ML20204C608
| ML20204C608 | |
| Person / Time | |
|---|---|
| Issue date: | 03/18/1999 |
| From: | Wigginton J NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9903230165 | |
| Download: ML20204C608 (12) | |
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NUCLEAR REGULATORY COMMISSION If WASHINGTON, D.C. 20066-0001 March 18, 1999 MEMORANDUM TO: Thomas H. Ess!g, Acting Chief l
Emergency Preparedness and Radiation Protection Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
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FROM:
James E. Wigginton, Senior Reactor Health Physi N
Emergency Preparedness and Radiation Protectio Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF PUBLIC MEETING WITH THE NUCLEAR ENERGY i
I INSTITUTE (NEI) REGARDING INSPECTION FINDINGS SIGNIFICANCE FOR ASSESSING RADIATION PROTECTION PROGRAMS On March 1,1999, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) at the NRC offices in Rockville, Maryland. Attachment 1 provides a list of workshop attendees.
The purpose of the meeting was to get stakeholder comments and feedback on NRC staff draft matrices and logic diagrams to be used by the NRC to help assess licensees' radiation protection (RP) programs at power reactors. These tools will allow NRC inspectors to determine the safety significance of individual (RP) inspection findings.
NRC and NEl staff summarized and discussed the NRC and industry efforts to date, and the goals and time schedules for this project. Future meetings were planned, with a goal of meeting with industry radiation protection managers at the end of March. The NRC staff handed out Attachment 2 (NRC's draft public/ occupational exposure matrices and a flow diagram).
The discussion started in the occupational RP area. Based on NEl feedback, the NRC staff agreed to consider the following issues. Clarify that the high radiation (HRA) and very high radiation (VHRA) decision gates apply to findings that present a risk to the worker (as opposed to minor administrative violations). Delete the " substantial potential" issue from the uncontrolled exposures gates, since this aspect is covered in the HRA and VHRA logic. Delete the 2 rem TEDE gate (NEl believes it redefines the performance indicator - uncontrolled exposure).
Clarify the distinction between radiation monitoring for worker dose assessment worker and job control (critical barrier). Rearrange and reorder pathways and gates on the logic diagram. The NRC staff noted that the as low as reasonably achievable (ALARA) area is currently being developed and will be discussed at a later meeting.
CONTACT: James E. Wigginton, PERB/NRR k
415-1059 fO 9903230165 990318 vhw Nb1 q
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s Discussion in the public RP area was abbreviated, due to time constraints. NEl had no significant problems with the draft matrix. The NRC staff noted that the flow logic for findings in the the transportation of radioactive materials RP area had not been developed. As this flow logic develops, changes in the public exposure matrix are likely. The staff committed to be2 n i
work on that logic and to discuss this developing area at the next meeting.
NEl provided feedback on several related issues. NEl noted that industry questioned why the NRC staff proposed estimates of occupational RP inspection hours (for excellent performers) were to increase over the existing core inspection baseline level. NRC staff reported that the NRC Transition Team is reexamining the overall inspection program, and inspection procedures are currently being drafted. The issue of needed onsite inspection resources will be addressed during this process. Related to performance indicators (PI), NEl also noted that both the NRC and NEl now agree (for simplification) to use single time-frame evaluation periods for Pl. NEl agreed to reexamine licensee data and bring a draft proposal to replace the existing one and three-year Pl evaluation periods with a single time-frame period.
It was agreed to carryover this discussion to the next meeting. The meeting was adjoumed.
Attachments: As stated cc w/att: See next page
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l Nuclear Energy Institute Project No. 689 l
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 i Street, NW 1776 i Street, NW Washington, DC 20006-3708-Washington, DC 20006-3708 Mr. Steven Driscol Radiation Protection INPO 700 Galleria Parkway Mr. Alex Marion, Director Atlanta, Georgia 30339-5957 Programs Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 I
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Distribution: Mtg. Summary w/ Dated March 18, 1999 1
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Radiation Prote: tion Inspection Finding Significance Meeting i
l 3/1/99 l
l List of Attendees Name Oraanization Steve Klementowicz USNRC Rich Emch USNRC Ken Barr USNRC Roger Pedersen USNRC Jim Noggle USNRC Jim Wigginton USNRC Charles Hinson USNRC Ralph Anderson NEl Paul Genoa NEl
a Overell Aceseensent Preeses l Finene seenense (Pi) l Ree mn Pre =*en i.e,.eeien rinense 1.
