ML20205Q360
| ML20205Q360 | |
| Person / Time | |
|---|---|
| Issue date: | 06/12/1986 |
| From: | Minogue R NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | Sniezek J NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| Shared Package | |
| ML20204J261 | List: |
| References | |
| FOIA-87-714 NUDOCS 8811090204 | |
| Download: ML20205Q360 (31) | |
Text
_
l Y$
4 o
Lk
((
o, UNITED STATE g
NUCLEAR REGULATORY COMMISSION o
t W ASHING TON, D. C. 20655 A..e*/
@r I/r-JUN 12 N6 ggp2&*
JL MEMORANDUM FOR:
James H. Sniezek, Director Regional Operations and Generic Requirements Staff FROM:
Robert B. Minogue, Director Office of Nuclear Regulatory Research
SUBJECT:
TRANSMITTAL OF COMMISSION PAPER " REVISION OF THE ECCS RULE CONTAINED IN APPENDIX K AND SECTION 50.46 0F 10 CFR PART 50" FOR CRGR FEVIEW This memorandum transmits the Connission Paper "Revision of the ECCS Rule contained in Appendix K and Section 50.46 of 10 CFR Part 50" for review by the Committee to Review Generic Requirements (CRGR).
I request that a meeting of the CRGR be scheduled to discuss the Comnission Paper and its enclosures.
Since our 1Ast meeting with the CRGR, the Cocrnission Paper has been revised to address ELD and NRR questions concerning how prescriptive the proposed rule should be in recommending models for LOCA analyses. As a result of meetings with ELD and NRR, the proposed rule is now written in a more general fom and accompanied by a regulatory guide which will be issued for coment coincident with the proposed rule. The regulatory guide will provide specific LOCA model recomendations based on a review by a panel of independent experts. In addition to these documents, a report "Compendium of ECCS Research for Realhtic ECCS Analysis," will be completed by the end of July to provide the technical supporting basis for allowing more realistic LOCA analyses.
NRR, ELD and DRR have concurred with the Commission Paper. The ACRS was briefed at a meeting of the Thermal Hydr;ulics Subcomittee on April 30, 1986.
All of the elements necessary for CRGR review are included in this package.
Please contact Jose N. Reyes of my staff on 42-74422 if you require additional infomation.
$b h%w Robert B. Minogue, Director l
)
Office of Nuclear Regulatory Research 8011090204 001007
/
mgm "a
g
'. \\
\\
e For:
The Comissioners From:
Victor Stello, Jr.
Executive Director for Operations
Subject:
REVISION OF THE ECCS RULE CONTAINED IN APPENDIX K AND SECTION 50.46 0F 10 CFR PART 50
Purpose:
To obtain Comission approval to publish a notice of proposed rulemaking revising the ECCS rule contained in Appendix K and i 50.46 of 10 CFR Part 50.
Category:
This paper covers a major policy matter.
Resource estimates are Category 1.
Issue:
(a) Whether 10 CFR 50.46 and Appendix K should be modified to reflect the current state-of-knowledge by permitting the use of realistic ECCS evaluation models.
(b) Whether to allow certain changes or corrections to be made to the ECCS evaluation models without requiring a complete reanalysis by the applicant er licensee.
Suman:
Section 50.46 of 10 CFR Part 50 requires that calculations be perfomed to show that the emergency core cooling systems (ECCS) will adequately cool the reactor in tne event of a loss-of-cool-ant accident (LOCA). Appendix K sets forth certain required and acceptable features that the evaluation models, used to perfom these calculations, must contain. The results of these calcula-l tions are used to detemine the acceptability of the ECCS per-formance.
In many instances, these calculations result in technical specification limits on the reactor operation (e.g.,
peak local power) in order to comply with the 2200'F cladding i
j tuperature limit and other limits of i 50.46. These limits j
restrict the total power output and optimal operation of many reactors (e.g., most Westinghouse plants) in tems of efficient fuel utilization, maneuvering capability and surveillance
Contact:
L.M. Shotkin, RES 427-4254 c
J
(
a The Comissioners 2
requirements. Removing unnecessary restrictions on operation would allow increased U.S. electricity production, worth several hundred million dollars a year, without loss of benefit to the public health and safety.
In some cases, removal of these restrictions would result in benefits to safety. For example, diesel generator reliability cuuld be improv.ed by requiring less rapid start times. Also, by allowing a higher neutron flux at the core center, less neutron leakage at the vessel wall would result, thus reducing vessel weld embrittlement and the likelihood of crack propagation due to pressurized thermal shock (PTS). The beneffcial safety effects of reduced vessel weld irradiation have been quantified for several reactors through extensive research performed as part of the PTS program.
NRC, DOE (including AEC and ERDA), U.S. nuclear industry and foreign research on ECCS perfomance since the present ECCS rule was issued provides a technical understanding which shows that the existing ECCS rule restrictions are more stringent than required. Thus, the staff recommends that the ECCS rule be amended to reflect this more realistic safety assessment and to remove unnecessary operating restrictions. This is consistent with the 1973 Comission opinion published with the existing rule. A number of alternative approaches have been considered by the staff and each approach evaluated in tenns of safety, impact on the industry, NRC and industry resources required. As a result, the staff recomends eliminating the. requirement to use Appendix K features. The prescriptive nature of Appendix K is no longer necessary in view of the current improved knowledge of ECCS performance. More realistic analyses, combined with uncertainty evaluations, can be used as an alternative method to demonstrate conformance with 5 50.46 criteria for ECCS perfonnance.
Alternatives: The staff has considered the following options for amending the ECCS rule:
A.
Retain the existing rule with its present conservatism (no change).
B.
Modify the ECCS rule as stated in the advance notice of proposed rulemaking published in the Federal Register on December 6, 1978 ;43 FR 57157 (Enclosure A ).
C.
Modify only certain models contained in Appendix K, for which research investigations have been coepleted and a well documented data base exists. These changes would be selected in areas for which new experimental data has shown I
- st the existing models contain a larger degree of conser.
O than justified by current data uncertainties or are v unrealistic.
l
\\
7 - -. _ - - - - - - _ - - - _ _
t t
The Consissioners 3
i D.
Eliminate the requirement to use Appendix K models and allow realistic models to be used. Reduce the 2200*F and 17% oxidation limits of i 50.46 appropriately to ensure that sufficient conservatism exists to cover uncertainties in the realistic calculation.
l l
E.
Eliminate the requirement to use Appendix K models and allow use of realistic models with an evaluation of the t
uncertainty in the overall calculation included, similar to the approach discussed in SECY-83-472. The i 50.46 limits of 2200'F and 17% oxidation would be unchanged.
