ML20209F228
| ML20209F228 | |
| Person / Time | |
|---|---|
| Issue date: | 07/02/1999 |
| From: | Wigginton J NRC (Affiliation Not Assigned) |
| To: | Essig T NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9907150274 | |
| Download: ML20209F228 (18) | |
Text
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- 4 UNITED STATES g
j NUCLEAR REGULATORY COMMISSION g
WASHINGTON, D.C. 20066 0001 l
%y July 2, 1999 MEMORANDUM TO: Thomas H. Essig, Chief Emergency Preparedness and Radiation Protection Section Operator Licensing, Human Performance & Plant Support Branch Division of Inspection Program Management Office of Nuclear Reactor Regulation
~
FROM:
James E. Wigginten, Senior Reactor Health Physicis Emergency Prepredness and Radiation Protecti ction Division of inspection Program Management I
Office of Nuclear Reactor Regulation j
SUBJECT:
SUMMARY
OF PUBLIC MEETING WITH THE NUCLEAR ENERGY
{
INSTITUTE (NEI) REGARDING SIGNIFICANCE DETERMINATION i
PROCESS TOOLS FOR ASSESSING RADIATION PROTECTION
{
PROGRAMS On May 26,1999, representatives of the Nuclear Energy Institute (NEl) met with
)
representatives of the Nuclear Regulatory Commission (NRC) at the NRC offices in Rockville, Maryland.
The purpose of the meeting was to get stakeholder comments and feedback on NRC staff proposed changes to draft significance determination process (SDP) logic diagrams to be used by the NRC to help assess licensees' radiation protection (RP) programs at power reactors.
These tools will allow NRC inspectors to determine the safety significance of individual RP inspection findings.
NRC and NEl staff summarized and discussed the NRC and industry efforts to date, and the goals and time schedules for this ongoing project. The NRC pilot inspection program starts June 1,1999, and the second NRC inspector training session is set for the week of June 21, 1999 in Texas. The NRC noted that the changes in the SDPs for the occupational and public comerstones would be completed by June 1 (except for the COC section of the transportation /Part 61 area, which will be completed before any scheduled inspection in that area). These changes will be discussed with the Regional HP management and staff at the monthly teleconference with NRR.
NEl noted that four licensee meetings were planned over the span of the pilot inspections, and the NRC staff were invited to participate. The NRC informed NEl that a Pl/SDP oversight and i
review process had been established to help ensure consistency among the Regions during the pilot process. Proposed Regional inspection SDP findings which are WHITE or greater will be
{
reviewed at NRR prior to being finalized.
. CONTACT: Jim Wigginton, IOLB/NRR,
-(301) 415-1059, JEW 2@NRC. gov.
9907150274 990702
()(ff1-3 PDR REVGP ERONUMRC PDR 6
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The SDP discussion started with the NRC staff covering substantive changes being considered in both the occupational and public exposure areas. The NRC staff discussed work in progress on the flow logic for handling inspection findings in the as low as reasonably achievable (ALARA) area (Part of the Occupational SDP, see Attachment 1). The staff is considering truncating the logic and eliminating the "high source term" and " work control" decision gates.
The staff believes that a pathway should be retained that could lead to a YELLOW finding. To achieve this, one criterion could be a troubled licensee exceeding some multiple of the industries rolling 3-year average collective dose. The stakeholders generally agreed that the staff proposals were moving the assessment process in the right direction.
A revision to the Public Radiation Safety SDP would allow for a WHITE finding in the Effluent j
Release branch (see Attachment 2). If the Licensee's ability to assess dose was inadequate, i
and failed to make the proper assessment, then a WHITE finding would be appropriate. The staff noted that this proposed addition is analogous to the Environmental Monitoring Program branch's subpart, and focuses on systemic programmatic problems.