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No No N'
ALARA HRA Uncontre#ed Cene mniece
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(>1000=s*hr)
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orVHRA?
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(Risk)?
N N
yee Yes Yee Yes
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GREEN
> 25 RRer PI TEDE&
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Sehetennel Potentiet?
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>2% STOC Linist Hera.s AnefyeWSurveye
>t0% Non STOC LintIt SnetrucWene to Workers I
>20% Fetel Lisnit (PWP/Posenge/Leboling)
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DRAFT EXAMPLES OF THE RISK SIGNIFICANCE OF INSPECTION FINDINGS IN OCCUPATIONAL EXPOSURE CORNERSTONE GREEN
( Licensee Response Band)
NRC or licensee-identified non-conformance that, if uncorrected, would result in an unplanned occupational TEDE greater than 100 mrem or >2% of 10 CFR Part 20 dose limits.
WHITE (Increased Regulatory Response Band)
Multiple NRC or licensee-identified non-conformances that, if uncorrected, would result in an unplanned occupational TEDE greater than 2 rem or >40% of 10 CFR Part 20 dose limits (with one or more PI's involving unplanned occupational TEDE greater than 100 mrem or >2% of 10 CFR Part 20 dose limits in past 12 months.
NRC or licensee-!dentified non-conformance involving an area with dose rates greater than 25 R/h with one or more barrier failures.
YELLOW
( Required Regulatory Response Band) i NRC or licensee-identified non-conformance that, if uncorrected, would result in an actual or substantial potential for an occupational TEDE in excess of 5 rem or greater than 10 CFR Part 20 dose limits.
NRC or licensee-identified non-conformance involving an area with dose rates greater than 25 R/h with three or more barrier failures.
NRC or licensee-identified non-conformance involving an area with dose rates greater than 500 R/h with one or more barrier failures.
RED (Loss of confidence in HP program's ability to provide assurance of worker safety)
NRC or licensee-identified non-conformance that, if unidentified and uncorrected, would result in an actual or substantial potential for an occupational TEDE in excess of 25 rem or grea'er than five times 10 CFR Part 20 dose limits.
NRC or licensee-identified non-conformance involving an area with dose rates greater than 500 R/h with three or more barrier failures.
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DRAFT NON-CONFORMANCE EVALUATION: PUBLIC EXPOSURE Objective:
Maintain exposures in the public domain less than 10 CFR Part 20, Plant Procedures, Appendix 1 to 10 CFR Part 50, and 10 CFR 71.5 GREEN (Licensee Response Band)
NRC identified non-conformance that results in exposure to a member of the public, from a release of licensed radioactive material to an unrestricted area or from direct exposure to radiation, to a TEDE greater than 0.025 rem but less than or equal to 0.1 rem.
NRC identified non-conformance that did not compromise effluent, environmental, or meteorologica! systems or programs to adequately monitor and assess the discharge of gaseous or liquid radioactive effluents to maintain exposure to a member of the public within Technical Specifications (i.e., keep radioactive effluents within the design objectives of Appendix i to 10 CFR Part 50)..
NRC identified non-conformance that did not did not compromise the safe transportation of licensed radioactive material, with the resulting exposure to a member of the public to a TEDE exposure less than or equal to 0.025 rom.
WHITE (Increased Regulatory Response Band)
NRC identified non-conformance that results in an actual or realistic potential exposure to a member of the public, from the release of licensed radioactive material to an unrestricted stea or from direct exposure to rcdiation, to a TEDE greater than 0.1 rem but less than or equal to 0.5 rem.
NRC identified non-conformance that represents a breakdown of the effluent, environmental, or meteorological systems or programs to adequately monitor and assoas the discharge of gaseous or liquid radioactive effluents, or a situation which results in a failure to maintain exposure to a member of the public within Technical Specifications (i.e., doses were greater than the design objectives of Appendix l to 10 CFR Part 50).
NRC identified non-conformance that results in an actual or realistic' potential exposure to a -
member of the public to a TEDE equal to or greater than 0.025 rem but less than or equal to 0.1 rom to a member of the public, which reflects a programmatic (rather than an isolated) weakness in the radioactive material control program.
NRC identified non-conformance in the transportation of licensed radioactive material not in conformance with the requirements of any of the following: 10 CFR Part 71, Department of i
Transportation regulations (49 CFR Parts 170 - 189) or the 10 CFR Part 61 licensed disposal site that results in an actual or realistic potential TEDE exposure greater than 0.1 rem but less than or equal to 0.5 rem to a member of the public.