In all alternatives, the current Appendix K would remain avail-4 able for those applicants not desiring to use a revised evili,4 tion model.
j 8.ackground:
10 CFR 50.46 provides "Acceptance Criteria for Emergency Core f
Cooling Systems (ECCS) in Light Water Nuclear Power Reactors."
i This section requires that calculations of loss of-coolant accidents (LOCA) be performed to show that the ECCS will maintain cladding temperatures, cladding oxidation, and hydrogen generation to within certain specified limits.
It also requires that a coolable core geometry be maintained and that long term i
decay heat removal be provided. Appendix K sets forth certain j
rules on how these calculations must be performed. The criteria of i 50.46 and the calculational methods specified in Appendix K were formally issued in January 1974 after extensive rulemaking
[
hearings and are based on the understanding of ECCS performance i
available at that time.
i in the ten years following the rulemaking, the NRC DOE (includ.
[
ing AEC and ERDA), the U.S. nuclear industry, and foreign researchers have obtained considerable information on ECCS l
perfonnanew. The majority of this LOCA research is complete and has greatly improved the understanding of ECCS performance i
during a LOCA. The methods specified in Appendix K. combined I
with other analysis methods currently in use, are now known to
(
be highly conservativen that is, the actual temperatures during I
a LOCA would be much less than the temperatures calculated with l
curreht evaluation models using Appendix K methods. This fact i
is illustrated by comparisons showing temperatures during LOCA i
simulations in LOFT which are more than 600'F lower than i
calculations performed using Appendix K procedures, i
t The ECCS research has allowed quantification of the Appendix K i
conservatism. The results of experiments, computer code development, and code assessment now allow more realistic l
calculations of ECCS performance during a LOCA than is possible using Appendix K procedures. These codes and experiments also I
permit the uncertainties in the calculations to be estimated.
I i
i g
\\
\\
\\
The Comissioners 4
Two categories of research have contributed to improving understanding of LOCA phenomena. The first category of research includes phenomena for which Appendix K requires specific calcu-lational models to be used.
Examples include decay heat, metal-water reaction rate, discharge model, reflood heat transfer at low reflood rates, and other heat transfer phenomena. Enclosure "B" provides a discussion of these research findings.
In some cases research has shown the required models to be inadequate (e.g., discharge model) and in one case nonconserntive for a limited range of conditions. The proposed revision would remove references to these models. Most of the requirements of Appendix K have been shown to be more conservative than needed to protect public health and safety. The best example is the decay heat calculation which is now known to be conservative by over 20% during the initial phases of the LOCA.
The second category of research is more general ar.d was directed toward a best estimate understanding of the overall performance of ECCS. This research includes many investigatiors into specific phenomena in the areas of heat transfer and two phase flow. Many facilities such as the THTF, FLECHT and the foreign CCTF and SCTF facilities have been used to obtain specific heat transfer data.
This research data has been used by the NRC and industry to develop major new computer codes which account for complex phenomena such as non-equilibrium and multidimensional effects and provide an ability to perfom best estimate calculations of ECCS perfomance. TRAC and RELAP5 are advanced codes developed by the NRC.
In addition, major integral test facilities such as LOFT, Semiscale, TLTA, MIST, FIST and a number of foreign facilities provide complete simulations of LOCA and other transients for comparison with the calculations of the new computer codes.
This allows assessment of the overall uncertainty of the calculations and identification of needed improvements. This research, furtner described in Enclosure "B", now allows significantly improved calculations of ECCS perfomance over those possible when Appendix K was developed.
The staff is preparing a report which documents in detail the ECCS research which has been perfomed and the current knowledge of ECCS perforcance ("Comnendium of ECCS Research for Realistic LOCA Analysis," DRAFT).
It is also known that some plants are now testricted in operat-ing flexibility by limits resulting from conservative calculations using current inctels and Appendix K requirements and Inay be forced to operat. by these limits in a manner that increases pressurized themal shock concerns.
These limits may also result in excessive testing and wear on key safety equipment.
In addition, Appendix K requires reanalystes to be performed in the event that errors are discovered or certain changes are m.ade to approved evaluation models. Very often, the reanalyses contribute little to safety, but require significant i
The Comissioners 5
staff and industry resources. Based on research perfomed, it is now known that these restrictions can be relaxed without affecting safety. Some research results have already been used in licensing calculations, but many important results cannot be used since Appendix K specifically prescribes certain methods now known to be overly conservative. Thus a modification to the ECCS rule is desiiable to relax unnecessary operating restrictions.
On December 6, 1978, the Conmission published an advance notice of proposed rulemaking (43 FR 57157) calling for a two-phase approach to the revision of 10 CFR Part 50 and Appendix K (Enclosure "A").
The first step would have been to make proce-dural changes and to permit minor technical changes which would not have reduced the conservatism contained in Appendix K.
The second step would have made further technical changes needed to account for research results or phenomena not specifically identified at the time the rule was promulgated but through operating experience had since been identified as having a significant affect on ECCS performance.
Staff activity on the ECCS rulemaking was severely curtailed as a result of the high priority efforts required by the TMI-2 l
accident. This ECCS rulemaking essentially sat domant until July 1981, when it was brought up again in the context of simplifying and streamlining the regulatory process.
The staff has reviewed the coments made by outside organiza-tions on the advance notice of proposed rulemaking, as well as a number of other comments received since that time.
In general, the correnters suppcet t rule change that would pemit greater flexibility in meeting the regulations and would incorporate the use of presently available research infomation. Many felt that the Phase 1 scope should be expanded to allow additional model changes such as use of the new decay heat standard.
The most consistent connent received from the industry, licensees, NRC contractors, and other government agencies was that a hearing like that required to support the original rulemaking should not be used to accomplish needed changes to the requirements. Many correnters indicated that they would not support a revision to the ECCS rule included in 10 CFR Part 50 and Appendix K if a lengthy adjudicatory hearing were required.
The ACR$ has also supported a revision to the ECCS rule, as most recently stated in the ACRS annual report to Congress (NUREG-1105). Based on the corrents received fr;/n the advance notice of proposed rule-making and general support for a revision to the ECCS rule the staff t'eactivated the effort to modify the ECCS rule.
Because of the delay in changing the ECCS rule, the staff has used an interim approach, described in SECY-83-472, to accom-modate requests for improved evaluation models like that m
7
s The.< m
- m: r,
6 s
received from the General Electric Co. This interim approach requires a realistic calculation with an evaluation of the uncertainty in the calculation, to demonstrate that an adequate conservatism or safety factor exists in the improved evaluation model.
Discussion:
Many options can be proposed for revising the' ECCS rule.