The staff handed out the draft flow diagrams and explanatory text for the transportation and Part 61 inspection findings areas (Attachment 3(a),(b) and (c)). To be consistent with the dose criteria on the Public Radiation Safety SDP, the 25 and 100 mrem doses in the Bieach branch were changed to 100 and 500 mrem (see 3(a)). Another change involved an a proposed split to improve the logic flow for the low level burial ground /Part 61 area - the revision would make these two separate areas (see 3(b)). Some discussion of the Breach area ensued, focusing on the > Type A branch. NEl did not support YELLOW or RED findings for a breach of a Type B package, having little to no direct impact (dose) on the public. The staff noted that package I
integrity was vital for packages containing large amounts of radioactive materials. As noted in (c), these packages are designed to withstand serious accident conditions with no loss of contents. If a licensee failed to meet requirements (left a drain valve open) and no l
containment was provided during the shipment, the staff believes a Yellow or RED finding is appropriate (given the potential impact on the public in the event of a serious transportation l
accident). The utility representative questioned the risk significance (in the Notification branch) of failing to notify the state govemor of a large quantity shipment before the package enters that state. The staff noted that, without adequate prior notice, the state response team could be unduly delayed in responding to the scene of an accident. Attachment 4 provides a list of workshop attendees. The meeting was adjoumed.
Attachments: As stated cc w/att: See next page N
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 l Street, NW Washington, DC 20006-3708 Washington, DC 20006-3708 Mr. Steven Driscoll t
Radiation Protection INTO 700 Galleria Parkway Mr. Alex Marion, Director Atlanta, Georgia 30339-5957 4
Programs Nuclear Energy institute Suite 400 1776 i Street, NW Washington, DC 20006-3708 I
W Distribution: Mtg. Summary w/ Dated July 2, 1999 Hard Cooy
- PUBLCisg'.,
IOLB R/F '
, MBranch
' DHickman SMagruder JWigginton.
TEssig JWhite, R1 -
KBarr, R2 GShear, R3 GGood, R4 N. Shah G.Kuzo R.Pedersen JNoggle CHinson WWard S.Klementowicz RAnderson, NEl PGenoa,NEl s
g0045 i
1 f
4 2-The SDP discussion started with the NRC staff covering substantive changes being considered in both the occupational and public exposure areas. The NRC staff discussed work in progress on the flow logic for handling inspection findings in the as low as reasonably achievable l
(ALARA) area (Part of the Occupational SDP, see Attachment 1). The staff is considering i
truncating the logic and eliminating the "high source term" and " work control" decision gates.
The staff believes that a pathway should be retained that could lead to a YELLOW finding. To
- achieve this, one criterion could be a troubled licensee exceeding some multiple of the I
industries rolling 3-year average collective dose. The stakeholders generally agreed that the staff proposals were moving the assessment process in the right direction.
A revision to the Public Radiation Safety SDP would allow for a WHITE finding in the Effluent Release branch (see Attachment 2). If the Licensee's ability to assess dose was inadequate, l
and failed to make the proper assessment, then a WHITE finding would be appropriate. The staff noted that this proposed addition is analogous to the Environmental Monitoring Program branch's subpart, and focuses on systemic programmatic problems.
The staff handed out the d' raft flow diagrams and explanatory text for the transportation and Part 61 inspection findings areas (Attachment 3(a),(b) and (c)). To be consistent with the dose criteria on the Public Radiation Safety SDP, the 25 and 100 mrem doses in the Breach branch were changed to 100 and 500 mrem (see 3(a)). Another change involved an a proposed split to l
improve the logic flow for the low level burial ground /Pa t 61 area - the revision would make these two separate areas (see 3(b)). Some discussion of the Breach area ensued, focusing on j
the > Type A branch. NEl did not support YELLOW or RED findings for a breach of a Type B i
package, having little to no direct impact (dose) on the public. The staff noted that package integrity was vital for packages containing large amounts of radioactive materials. As noted in
-l (c), these packages are designed to withstand serious accident conditions with no i
!oss of contents. If a licensee failed to meet requirements (left a drain valve open) and no containment was provided during the shipment, the staff believes a Yellow or RED finding is appropriate (given the potential impact on the public in the event of a serious transportation accident). The utility representative questioned the risk significance (in the Notification branch) of failing to notify the state governor of a large quantity shipment before the package enters that state. The staff noted that, without adequate prior notice, the state response team could be unduly delayed in responding to the scene of an accident. Attachment 4 provides a list of workshop attendees. The meeting was adjourned.