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DRAFT YELLOW (Required Regulatory Response Band)
NRC or licensee identified non-conformance that results in an actual or realistic potential TEDE exposure greater than 0.5 rem but less than or equal to 1.0 rem to a member of the public.
NRC or licensee identified non-conformance of multiple examples which of actual or realistic potential TEDE exposure greater than 0.1 rem but less than or equal to 0.5 rem to a member of the public, which reflects a programmatic (rather than an isolated) weakness in the radiation control program.
NRC or licensee identified non-conformance of multiple examples of the transportation of licensed radioactive material not in conformance with the requireinents of any of the following:
10 CFR Part 71, Department of Transportation regulations (49 CFR Parts 170 - 189) or the 10 CFR Part 61 licensed disposal site that results in an actual or realistic potential TEDE exposure greater than 0.1 rem but less than or equal to 0.5 rem to a member of the public.
Bgp (Loss of confidence in Plant's ability to provide assurance of radiological safety to a member of the public.
NRC or licensee identified non-conformance that results in an actual or realistic potential TEDE exposure greater than 1.0 rem to a member of the public.
NRC or iicensee identified non-conformance of multiple examples which would result in an f
actual or realistic potential TEDE exposure greater than 0.5 rem but less than or equal to 1.0 rem to a i.nember of the public, which reflects a programmatic (rather than an isolated) weakness in the radiation control program.
NRC or licensee identified non-conformance of multiple examples of the transportation of licensed radioactive material not in conformance with the requirements of any of the following:
10 CFR Part 71, Department of Transportation regulations (49 CFR Parts 170 - 189) or the 10 CFR Part 61 licensed disposal site that result in an actual or realistic potential TEDE exposure greater than 0.5 rem to a member of the public.
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' Discussion in the public RP area was abbreviated, due to time constraints. NEl had no significant problems with the draft matrix. The NRC staff noted that an important public RP area had not been developed - transportation of radioactive materials. The staff committed to begin l
work in that area and to discuss this area at the next meeting.
NEl provided feedback on several related issues. NEl noted that industry questioned why the l
NRC staff proposed estimates of occupational RP inspection hours (for excellent performers) were to increase over the existing core inspection baseline level. NRC staff reported that the l
NRC Transition Team is reexamining the overall inspection program, and inspection procedures are currently being drafted. The issue of needed onsite inspection resources will be addressed during this process. Related to performance indicators (PI), NEl also noted that both the NRC and NEl now agree (for simplification) to use single time-frame evaluation periods for Pl. NEl agreed to reexamine licensee data and bring a draft proposal to replace the existing one and three-year PI evaluation periods with a single time-frame period.
It was agreed to carryover this discussion to the next meeting. The meeting was adjoumed.
1 Attachments: As stated Oc w/att: See next page
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DISTRIBUTION: See attached page DOCUMENT NAME:G:\\MTSUMNEl.WPD OFFICE PERB/Q PERB a
JWiMton TEssig #k NAME DATE 3//M9 3/IS /99 OFFICIAL RECORD COPY
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< j Discussion in the public RP area was abbreviated, due to time constraints. NEl had no significant problems with the draft matrix. The NRC staff noted that an important public RP area had not been developed - transportation of radioactive materials. The staff committed to begin work in that area and to discuss this area at the next meeting.
NEl provided feedback on several related issues. NEl noted that industry questioned why the NRC staff proposed estimates of occupational RP inspection hours (for excellent performers) were to increase over the existing core inspection baseline level. NRC stnff reported that the NRC Transition Team is reexamining the overall inspection program, and inspection procedures are currenti being drafted. The issue of needed onsite inspection resources will be addressed f
during this process. Related to performance indicators (PI), NEl also noted that both the NRC and NEl now agree (for simplification) to use single time-frame evaluation periods for Pl. NEl agreed to reexamine licensee data and bring a draft proposal to rep! ace the existing one and three-year Pl evaluation periods with a single time-frame period.
It was agreed to carryover this discussion to the next meeting. The meeting was adjourned.
Attachments: As stated cc w/att: See next page l
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i DISTRIBUTION: See attached page DOCUMENT NAME:G:\\MTSUMNEl.WPD OFFICE PERB/ Q PERB o
JWiMton TEssig %C.
NAME DATE 3//M9 3/16 /99 OFFICIAL RECORD COPY i
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