Based on staff discussions, taking into account the numerous cocrnents received and the industry efforts in response to SECY-83-472, the staff developed several different options for revising the ECCS rule.
In this section, each option is dis-cussed and evaluated.
Alt. A:
Retain the existing ECCS rule with its present con-servatism (no change).
PRO: a.
The current well-established and st3ble licensing process would be retained.
b.
No staff resources would be required for rulemaking.
CON: a.
Many plants would continue to be unr.eces-l sarily restricted in operation by the cur-l rent rule.
b.
Many licensees would continue to seek relief from restrictions through requests for l
exemptions or by using the approach l
discussed in SECY-83-472. Both these approaches are interim measures and should not substitute for revising the rule to make it consistent with current knowledge and practice.
Alt. B:
Modify the ECCS rule as stated in the advanced notice of proposed rulemaking published in the Federal Register on December 6, 1978; 43 FR 57157.
PRO: Consistent with previously-stated plans and would allow minor changes to be quickly implerrented.
CON: a.
Substantial changes would be delayed until a later phase, b.
Oces not resolve coments received on the advanced notice recommending more substan-tial changes.
1 l
/
/
l l
The Comissioners 7
Alt. C:
Modify certain models contained in Appendix K, for which research investigations have been completed and a well-documented data base exists. These changes would be selected in areas for which new experimental data has shown that the existing models contain a larger degree of conservatism than justified by current data uncertainties or are obviously unrealistic.
PR0: a.
Plants would no longer be limited in opera-tion by current ECCS rule restrictions, b.
This would be in agreement with Comission policy (NUREG 0885) to incorporate the results of research into the licensing process.
CON: a.
The revised ECCS rule might not contain suf-ficient and quantified conservatism to account for calculational uncertainty.
Additional analyses would be required to demonstrate that sufficient conservatism remained in the calculation, e
b.
The ECCS rule may have to be changed in the future to make use of research results or other information which may become available.
Alt. 0:
Eliminate the requirement to use Appendix K models and allow realistic models to be used.
Reduce the 2200*F and 17% otidation limits of i 50.46 appropriately to ensure that sufficient conservatism exists to cover uncertainties in the realistic cal:ulation.
t PRO: a.
Maximum use of coepleted research could be i
made in licensing to relax unnecessary l
4 l
cperating restrictions.
This would be in agreement with Comission policy (NUREG-0885) to incorporate the results of l
research into the licensing process.
b.
Licensing models would provide more real-istic calculations to allow more accurate detemination of the ef fect of equipment i
changes or failures and operating procedures.
l CON: a.
The conservatism used to account foe uncer.
tainties would be fixed throvah v.e revised i
1 50.46 timits and could not e varied to m,
_,. _ _ _ _ _ _ - ~ _ _ -...,,,,, _,,,., _, _
-w-
The Comissioners 8
account for more accurate e.alculations of uncertainty which may be available in the future (i.e.
little incentive for further improvement),
b.
Additional staff resourfes would be required to establish fixed conservatisms applicable to all plant types.
c.
The introduction of a less prescriptive rule would provide a greater opportunity to challenge licensing amendments.
Alt. E:
Eliminate the requirement to use Appendix K models and allow use of realistic models with an evaluation of the uncertainty in the overall calculation included, similar to the approach discussed in SECY-83-472. The i 50.46 limits of 2200*F and 17% oxidation would be unchanged.
PRO: a.
Maximum use of completed and future research could be made in licensing to relax unneces-sary operating restrictions. This would be in agreement with Con ission policy (NOREG-0885) to incorporate the results of research into the licensing process, b.
Licensing models would provide more realistic calculations to allow more accurate detemination of the effect of equipment changes or failures and operating procedures.
c.
The urcertainty evaluation would quantify the conservatism in the calculations which could change as the accuracy of the calcula-tions improved.
d.
The industry and NRC staff are already investing effort to follow this approach.
CON: The introduction of a less prescriptive rule would provide a greater opportunity to challenge licensing amendrrents.
In all alternatives considered the current Appendix K would remain available for those applicants or licensees not desiring to use a revised evaluation model.
The Consnissioners 9
The staff believes that Alterndtives A and B, which would provide little or no change in the ECCS rule, are unacceptable.
The ECCS rule should be changed because:
(1) A data base now exists that supports relaxation of the ECCS rule.
(2) A revised ECCS rule would remove unnecessary operating restrictions on plants.
(3) Almost all U.S. research on LOCAs has been completed. The remaining portions of the MIST and 20/30 programs are l
expected to provide valuable information for assessment of models, but should not affect the proposed rule change for the reconsnended alternative.
(4) Nuclear reactor v6dders are curre[itly working on future plant designs which would be influenced by the revised ECCS rule.
The staff has also considered Alternative C which would modify certain models in Appendix K, for which research investigations are completed. The revisions considered under Alternative C include:
a.
Reanalysis requirements, b.
Post-CHF beat transfer, i
c.
Return to nucleate boiling.
I d.
Refill and reflood heat transfer (steam cooling below reflood rate of one inch per second),
e.
Fission product decay, f.
Metal water reaction, and g.
Discharge model.
Based on recent supporting analyses performed by vendors and natiodal laboratories, the staff has determined that if Appendix K were to be revised according to Alternative C, it is possible that the remaining overall conservatism in the evalua.
tion models would be on the same order or less than the uncer.
tainty of the calculation, as discussed in Enclosure "C".
This would be unacceptable since one could no longer assume that Appendix K contained sufficient conservatism to account for the total uncertainty in the calculation. Thus, use of Alternative I
C without supporting uncertainty analysis was dropped from I
consideration.
A
The Comissioners 10 P
The staff also considered revising Appentlix K in a manner similar to Alternative C but requiring an additional uncertainty analysis to ensure that th's evaluation model contained sufficient conservatism. This option would require i
two calculations, a realistic calcutation with uncertainty ana-lysis and an evaluation model calculation.
This option was also dropped from consideration sinte the licensee would be required to perform two calculations, of which one, the evaluation model, would provide little benefit to safety.
Based on our current technical understanding of ECCS performance, the approach of a prescriptive Appendix X is no longer necessary. A realistic calculation, taking into account the overall uncertainty in the analyses. is an acceptable approach which ensures the safety of the public without unnecessarily restricting applicants and licensees.
Thus, the staff has concluded that the ECCS rule should be revised accord.
ingly and the requirement to use Appendix X eliminated.
There-fore. Alternatives D and E were considered, both of which use realistic calculations. The difference between the alternatives is in the treatment of uncertainties. Alternative 0 would reduce the 150.46 limits of 2200'F and 17% cladding oxidation to cover uncertainties in the calculation and uncertainties in the point at which substantial core damage would occur.
