ML21244A321
| ML21244A321 | |
| Person / Time | |
|---|---|
| Issue date: | 08/18/2021 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| Brown, C, ACRS | |
| References | |
| NRC-1633 | |
| Download: ML21244A321 (145) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Radiation Protection and Nuclear Materials Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, August 18, 2021 Work Order No.:
NRC-1633 Pages 1-92 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4
(ACRS) 5
+ + + + +
6 RADIATION PROTECTION AND NUCLEAR MATERIALS 7
SUBCOMMITTEE 8
+ + + + +
9 WEDNESDAY 10 AUGUST 18, 2021 11
+ + + + +
12 The Subcommittee met via Video 13 Teleconference, at 9:30 a.m. EDT, Ron Ballinger, 14 Chairman, presiding.
15 COMMITTEE MEMBERS:
16 RONALD G. BALLINGER, Chair 17 VICKI BIER, Member 18 CHARLES H. BROWN, JR. Member 19 GREG HALNON, Member 20 WALTER L. KIRCHNER, Member 21 JOSE MARCH-LEUBA, Member 22 JOY L. REMPE, Member 23 MATTHEW W. SUNSERI, Member 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
2 ACRS CONSULTANT:
1 STEVE SCHULTZ 2
3 DESIGNATED FEDERAL OFFICIAL:
6 ALSO PRESENT:
7 STEVEN GARRY, NRR 8
SCOTT MOORE, Executive Director, ACRS 9
JENNIFER WHITMAN, NRR 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
3 CONTENTS 1
2 Opening Remarks and Objectives 4
3 Staff Opening Remarks..............
6 4
Jennifer Whitman, Acting Deputy Division 5
Director, NRR/DRA.............
6 6
Reason for the Revision and Key Changes.....
8 7
Steve Garry, NRR/DRA 8
8 Public Comments on Key Changes
......... 64 9
Steve Garry, NRR/DRA
........... 64 10 Opportunity for Public Comments (No comments).. 75 11 Committee Discussion
.............. 75 12 Adjourn..................... 92 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
4 P R O C E E D I N G S 1
9:30 a.m.
2 CHAIR BALLINGER: Good morning, everyone.
3 The meeting will now come to order.
4 This is a meeting of the Radiation 5
Protection and Nuclear Materials Subcommittee of the 6
Advisory Committee on Reactor Safeguards. I'm Ron 7
Ballinger, Chairman of today's Subcommittee meeting.
8 ACRS members present are Charles Brown, 9
Greg Halnon, Jose March-Leuba, Walt Kirchner, Joy 10 Rempe, and our consultant, Steve Schultz. If I've 11 missed anybody, please let me know, but I think I have 12 everybody.
13 During today's meeting, the Subcommittee 14 will discuss Draft Regulatory Guide DG-1377, 15 Measuring, Evaluating, and Reporting Radioactive 16 Material in Liquid and Gaseous Effluents and Solid 17 Waste, Revision 3, which is Revision 3 of Regulatory 18 Guide 1.21. The Subcommittee will hear presentations 19 by and hold discussions with the NRC staff from NRR 20 and other interested persons regarding this matter.
21 The rules for participation in all ACRS 22 meetings, including today's, were announced in The 23 Federal Register on June 13th, 2019.
24 The ACRS section of the U.S. NRC public 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
5 website provides our Charter, Bylaws, agendas, letter 1
reports, and full transcripts of all full and 2
subcommittee meetings, including slides presented 3
there.
4 The meeting notice and agenda for this 5
meeting were posted there. We have received no 6
written statements or requests to make an oral 7
statement from the public.
8 The Subcommittee will gather information, 9
analyze relevant issues and facts, and formulate 10 proposed positions and actions, as appropriate, for 11 deliberation by the full Committee.
12 The rules for participation in today's 13 meeting have been announced as part of the notice of 14 this meeting previously published in The Federal 15 Register.
16 A transcript of the meeting is being kept 17 and will be made available, as stated in The Federal 18 Register notice.
19 Due to the COVID pandemic, today's meeting 20 is being held over Microsoft Teams for ACRS and the 21 NRC staff. There is also an MS Teams telephone bridge 22 line allowing participation of the public.
23 When addressing the Subcommittee, the 24 participants should, first, identify themselves and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
6 speak with sufficient clarity and volume, so that they 1
may be readily heard. When not speaking, we request 2
that participants mute your computer microphone or 3
phone.
4 We will now proceed with the meeting, and 5
I would like to start by calling on -- let's see, 6
Jennifer Whitman is, I hope, here.
7 MS. WHITMAN: Yes.
8 CHAIR BALLINGER: Jennifer, are you here?
9 MS. WHITMAN: I am here.
10 Good morning, Mr. Chairman and Members of 11 the ACRS.
12 Can you not hear me?
13 CHAIR BALLINGER: Jennifer, are you here?
14 MS. WHITMAN: I am here.
15 MR. BROWN: I'm going to call Ron.
16 CHAIR BALLINGER: Yes, she is.
17 MS. WHITMAN: All right. Can you hear 18 now?
19 CHAIR BALLINGER: I'm going to call on 20 Jennifer Whitman, Acting Deputy Division Director, 21 NRR/DRA, for opening remarks.
22 So, Jennifer, the floor is yours.
23 MS. WHITMAN: Okay. Can everybody hear me 24 now?
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
7 MR. ROCHE-RIVERA: Yes, we can.
1 MS. WHITMAN: All right. So, good 2
morning, Chairman and Members of the ACRS. I'm 3
Jennifer Whitman, the Acting --
4 CHAIR BALLINGER: Hello. Yes.
5 MS. WHITMAN: -- Deputy Director of the 6
Division of Risk Assessment in NRR. I want to thank 7
you all for allowing us to present to you today the 8
changes we've proposed as Revision 3 to Reg Guide 9
1.21, Measuring, Evaluating, and Reporting Radioactive 10 Material in Liquid and Gaseous Effluents and Solid 11 Waste.
