ML20198K094

Summary of 981029 Workshop with NEI in Washington,Dc Re Continue Discussion & Development of Performance Indicators to Be Used by NRC to Help Assess Licensee Radiation Protection Programs at Power Reactors

ML20198K094
Person / Time
Issue date:	11/23/1998
From:	Wigginton J NRC (Affiliation Not Assigned)
To:	Chris Miller NRC (Affiliation Not Assigned)
References
PROJECT-689 NUDOCS 9812300336
Download: ML20198K094 (14)

Text

m. - -

. ~. -

w,.a, x

on.+

<a m.n

..,a a+_..

.n.,,

u.

-n...-+

a

....a s

..a.

,=.+-,s.

a

.x

+

.c._.s...

a 1

1. %g\\

UNITED STATES l

p s

NUCLEAR REGULATORY COMMISSION 1

WASHINGTON, D.C. 3000H001

\\, m.

November 23, 1996 j

d' l

MEMORANDUM TO: Charles L Miller, Chief i

Emergency Preparedness and Radiation Protection Branch i

Division of Reactor Program Management j

Office of Nuclear Reactor Regulation fj

]

FROM:

James E. Wigginton, Senior Reactor Health Physicist Emergency Preparedness and Radiation Protection Br l

Division of Reactor Program Management Office of Nuclear Reactor Regulation t

SUMMARY

OF, WORKSHOP WITH THE NUCLEAR ENERGY l

INSTITUTE (NEI) REGARDING PERFORMANCE INDICATORS FOR l

ASSESSING RADIATION PROTECTION PROGRAMS i

l On October 29,1998, representatives of the Nuclear Energy Institute (NEI) and power plant

[

licensee radiation protection managers and senior technical staff met with representatives of j

the Nuclear Regulatory Commission (NRC) at NEl's office in Washington, D.C. Attachment 1 l

provides a list of workshop attendees, The purpose of the workshop was to continue discussion and development of performance i

j indicators (PI) to be used by the NRC to help assess the licensee's radiation protection I

programs at power reactors. NRC management provided an introduction to start the meeting, emphasized and summarized the NRC efforts, goals and time schedules for the project. The NEl Senior Project Manager noted that the power plants were well represented by the large i

tumout and good cross section of radiation protection personnel. Attachment 2 (NRC's draft public/ occupational exposure Pls and " key attributes") and Attachment 3 (NEl's draft Pls for the public and the workers) were exchanged among the meeting participants.

The discussion started in the public area - the area of most likely consensus. This includes i

transportation, radioactive material release, and effluents (using the NEl nomenclature). After some discussion of the draft Pls for the transportation area, NEl proposed that this area not be covered by Pls, but remain an area for the baseline inspection program. The NRC staff had no objections to that proposal. The benefits and difficulties of using Pts in the material release area were discussed and no consensus could be reached relative to the action level-what is a i

reasonable dose value for public exposure and corresponding quantity of radioactive material?

)

It was agreed to carryover this discussion for possible resolution at the next meeting. After much discussion of the details of the current reporting requirements for effluent events, the group reached consensus that NEl's " single bullet" PI for effluents sufficiently covered the corresponding NRC's (1)-(iii) bullets.

i CONTACT: James E. Wigginton, PERB/NRR 415-1059 NN i

9812300336 981123 PDR REVGP ERONUPEC PDR RM e.f d

~

2 In the occupational radiation safety area, consensus was reached on'NEl's first bullet (NRC's (ii)), dealing with problems with locked high radiation areas (HRA) and very high radiation areas l

(VHRA). However, industry would rather use "nonconformance with" requirements rather than -

i the loss-of-barrier approach proposed by the NRC. Additionally, for VHRA, any -

i nonconformance with the licensee's procedure would be the standard, rather than Part 20 1

(since 20.1602 is a performance based regulation). For the se low as reasonably achievable (ALARA) area, all agreed that this area was not amenable to the Pl assessment approach, but would be best assessed in the traditional way -licensee self-assessment and focused NRC baseline inspection. Given the difficulty in the view of industry to adequately define radiation protection barriers associated with NRC bullet (iii), NEl does not support a Pl for unlocked HRA (dose rates less than 1000 mr/h). If this' position holds, the NRC then would include this area in their baseline inspection program. The final proposed P1 for the occupational area involved

- unintended worker dose in excess of some percentage of the NRC dose limits, resulting from -

non-compliance with Part 20/ licensee requirements / procedures (as proposed by NEI) or as a

. result of one or more barriers (NRC's proposal). No consensus could be reached on what

- percentage (of the dose limits) was appropriate, and both NEl and the NRC agreed to reexamine their positions on this draft Pl.