Alter-native E would require an er.a.ertainty factor to be added to the best estimate calculation. Alternative 0 was not selt.cted because (1) the i 50.46 limits of 2200*F and 17% cladding oxidation are believed to already be appropriate and conservative limits below which substantial core damage will not occur, as discussed in Enclosure "C", (2) the conservatism used
[
to account for uncertainties in the calculation would be fit ed i
and could not be varied to account for more accurate cal.
I I
culations, and (3) further staf f analyses would be required to l
support establishing these limits.
I The staff recomends that Alternative E be adopted. This alter-t l
native would require that the licensee show that the criteria of I 50.46 are ret using a realistic calculation comt.ined with an evaluation of the uncertainty of the c. ?'all calculation.
This uncertainty evaluation, combined with O e additional conservatism in the 2200'F criteria, would ensure a negligible risk to the public. This approach to licensing is consistent l
with the interim method discussed in SECY 83-472 except that the L
additional Appendix K calculation, which contributes little to safety, would not be required.
Further. Appendix K would remain
/
available (with minor modifications) as an alternative.
l Therefore, licensees and applicants which do not Leed nor desire l
relief free current operating restrictions would have no new l
requireeents and could continue to meet existing Appendix K l
requ i recren,s.
The burden of perfoming new l
t
I The Commissioners 11 k.li calculations would only be placed on those tpplicants and licensees who elect to gain relief from 1.0CA restrictions.
The proposed ECCS rule chanc.e would also provide relief from the reanalysis reouirements which so not contribute substantially to safety, as well as a' low use of the technical understanding of ECCS phe,'.omena that has been obtailed since tne current rule was issued.
The modificatien would ellow applicants and licensees relief from unnecessary operations! restrictions resulting frori loss-o'-coolant accident (1.0CA) aralyses and still result in an the ECC. <;nalyses. This t
adequate level of conservatism d'.
revision in the analysis methods is expected to reduce tha calculated peak clad tc. perature in a typical plant and allow an m
increase in the local peak power or total power, as discussed in inclosure "C".
The additional. flexibility ceuld also be used to
}
improve safety (e.g., reduce the Mutron flux on the reactor vessel wall to he.1p alleviate the pressurized themal s: sock problem) and irprove the efficiency of reactor op0 rations.
These changes would allow $ %e plants to increase total power, improve fuel burnups, has' '
- 1ger fuel cycles, accomodate s*eam generator tube p' egging and reduce equipment surveillance requirements, thereby reducing operating costa.
Enclosure '0" is a Regulatory Analysis describing some of these potential cost savings.
Resource NRC staff resources to irvlement the proposed rv e enange are Estimates:
thought to be negligible under the assumption that no unusual or special rulenaking proced"' t (= g adjudicatory hearinp' will be established by the *,vp,,uon.
If the, Corriission chooses to hold hearings, rNrces would have to be diverted from other high priority activities.
Given that the rule is implem nted, t'0 impact of the changes on resource ?cuuirements will deper.d on. the number of applicants or licensees which make use of the rule change.
The major staff resource, required under the proposed rule change would be to rev*<w the realie.ic modeh and uncertainty analysis required bv the revised EC'.b Ruts. Based on previous experience with *.he General Electric Co.
SAFER model and the learn hg th
- nas resulted from these efforts, it is estimated that app %ximately ci,e '.taff year would be requ? red to review
,..O. ; neric model subrnitted. There are four major reactor vendors (GE already has a revised evaluation model approved under the existing Appendix K for jt.t pump plants but is f
currently working on s, new evaluatic:' model for non jet pump
/
plants and may update their rethodology under a new rule) and several fuel suppliers and utilities which perform their own analyses and potentially migh'. $1bmit ge.seric Nelt for review.
However, it is expected that onl/ 3 or 4 gev h Todels would be submitted tince not all plants would bentrit,i.o the *ule change.
Thus, about 3 4 staff years would bc
. quired to review
\\
\\
r
~'
i The Comissioners 12 2
the expected generic models. Once a generic model is approved, the plant specific review is very short.
In addition, several vendors are currently planning to submit realistic models in conjunction with the use of SECY-83-472. Therefore, staff resources would be expended to review these models in any event.
Recommendations:
That the Comission:
1.
Approve the publication of proposed amendments, as set forth in Enclosure "E", which would allow certain changes and corrections to be made to the ECCS evaluation models without requiring an imediate reanalysis by applicants or licensees and would permit the use of realistic calculations, along with uncertainty analyses, to be used in the evaluation of ECCS performance.
Evaluation models based on Appendix K features could also continue to be used.
2.
Note that:
a.
The notice of proposed rulemaking in Enclosure "E" will be published in the Federal Register, allowing 180 days for public coment, b.
Pursuant to il 51.21 and 51.31 of 10 CFR Part 51 of the Comission's regulations, a preliminary environmental assessment and finding of no significant impact is attached as Enclosure "F".
c.
Pursuant to the Regulatory Flexibility Act of 1980, the proposed rule contains a statement that the Comission certifies that the rule will not, if promulgated, have a significant economic impact upon a substaatial number of small entities and a copy of this certification will be forwarded to the Chief Counsel for Advocacy, S8A by the Division of Rules and Records, ADM; d.
The sebcommittee on Nuclear Regulation of the Senate Comm:ttee on Environment and Public Works, the Subcom-m'ttet on Energy and the Environment of the House Com-m'.i.ee on Interier and Insular Affairs, the 5 4bcomittee on Energy Conservation and Power of the
..ouse Comittee on Energy and Comerce, and the 5:Jbcomittee on Environment. Energy and Natural Resources of the House Comittee on Government Operations will be informed.
l e.
A Regulatory Analysis is attached as Enclosure "D";
i 1
a, The Commissioners 13 f.
A draft regulatory guide (Enclosure "G") will be issued for public connent, g.
Copies of the Notice of Proposed Rulemaking will be-distributed by the Office of Administration, Division of Technical Information and Document Control to each affected applicant, licensee, and other interested parties.
h.
The ACRS has been regularly consulted concerning this proposed rule change a.1d has been provided this infor-mation for comment.
i.
Although a backfit analysis is not required by 10 CFR 50.109 because the proposed rule does not require applicants or itsensees to make a change but only offers additior.
"tions, the factors in 10 CFR 50.109(c) have been analyzed and are included for information (Enclosure E).
e
u l
\\
LQ The.Cosmissioners 14 Scheduling:
I recommend affirmation at an open meeting. No specific circumstance is known to the staff which would require Commission action by any particular date in the near term.
Victor Stello, Jr.