Attachments: As stated cc w/att: See next page DISTRIBUTION: See attached page DOCUMENT NAME: G:\\EP&HP SECTION\\wigginton\\neimtgmins52699.wpd OFFICE lOHB Qp' IOHB /),
JWidton TEssig #h NAME DATE 6/29/99
'j/1J99
i c4 Distribution: Mtg. Summary w/ Dated July 2, 1999 i
Hard Coov PUBLIC IOLB R/F MBranch DHickman SMagruder JWigginton TEssig JWhite, R1 KBarr, R2 GShear, R3 GGood, R4 N. Shah 1
G.Kuzo R.Pedersen l
JNoggle CHinson WWard S.Klementowicz RAnderson, NEl l
PGenoa, NEl t
i l
OCCUPATIONAL RADIATION SAFETY Draft t
(ALARA)
FINDING 1
1 f Actual Job Dose Prged No ;l NO FINDING l Yes 1 P j
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i Attachment i Radiation Protection inspection Finding Significance Meeting
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Name Oraanization Alan Madison USNRC Morris Branch USNRC l
Roger Pedersen USNRC Steve Klementowicz USNRC
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Jim Wigginton USNRC j
Charles Hinson USNRC i
Lynnette Hendricks NEl f
Ralph Anderson NEl PaulGenoa NEl Gabe Salamon PSE & G Dennis Zannoni Stcte of New Jersey i
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. (c)
TikANSPORTATION AND PART 61 Radiation Limits Exceeded The limits on radiation levels of a package offered for transport are found in 49 CFR 173. These include both limits for external and removable surface contamination. The extemal radiation levellimits vary somewhat as a function of the type of shipment (non-exclusive and exclusive-use). Specific limits exist also as a function of distance from the package and for the area occupied by the driver. These extemal radiation limits are found in 49 CFR 173.441 and are duplicated in Part 71.47 (as related to Type B radioactive material ahipments).
The limits for removable (non-fixed) surface contamination on a package are found in 49 CFR 173.443 (Table 11) and vary as a function of type of shipment (non-exclusive and exclusive use), and vary relative to the type of nuclides (alpha, and beta / gamma emitters). Additionally for certain exclusive-use shipments, the surface contamination levels can be ten times higher during the shipment.
The extemal radiation level branch provides for a graded approach for assessing the level of significance of findings. Exceeding any of the limits and increasing multiplies of the limits provide for WHITE, YELLOW and RED findings.
The removable surface contamination level branch provides for a graded approach for assessing the level of significance of findings. Exceeding any of the limits and increasing multiplies of the limits provide for WHITE, YELLOW and RED findings. Note that to have a HED finding, the surface contamination levels must not only exceed 100 times the limit, but the unrestricted area must have been contaminated as well.
i.
1 4
' TRANSPORTATION AND PART 61 Breach of Packaae Durina Transit -
DOT and NRC shipping regulations relative to packaging requirements are diverse. Generally, these requirements become more strin0ent as a function of several factors. As the quantity, type, form (i.e.,readily dispersible) of radioactive material varies (increases), then the potential impact on the public (dose) increases as a result of a package breach during transit. For purposes of significant risk determinations, a package breach means a loss of containment.
The actual or potential impact on the public from a package breach then is a function of the pacMge contents. For Type A packages normal conditions of transport are assumed; this -
includes rough handling tests as specified in the DOT regulations (i.e., drop, water, puncture and crush tests). Thus, during normal conditions of transport Type A packages are designed to prevent the loss or dispersal of radioactive material contents, and maintain radiation levels below limits. If a breach occurs under conditions more adverse than the rough handling tests,
then a breach finding would not be appropriate unless it can be : Lown that licensee negligence contributed to the loss of containment. If a breach occurs during tra.Wt with equal to or less than the normal conditions of transport and the licensee failed to meet transportation requirements (resulting in the breach), then a breach finding is appropriate.
Type B packages must meet the performance and packaging requirements of Type A, as well as beyond normal conditions of transport. They are designed to withstand hypothetical serious accident conditions with no loss of containment (no breach), as measured by leak-rate testing.