12 The Division of Risk Assessment has the 13 technical lead for the Agency in the areas of 14 radiation protection and radioactive consequence 15 analysis. Our staff develops and updates guidance 16 documents, performs technical reviews of licensing 17 applications, and oversees the implementation of the 18 reactor oversight process in the radiation safety 19 areas. DRA staff provides guidance and support to our 20 regional inspection staff in addressing complex 21 radiation safety technical and policy issues.
22 And Reg Guide 1.21 was last updated nearly 23 12 years ago, and our staff identified a need to bring 24 our guidance up-to-date with current standards and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
8 practices. So, today, you'll hear from the staff how 1
the updates to the Reg Guide provide detailed guidance 2
on how to meet NRC radioactive effluent control 3
program requirements and how we addressed the public 4
comments that were received on the draft when we 5
published it for public comment.
6 Now, I'll introduce the technical lead for 7
this Reg Guide revision, Steve Garry. He's a Senior 8
HP in DRA in NRR and has been with the NRC since 2006.
9 He has more than 25 years of experience in HP work, 10 including work at several nuclear power plants. And 11 while Steve was the lead for this project, I want to 12 note and thank the many other HPs in NRR, NMSS, 13 Research, and the Regions that have supported this Reg 14 Guide update.
15 We're looking forward to answering any of 16 your questions that you may have. And with that, I 17 will turn it over to Steve.
18 MR. GARRY: Okay. Thank you, Jennifer.
19 Yes, welcome, everyone, and thank you for 20 the opportunity to kind of showcase our radioactive 21 effluent and environmental monitoring programs.
22 As Jennifer said, this is Revision of Reg 23 Guide 1.21. This will be Revision 3. Revision 2 was 24 issued in 2009.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
9 And with that, we'll go to the next slide, 1
Mike.
2 Okay. So, what we're going to talk about 3
today, we're going to talk about the purpose of Reg 4
Guide 1.21. We're going to review the effluent 5
regulations, the effluent Tech Specs, the effluent 6
reports that are submitted by the licensees, the 7
analysis of those reports generated into effluent 8
trends, and then, we're going to discuss important 9
changes to the Reg Guide. And then, we're going to 10 discuss the resolution of public comments, as time 11 permits.
12 Next slide.
13 Okay. So, the purpose of Reg Guide 1.21 14 is, as the title says, measuring, which means that the 15 plant has the requirements to measure the radioactive 16 effluents, to evaluate the impact of those effluents, 17 and to report the amount of radioactivity that's 18 discharged in liquid and gaseous effluents.
19 In addition, we're going to discuss the 20 reporting of solid rad waste shipments, and then, 21 finally, we're going to discuss the assessment and 22 reporting of public dose as a result of the release of 23 those effluents.
24 Next slide.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
10 Okay.
We use a
risk-informed, 1
performance-based approach in this. We started that 2
back in 2009. The regulations talk about principal 3
radionuclides.
And in
- 2009, those principal 4
radionuclides were identified as those radionuclides 5
that contribute more than 1 percent of the dose or 1 6
percent of the total activity released.
7 We offer the aspect that the licensees can 8
select their lower limits of detection. And there are 9
acronyms at the end of this slide, if anyone would 10 like those, or please feel free to speak up and I will 11 explain any acronym. LLD is the lower limit of 12 detection; in other
- words, how sensitive the 13 instruments are to be able to measure the 14 radioactivity.
15 And there's, basically, two criteria for 16 that. There's the original LLDs that the NRC issued 17 back 30 years ago, all of the more updated MARLAP 18 system of determining lower limits of detection. And 19
- briefly, MARLAP is the Multi-Agency Radiation 20 Laboratory Accreditation Protocols, which basically 21 originate or use the concept of a data quality 22 objective. In other words, what are you trying to do 23 with this measurement? And based on what you're 24 trying to do with it, that kind of drives how 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
11 sensitive your instruments need to be to achieve that 1
objective.
2 We incorporate the risk-informed 3
decisionmaking on residual radioactivity. And 4
basically, what we're saying there is that if there's 5
a leak or a spill or some residual radioactivity on 6
the site, that the licensee should do an evaluation of 7
the risk involved with cleaning up that residual 8
activity.
9 CHAIR BALLINGER: This is Ron Ballinger.
10 I'm sorry, I was "Lenovo'ed" originally with my 11 computer.
12 But, in looking at this, is there any risk 13 of what I would call creeping sensitivity, where 14 instrumentation sensitivity becomes better with time?
15 And is there any risk of the licensees being racheted 16 by this?
17 MR. GARRY: No, because they're allowed to 18 use -- you know, a Reg Guide is one acceptable method.
19 Other methods are acceptable, but a Reg Guide provides 20 acceptable methods. And if licensees want to use a 21 different method, they're allowed to do that. They 22 just need to have a good technical basis for that.
23 And we're actually offering more 24 flexibility by offering the selection of the LLDs 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
12 based on more current guidance given in MARLAP.
1 CHAIR BALLINGER: Thank you 2
MEMBER KIRCHNER: Ron, this is Walt 3
Kirchner.
4 CHAIR BALLINGER: Yes?
5 MEMBER KIRCHNER: I was going to ask the 6
same question, too. And I'll construct an analogy.
7 About a decade or so ago, I was much involved in the 8
Great Lakes and water quality standards. And what 9
evolved over time was that the capability of the 10 measuring technology just increased and increased.
11 That was all for the better. But it did result, Ron, 12 in just what you're proposing or supposing. And that 13 is that one started getting at detection levels that 14 set limits for releases that were well below what 15 naturally occurred in the Great Lakes, notwithstanding 16 the pollutants, and so on and so forth. And then, you 17 had -- how should I say? -- a situation where the 18 technology was driving the regulatory system to 19 standards that were, basically, in some cases perhaps 20 not achievable.
21 CHAIR BALLINGER: Yes, I think I would 22 agree with that. I mean, I think Joy would probably 23 chime in, because I think something similar to that is 24 happening at Fukushima.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
13 MS. WHITMAN: This is Jennifer Whitman.
1 I'd ask that we let Steve continue because 2
he does discuss the regulations, and we're aren't 3
changing the regulations and that's where the limits 4
are derived from. And so, if we let him continue 5
through, I think you'll see that, with no changes to 6
the regulations, I don't think what you're talking 7
about will be a concern.