Executive Director for Operations
Enclosures:
A - Advanced Notice of Proposed Rulemaking, 12/06/78 8 - Sunnary of ECCS Research C - Conservatism in Appendix X and 50.46 0 - Regulatory Analysis E - Notice of Proposed Rulemaking F - Environmental Assessment G - Oraf t Regulatory Guide 4
i l
1 1
,w
.-r,
,-.,.v--
-e--
< - - -, - -. * -,, -. - ~,.
--,e r ------ - - -,--,
i The Comissioners 15 Scheduling:
I recomend affirmation at an open meeting. No specific circumstance is known to the staff which would require k
Comission action by any particular date in the near term.
l Victor Stello, Jr.
I Executive Director for Operations
Enclosures:
A - Advanced Notice of Proposed Rulemaking, 12/06/78 B - Sumary of ECCS Research C - Conservatism in Appendix K and 50.46 0 - Regulatory Analysic E - Notice of Proposed Ruleaaking F - Environmental Assessment G - Draf t Regulatory Guide Distriteution:
Subject MFleishman, RAMRB Chroa W0lmstead, ELD Cir WShields, ELD Branch R/F TScinto ELD RBMinogue TSpies, NRR DFRoss BSheron, NRR FGillespie WMorris LMShotkin WDBeckner DSolberg NZuber HTovmassian JReyes JReyes R/F
.W Og y D6
- i. S RES; b >
RES/R IB RES/RSRB RES/RSRB RES/RSRB CRESS:SS 5520 JNR( es:cif Mfleishman HTovmassian WDBeckner LMShotkin 5/2/86 6/ 1 /86 5/d'/86 8/JI/86 6/f/86 G//V/86 RES RES f
ADM ELD NRR f
[fEconti WMo i
DGrimsley GCunningham HDenton 4
86 6/(,/86 g/
86 5/14/86 6/ 4 /86 5/21 /86 RE Concurrence with cocnents; Conments incorporated R8h oque 6/ p 86 7
h f
0 g Af b
a r
]
[
'l bb t
SUMMARY
OF PROPOSED GENERIC REQUIREMENTS FOR CRGR REVIEW t
j OFFICE OF NUCLEAR REGULATORY RESEARCH DATE: August 1, 1986 t
RES TASK NO.: MS-602-8 RES TASK LEADER: John A. O'Brien MSEB, DET, RES TELEPHONE:
301-443-7854 Title of Proposed Action
- I Pipe Rupture Requirements for Nuclear Power Plants
'l i
Type of Action
(
l SRP Revision Category:
Category 2.
The arbitrary intennediate break relaxations of this revision have been requested by about fifteen utilities. Consistency demands that the SRP reflect current practices and views.
)
t
(
Statement of the Problem The U.S. Piping Review Comittee has identified a number of difficulties resulting from dynamic effects associated with postulated arbitrary The following is a direct quote from Volume 5 intermediate pipe ruptures.
of NUREG-1061, "Report of the U.S. Nuclear Pegulatory Comission Piping Review Comittee" April 1985:
"As a result of these so called arbitrary intennediate break criteria, many pipe whip restraints have been installed. These restraints have resulted in many problems, which are described as follows:
Designing for the two arbitrary Complications in Pipe System Design.
intennediate breaks is a difficult process because the location of the o
two highest stress points tends to change several times as a result of the iterative process involved in the seismic design of piping sys-The SRP (NUREG-0800, dated July 1981) provides criteria intend-tems.
ed to reduce the need to relocate intennediate break locations when i
i the high stress points shift as a result of piping reanalysis; in The two locations practice, these criteria provide little relief.
selected by the stress calculation may not be the actual locations of highest stress because the mathematical model may differ from the ac-If the locations are not actually representative, tual piping system.
proper protection may not be provided in accordance with the system's design.
\\
r o
Cost Factors. As a result of the arbitrary intennediate break re-quirements, an excessive number of pipe rupture protection devices have to be designed and constructed. The cost for the design, con-struction, and operational service maintenance is estimated to be from
$4 million for nine major systems to $30 million for all systems.
Restricted Access for Inservice Inspection. The leak-before-break o
concept can be implemented only when inservice inspection and/or leak-detection systems provide early detection of possible cracks and potential leaks in the system. However, the pipe rupture protection devices block access to welds and thus hinder inservice inspection.
I The removal and reinstallation of the pipe rupture protection devices will add to the time required to perfonn necessary inservice inspections. Restricted access will also increase Occupational radiation exposure during repair, ma.intenance, and decontamination operations, Increased Heat loss to Surrounding Environment. Because pipe whip o
restraints fit closely around the high-energy piping, the piping insu-lation must often be cut back in these areas to avoid interferences, thus creating convection gaps adjacent to the restraints. This cre-ates an overall increase in heat loss to the surrounding environment and is a major contributor to the tendency for many containments to operate at temperatures near technical specification limits.
l Unanticipated Thermal Expansion Stress. Pipe rupture protection de-o vices are designed not to restrict pipe-free thermal expansion.
Should these devices inadvertently come into contact with the pipe itself, unanticipated stresses due to restraint of thennal expansion can be introduced. The precise consequences of this incident are dif-ficult to assess. Probabilistic analyses performed by the Lawrence Livennore National Laboratory indicate in general that the resultant reduction in flexibility reduces the overall safety margin of the pipe system."
A need exists to remove these difficulties which result from the dynamic Since effects of postulated arbitrary intennediate pipe ruptures.
arbitrary intermediate pipe ruptures are required only by Branch Technical j
I Position MEB 3-1 of SAP 3.6.2, a revision to this document is appropriate.
Additionally, MEB 3-1 (last revised in July 1981) contains citations to stress limits and other factors in the ASME Code which are no longer in effect. To update SAP 3.6.2 to reflect the latest ASME Code requirements, a review was performed by E. C. Rodabaugh for the NRC and his reconnendations have been implemented in this revision of SRP 3.6.2.
l f
= - - - - - - - - - - -
.T.
t Objective To obtain CRGR approval to publish in the Federal Register a proposed re-vision to Branch Technical Position MEB 3-1 of SRP 3.6.2 with the aim of obtaining public consnent..
Selected Milestones:
(Intennediate Milestones Not Indicated)
Package sent to CRGR Sept 1986 CRGR Review of Proposed Revision Completed Nov 1986 ACRS Review of Proposed Revision Completed Jan 1987 Federal Reglster Notice of Proposed Revision Published Feb 1987 4
Federal Register Notice of SRP Issuance Published Feb 1988
=
Action Proposed This action relaxes arbitrary intermediate pipe rupture provisions in Li Branch Technical Position MEB 3-1 of SRP 3.6.2.
Additionally, stress limits and other ASME citations are updated by this revision. This update i
has no value-impact because it is already being implemented.