These design considerations and criteria are contained in 10 CFR Part 71.73, and include free fall, crush, puncture, fire, and water immersion. Given these rigorous design requirements, any breach of a Type B package in transit (in less than hypothetical accident conditions) is a candidate for a Yellow or Red finding. If the licensee failed to meet the transportation requirements, and this failure contributed to the breach, then a breach finding is appropriate.
The significant risk determination after a design basis accident will be determined on a case-by-case basis.
The less-than-or-equal-to Type A shipment branch provides for a graded approach for assessing the level of significance of findings. If a breach in a Type A container occurs as a result of the failure to meet transportation requirements, but no loss of control of the contents is evident, then the finding is Green. An example could be a solidified radwaste liner, inside a Type A package where the closure lid was loose (not tightened down). In this case, given the form of the radioactive contents, loss of control of the materialis very unlikely. However, on a similar shipment, failure to properly torque the closure lid bolts (35 ft-lbs versus required 45 ft-Ibs) is not a breach, assuming the licensee analysis demonstrates that package integrity would be maintained during the normal conditions of transport.
While power reactor shipping history has demonstrated that serious mishaps are highly unlikely, if a transportation incident occurs with a package br6ach, then public dose consequences could result. The next two blocks in the Type A branch (assuming a breach) focus on public and occupational doses that occur as a result of the loss of control of package contents. These are actual doses to real individuals, and depending on the level, would lead to either Yellow or Red findings. Note that for a member of the public, the dose would in almost all cases be an estimate. Designated on-scene trained responders (e.g., local county Hazmat emergency team) would be designated occupational workers, subject the occupation dose limits.
The greater-than-Type A branch provides for a Yellow finding, assuming no loss of control of package contents. A Red finding would result if package contents control was lost. An example of a Yellow finding is where a receiving facility finds the incoming shipment (irradiated components) package's drain valve on the package open - a direct pathway to environment, but no potential for loss of control of materials (assuming normal conditions of transport). A Red finding is appropriate for the same "open valve" scenario if the package contents were spent fuel-fission product gases released continuously to the environs during the shipment, assuming normal conditions of transport. However, in the event of a transportation accident that led to loss of fuel integrity, public dose consequences could exceed acceptable levels before adequate protective measures could be implemented.
' TRANSPORTATION AND PART 61 kgw Level Berial Ground Access Nuclear power plants ship low-level waste (LLW) to licensed LLW burial grounds. These facilities (typically licensed by the he st State) have the responsibility and authority to grant access to licensees for disposal of LLW. These LLW burial grounds have specific disposal criteria (aside from DOT /NRC shipping regulations) that licensees must meet (e.g., Waste Characterization, Part 61.56). In the past, some NRC licensees did not meet the acceptance standards of the LLW burial ground, and were issued temporary bans - the burial ground would not accept LLW from non-compliant licensees for extended time periods. As the receiving party, the LLW burial facilities are required to inspect for certain non-compliances with shipping regulations. Repeated failures to meet these and the disposal grounds requirements can weigh in on the LLW facilities decision to prohibit access to the LLW burial site. While recent NRC licensee performance has been excellent, if a licensee is banned for an extended period of time (typically one month, based on repeated performance failures and shortcomings),
the finding is Yellow.
Part 61 Findino if a licensee ships waste and it is determined that the waste was under-classified, contrary to the requirements of 10 CFR Part 61.55 (e.g., waste classified at Class A, but later found to be Class B), then the finding is White.
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(
TRANSPORTATION AND PART 61 Failure to Make Notifications or Provide Emeroency info mation This branch of the logic diagram focuses on vital communication and information, and notification requirements that must be provided by the licensee. Shippers of hazardous materials are required to provided emergency response information. These requirements '
(in 49 CFR Part 172, Subpart G, Section 172.600) apply to any shipment which is required to have shipping papers. Shipments of excepted radioactive material packages (limited quantities,
" empty" packages, etc) are not subject to the emergency response information.
NRC regulations (10 CFR 71.97) require advance notification to state govemors for shipments of irradiated reactor fuel and nuclear waste under certain conditions. These notifications include quantity and form, and type of shipping container required. Notifications must be made in a timely manner to all the states hosting the radioactive material shipment. Additionally,10 CFR 20.1906 requires receivers of certain packages of radioactive materials to perform timely extemal and surface contamination radiation monitoring upon receipt of the packages. If applicable radiation limits are exceeded, the receiving licensee must then report the event to the appropriate NRC Regional Office.