8 MEMBER REMPE: So, this is Joy, since my 9
name was mentioned.
10 As you go forward, when I looked at the 11 Reg Guide and slides, there's very little discussion 12 about the amount of tritium that's released, the 13 limits on that. And if you could discuss a little bit 14 about how you selected your limits for the amount of 15 tritium in releasable water, I would appreciate it.
16 And also, if you considered what is being done 17 internationally with other plants, because that is the 18 biggest concern with what Ron is mentioning, with the 19 water that's been released and how the Japanese are 20 dealing with it. The other isotopes they've taken 21 care of. Okay?
22 CHAIR BALLINGER: In deference to the 23 staff, they actually in the Reg Guide use tritium as 24 an example of activity versus does, which is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
14 important.
1 MEMBER REMPE: Right.
2 MR. GARRY: Yes, tritium is actually 3
fairly easy to detect. You can use liquid 4
scintillation counting and get down to something like 5
500 picocuries per liter pretty easily. With advanced 6
techniques, you can go lower. But we don't drive them 7
lower and lower on that. We have an LLD that was 8
established back in the late 1970s of 10,000 and 9
20,000 and 30,000 picocuries per liter. You know, the 10 EPA Drinking Water Standard is 20,000 picocuries per 11 liter.
12 MEMBER REMPE: That's the point I wanted 13 to get to. So, I'm glad you mentioned that, because 14 EPA actually has a very limiting value. And they 15 thought about that they could raise it, is my 16 understanding, and they left it at the 20,000 17 picocuries per liter. And I just am wondering how the 18 NRC compares to what EPA is requiring, and was that 19 thought about much in your preparation of this Reg 20 Guide update?
21 MR. GARRY: No, because we stayed with the 22 standard that was set back in the late '70s, which is 23 20,000 and 30,000 picocuries per liter for 24 environmental monitoring.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
15 MEMBER REMPE: Okay. Because, yes, the 1
EPA actually acknowledged that they could have gone 2
higher and they left at 20,000. But I just was 3
curious if you thought about increasing things at all, 4
but I guess you didn't?
5 MR. GARRY: Well, we're trying to provide 6
stability as much as we can without making the 7
licensees rachet back and forth to different values, 8
and so forth. And the 20,000 is, obviously, the EPA 9
Drinking Water Standard. So, my thought is that there 10 really is no need to drive that --
11 MEMBER REMPE: Oh, we definitely don't 12 want to go lower, but, I mean, you could have gone a 13 little higher, I guess is the question, but I guess 14 you didn't think about doing that at all?
15 MR. GARRY: No, because we wanted 16 stability, and there was no need. It's readily 17 detectable at 20 and 30 thousand picocuries per liter.
18 So, we don't need to drive it higher to save any costs 19 by the licensees.
20 MEMBER REMPE: Thank you.
21 MR. GARRY: Okay. So, moving on, then, we 22 adopted the MARSSIM, which is the federal agency 23 Multi-Agency Radiation Survey and Site Investigation 24 Manual data quality objectives. So, we're allowing 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
16 licensee flexibility to go review the other federal 1
agencies' standards and reevaluate the program, if 2
they wanted to, based on data quality objectives.
3 And then, with tritium leaks and spills, 4
there's always an issue of risk communication and 5
notification of local authorities of spills and leaks.
6 So, that's another aspect of our risk-informed, where, 7
basically, some jurisdictions want to know a lot about 8
leaks and spills. Some jurisdictions don't need as 9
much information. So, risk-informed allows them to 10 choose when they need to be making those 11 communications.
12 Next slide, please.
13 Okay. So, I want to briefly review our 14 regulations. We have quite detailed regulations.
15 Some confusion has been generated in the fact that 16 there are two separate sections of the regulations.
17 There's 10 CFR 50.36, and for lack of a better word, 18 I'll call those general Tech Specs that apply to the 19 operation of the plant with limiting conditions of 20 operation, and so forth. And that's what people 21 commonly refer to as Tech Specs.
22 But, after that section, 10 CFR 50.36, at 23 the very end of that section, there's a new section, 24 another section. And that section is commonly 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
17 confused, but that's because it's labeled 10 CFR 1
50.36a, where that "a" is not in parentheses. It's 2
part of the title. And so, that's where the 3
regulations requiring Tech Specs on effluents 4
originate.
5 And what it says there in 10 CFR 50.36a(a) 6 is, basically, the objective to keep the releases to 7
unrestricted areas as low as reasonably achievable.
8 In order to do that, each licensee and each applicant 9
for a design certification or a manufacturing license 10 has to include Tech Specs that, in addition to 11 complying with the applicable provisions the dose 12 limits -- and 10 CFR 20 is the standards for 13 protection against radiation. Paragraph 1301 of this 14 chapter is the dose lots. So, bottom line is, there 15 is a regulation saying, licensees, you need Tech Specs 16 on effluents, and they need to be incorporated in Tech 17 Specs as part of the general Tech Specs.
18 Next slide, please.
19 So, what 10 CFR 50.36a, then, also says, 20 that not only do you have to have Tech Specs, you have 21 to submit a report to the Commission annually. You 22 have to tell us the quantity of each of the principal 23 radionuclides released to unrestricted areas in liquid 24 and gaseous effluents in a previous 12 months. So, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
18 there's a transparency aspect here where the licensees 1
have to submit a report to the NRC. And I'll show you 2
what we do with those reports.
3 Next slide, please.
4 Okay. So, let's talk about what the 5
public dose limits are now. Now this is a very 6
sensitive issue because this is release of radioactive 7
material into the unrestricted area. And the 8
consequences of those releases, then, we have a series 9
of limits to control the dose to members of the 10 public. The NRC establishes a highest level of 100 11 millirem of total effective dose equivalent, and that 12 applies to not only nuclear power plants, but to 13 materials licensees as well. So, that's a general 14 high-level number that applies to any NRC licensee.
15 In addition to that, EPA has regulations.
16 And in 40 CFR 190, the EPA established a limit of 25 17 millirem to the whole body and organs, with the 18 exception for thyroid of 75 millirem. And again, 19 that's the EPA high-level value.