Supporting Document NUREG-1061, Volume 5, April 1985 Affected Plants A population of 80 PWR giants (62 operating and 18 under construction) with a remaining lifetime of 2689 plant years and 35 BWR plants (31 operating and 4 under construction) with a remaining lifetime of 1157 plant years was included in this evaluation.
Implementation The relaxation relating to arbitrary intermediate pipe ruptures is not mandatory. Applicants and licensees need not develop any technical information nor prepare any value/ impacts to take advantage of the SRP revision. About fifteen utilities have requested relaxation regarding arbitrary intennediate pipe ruptures.
Licensees of operating plants desiring to eliminate previously required dynamic effects from arbitrary intermediate pt:
ruptures may use the provisions of 10 CFR 50.59.
5
,-,,n..-
1 6
REGULATORY FLEXIBILITY ANALYSIS FOR 10 CFR PART 20 IMPROVED PERSONNEL DOSIMETRY PROCESSING This rule will require NRC licensees that are required by NRC regulations such as 10 CFR 20,202(a) and 10 CFR 34.33(a) to provide monitoring to workers, to have those dosimeters that require processing processed by a processor that has' been accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Bureau of Standards (NBS).
Currently NRC licensees are not required to utili;:e the services of accredited processors since performance requirements for dosimetry processing are not included in the regulations.
This rule establishes common testing and quality assurance procedures for dosimetry processing based upon a national consensus standard, ANSI N13.11, and should eliminate many current problems that include inappropriate calibration sources, poor process control, inadequate instrumentation, and clerical errors.
The hRC considers that this form of accreditation by NVLAP is needed to provide improved accuracy and reliability of occupational worker dose records.
The need for performance requirements for dosimetry processors was recognized as early as 1955 when the Atomic Energy Commission funded the NBS to undertake the first intercomparison of film badge response.
l Unfortunately, no suitable performance standards were developed prior to ANSI N13.11 in 1983.
At issue are the following:
The commercial dosimetry processing business is highly competitive, l
Hell qualified firir.s compete against less-qualified firms.
Many customers of commercial processors have little expertise in dosimetry processing.
l Customers generally contract to '..ne lowest bidder.
1 h[
l 08/11/86 1
.... -u
\\
\\
l Less-qualified firms may neglect technical and operational details to keep their prices low.
Well-qualified finns may reduce the quality of their processing perfonnance in order to remain competitive.
In order to maintain quality processing, it is imperative that standards of pet fonnance and accuracy be adopted.
Accreditation under NVLAP involves three separate actions:
(1) documenta-tion of responsible personnel, equipment, facilities, and quality control proce-dures; (2) proficiency testing of dosimeters in accordance with the procedures of ANSI N13.11; and (3) on-site assessment by NVLAP assessors of operations, equipment, and quality assurance procedures. Costs to the dosimetry processors for NVLAP accreditation depend to a large extent on the size of the processing operation. These consist of an initial cost associated with documenting and setting up quality control procedures, biennial costs associated with proficiency testing, and maintenance costs for the in-house QA program. The initial one-time cost of setting up the program is estimated to be about $7,000. The NRO staff believes that the majority of dosimetry processors have already incurred this cost in association with the three rounds of performance testing conducted by the University of Michigan. Maintenance costs for the QA program are esti-mated by NVLAP to range frcm $2,000 biennially for a small processor to $6,500 biennially for the larger processors.
Proficiency testing costs vary consider-ably according to the number of different dosimeter types tested and the number of categories tested for each type. Typical costs for a small processor with one dosimeter type tested in one category is $3,700 biennially, while costs to a larger processor with one dosimeter type tested in all eight categories is
$10,250 biennially. There is also a one-time fee for new applicants of $450.
There are currently 90 known personnel dosimetry processors in the U.S.
that perform personnel dosimetry services either in-house or comercially. Ten of these are considered to be "small entities" as defined in Section 601(3) of the Regulatory Flexibility Act. The source of this infonnation is a letter dated November 8,1982, from the University of Michigan (UM) written in con-junction with a series of three pilot tests on personnel dosimetry processors conducted by UM under an NRC contract.
A copy of the letter is available for 08/15/86 2
Enclosure D
i inspection upon request or copy for a fee at the NRC's Public Document Room, 1717 H Street NW, Washington, DC.
The total volume of business within the dosimetry processing industry is estimated at $34 million annually with the 10 small entities identified above sharing approximately 0.5% of the market or $170,000. While the NRC does not know the distribution of this volume of business among these small entities, an equal distributien of the business would indicate an average income of $17,000.
The initial cost of $7,450 and biennial cost of $5,700 for NVLAP accreditation of small processors cited above would have a significant impact on any processor whose annual incore is only $17,000.
Coments received from *iicensees and the processing industry on the proposed rule and initial regulatory flexibility statement included many that objected Most of the comenters felt that the costs of the '
to the costs of the program.
NVLAP program could be reduced significantly for small p ocessors by eliminating
.the in-house assessments by NYLAP assessors. Others felt that a differential fee schedule should be adopted for small processors, and a few felt that 'the quality assurance inspections should be conducted by NRC rather than NVLAP personnel.
The Comission believes that third-party accreditation under NVLAP will provide and maintain the much needed improvement in dosimetry processing. Consideration of this finding and the alternatives considered are described in the Regulatory Analysis. The Comission rejects the concept of different compliance or reporting requirements (such as preferentially eliminating in-house NVLAP assessments) between small and large processors since this concept is counter to the initial goal of establishing uniform and consistent procedures throughout the dosimetry industry. The Comission likewise rejects the suggestion that NRC quality assurance inspections be substituted for NVLAP inspections sirce these inspections or assessments are an essential part of the laboratory accreditation program and fall under the jurisdiction of NBS. In regard to a differential fee schedule, NRC has no authority to impose such a schedule since NBS sets NVLAP l
accreditation fees. Small processors should be aware that grants are available j
l from the Small Business Administration to assist small businesses meet Fedarally imposed licensing fees.
l l
l 3
Enclosure D i
08/15/86 i
\\
The Comission has considered the impact of mandatory NVI.AP accreditation and has concluded that the benefits that would result to workirs, licensees, I
the NRC, and the general public render it necessary in spite >f the program's possible negative economic impact on small entities.
i b
o t
r<
I t
1 i
i 1
3, i
i 4
Enclosure D 08/15/86
s.
L_
,R
(]
REGULATORY ANALYSIS FOR j
10 CFR PART 20 IMPROVED PERSONNEL 00SIMETRY PROCESSING 1.
PROPOSED ACTION NRC liunsees are required to provide personnel monitoring (dosimetry) to workers who have the potential for receiving radiation doses as specified in 10CFR20,202(a)and10CFR34.33(a).
