ML20205S138
| ML20205S138 | |
| Person / Time | |
|---|---|
| Issue date: | 04/20/1999 |
| From: | Wigginton J NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9904260108 | |
| Download: ML20205S138 (13) | |
Text
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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20666 0001
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- 8 April 20, 1999 MEMORANDUM TO: Thomas H. Essig, Chief Emergency Preparedness and Radiation Protection Section Division of Inspection Program Management Office of Nuclear Reactor Regulation FROM:
James E. Wigginton, Senior Reac r ealth sicist Emergency Preparedness and R.d' son Protection Section Division of Inspection Program Management Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF PUBLIC MEETING WITH THE NUCLEAR ENERGY INSTITUTE (NEl) ON INSPECTION FINDINGS SIGNIFICANCE FOR ASSESSING RADIATION PROTECTION PROGRAMS On April 5,1999, representatives of the Nuclear Energy Institute (NEI) met with representatives of the Nuclear Regulatory Commission (NRC) at the NRC offices in Rockville, Maryland. 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.
The discussion started with NEl providing comments on the NRC staff's draft Occupational Exposure flow chart (Attachment 2). Industry feedback focused on the " Substantial Potentiar for overexposure (SPO) branch, and some licensses thought that SPO was a new tool. NRC
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staff confirmed that the SPO construct had been used for years in the enforcement process.
The NRC is amenable to comments and suggestions on the current SPO guidance
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(section 8.4.1 of NUREG/BR-0195, NRC Enforcement Manual). Both NRC and NEl agreed that critical barriers would be removed from the logic diagram. The staff had no problem with industry's request to change the " uncontrolled Exposure" block to " Unintended Exposure",
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The ALARA finding discussion generated several key points (Attachment 3). The staff agreed that the term, ALARA finding needs to be defined and accompanying illustrative examples would be helpful (the staff had work in progress on this issue). The staff noted that for the site person-rem quartiles of performance, these points would be fixed (based on a reasonable set of recent yearly data). Additionally, the NRC noted that the blocks at the bottom of the flowchart, source control and work control f;ndings, both need explanatory background text for clarity. NEl noted that the flow logic could benefit by t implifying the construct.
CONTACT: James E. Wigginton,IOHB/NRR
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(301-415-1059)
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l The NRC discussed proposed changes to Attachment 4 (NRC March 16,1999, draft Public Radiation Safety flow diagram). The discussion focused on proposed changes to the flow chart based on comments received ouring the March 30,1999 meeting.
Changes were proposed in all areas; radioactive material control, effluent releases, and environmental monitoring. The intent of the changes is to ensure that the " significance" of each area is relatively uniform across the comerstone. For the effluent release area, a comment was made to replace the " events" based criteria with dose based criteria to assess licensee performance. A similar comment was made for the environmental area; replace the " numbers" based criteria with one that assesses the ability of a licensee to assess environmental impact.
The proposed changes appeared to be reasonable and consistent with the intent of the significance determination process. It was agreed that the proposed changes would be discussed with NRC management prior to the next public meeting on April 13,1999.
The NRC staff described the changes made to the transportation and Part 61 risk matrix (Attachment 6). Several of the " Breach" findings (for Type A and B packages) moved to more risk significant levels, based on feedback from the Regions and NRC headquarters staff.
NMSS is currently developing the certificate of compliance risk findings, and is reviewing the first draft of the logic diagram. The staff is looking forward to receiving Gdditional industry comments on the risk matrix.
The next planned meeting date was scheduled, and this meeting was adjoumed.
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Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page DOCUMENT NAME:G:\\MTSUM405.WPD OFFICE lOH Q RR SC, IOHBo JWhn TEssig M NAME DATE M 99 404/99 OFFICIAL RECORD COPY
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. t The NRC discussed proposed changes to Attachment 4 (NRC March 16,1999, draft Public Radiation Safety flow diagram). The discussion focused on proposed chances to the flow chart based on comments received during the March 30,1999 meeting.
j Changes were proposed in all areas; radioactive material control, effluent releases, and environmenta! monitoring. The intent of the changes is to ensure that the " significance" of each area is relatively uniform across the comerstone. For the effluent release area, a comment was made to replace the " events" based criteria with dose based criteria to assess licensee performance. A similar comment was made for the environmental area; replace the " numbers" based criteria with one that assesses the ability of a licensee to assess environmentalimpact.
The proposed changes appeared to be reasonable and consistent with the intent of the significance determination process. It was agreed that the proposed changes would be discussed with NRC management prior to the next public meeting on April 13,1999.
The NRC staff described the changes made to the transportation and Part 61 risk matrix (Attachment 6). Several of the " Breach" findings (for Type A and B packages) moved to more risk significant levels, based on feedback from the Regions and NRC headquarters staff.
NMSS is currently developing the certificate of compliance risk findings, and is reviewing the first draft of the logic diagram. The staff is looking forward to receiving additional industry comments on the risk matrix.
The next planned meeting date was scheduled, and this meeting was adjoumed.
