operated by the National Bureau of Standards. This matter is scheduled for CRGR review at Meeting No. 98 on Thursday, October 16, 1986, in room 6507 MNBB, 1-2 p.m.

/C Ronald . Bellamy Regicnal Operations and Generic Requirements Staff

Enclosure:

As stated cc: J. Sniezek K. Goller, RES R. Alexander, RES D. Nellis, RES Distribution:

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Sumary and issue Identification on CRGP Feview Item, Meeting No. 98 Optober 16, 1986 IDENTIFICATION Proposed re"ision to the NRC regulations on personnel monitoring in 10 CFR Part 20 to requi.e that personnel dosimetry processors be accredited under the National Voluntary Laboratory Accreditation Program operated by the National Bureau of Standards (Department of Cousnerce).

OBJECTIVE The CRGR is requested to review and recomend in favor of the proposed revision to require accreditation of personnel monitoring processors. The objective of the proposed revision is to improve the accuracy and reliability of personnel dosimetry and thereby provide a significant health benefit.

BACKGROUND The package sutaitted for CRGR review was transmitted by D.F. Ross to J.H. Sniezek on September 11, 1986, and included:

a. Propo:ed rule change to 10 CFR Part 20--Federal Register Notice

b. Regulatory Flexibility Analysis

c. Backfit Analysis

d. Analysis of Coments

e. Sample Congressional Letter

f. Public Announcernent ,

DISCUSSION l

In order to satisfy personnel monitoring requirements in 10 CFR 20.202(a) and 10 CFR 34.33(a), and the associated documentation requirements in 10 CFR 20.401(a) and 10 CFR 34.33(e), NPC licensees supply workers with dosimeters, l These dosimeters require processing after the exposure to detemine what ex- '

posure has occurred. There are no regulations for perfomance standards for this dosimetry processing, even though accurate and consistent measurements are directly related to the ability of the licensees to confom to NRC regulations in 10 CFR 70.101, j  !

The NRC sponsored two rounds of proficiency testing of processors against I Fealth Physics Society Standards in 1977-1979, noting major changes required I for some processors. In the first round 62 percent of the individual dosimeter readings were within 230 percent of the true dose, and 73 percent were within 4

30 percent for the second round. The NRC issued a proposed rule change in j March 1980, receiving 46 coment letters on the various options proposed. l

2 Feview of the coments resulted in the NRC asking NBS in 1980 to establish an accreditation program under the National Voluntary Laboratory Accreditation Program (NVLAP). A third perfonnance test was conducted, indicating 78 percent of the processed TLDs within t 30 percent of the true dose. On January 10, 1984, a Notice of Proposed Rulemaking was published by NRC that would require NRC licensees to use dosimetry processors accredited by NVLAP for processing personnel dosimeters required by NRC regulations. An effective date of one year after publication of the rule is specified. The NRC received 96 coment i letters, mostly favorable. The major objections were the costs to smell pro-cessors and to medical and hospital licensees. l i

ISSVES

1. Although generally the processors of dosimeters are doing an adequate job today, without the rule change many processors would reduce their comit-ment to providing competent analyses, and other less-than-adaquate com- >

panies might enter the business. NVLAP certification establishes a label I of competent, professional perfonnance. Note that most power reactor l licensees already use processors that are NYLAP-certified and, without the i rule, many processors may decide not to continue being accredited. The l Region I contractor to process NPC Region 1 employee dosimeters (Landauer) l is NVLAP certified. 1 l

2. Conversely, what is wrong with the st6tus quo? If a licensee program I (whether contracted out or not) is so bad that we cannot conclude they satisfy the regulations, we can simply take enforcement action--no rule change required. I

3. Should NVLAP certification take the place of NRC ins:ection activities?

Although it is useful for the inspector to know whetier the lisensee's processor is certified, is this enough? The inspector would still need to check records, see QA/QC involvement, observe onsite implementation of procedures. Further, NRC Regions would need timely copies of the NVLAP Quarterly Certification status. Is a NRC-NBS Memorandum of Understanding warranted 7 4 Is this area a candidate for industry self-regulation? hhat does ICRP, NCRP, or the Health Physics Society think?

5. Note the rule change would be for required personnel dosimetry only--not environmental, dosimeters or addition 31 dosimeters the licensee chooses to use. Yet extremity dosimeters are specifically excluded from the rule change. If regulations specify allowable doses to hands and foreann, feet i and ankles, wouldn't it make sense to include these dosimeters? I

6. It appears a potential benefit of NVLAP certification is missing. What l about public perception? Increased confidence of the public that doses ar2 accurate and that the NRC can adequately regulate the nuclear in-dustry? Being able to state that the dosimeters were processed by a certified laboratory should certainly make dealing with the public and press inquirie; easier to handle, especially if potential overexposures, or an accident situation, are under discussion. The Backfit Analysis also ignores benefits of eliminating gross overestimates. This can save on inspection time, licensee evaluation time, public perception, response to outside inquiries, and management review time.

7. The cost of NYLAP certification is not excessive, and should be considered a "cost of doing business," similar to any other certification. Note costs are estimated at $3,000 to $8,400 annually per dosimeter type, de-pending on how many radiation categories are tested.

8. The Rule change only affects occupational workers, and those for which doses are underestimated (if the dose would have been overestimated, the worker would not receive more exposure). Also, the rule change itself won't save dose, it only gives greater accuracy. Therefore, can you make an argument for substantial improvement in the public health and safety?

9. CRGR may want to consider the following technical questions:

a. What were the number of dosimeters used in the NVLAP comparison (top of page 4 of EDO memorandum to the Comission)? Is it statistically adequate?

b. Page 17 of the proposed rule indicates the NRC plans to issue sup-plementary information to help licensees detemine appropriate testing categories. What infonnation; how published? How is infonnation being distributed now?

c. What are the one versus eight testing categories? Are eight needed?

How does this affect accreditation costs?

d. Page 3 of the Regulatory Flexibility Analysis assumes that the small processor derives his entire income from dosimeter processing. This may not be realistic, which would make the case stronger that the cost of MVLAP certification is not of great consequence.

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OCT 101986 MEM0PANDUM FOR: Robert M. Bernero, NRR Richard W. Starostecki, IE Richard E. Cunningham, NMSS Denwood F. Ross, RES Clemens J. Heltemes, Jr., AE00 Joseph Scinto, OGC THRU: John E. Zerbe, Director Regional Operations and Generic Requirements Staff FROM: Ronald R. Bellamy Regional Operations and Generic Requirements Staff

SUMMARY

AND ISSUE IDENTIFICATION FOR CRGR MEETING NO. 98 Enclosed for your information and use is the ROGR staff sumary associated with the proposed rule change that would require personnel dosimetry processors be accredited through the National Voluntary Laboratory Accreditation Program operated by the National Bureau of Standards. This matter is scheduled for CRGR review at Meeting No. 98 on Thursday, October 16, 1986, in room 6507 MNBB, 1-2 p.m. l l

kRonald R. Bellamy Regional Operations and Generic Requirements Staff

Enclosure:

As :tated cc: J. Sniezek K. Goller, RES R. Alexander, RES

0. Nellis, RES i

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