Data from these personnel dosimeters are the bases for licensee and NRC records of external doses to workers. At present the NRC has not specified performance criteria or quality controls on the processing of personnel dosimeters.
Several studies of dosimetry processor perfonnance conducted between 1967 and 1976 indicated poor perfonnance by processors when tested against available standards. These studies clearly demonstrated that there was a need for a connon performance standard for both film and thermoluminescent dosimeter testing.
Directly as a result of these tests, a new performance standard for dosimetry was developed by the Health Physics Society Standards Comittee and was subsequently published as ANSI N13.11. The ability of dosimetry processors to meet the criteria of this standard was evaluated in a series of three tests conducted for the NRC at the University of Michigan.
The Michigan tests showed an increase in the number passing from 48% to 75% between tests one and three, indicating that personnel dosimetry processors were capable of oking the much needed improvements.
Subsequent to the three tests discussed above, a dosimetry accreditation program under the National Voluntary Laboratory Accreditation Program (NVLAP) of the National Bureau of Standards (NBS) began operation in January 1984 and, for the first quarter.
l l
recorded a passing rate of 93%.
I Based on the results discussed above, the NRC concluded +5at an amendment to the current regulations is needed to ensere improved personnel dosimetry j
processing. The amendment would include not only perfonnance testing but would include checks on the quality assurance program of the processors. The amend-ment would require all NRC licensees that are required to provide personnel 0
i 08/15/86 1
Enclosure B l
dosimetry to have the dosimeters processed by an accredited personnel dosimetry processor.
2.
OBJECTIVES The objectives of the regulatory amendments are to ensure the accuracy and reliability of occupational worker dose records by requiring that the processing of personnel dosimeters (used to measure occupational doses of the workers) be performed uniformly through the application of specified accreditation procedures.
Several tests have indicated that many dosimetry prccessors perform poorly when tested against performance standards, and some report radiation doses in a manner that is difficult to understand.
Use of standard performance tests and quality control in an accreditation program will ensure that exposed workers will have the advantage of personnel dosimetry evaluated against an acceptable national standard, regardless of which processor does the work.
3.
ALTERNATIVES Five alternatives were considered:
(1) No change in current requirements (2) Require licensees to have processing perfonned by a processor that had successfully participated in dosimetry performance testing admini-stered in accordance with ANSI N13.11 and that had a documented QA pro-j gram whose elements would be specified in NRC regulations.
(3) Require licensees to have their processing perfonned by a processor that had successfully participated in dosimetry perfonnance testing administered in accordance with ANSI N13.11 by an NRC specified test-i ing laboratory and that had a documented QA program whose elements would be specified in NRC regulations (this alternative differs from the previous alternative in that NRC would specify the proficiency I
testinglaboratory).
This alternative could be accomplished by either of the following options.
08/15/86 2
Enclosure B l
Option A: NRC licensees would be required to utilize the services of j
a processor that had successfully participated in perfonnance testing at a proficiency testing laboratory that had been contracted by the NRC. NRC inspectors would examine written proof that the processor had participated in the program and would ensure that the processor maintained a QA program as specified in NRC regulations.
Option B:
NRC licensees would be required to utilize the services of a processor that had been accredited under the NVLAP of the NBS.
This program would involve:
(a) Performance testing in accordance with ANSI N13.11 (b) Information collected by questionnaire, and (c) Onsite inspection of routine dosimetry processing and QA tech-niques by NVLAP contracted assessors.
(4) NRC would request from Congress Qe authority to license per-sonnel dosimetry processors dire:tly sincts many of these pro-cessors are not NRC licensees.
(S) NRC would change the regulations to require that licensees obtain their personnel dosimetry services from an NRC-operated or an NRC-contracted dosimetry service.
4.
CONSEQUENCES Alternative 1: No change in current requirements.
This alternative would probably result in no change in the status quo.
The NRC would continue the practice of attempting to enforce existing regulatory requirements on personnel rnonitoring without the benefit of any performance standard or quality control procedures against which to judge conformance by its licensees. Workers would continue to use dosimeters which are often not i
08/15/86 3
Enclosure B
calibrated to their specific needs while responsible processors that have voluntarily joined the NVLAP accreditation program would be likely to drop out of the program for economic reasons in order to compete with the less responsible and less qualified segment of the dosimetry processing community. This alter-native would entail no costs to the NRC and the only costs to the dosimetry processing industry would be to those processors that had applied voluntarily for NVLAP accreditation.
Alternative 2: Require licensees to have their processing performed by a pro-cessor that has successfully participated in a testing program administered in accordance with Ahst N13.11 and that has a documented QA program that meets the requirements specified in NRC regulations.
NRC would not specify the testing laboratory and would specify the necessary QA elements in its regulations.
This alternative would allow dosimetry processors and users the fr,eedom to establish one or more testing laboratories without government involvement and to use the laboratory of their choice on the basis of competitive pricing or some other parameter. No government resources would be used in establishing the testing laboratory. On the other hand, there would be no guarantee that industry would establish several, or even one, testing laboratory.
- Further, this alternative would require the NRC to develop a 3et of QA requirements for incorporation in the regulatfons with an estimated cost to the NRC of 1/2 man-year of effort. Also this alternative would require an inspection and enforce-ment effort estimated to be 1 staff-year annually to assess the adequacy of licensees' and processors' QA programs.
Additionally, NRC inspectors would not inspect processors that are not NRC licensees.
Alternative 3: Require licensees to have their processing performed by a pro-cessor that has successfully participated in a testing program administered in accordance with ANSI N13.11 by an NRC-specified testing laboratory and that has a documented QA program that meets the requirements specified in NRC regulations.
This alternative could be met by either of two options:
Option 3A: The NRC would obtain the services of a performance testing laboratory through a competitive bidding process. NRC licensees would be required to have their processing performed by a processor that had suc-cessfully participated in the testing at this testing laboratory. NRC nc osure B N 18/ N = e w.. u. ~.......
inspectors would examine written proof that uch testing had been performed successfully and that the processor had a documented QA program that met the requirements specified in NRC regulations.
This alternative appeared to have worked well in the past during the performance testing program where the University of Michigan operated the proficiency testing laboratory under an NRC competitive contract. This alternative would not require extensive NRC staff resources for administra-tion and contract review. On the o?her hand long-term Federal resources would have to be budgeted for operation of the laboratory in the event that the progran did not become self supporti19 This alternative w0uld also require an estimated 1 person-year annu sily to assess the adequact of the licensees' and processors' QA programs, t
Option 3B: The NRC would specify in its regulations tnat third-party accreditation would be utilized and that licensees would be required to have their processing performed by a processor that had been accredited l;
under the NVLAP of the NBS.