20 Okay. So, under the regulations, the 21 licensees needed to propose, and we accepted, Tech 22 Specs. In Tech Spec 5.5.4 in the administrative 23 section of the Tech Specs, we set the nuclear power 24 plant annual dose criteria. And what that criteria 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
19 is, now that's not a limit, but that's a criteria. We 1
expect them to operate within these criteria. If they 2
don't, then we have exceptions in what they need to 3
do. But they need to operate within the 10 CFR 50, 4
Appendix I, ALARA design criteria.
5 Now, just briefly, 10 CFR 50, Appendix I, 6
is a requirement by the NRC that, when they propose a 7
new nuclear plant, they have to add enough rad waste 8
processing systems to keep the doses to the members of 9
the public as low as reasonably achievable. So, they 10 then specify specific limits.
11 So, for air dose, which would be the dose 12 at the site boundary, even if there's not a person 13 there, it's an air dose limit of 10 millirem gamma or 14 20 millirem beta. And then, to locations where there 15 are actually people, the liquid effluents can result 16 in no more than 3 millirem total body dose or 10 17 millirem to any organ. And for gases, radioactive 18 gases, there's a specific limit on iodines and 19 particulates of 15 millirem. So, those are, call them 20 "the operating criteria" that the plants need to meet 21 in order to be deemed the effluents are as low as 22 reasonably achievable.
23 Next slide.
24 Okay. Another section of the Tech Specs 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
20 lay out that licensees are required to have a 1
radioactive effluent controls program. And it 2
specifies that that program should be put into an 3
offsite dose calculation manual. In other words, you 4
can consider that a licensee procedure that says:
5 Here's how we will control effluents. Here's how we 6
will measure them. Here's how we will report them.
7 And this effluent controls program needs 8
to conform to the regulations. 10 CFR 50.35a has to 9
be implemented by procedures, maintain doses to the 10 public as low as reasonably achievable, and if the 11 program limits are exceeded, to take specific remedial 12 actions to get back into compliance with -- not 13 compliance -- conformance with Appendix I.
14 Next slide, please.
15 Okay. So, let's take a look at -- and 16 this is all laid out in Tech Specs. Now I'm taking 17 these slides from NUREG-1431, which are 10 standard 18 Tech Specs for a Westinghouse-designed plant. So, the 19 Tech Specs
- require, 554, maintain monitoring 20 instrumentation.
- Okay, so the plants have 21 requirements to keep their equipment working and to 22 perform surveillance tests, and use set points that 23 are calculated in accordance with the ODCM. But this 24 program will limit the instantaneous release of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
21 radioactive effluents to concentrations within 10 1
times the 10 CFR 20, Appendix B, annual average 2
concentrations. So, they are allowed a short-term 3
higher-level release than the annual average, but only 4
for a short period of time. And that's based on the 5
10 times Appendix B.
6 There was a change to the NRC regulation 7
10 CFR 20 back in 1991 where the old public dose 8
limits were 500 millirem. That got lowered to 100 9
millirem. And as a result, we had to change Tech 10 Specs and we maintained the same level of effluent 11 control as was there previously, in spite of the fact 12 that the dose limits had been reduced; that the 13 program needs to monitor, sample, and analyze liquid 14 and gaseous effluents, as you would expect.
15 Next slide.
16 The controls program continued here, that 17 the liquid effluents, they need to limit the public 18 dose to 1.5 millirem per quarter or 3 millirem per 19 year. The idea being there that, if you have a 20 release rate early in the year, you need to get back 21 into an averaging system to where you're going to end 22 up at the end of the year with no more than 3 millirem 23 to the total body.
24 The program requires the licensees to keep 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
22 track of the doses on a 31-day basis. And every 1
month, they have to calculate the doses from their 2
effluent releases and make sure they're in compliance 3
and cumulate those doses, so that, as they go, we know 4
where they are as they approach the end of the year.
5 And on a monthly basis, they need to use their rad 6
waste effluent treatment systems to keep the releases 7
every 31 days, not to exceed more than 2 percent of 8
Appendix I. So, we're establishing Tech Specs that 9
are more and more stringent and more and more 10 guaranteeing that they're going to be able to meet the 11 design criteria at the end of the year.
12 Next slide, please.
13 Okay. For gaseous effluents, to limit the 14 instantaneous dose rate, so if they're releasing the 15 waste gas decay tank noble gases, the instantaneous 16 dose rate can be no more than 500 millirem per year 17 or, in hourly terms,.057 millirem per hour. And for 18 iodines and particulates, the releases can be no more 19
-- iodine and tritium and particulates, the releases 20 can be no more dose rate than.17 millirem per hour.
21 Next slide, please.
22 So, we have the air doses then, the 5 23 millirem gamma and 10 millirem beta. That's the 24 quarterly limits. The annual limits are the ones we 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
23 talked about earlier from Appendix I, 10 millirem 1
gamma, 20 millirem beta.
2 The organ doses, the quarterly doses are 3
limited to 7.5 millirem, the annual doses to 15 4
millirem.
5 And I think just to comment, back in the 6
early days in the late '70s, or whatever you consider 7
early days, there was a lot of concern about the 8
release of iodine. And so, they were tracking here 9
the quarterly and annual doses to make sure that no 10 member of the public exceeded the ALARA criteria. And 11 then, again, the Tech Specs require the compliance 12 with the EPA dose limits, which rarely get challenged 13 because the Appendix I limits are much more 14 restrictive.
15 Next slide, please.
16 Okay. And ODCM, the Offsite Dose 17 Calculation
- Manual, has to be established, 18 implemented, and maintained. Now these ODCMs are 19 pretty comprehensive. They're typically 2 to 5 20 hundred pages procedure, instructing the plant staff 21 how to measure and do these dose calculations, and not 22 only on effluent controls, but it also establishes the 23 environmental monitoring program. So, they calculate 24 the potential impact, based on the effluent release 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
24 rates, and then, they go out in the environment and 1
they take samples and they measure the radioactive 2
effluents that could exist out in the environment.
