ML20206H633
| ML20206H633 | |
| Person / Time | |
|---|---|
| Issue date: | 01/15/1986 |
| From: | Yuhas G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML20206H509 | List: |
| References | |
| NUDOCS 8606260238 | |
| Download: ML20206H633 (22) | |
Text
, - .
January 15, 1986 Speech before the Arizona Chapters of the Health Physics and American Nuclear Society Invited Speaker: Gregory P. Yuhas Chief, Facilities Radiological Protection Section NRC, Region V Topic: The NRC Regulatory Process and Radiation Protection, A Region V Perspective Location: Embassy Suites Hotel 3210 NW Grand Avenue Phoenix, Arizona
Contact:
Mr. Robert Metzger President, Arizona Chapter 7713 S. Sutte Avenue Tempe, Arizona (602) 966-9676 9
i 8606260238 860619 PDR MISC PDR 8606260147 l
The NRC Regulatory Process and Radiation Protection A NRC Region V Perspective A. Introduction
- 1. Opening greeting
- 2. Summarize order of presentation
- a. The regulatory framework
- b. Inspector methodology
- c. Utilization of inspection findings
- d. Discussion of recent examples
,' B. The Regulatory Framework
- 1. What is the NRC?
The U.S. Nuclear Regulatory Commission is an independent federal regulatory agency that was created by the Congress in 1975. While the NRC may be an independent agency, there is significant Congressional interest and oversight.
Representative Morris K. Udall (D AZ) is chairman of the Committee on Interior and Insular Affairs, the Subcommittee on Energy and the Environment and serves on the Subcommittee on Water and Power.
. . The NRC budget is acted on by the Subcommittee on Water and Power which is chaired by Representative George Miller (D CA).
Representative John D. Dingell (D MI) is chairman of the Committee on' Energy and Commerce and the Subcommittee on Oversight and Investigations while Representative Edward J. Markey (D MA) serves as chairman of the Subcommittee on Energy Conservation and Power.
In the Senate, Alan K. Simpson (R WY) chairs the Subcommittee on Nuclear Regulations.
- 2. NRC Authorities NRC's legal authorities stem primarily from three federal statutes:
- 3. NRC Responsibilities By law, NRC's responsibilities include the following:
' Protecting the public health and safety
- Protecting the environment
' Assuring protection of wielear facilities and materials from
- theft, sabotage or diversion u .eman - nform a , ,u u n u- m .e4 N
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The NRC fulfills its responsibilities through a comprehensive regulatory program that includes:
- Licensing the construction and operation of nuclear reactors and other civilian facilities that use radioactive materials.
' Development and enforcement of rules and regulations governing the possession, use, processing, packaging and disposal of radioactive materials.
' Inspection of licensed facilities and activities to assure compliance with NRC rules and regulations.
' Conduct of public hearings and publication of technical reports on matters pertaining to NRC-licensed activities.
- A " confirmatory" resesrch program to assist the agency in the conduct of its licensing, inspection and related regulatory functions.
- 4. NRC Organization / Region V Briefly desc. ribe HQ organization.
Describe Region V with names and functional assignments within the Division of Radiation Safety and Safeguards.-
- 5. NRC Rules and Regulations
- a. Discuss what they are.
- b. Where can you get them?
-4 Copies of NRC rules and regulations are contained in Title 10, Code of Federal Regulations (10 CFR), which is available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402.
- c. How do you read them?
- Emphasize Federal Register Notices and Statement of Considerations. Published Revision of 10 CFR 20, December 20, 1985.
! ' Careful review of committed documents, i.e., NBS Handbook 58, ICRP 2, ICRP 26, etc.
- d. Highlight parts involving radiation protection, i.e., 10 CFR 19, 10 CFR 20.
- 6. Other aspects of regulation i a. Mention agreement states
- b. Memorandums of Understanding a
)
.c.-. ,
I
. e !
l INFO / ALARA DOT / Transportation EPA Clear Air Act / 40 CFR 190 C. Inspector Methodology
- 1. Responsibility:
It is the NRC inspector's responsibility to verify that licensed activities are being conducted consistent with regulatory requirements and license conditions.
. ~.
In addition, it is also the inspector's responsibility to assess the adequacy of licensee performance and to alert NRC management of any situation which may be deleterious to the public health and safety j or that may require licensing change or regulatory action.
For example: During a routine inspection it becomes apparent that the licensee is not providing sufficient resources to implement the approved radiation protection program. The inspector is expected to surface facts which would substantiate such an observation even without items of noncompliance so that NRC could take action necessary to prevent more serious problems from developing.