The dosimetry laboratory accteditation program was started in 1981 l
under an Interagency Agreement between tie NRC and NBS, and a performance testing laboratory was contracted for by the NBS. Proficiency testing and NVLAP accreditation of processors kun in Janui.*y 1984.
Because proficiency testing and Ni' LAP accreditation of processors began in 1984, the costs fo-implementation of such a program have already been incurred, and the effective implementation cost of such a program is therefore zero.
The l
program is expected to be self-supporting through the accreditation feer, charged to the processors.
Costs to processort for accreditation depend upon the size of the processor's I
operation, the number of dosimeter types to be tested, and the number of test categories requested for each dosimeter type.
One cost to processors that is not included in the NVLAP August 31, 1984, fee schedule (49 FR 34547) is that l
of initiating and maintaining the quality control and quality assurante system f
required by NVLAP and examined by NVLAP assessors during onsite visits to proces%r facilities.
08/15/86 5
Enclosure B t
Based on an estimate of a 5 person-week effort to initiate the quality system combined with some possible retesting and consultation, the initial one-time cost is estimated to be approximately $7,000. Most of the processors that participated in the three voluntary testing programs have already absorbed this initial cost. Maintenance of the quality systems is estimated by NVLAP to range from $2,000 to $6,500 biennially for small and large processors respectively.
Biennial accreditation fees vary from $3,700 for a small processor with one dosimeter type tested in a single category to $10,250 for a large processor with one dosimeter type tested in all 8 of the test categories.
The total costs of the program range from $5,700 to $16,750 (or approximately $3,000 to $8,400 annually) to each of the 90 known dosimetry processors.
Estimates of the annual costs to the industry indicate that 14 processors may be considered large with total annual program costs of $118,000, 66 fall in the intermediate category with total annual costs of $330,000, and 10 fall in the small category with o
total annual costs of $30,000, for an overall total of $478,000 per yea.r.'
The current costs of providing dosimetry to the 327,000 workers monitored by NRC licensees is $7,850,000 annually, based on an average cost of $24.00 annually per worker with monthly changes of dosimeters. Assuming that all of the annual costs of accreditation, $478,000, would be passed on to NRC licensees, the cost to the estimated 4,500 licensees would be increased by $106 annually from $1.744 to $1,850, or an increase of 6%.
The principal benefit that would result to the 327,000 workers of NRC licensees from imposition of this rule is the increased accuracy and reliability of the recorded and reported occupational dose, which is of considerable significance in epidemiological studies and which also allows both employer and employee to better assess and control the radiation hazards of the workplace.
The annual cost of this increased accuracy and reliability is $1.46 per worker.
Adoptior, of this option will allow NRC to impose minimum acceptable criteria through NVLAP accreditation on personnel dosimetry processors that are not subject to present NRC regulations.
Since it is expected that most dosimetry processors will wish to become accredited, the net effect of this option will be to benefit a much larger comunity of workers than that of NRC licensees. These are the same processors that process badges for Agreement State licensees and a large and diverse connunity involved principally with X-ray rachines that does not include NRC licensees and regulated under the 08/15/86 6
Enclosure B
C Occupational Health and Safety Administration of the Department of Labor.
In addition, this option is expected to save the NRC about 1 person-year / year by using NVLAP assessors instead of NRC's IE personnel to conduct onsite assess-ments of processors. NRC inspectors would be relieved from inspection of certain QA activities and would only be required to perform routine inspections of personnel dosimetry records.
This option would establish common testing and quality assurance procedures on personnel dosimetry processing and pmvide NRC inspection personnel with a much needed benchmark against which to enforce existing regulatory requirements on personnel monitoring.
It also would bring improved accuracy and reliability to the dosimetry processing industry through the use of standard procedures and oversight by NBS.,the nationally recognized standards authority.
Finally, the quality and reliability of personnel dosimetry records would increase, partly as. a result of periodic retesting requirements and partiy as a result o.f the elimination of irresponsible or incompetent dosimetry processors.
Alternative 4 Seek Congressional authority for the NRC to license personnel dosimetry processors directly since many are not presently NRC licensees. This alternative is probably unwieldy in that Congress may choose not to provide such authority or at best delay passing the needed legislation for an unacceptable period of time.
In addition, this alternative would require an increased expenditure of funds for NRC's IE personnel of about 300% above the present expenditures for inspection of licensee processors.
(NRC licensees employ only about 25% of the 1.4 million workers in the U.S. who require personnel monitoring.)
Alternative 5 Change the regulation to require that licensees obtain their personnel dosimetry services from an NRC-operated or an NRC-contracted dosimetry service.
Since the NRC does not presently have the technical staff, facilities, funding, or experience to operate such a service, the alternative is limited to an NRC-contracted dosimetry service.
Since this option would undoubtedly put most of the dosimetry processors out of business, it is unlikely to be acceptable either to the industry or to Congress and would require a long-term outlay of Federal funds to support such a contracted dosimetry service.
08/15/86 7
Enclosure B
c...
5.
DECISION RATIONALE The staff proposed that alternative 3B be adopted. Alternative 1 is rt-jected outright since it offers no hope of meeting the objective of improving the accuracy and reliability of occupational worker dose records by standard-izing dose determinations obtained from dosimetry processing. Alternative 2 is rejected because of the additional costs to the NRC and the uncertainty that indJstry would establish a testing laboratory. Alternative 3A is rejected because of the requirement for budgeting long-term Federal resources to operate the testing leboratory and the costs to the NRC in assessing the licensees' and processors' QA programs. Alternative 4 is rejected because of the uncertainty t
in obtaining the required authority from Congress and because of the additional inspection costs involved. Alternative 5 is rejected because of the require-ment for a long-term outlay of Federal funds and the negative effect it. would have on the dosimetry processing industry.
6.
IMPLEMENTATION The final rule specifying the requirement for accreditation of personnel dosimetry processors will become effective one year after publication of the t
rule in the Federal Register. The NVLAP testing and accreditation program has been in operation for more than two years; and, on the basis of this operating experience, it has been found that a minimum of about six months is required for processors to receive accreditation.
Since some processors fail the first round of testing, an additional three months is generally necessary.
On the basis of this time frame, the Comission has determined that an effective date of one year af ter publication is an adequate time period to require implementa-tion of the rule. No additional staff action or additional funding is required.
This action is related to and in conformance with Section 20.501(c) of the new proposed 10 CFR Part 20 which was published January 9,1986(51FR1092).
No other existing or proposed requirements are affected.
!l i,
i 1i 08/15/86 8
Enclosure B
_