3 The ODCM has all these equations, methodologies, 4
parameters to calculate the dose, and it contains a 5
description of what information needs to be reported 6
to the NRC in the annual effluent and environmental 7
reports.
8 Next slide, please.
9 Okay. So, once the licensees complete an 10 annual cycle, they're required to submit these annual 11 effluent and environmental reports. And they submit 12 them annually to the NRC. The environmental report 13 has to be reported to the NRC by May 15th, and the 14 effluent report has to be reported to prior to May 15 1st.
16 Now what we do with these reports is we 17 make them all publicly available. So, they're posted 18 on our NRC public website. And here's an excerpt 19 below. The excerpt below shows each plant with a 20 hyperlink to their reports. So, for example, ANO-1 21 and -2, you could click on that link, and it will take 22 you to their reports.
23 So, next slide, please.
24 So, here's what it looks like. This would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
25 be the ANO annual reports. And you can see, for each 1
calendar year, you can see what they released and what 2
the doses from those releases are by clicking on these 3
hyperlinks.
4 And similarly, the environmental reports.
5 If you want to see the sampling and the analysis and 6
the concentrations that are being measured in the 7
environment, you can click on whichever year you'd 8
like, whichever plant, and you can see this data.
9 Next slide, please.
10 So, here's a typical effluent report. It 11 includes an introduction, supplemental information, 12 but it has a section on gaseous effluents, liquid 13 effluents, and solid waste. And it's got a section on 14 doses, the radiological impact to man. And it's got 15 a compilation of the meteorological data. Not all of 16 them have that, but that's available in the ANO 17 report.
18 Next slide, please.
19 And here's the annual environmental 20 report. So, Section 3 here will cover the sampling 21 program that tells you what samples are being 22 collected. Typically, it's grass, milk, water, 23 drinking water, vegetables, direct radiation. There's 24 a whole slew, whatever they're monitoring for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
26 environmental program, they're describing it here.
1 Then, they analyze it and interpret the 2
trends of those results and report those. And then, 3
they put together a radiological environmental 4
monitoring program summary. And then, they report, 5
for example, some of the samples might get lost.
6 Maybe the milk cow stopped milking, the garden didn't 7
produce in the winter, whatever. If there were any 8
deviations, they explain the justification why they 9
had to deviate from the required program.
10 And then, there's the monitoring results.
11 That will give you the concentrations of each 12 radionuclide that's detected. And the Tech Specs 13 require them, the ODCM requires them to do an inter-14 laboratory comparison result and a
dosimetry 15 comparison report.
16 Next slide, please.
17 And again, all these detailed reports are 18 available on our website that you can look at any 19 plant for any of the more recent years.
20 Okay. Once we get all those reports, we 21 compile a summary of all those reports in this 22 document called NUREG/CR-2907, Radioactive Effluents 23 Summary Report from Nuclear Power Plants.
24 Next slide, please.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
27 Okay. So, here's what's in this summary 1
report. And this is a very well-designed and very 2
explanatory discussion of what's happening. So, in 3
the introduction, we talk about the purpose and the 4
scope. We talk the source of the data is directly 5
from the plants. We talk about the limitations of the 6
data. Then, we go into a description of the data; the 7
measuring of radioactivity in effluents; the dose 8
units and limits; the radiation dose to the public, 9
and other sources. And then, we get into the detail:
10 the effluent data, the radioactive material, and 11 liquid and gaseous effluents, short-term trends, long-12 terms trends, a summary reference. And again, this is 13 all put together, essentially, as a summary report for 14 not only NRC staff, but for the public and, also, for 15 the plants to use to compare it to other plants.
16 Next slide, please.
17 So, you might ask, what has been the trend 18 of the releases of radioactive effluents over the last 19 35 or 40 years? You can see, back in 1975, that the 20 BWR gases were approximately 50,000 curies per year, 21 and the current is about -- I don't know; what is 22 that? -- it's 50 curies. And PWRs, similarly, went 23 from about 5,000 curies down to about 1 curie.
24 Now this is a phenomenal decrease in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
28 amount of radioactive effluents by, roughly, a factor 1
of 100 to 1,000 decrease in the amount of radioactive 2
effluents. You can see the continuing progress that 3
the plants have made in reducing their radioactive 4
effluents.
5 You may ask, what is the cause of that; 6
what happened? Well, there are basically two criteria 7
for the noble gases. First of all, fuel performance.
8 In the early days, the fuels had a lot of leakers, and 9
when a fuel leaks, it releases noble gas into the 10 reactor coolant system, and that ultimately has to be 11 degassed and ultimately released. So, there were a 12 lot of fuel leakers, so there was a lot of noble gas 13 to deal with. Those fuel pens, the fuel engineering 14 has improved dramatically, and the number of fuel 15 leakers now and the foreign material control programs, 16 and so forth, have really cleaned up the reactor 17 coolant system gases and led to a decrease.
18 A second reason is the additional, 19 especially for the BWR, the advanced off-gas systems, 20 the charcoal delay systems that hold up these gases.
21 Now some of these gases are very short-lived, like two 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> or four hours, or so forth. So, a holdup of 5 23 or 10 days will do a great deal in reducing the amount 24 of radioactivity that's released. So, a lot of credit 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
29 goes to the plants and the plant design that have 1
added these new effluent processing systems. And 2
that's why PWRs have a waste gas decay tank, and the 3
BWRs have the charcoal delay systems. So, I just 4
wanted to acknowledge the decrease by a factor of 100 5
to 1,000 over the last 40 years.
6 Next slide, please.
7 Similarly, liquid effluents. Look what's 8
happened with the liquid effluents. They have 9
decreased by, roughly, a factor of 100 to 1,000. And 10 again, the same reasons. If the fuel is not leaking, 11 then you don't have as many particulates to deal with.
12 You still have activation products, but you don't have 13 as many fission products. So, the fuel performance 14 has led to a decrease.