For Block N1 (10 CFR 71.97 non-compliance), if the licensee fails to make the required notifications before the shipment entered the State's boundary (crossed the State line) for interstate shipments, the finding would be WHITE. For intrastate shipments, if the shipment was put on public roads / rails before the Governor received the required notification, then a finding would be WHITE. Note that any other timeliness non-compliances (e.g., notification not postmarked at least 7 days before the 7 day shipment period), these findings would be GREEN.
For Block N2 (49 CFR 172.602 non-compliance), if the licensee fails to provide the required emergency response information to the shipment carrier (the shipment leaves the licensee's facility and control without the required information), the finding is WHITE. If the carrier misplaces or loses the material (beyond the licensee's control), the finding is GREEN.
For Block N3 (49 CFR 172.604 non-compliance), if during an actual emergency the licensee does not respond in a timely manner in accordance with the requireme'nts (or had not provided the 24-hour telephone number), the finding is WHITE.
For Block N4 (10 CFR 20.1906), if the licensee's receipt surveys show that the package's extemal or surface contamination radiation levels in excess of the Part 71 limits and the facility fails to make an immediate report, then the finding is WHITE. Other non-compliances are GREEN.
i l
1
4 A
TRANSPORTATION AND PART 61
]
pertificates of Comoliance
<UNDER DEVELOPMENT _BY NMSS>
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)
4
e The SDP discussion started with the NRC staff covering substantive changes being consider in both the occupational and public exposure areas. The NRC staff discussed work in prog on the flow logic for handling inspection findings in the as low as reasonably achievable (ALARA) area (Part of the Occupational SDP, see Attachment 1). The staff is considering truncating the logic and eliminating the "high source term" and " work control' decision gates.
The staff believes that a pathway should be retained that could lead to a YELLO'N finding. To achieve this, one criterion could be a troubled licensee exceeding some rnultiple of the industries rolling 3-year average collective dose. The stakeholders generally agreed that the staff proposals were moving the assessment process in the right direction.
A revision to the Public Radiation Safety SDP would allow for a WHITE finding in the Effluent Release branch (see Attachment 2). If the Licensee's ability to assess dose was inadequate, and failed to make the proper assessment, then a WHITE finding would be appropriate. The staff noted that this proposed addition is analogous to the Environmental Monitoring Program branch's subpart, and focuses on systemic programmatic problems.
The staff handed out the draft flow diagrams and explanatory text for the transportation and Part 61 inspection findings areas (Attachment 3(a),(b) and (c)). To be consistent with the dose criteria on the Public Radiation Safety SDP, the 25 and 100 mrem doses in the Breach branch were changed to 100 and 500 mrem (see 3(a)). Another change involved an a proposed spCt to improve the logic flow for the low level burial ground /Part 61 area - the revision would make these two separate areas (see 3(b)). Some discussion of the Breach area ensued, focusing on the > Type A branch. NEl did not support YELLOW or RED findings for a breach of a Type B package, having little to no direct impact (dose) on the public. The staff noted that package integrity was vital for packages containing large amounts of radioactive materials. As noted in (c), these packages are designed to withstand serious accident conditions with no loss of contents, if a licensee failed to meet requirements (left a drain valve open) and no containment was provided during the shipment, the staff believes a Yellow or RED finding is appropriate (given the potentialimpact on the public in the event of a serious transportation accident). The utility representative questioned the risk significance (in the Notification branch) of failing to notify the state govemor of a 5rge quantity shipment before the package enters that state. The staff noted that, without adequate prior notice, the state response team could be unduly delayed in responding to the scene of an accident. Attachment 4 provides a list of workshop attendees. The meeting was adjoumed.
Attachments: As stated cc w/att: See next page
. DISTRIBUTION: See attached page DOCUMENT NAME: G:\\EP&HP SECTION\\wigginton\\neimtomins52699.wpd OFFICE lOHB y IOHB A, NAME JWihton TEssig #h DATE B/39/9g y/ t/gg
..