NEl and industry are planning to start the verification and validation (V & V) process for the draft Pls that have tentative consensus, and some of the preliminary results of this process t

should be discussed at the next scheduled meeting. The V & V results are necessary to initially establish at least face-validity for the Pls and to aid in setting thresholds for performance. The meeting was adjoumed.

l Attachments: As stated t

i cc w/att: See next page i

i i

1 f

i l

{

i 4

i 4

l I

4 w

..-..~_... _..-..... -. -.... -

l:

f Nuclear Energy Institute Project No. 689 cc: Mr. Ralph Beedle Ms. Lynnette Hendricks, Director Senior Vice President Plant Support '

and Chief Nuclear Officer Nuclear Energy Institute Nuclear Energy Institute Suite 400 Suite 400 1776 l Street, NW l

17761 Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Steven Driscol Radiation Protection INPO 700 Galleria Paikway Mr. Alex Marion, Director Atlanta, Georgia 30339-5957 Programs Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 4

.o Distribution: Mtg. Summary w/ Dated nnv mw.*

9, 1998 Hard Coov PUBLIC' PERB R/F SMagruder JWigginton PBaranowsky TEssig CMiller REmch JWhite, R1 KBarr, R2 GShear, R3 B.Murray, R4 N. Shah G.Kuzo R.Pedersen S.Klementowicz 1

'O; o [J

..A i

i s

.-- c w--

Radiation Protection Performance Indicator Meeting 10/29/98 List of Attendees Name Oraanization Tom Essig USNRC 2

Pat Baranowsky USNRC Steve Klementowicz USNRC George Kuzo USNRC Roger Pedersen USNRC Nirodh Shah USNRC Jim Wigginton USNRC 4

Lynnette Hendricks NEl Ralph Anderson NEl Paul Genoa NEl Alan Nelson NEl i

Alice Clamp NEl Steve Unglesbee NEl William Harris PECO Frank Rescek Comed L.A. Blue SCE & G Gooch Cheatham CP&L F.L. Thamasson Virginia Power Wayne Carr Southem Nuclear Travis Beard Northem States Power Mark D. Rigsby B.G. & E Steve Driscoll INPO Russell Gray P.G. & E Ken Coon Arizona Public Service l

t I

r i

P

~.. - _ =.

NRC l

PUBLIC EXPOSURE 1

Cornerstone:

Assure adequate protection of pubile health and safety i

1 i

Desired Result:

To maintain doses to a member of the public from normal operations to (1)less that 10 CFR Part 20 limits and (ii) ALARA i

i i

d 1

i 1'

a 4

d 5

e h

1

l

\\

i PUBLIC EXPOSURE CORNERSTONE KEY ATTRIBUTE Measurement Areas Measurement Performance Indicator Plant, (Facilities Configuration Control Instrumentation Cals Equipment, Instruments)

Equipment Aree Rad Monitors Availability PM@

Program / Processes Offsite Dose Effluent Release Dose Estimates

[

Unplanned /Unmonito red Effluent Releases i

Procedure Quality Rad Material Release of Material Controls from RCA 4

DOT Transport i

Limits Enfir nmoshl

- Nif"J o

materin n

- so - p h a. A Human Performance Training Y

Ouali$catiYns Performance i

t.

~

PUBLIC EXPOSURE PROPOSED PERFORMANOE INDICATORS (l)

Percent of Projected Annual Offsite Dose to Maximum Exposed Individual (i.e.,2_% 10 CFR Part 50, Appendix ! tr 10 CFR Part 20 Limits )

(ii)

Reportable off Site Dose Calculation Manual,5 vents (ODCM) Events (i.e., setpoint calculations, unmonitored releases, exceed allowable release rate or dose)

(iii)

Percent of Effluent Process RMS Availability (i.e., 5_ % availability when needed)

(iv)

Unauthorized release of radioactive rhaterial (i.e., e.g., number of times material released with dose or dose rates _t _ mrem or mrem /hr)

]

i l

l (vi)

Exceeding DOT Package Exposure Rate or Contamination Limits 4

(Number of instances where packages shipped with exposure / contamination levels E DOT package shipping requirements and determined to be result of licensee's actions

\\

i

-,,u

e OCCUPATIONAL EXPOSURE ll Cornerstone:

Assure adequate protection of radiation worker pubik: health and j

safety i

i Desired Result:

To maintain doses to radiation workers from normal operations to (1) less that 10 CFR Part 20 limits and (ii) ALARA j

a d

9

l l e i e e

OCCUPATIONAL EXPOSURE CORNERSTONE KEY ATTRIBUTE Measurement Areas Measurement PI l

Plant. (Facilities Equipment / Instruments Instrument Cats Equipment, instruments) l Area Rad Monitors Availability i

1 Source Term l

I I

Program / Process Red Material Controls Contaminated Space l

Leak Control Program l

l Exposure Control /

Dose Monitoring Monitoring RP Barriers I

Planning individual & Committed Dose l

l Human Performance Training HPTechs Quals Performance t

V s

DRAFT FOR DISCUSSION Occupational Radiation Safety Performance Indicators t

Expected Result: Maintain occupational doses below regulatory limits.

t nonconformance with technical specifications and 10 CFR Part 20 requirements for locked high radiation and very high radiation areas.

nonconformance with 10 CFR Part 20 requirements orlicensee procedures that e

result in unintended dose in excess of10% of a Part 20 limiti.