15 In addition, the plants have added better 16 liquid rad waste processing systems. They've gone to 17 better resins, so that the resins will absorb these 18 particulates before they get released. And they've 19 gone to reverse-osmosis systems to, again, filter the 20 release as much as you can. And as you know, tritium 21 cannot be filtered, and it really doesn't do a lot of 22 good to hold up tritium because it's got like a 11-23 year half-life. So, nevertheless, there's been a 24 factor of 100 to 1,000 decrease as well in the liquid 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
30 effluents. So, the sophistication of the radiological 1
effluent monitoring and control programs at the plant 2
have really improved over the last 40 years.
3 Next slide, please.
4 CHAIR BALLINGER: This is Ron. This is 5
Ron.
6 So, the clear message here is don't fail 7
the fuel?
8 MR. GARRY: That's the No. 1 message, yes.
9 CHAIR BALLINGER: But, for comparison 10 purposes, I think -- and my memory escapes me here --
11 a nuclear power plant can only result in a dose to the 12 public which is some fraction of a number. And so, my 13 question is, for the fleet, how do the annual releases 14 compare, annual dose -- excuse me -- compare with the 15 average annual dose from background radiation to the 16 public compared to that rule limit? I think it's 17 1/10th?
18 MR. GARRY: Well, we don't have a criteria 19 as compared to background. We have a criteria as 20 compared to our most restrictive limit, which is the 21 10 CFR 50, Appendix I, criteria.
22 CHAIR BALLINGER: Yes, I understand that, 23 but I guess what I'm trying to get a feeling for is 24 the actual impact of the fleet on the annual dose that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
31 the public would receive in any case.
1 MR. GARRY: Okay. Well, basically, the 2
tritium doesn't cause very much dose. It takes a lot 3
of tritium to cause dose, especially when you consider 4
the fact that a lot of the tritium is released in the 5
liquid effluents to rivers or lakes. So, when it's 6
released to a river, it, basically, flows downstream 7
quite quickly and you don't get a buildup in the 8
environment. However, if they're discharging to a 9
lake, then there is a buildup of residual tritium in 10 that lake. And nevertheless, the licensees still need 11 to meet the regulatory limits on doses. And we're 12 going to discuss that in a little more detail here in 13 a few minutes.
14 CHAIR BALLINGER: Thank you.
15 MR. GARRY: Okay. So, why do we need to 16 revise Reg Guide 1.21? Well, first of all, we have a 17 process called a periodic review, where we look at the 18 existing Reg Guides that we have issued and we review 19 them and determine if there's a need for an update.
20 And in our review, periodic review of Reg Guide 1.21, 21 we identified that we needed to provide an update.
22 And there are basically six areas that were driving 23 the need for that update.
24 We, one, needed to provide guidance and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
32 acceptable methods for calibration of the accident 1
range containment radiation monitors and the accident 2
range effluent monitors. That guidance had been 3
contained in an old NUREG, and we wanted to bring it 4
forward to the current Reg Guide that would be a 5
little more publicized.
6 MEMBER REMPE: So, this is Joy.
7 On this first one, after what happened at 8
Fukushima, it was difficult to use the monitors 9
because there was so much release. And so, when you 10 think about your accident range effluent monitors, and 11 they did say in the Reg Guide that you had to consider 12 a core melt, do you consider what needs to be done in 13 such extreme situations? Or how do you take into 14 account the difference in isotopic content that might 15 occur and the changes because, suddenly, your 16 background's higher and to monitor additional 17 releases? Have those types of considerations been 18 considered?
19 MR. GARRY: Yes. As far as Fukushima 20 goes, you know, that, basically, was a disaster. They 21 lost electrical power. They didn't have monitored 22 effluent release paths because the buildings, 23 basically, blew up. So, the scope of that accident 24 was far in excess of a smaller accident where the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
33 accident range monitors would be useful, because they 1
lost electrical power; they didn't have a monitor 2
release path.
3 MEMBER REMPE: So, in your accident 4
release -- this is, again, the Reg Guide says you 5
consider a core melt accident -- what kind of 6
frequency do you have for a cutoff frequency for how 7
far down you go?
8 MR. GARRY: Well, I don't know how to 9
exactly answer that. What we have is like Three Mile 10 Island was a core melt, and in that there was a 11 release of noble gases, and those noble gases, 12 basically, bypassed containment. Basically, some of 13 the gases were absorbed in the water that was on the 14 floor. The reactor coolant drain tank overflowed to 15 the floor of the reactor building. The sump filled 16 out. They pumped the water over to the aux building.
17 They have valve leakage, and so forth, that the gas 18 came out of the water, and then, got exhausted from 19 the auxiliary building and went past the accident 20 range effluent monitors. So, that was a monitored 21 release of a core melt. And that's, basically, the 22 design of this.
23 Similarly, if there was a different type 24 of accident -- let's say a LOCA -- where you have a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
34 double-ended pipe break, or whatever, then the later 1
is going to be released to the reactor building and 2
the radiation is going to be released to the (audio 3
interference), sitting there watching and monitoring.
4 And that happened at TMI. The TMI containment high-5 range monitor went to about 800R per hour. So, they 6
knew, basically, how severe the gas was in the reactor 7
building, and they knew that the noble gas being 8
bypassed through either the letdown system or through 9
the containment sump was monitored as well by the aux 10 building exhaust ventilation.
11 MEMBER REMPE: Now again, we're supposed 12 to be going to a risk-based regulatory regulator, and 13 I guess what I'm hearing is, well, we've looked at, 14 basically, what we saw at TMI and we think we can 15 accommodate that or design basis accidents such as the 16 LOCA.
17 MR. GARRY: Right. The General Design 18 Criteria 60 and 64, essentially, established design 19 requirements where the plant has to have this type of 20 instrumentation.
21 MEMBER HALNON: Hey, Steve, this is Greg 22 Halnon.
23 Wasn't this No. 1 the subject of some 24 industry interaction and some white findings in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
35 last, say, three or four or five years?
1 MR. GARRY: Yes. Vogtle got a white 2
finding for their containment high-range monitor 3
calibration.
4 MEMBER HALNON: Does this resolve the --
5 I guess I don't say "misunderstanding" -- but the lack 6
of clarity in the industry, so it will be clear for 7
what has to happen to present that?