- 2. Preparation -
- a. Discuss inspection procedures '
- Purpose, scope
" Minimum, basic, supplemental
- SALP
- b. Describe references reviewed
- Regulatory requirements / Statements of Consideration
- License conditions and Technical Specifications
~. , .
i
" Licensee commitments
- Licensee Event Reports / Routine reports N
- IE Bulletins, [virculars and Notices ,
W' w*
- NRC Regulatory Guides (Discuss 8 series) /
- NUREGS
- Industry Standards (ANS, ANSI)
- Manufactures recommendations
- c. The licensee's previous inspection history and outstanding item
- list is also reviewed. 4 l 3. Inspection process i
- a. Entrance Interview a
1
- b. Tour of restricted area l
- Independent measurements
- c. Review of records i
- d. Discussion with licensee representatives
- e. Review of licensee internal audits and corrective actions.
l f. Dealing with findings and determining causation factors.
- 4. The Exit Interview 2
, Discuss this process and stress its importance as a candid vehicle of preliminary inspection findings and observations.
D. Utilization of Inspection Findings
- 1. Interoffice review
" Deliberate digestion of inspection. data.
4
]
7 t
- 2. Debriefing and coordination
- Discussions with other inspectors and appropriate management representatives.
- 3. Inspection report
- Purpose '
' Outstanding items
- Time of issue
- 4. Enforcement findings
' Noncompliance / violations
- Deviations
" Unresolved items
- 10 CFR 2 Appendix C
- Root cause/ objective E. Examples, Five-Year Review
- 1. 1977 conclusion: Without strong NRC action RPMs frequently could not implement good radiation protection programs.
- 2. 1977-1979 commercial industry no better off. RPM typically reporting to Operations Supervisor and usually responsible for chemistry, i.e., Ginna, con Yankee, Oyster Creek.
- 3. March 28, 1979 -- See NUREG-0600
- Review summary statement from NUREG-0855
,, - _. .._. , . . . - . _ ,. - ,-. - ,- - .e.
- As a result of this event, NRC recognized the need to perform a generic evaluation of power reactor health physics programs.
Describe NUREG-0855, Health Physics Appraisal Program. Summarize conclusion (P.22).
"The single greatest cause for weaknesses in the radiation protection programs can probably be traced back to the general attitude toward radiological safety. Management often considered the radiation protection group more of a routine service organization than a radiation support function integrated into the fabric of overall plant operations. Consequently, funding, staf fing, and management backing were frequently provided at the minimum level. Also, foremen and supervisors in other departments tended to have an attitude that the burden for assuring radiological safety rested almost entirely on the radiation protection group rather than understanding that such responsibility was properly that of all line management. Their-failure to demonstrate a continuing concern for proper radiological work practices results in the workers adopting a similar attitude."
- 4. Some licensees were slow to respond to HPA recommendations, i.e.,
SCE -- discuss.
- 5. 1980-1981 Congress concern about LWR dose. ALARA rule proposed but deferred to INPO by Memorandum of Understanding. Discuss Reg.
Guide 8.X.
- 6. 1981 - Present, NRC aggressively looking at radiation protection.
Things look better in Region V.
F. Current Radiation Protection Related Findings
' Occupational Exposure:
=. . _ - . .. - -- .- .
.. Rancho Seco - thermal sleeve fragment l Trojan - steam generator insert Point: First line supervision and the value of aggressive followup actions.
i
~
San Onofre - fuel fleas Point: Need for extra vigilance during unusual conditions.
- Effluents and the Environment Rancho Seco - liquid fish pathway 1
Point: Lack of corporate commitment. Need to look beyond an obvious limit.
I San Onofre - volume of liquid effluents Point: Public concern for the environment.
- 0ther related issues:
1 4
j San Onofre, Palo Verde, Rancho Seco PASS l
Point: Learn from industry experience.
i i
In conclusion I would like to ssy that it is my opinion that:
- 1. Your responsibility is to establish and implement good radiation protection programs. By good, I mean programs that not only meet regulatory requirements but far exceed them in most cases.
_lo_
- 2. My responsibility is to determine if you have and, when appropriate, provide such incentive as may be necessary to assure .that you at least meet the minimum standards.
- 3. If we both do our jobs, perhaps a more successful utilization of atomic energy may yet be realized.