Attachments: As stated cc w/att: See next page 4
t 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 I Street, NW 1776 i Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Steven Driscol Radiation Protection -
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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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.;w Distribution: Mtg. Summary w/ Dated April 20, 1999 BL C PERB R/F j
MBranch RGallo SMagruder JWigginton TEssig JWhite, R1 KBarr, R2 GShear, R3 -
GGood, R4 CPostusny TMatula GKuzo RPedersen JNoggle CHinson SKlementowicz RAnderson, NEl PGenoa, NEl
1 Distribution: Mtg. Summary w/ Dated Auril 20, 1999 Hard Coov PUBLIC PERB R/F MBranch RGallo SMagruder JWigginton 4
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JWhite, R1 KBarr, R2 1
GShear, R3 GGood, R4 CPoslusny TMatula GKuzo RPedersen JNoggle CHinson SKlementowicz RAnderson, NEl PGenoa, NEl i
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Radiation Protection inspection Finding Significance Meeting 4/5/99 List of Attendees Name Oraanization Roger Pedersen USNRC Tom Matula USNRC Jim Wigginton USNRC Charles Hinson USNRC Ralph Anderson NEl Paul Genoa NEl
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DRAFT EXAMPLES OF THE RISK SIGNIFICANCE OF INSPECTION FINDINGS IN PUBLIC CORNERSTONE: TRANSPORTATION AND PART 61 ISSUES AT NUCLEAR I
POWER PLANTS GREEN
( Licensee Response Band)
NRC or licensee identified non-conformance involving waste shipment with surface contamination levels greater than 10 CFR Part 71 or 49 CFR 173 limits.
Breach (loss of containment integrity) of a package during transit, without the loss of any package contents.
WHITE (Increased Regulatory Response Band)
NRC or licensee-identified non-conformance involving waste shipment with surface contamination levels greater than five times 10 CFR Part 71 or 49 CFR 173 limits.
NRC or licensee-identified non-conformance involving waste shipment with external dose rates greater thar.10 CFR Part 71 or 49 CFR 173 dose limits.
Failure to comply with 10 CFR Part 71 by making waste shipment (shipment enters State boundary) without making required advance notification.
Failure to provide emergency response information as required by 49 CFR 172.602 or 49 CFR 172.604.
Breach of Type A package during transit.
NRC or licensee-identified non-conformance that results in a non-conservative waste classification as required by 10 CFR Part 61.
YELLOW
( Required Regulatory Response Band)
NRC or licensee-identified non-conformance involving waste shipment with surface contamination levels greater than fifty times 10 CFR Part 71 or 49 CFR 173 limits.
NRC or licensee-identified non-conformance involving waste shipment with external dose rates greater than five times 10 CFR Part 71 or 49 CFR 173 dose limits.
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Breach of package during transit resulting in a loss of control of the contents which results in a estimated dose to a member of the 'public greater than 10 mrem TEDE or an occupation dose greater than 200 mrem TEDE.
i Low Level waste burial ground denies Licensee access -- authority will not accept licensee waste as result of deficiencies in transportation activities or Part 61 non-conformances.
NRC or licensee-identified non-conformance with package's certificate of compliance resulting in shipping wasts in an unanalyzed configuration (beyond the package's design basis rating).
RED l
(Loss of confidence in HP program's ability to provide assurance of worker safety)
NRC or licensee-identified non-conformance involving waste shipment with surface contamination levels greater than one-hundred times 10 CFR Part 71 or 49 CFR 173 limits and resulting in contamination of the unrestricted area.
NRC or licensee-identified non-conformance involving waste shipment with external dose rates greater than ten times 10 CFR Part 71 or 49 CFR 173 dose limits.
Breach of package during transit resulting in a loss of control of the contents which results in a dose to a member of the public greater than 25 mrem TEDE or an occupation dose greater than 500 mrem TEDE.
Breach of Type B package during transport.
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j 4
l The NRC discussed proposed changes to Attachment 4 (NRC March 16,1999, draft Public Radiation Safety flow diagram). The discussion focused on proposed changes to the flow chart based on comments received during the March 30,1999 meeting.
Changes were proposed in all areas; radioactive material control, effluent releases, and environmental monitoring. The intent of the changes is to ensure that the " significance" of each area is relatively uniform across the cornerstone. For the effluent release area, a comment was made to replace the " events" based criteria with dose based criteria to assess licensee I
performance. A similar comment was made for the environmental area; replace the " numbers" based criteria with one that assesses the ability of a licensee to assess environmental impact.
The proposed changes appeared to be reasonable and consistent with the intent of the significance determination process. It was agreed that the proposed changes would be l
discussed with NRC management prior to the next public meeting on April 13,1999, i
The NRC staff described the changes made to the transportation and Part 61 risk matrix (Attachment 6). Several of the " Breach" findings (for Type A and B packages) moved to more risk significant levels, based on feedback from the Regions and NRC headquarters staff.
NMSS is currently developing the certificate of compliance risk findings, and is reviewing the i
first draft of the logic diagram. The staff is looking forward to receiving additionalindustry i
comments on the risk matrix.
l l
The next planned meeting date was scheduled, and this meeting was adjourned.
Attachments: As stated I
cc w/att: See next page l
DISTRIBUTION: See attached page DOCUMENT NAME:G:\\MTSUM405.WPD l
OFFICE lOH Q RR SC, IOHBo JW[on TEssig M NAME DATE M/99 4/2n /99 l
OFFICIAL RECORD COPY i