8 MR. GARRY: Well, we gave a training 9
course to our NRC inspectors on how to inspect the 10 containment high-range monitor calibration. The basic 11 mistake made at Vogtle was that they changed the 12 calibration geometry. They had a misconception that 13 the monitor should be checked at 17R per hour. Now, 14 as their source decayed, they couldn't get 17R per 15 hour1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. So, they mistakenly said, well, we know how to 16 get that back up to 17R per hour; we'll just slide the 17 source closer to the instrument. Well, when the plant 18 does a calibration, they're really doing a calibration 19 check, and a calibration check is, hey, is that 20 instrument working properly? That's the real 21 question.
22 So, to know if it's working properly, you 23 have to compare it to something. And you should 24 compare it to what the manufacturer told you was the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
36 right comparison, the right conventionally true value.
1 Well, Vogtle didn't do that. They didn't understand 2
the calibration process. And so, they slid that 3
source closer to the detector, so that they finally 4
got it to read 17R per hour, which was not the 5
objective. The objective is to see if it's operating 6
properly.
7 MEMBER HALNON: So, the guidance you have 8
here will clarify or at least prevent that from 9
happening in the future?
10 MR. GARRY: Well, it will provide them as 11 much guidance as we can as to how to get that. Now we 12 may in the future give more guidance on calibration of 13 instrumentation, but, for now, what we did is we 14 carried forward the calibration criteria that's laid 15 out in NUREG-0737 into this Reg Guide, so that it's 16 prominent information.
17 MEMBER HALNON: Okay.
18 MEMBER REMPE: Does the information 19 indicate how often the calibration has to be done and 20 that it has to be in this traceable source, and all of 21 that type of information?
22 MR. GARRY: Yes. The only time the 23 containment high-range monitors can be calibrated are 24 during outages. So, that's the periodicity of it.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
37 And typically, the plants are on an 18-month or a two-1 year fuel cycle. So, that's how often it's 2
calibrated.
3 Most of these containment high-range 4
monitors are very good, stable instruments. They're 5
ion chambers that perform well for a long period of 6
time. So, fortunately, the calibration check, all 7
they have to do is verify that it's still working 8
right.
9 MEMBER REMPE: And so, you have something 10 that says you've got to do it at least every two years 11 to give them that flexibility and they do have to show 12 that their source is -- I mean, we used to have to buy 13 or send back our sources to show that they were NIST 14 traceable when we were doing checks on monitors. Do 15 you guys have those kind of requirements?
16 MR. GARRY: Yes. Well, Tech Specs 17 themselves have a criteria on post-accident monitoring 18 systems, and that includes a containment high-range 19 monitor, that they need two of them and they need to 20 be recalibrated or they need to have a calibration 21 check every refueling outage.
22 MEMBER REMPE: Okay.
23 MR. GARRY: Okay. Another update we 24 wanted to give in the Reg Guide is on recommendations 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
38 for reviewing and updating the long-term annual 1
average chi-over-Q and D-over-Q values. As we all 2
know, with climate change and so forth, the weather is 3
changing, or at least some people believe it is. So, 4
we wanted to have better guidance on updating their 5
long-term annual average chi-over-Qs and D-over-Qs.
6 So, we'll talk about that a little later.
7 There has been some confusion in the 8
industry on reporting of low-level waste, two aspects 9
of that: the classification of the waste and the 10 reporting of the shipments. So, we're going to talk 11 about that in more detail in a little bit, too.
12 We wanted to clarify environmental 13 guidance for monitoring iodine in drinking water.
14 We're going to talk about these things in more detail.
15 We need to provide guidance on making 16 changes to the effluent and monitoring environmental 17 programs when transitioning to decommissioning. We've 18 had several calls from licensees saying, hey, what do 19 we need to do with our ODCM now that we're going into 20 decommissioning? So, we wanted to give some guidance 21 on that.
22 And then, we wanted to incorporate 23 guidance from Regulatory Issue Summary 2008-3 on the 24 return and the reuse of previously discharged 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
39 radioactive effluents.
1 Next slide, please.
2 We're going to go into detail on some of 3
these things.
4 Okay. The calibration of the accident 5
range monitors. Post-TMI, NUREG-0737 has item II.F.1, 6
Additional Accident Monitoring Instrumentation.
7 There's three sections of it: how to monitor noble 8
gas; how to monitor iodine and particulates, and how 9
to do the containment high-range monitoring.
10 Next slide.
11 So, we carried that guidance from 12 NUREG-0737 into the Reg Guide. And basically, on the 13 high-range noble gas effluent monitor, it's typically 14 monitored with an ion chamber or GM detector which 15 read out in units of dose or count rate, MR per hour 16 or counts per minute. And we're explaining that the 17 manufacturer performs the initial design calibration.
18 The manufacturer provides the instrument response 19 factor based on xenon-133, and that the licensees, all 20 they need to do is this periodic calibration check 21 with a solid source to ensure proper operation.
22 Next slide.
23 We have iodine and particulate sampling 24 and analysis. The NUREG-0737 recognizes that real-25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
40 time, live monitoring of iodine and particulates is 1
not practical. Therefore, licensees need to have 2
procedures for the collection and analysis of charcoal 3
cartridges.
4 Now, remember that the normal operating 5
plant never has to do iodine/particulate sampling 6
using their emergency instrumentation systems. They 7
need to have procedures on how to collect a hot sample 8
and how to analyze it; and that the iodine releases 9
during a dose assessment during the first few hours of 10 an accident can be calculated based on petitioning or 11 scaling factors to the noble gas. And we give some 12 references in there as to how to determine those 13 scaling factors.
14 Next slide, please.
15 And finally, the containment high-range 16 monitor. The high-range reading is 10 million R per 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. Remember, TMI went up to 800 R per hour. And 18 this monitor is used for two purposes.
19 The first purpose is in the core damage 20 assessment models. Now I think you probably know 21 pretty well the TMI history, but the bottom line was, 22 in the first few hours of TMI, they did not know what 23 the status of the core was. They didn't know if the 24 plant was going to blow up. They didn't know if they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
41 needed to evacuate. They didn't know what they needed 1
to do.