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January 15, 1986 Speech before the Arizona Chapters of the Health Physics and American Nuclear Society Invited Speaker: Gregory P. Yuhas Chief, Facilities Radiological Protection Section NRC, Region V Topic: The NRC Regulatory Process and Radiation Protection, A Region V Perspective Location: Embassy Suites Hotel 3210 NW Grand Avenue Phoenix, Arizona
Contact:
Mr. Robert Metzger President, Arizona Chapter 7713 S. Sutte Avenue Tempe, Arizona (602) 966-9576
The NRC Regulatory Process and Radiation Protection A NRC Region V Perspective 1
A. Introduction
- 1. Opening greeting
- 2. Summarize order of presentation 4
4
- a. The regulatory framework
- b. Inspector methodology
- c. Utilization of inspection findings
- d. Discussion of recent examples B. The Regulatory Framework
- 1. What is the NRC7 ,
The U.S. Nuclear Regulatory Commission is an independent federal regulatory agency that was created by the Congress in 1975. While the NRC may be an independent agency, there is significant Congressional interest and oversight.
Representative Morris K. Udall (D AZ) is chairman of the Committee on Interior and Insular Affairs, the Subcommittee on Energy and the Environment and serves on tho Subcommittee on Water and Power.
9
-2 The NRC budget is acted on by the Subcommittee on Water and Power which is chaired by Representative George Miller (D CA).
Representative John D. Dingell (D MI) is chairman of the Committee on Energy and Commerce and the Subcommittee on Oversight and Investigations while Representative Edward J. Markey (D MA) serves as chairman of the Subcommittee on Energy Conservation and Power.
In the Senate, Alan K. Simpson (R WY) chairs the Subcommittee on Nuclear Regulations.
- 2. NRC Authorities NRC's legal authorities stem primarily from three federal statutes:
' National Environmental Policy Act of 1969
- 3. NRC Responsibilities By law, NRC's responsibilities include the following:
' Protecting the public health and safety
" Protecting the environment
' Assuring protection of nuclear facilities and materials from theft, sabotage or diversion
[f
' Assuring-co n f ormityw it h% n t i-t ru s t4aws N $) y*
'% j
'l '~
<e, ij
'* l' n ,. . ,,_,,
f er
)
, l 'P?r ca,s...). e. [.
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- _~-
The NRC fulfills its responsibilities through a comprehensive regulatory program that includes:
' Licensing the construction and operation of nuclear reactors and other civilian facilities that use radioactive materials.
' Development and enforcement of rules and regulations governing the possession, use, processing, packaging and disposal of radioactive materials.
~. .
' Inspection of licensed facilities and activities to assure compliance with NRC rules and regulations.
' Conduct of public hearings and publication of technical reports on matters pertaining to NRC-licensed activities.
- A " confirmatory" research program to assist the agency in the conduct of its licensing, inspection and related regulatory functions.
- 4. NRC Organization / Region V Briefly describe HQ organization.
Describe Region V with names and functional assignments within the Division of Radiation Safety and Safeguards.
- 5. NRC Rules and Regulations
- a. Discuss what they are.
- b. Where can you get then?
, , -4 -
Copies of NRC rules and regulations are contained in Title 10, Code of Federal Regulations (10 CFR), which is available from the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402.
a >
4
- c. How do you read them?
- Emphasize Fcderal Register Notices and Statement of Considerations. Published Revision of 10 CFR 20, December 20, ,
1985.
' Careful review of committed documents, i.e., NBS Handbook 58, ICRP 2. ICRP 26, etc.
l
- 6. Other aspects of regulation
- a. Mention agreement states 4
- b. Memorandums of Understanding I
I~
- d h
INPO / ALARA DOT / Transportation EPA ;
Clear Air Act / 40 CFR 190 i
i
- C. Inspector Methodology '
- 1. Responsibility:
.i It is the NFC inspector's responsibility to verify that licensed {
activities are being conducted consistent with regulatory i requirements and license conditions.
I
{e In addition, it is also the inspector's responsibility to assess the adequacy of licensee performance and to alert NRC management of any situation which may be deleterious to the public health and safety or that may require licensing change or regulatory action.
i For example: During a routine inspection it becomes apparent that the licensee is not providing sufficient resources to implement the 1 approved radiation protection program. The inspector is expected to '
j surface facts which would substantiate such an observation even without items of noncompliance so that NRC could take action necessary to prevent more serious problems from developing. !
- 2. Preparation
- I J
- a. Discuss inspection procedures
- Purpose, scope
- Minimum, basic, supplemental '
- SALP .