Expected Result: Maintain an effective ALARA program.

This area may not lend itself to assessment through use of a performance indicator. It should be assessed through a combination oflicensee self-assessment (as required by 10 CFR Part 20) and a focused baseline inspection program.

i l

1 I

5 This indicator would exclude occurrences involving discrete radioactive pa ti l resolution through rulemaking.

r c es pending l

OCCUPATION EXPOSURE PROPOSED PERFORMANCE INDICATORS e

(1)

A single uncontrolled unplanned event that led to an individual receiving 2_% of 10 CFR Part 20 limits.

(ii)

Loss of radiation protection (RP) barrier associated with locked high radiation (LHRA) and very high radiation areas (VHRAs)

Loss of 21 radiation protection (RP) barriers for TS defined LHRAs and VHRAs. For plants that control HRAs oy 10 CFR 20.1601, loss of a 1 (RP) barrier for areas exceeding 1000 mrem /hr.

'(iii)

Loss of multiple RP barriers associated with high radiation areas.

1 (e.g., loss of 2 2 barriers such as the loss of physical posting and administrative controls

)

in a HRA).

i (iv)

Percent availability of select area radiation monitors (ARMS)

(e.g., ARMS available for primary chemistry lab, in-core probes room etc)

J l

4 3

j i

I

i l.

l 2

1 l

In the occupational radiation safety area, consensus was reached on NEW's first bullet (NRC's (ii)), dealing with problems with locked high radiation areas (HRA) and very high radiation areas (VHRA). However, industry would rather use "nonconformance with" requirements rather than the loss-of-barrier approach proposed by the NRC. Additionally, for VHRA, any l

nonconformance with the licensee's procedure would be the standard, rather than Part 20

)

i (since 20.1602 is a performance based regulation). For the as low as reasonably achievable 1-(ALARA) area, all agreed that this area was not amenable to the Pl assessment approach, but l

would be best assessed in the traditional way - licensee self-assessment and focused NRC i

j baseline inspection. Given the difficulty in the view of industry to adequately define radiation i

protection barriers associated with NRC bullet (iii), NEl does not support a PI for unlocked HRA (dose rates less than 1000 mr/h). If this position holds, the NRC then would include this area in i

their baseline inspection program. The final proposed P! for the occupational area involved i

unintended worker dose in excess of some percentage of the NRC dose limits, resulting from l

non-compliance with Part 20/ licensee requirements / procedures (as proposed by NEI) or as a l

result of one or more barriers (NRC's proposal). No consensus could be reached on what percentage (of the dose limits) was appropriate, and both NEl and the NRC agreed to reexamine their positions on this draft Pl.

NEl and industry are planning to start the verification and validation (V & V) process for the l

draft Pts that have tentative consensus, and some of the preliminary results of this process should be discussed at the next scheduled meeting. The V & V results are necessary to j

establish at least face-validity for the Pls anJ to aid in setting thresholds for performance. The meeting was adjoumed.

Attachments: As stated j

cc w/att: See next page i'

DISTRIBUTION: See attached page l

l DOCUMENT NAME:G:\\MTGSUM10.29 4

)

OFFICE PERBdp PERB f

JWihton CMiller.-k, NAME c

I DATE 11/ 8 /98 D

11/ ;/98 OFFICIAL RECORD COPY 2

1 a.

Attaenment.5 14 E T-DRAFT FOR DISCUSSION Public Radiation Safety Performance Indicators Transoortation:

Program deficiencies which result in occurrences where removable radioactive surface contamination exceeds the package limits of 10 CFR 71.87(i) i 3 w.y(h::

f Program deficiencies which result in occurrences where the external radiation e

level exceeds the limits of 10 CFR 71.47 Radioactive Material Release Unauthorized releases of radicactive material which could result in public e

exposure in excess of 10 mrem (10% of the 100 mrem public dose limit established in 10 CFR 20.1301).

EfEuents Efiluent events which are reportable to the NRC under 10 CFR 20,10 CFR 50 Appendix I, ODCM, or Effluent Technical Specifications. (Note-this PI does not include actions related to the REMP.)

..