- b. Describe references reviewed i
)
- Regulatory requirements / Statements of Consideration f
- License conditions and Technical Specifications j
_ _ _ . ~ _ . . . . . . .. ._ __ ._ . - . ._ .- - .. . - _. m.. .- ._ -._
r
+
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t i
' Licensee commitments '
i
- Licensee Event Reporta/Jtoutine reports #
% g .r'
.[ *IE Bulletins, f f;;.1_; and Notices f
+
u
{ 'NRC Regulatory Guides (Discuss 8 series) Aw '- ;
] 'NUREGS j4 e f
- ' Industry Standards (ANS. ANSI) ;
! ' Manufactures recommendations i
i I $
I
- c. The licensee's previous inspection history and outstanding' item list is also reviewed. I 1
J i
- 3. Inspection process i
l i
- s. Entrance Interview ,
- I
- b. Tour of restricted area
- Independent measurements
- c. Review of records (
t I
- d. Discussion with licensee representatives e o 8
- e. Review of licensee internal' audits and corrective actions.
i [
i ,
4 i
- f. Dealing with findings and determining causation factors. '
{ l
\
- 4. The Exit Interview .
i i
Discuss this process and stress its importance as a' candid vehicle' ~I of preliminary inspection findings and observations.
t !
f
, D. Utilization of Inspection Findings _ .
i I
- 1. Interoffice review i I,
4
- Deliberato digestion of inspection data.
i ;
L
.. . . - - - . - . . - - . . _ - ~ . .. .. _. ._ .. - . . . - . - . _ - _
J
.2. Debriefing and coordination
- Discussions with other inspectors and appropriate management representatives. ,
! 3. Inspection report i
- Purpose '
' Outstanding items j ' Time of issue i i
j 4. Enforcement findings a
- Noncompliance / violations
' Deviations J
- Unresolved items i
- L
, 5. Enforcement policy I i
- 10 CFR 2 Appendix C i ' Root cause/ objective
{ E. Examples. Five-Year Review t
i l 1. 1977 conclusion: Without strong NRC action RPMs frequently could not implement good radiation protection programs.
- 2. 1977-1979 commercial industry no better off. RPM typically 1
- reporting to Operations Supervisor and usus11y responsible for i l
chemistry, i.e., Ginna, Con Yankee, Oyster Creek, i
1, 3. March 28, 1979 -- See NUREG-0600 i
- ' Review summary utntement f rom NUREG-0855
! l i
i 4
I
. I i >
, , 4
'As a result of this event, NRC recognized the need to perform a ;
generic evaluation of power reactor health physics programs.
Describe NUREC-0855, Health Physics Appraisal Program. Summarize conclusion (P.22).
I "The single greatest cause for weaknesses in the radiation !
! protection programs can probably be traced back to the general
.r '
attitude toward radiological safety. Management often considered the radiation protection group more of a routine service
- organization than a radiation support function integrated into the ,
i fabric of overall plant operations. Consequently, funding, f staffing, and management ab'cking were frequently provided at the ;
! minimum level. Also, foremen and supervisors in other departments i
tended to have an attitude that the burden for assuring
]- radiological safety rested almost entirely on the radiation protection group rather than understanding that such responsibility was properly that of all line management. Their failure to demonstrate a continuing concern for proper radiological work practices results in the workers adopting a similar attitude."
-f j 4. Some licensees were slow to respond to HPA recommendations, i.e.,
SCE -- discuss.
i
- 5. 1980-1981 Congress concern about LWR dose. ALARA rule proposed but j deferred to INPO by Memorandum of Understanding. Discuss Reg.
I Cuide 8.X.
f 6. 1981 - Present, NRC aggressively looking at radiation protection. ,
Things look better in Region V.
F. Current Radiation Protection Related Findings ;
l, j *0ccupational Exposure:
i
. ., _g_
Rancho Seco - thermal sleeve fragment.
Trojan - steam generator insert Point: First line supervision and the value of aggressive i
followup actions.
~
San Onofre - fuel fleas Point: Need for extra vigilance during unusual conditions.
4
- Effluents and the Environment i
Rancho Seco - liquid fish pathway i
1 Point: Lack of corporate commitment. Need to look beyond an j obvious limit.
I 1
j San Onofre - volume of liquid effluents 1
Point: Public concern for the envitonment.
i 1
4
- 0ther related issues:
San Onofre, Palo Verde, Rancho Seco PASS Point: Learn from industry experience.
1-i
{ In conclusion 1 would like to say that it is my opinion that:
i i
j 1. Your responsibility is to establish and implement good radiation protection programs. By good, 1 mean programs that not only meet l regulatory requirements but far exceed them in most cases.
1 i
I i
c , -10
- 2. My responsibility is to determine if you have and, when appropriate, Provide such incentive as may be necessary to assure that you at least meet the minimum standards.
- 3. If we both do our jobs, perhaps a more successful utilization of atomic energy may yet be realized.
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