2 As a result of that, NRC issued some post-3 accident sampling criteria, and that sampling criteria 4
required the plants to have to go grab reactor coolant 5
samples and analyze them. There was a lot of 6
technical difficulties with that.
7 As a result of that, the vendors, a couple 8
of years later, made some Topical Report submittals to 9
the NRC saying, "We don't really need to do all that 10 post-accident sampling if we have an alternative 11 method." And that alternative method is a core damage 12 assessment model, and that takes input like core exit 13 thermocouple temperature readings, reactor coolant 14 system pressure and temperature. And one of the 15 inputs is the containment high-range monitor. So, 16 we're describing that in the Reg Guide.
17 But the manufacturer is going to do the 18 primary initial calibration for this, and then, the 19 manufacturer is going to give the instrument response 20 factor. And then, the value is 1 times (audio 21 interference); it's 11 amps per hour.
22 But the licensees need to just perform 23 this periodic solid source calibration in the 1-to 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> range, and the I&C staff will do the electronic 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
42 calibration above 10R per hour.
1 Next slide, please.
2 Okay. Chi-over-Qs and D-over-Qs. As you 3
know, chi-over-Q is the dispersion factor, how the 4
radioactive effluent disperses after it's released 5
from the plant vent, and the D-over-Qs, which are the 6
deposition rates of the iodines and the particulates.
7 The previous guidance was, if the chi-over-Q changed 8
in a non-conservative direction by 10 percent, then 9
the licensee should go back and adjust their computer 10 codes to use a more updated chi-over-Q.
11 So, our meteorological staff reviewed this 12 and approved the change. That's going to be, for lack 13 of a better word, ratcheting the licensees to making 14 changes to the computer codes too often. The whole 15 overall accuracy of this whole system is not within 16 plus or minus 10 percent. So, we allowed in the 17 revised Reg Guide that they need to update the 18 computer codes if the dispersion factor increases, or 19 decreases in a non-conservative direction by 20 or 30 20 percent. So, that will give them a little better 21 relief from ratcheting their changes to their computer 22 programs just based updated weather patterns.
23 Next slide.
24 MEMBER HALNON: Hey, Steve, this is Greg 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
43 Halnon again.
1 On that last slide, there's a Reg Guide 2
4.28 coming out using the ARCON model for offsite. Is 3
there any effect or is there a synchronization needed 4
to be done, or at least a reference between those two 5
before that Reg Guide gets issued?
6 MR. GARRY: The meteorological staff put 7
out that, and I looked at that this morning, Draft Reg 8
Guide 4.28. That's for control room doses and onsite 9
dispersion.
10 MEMBER HALNON: Okay. Well, the new 11 revision is looking at being able to use that for the 12 new reactors, SMs, for offsite.
13 MR. GARRY: Right.
14 MEMBER HALNON: So, I just wanted to make 15 sure that those two don't conflict with each other, 16 once they get issued.
17 MR. GARRY: Yes, this is for offsite 18 dispersion during routine effluent releases. The 19 other is for onsite dispersion during accidents.
20 MEMBER HALNON: Okay.
21 MEMBER KIRCHNER: But I think Greg is 22 right that the proposal is to use the other for the 23 small reactors, small modular reactors, because of the 24 anticipation that they're going to pull in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
44 exclusionary boundaries and such. So, the (audio 1
interference) would be used once you've crossed the 2
site boundary.
3 MEMBER HALNON: Correct. That's right.
4 Thanks, Walt.
5 MR. GARRY: Okay.
6 MEMBER HALNON: Yes, I think you've got to 7
look at it from the perspective of it being broader 8
than what it has been traditionally been used as. So, 9
my question was just to make sure they're synchronized 10 and that there's no conflict there.
11 MR. GARRY: Okay. No, I reviewed it this 12 morning. I didn't see a conflict in it. And it was 13 prepared by the meteorologist group.
14 MEMBER HALNON: Okay. We'll be doing 4.28 15 in the future, when it gets through public comment, 16 and we'll look back at this to make sure and just give 17 you a second check on it.
18 MR. GARRY: Okay. Thanks.
19 Next slide.
20 Okay.
Low-level waste shipment.
21 Basically, there's two changes that aren't being made 22 here. One is reporting waste classification. I'd 23 like to describe waste classification.
24 That is a concept of how, for lack of a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
45 better word, risky or dangerous this rad waste is to 1
be disposed into a licensed low-level waste disposal 2
facility. So, that lift into the ground as a rad 3
waste needs to be determined when the waste is in its 4
final form.
5 As you know, most or a lot of the waste 6
from a nuclear power plant is now sent to a rad waste 7
processor. In the old days, the waste was sent for 8
direct disposal. It was put into 55-gallon drums, a 9
lot of it, and taken to a landfill and it was direct 10 disposal. The truck went from the power plant to the 11 waste disposal facility. In most cases, the waste 12 could be classified because it was in final form. It 13 was in the 55-gallon drum. That was the final form.
14 The resin was in a 55-gallon drum.
15 Currently, due to the cost of low-level 16 waste disposal, most waste is sent from the power 17 plant to a waste processor, and they will process that 18 waste into a lower volume for volume reduction. And 19 they've achieved some huge volume reductions. Resin, 20 for example, is essentially melted or burned down into 21 ashes. And so, the volume is, let's just say, a 22 factor of 100 decrease in the volume. At the same 23 time, there's a factor of 100 increase in the 24 concentrations of the radioactive materials in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
46 ash. So, the waste classification can be much 1
different after waste processing.
2 Similarly, for dry active waste, which is, 3
basically, SeaLand containers of clothing and 4
paperwork and garbage coming out of the plant that's 5
slightly contaminated. That, again, is incinerated.
6 So, you get a SeaLand container which is roughly 1,000 7
cubic feet. When they get done incinerating that, 8
that's going to be down to 3 or 4 cubic feet, and the 9
concentrations will have increased by a factor of 100 10 or so. So, the waste cannot be classified until it's 11 in final form.
12 The previous version of the Reg Guide 13 asked the licensees to report the waste 14 classification. And the licensees have told us, hey, 15 we can't do that because it's not in final form. And 16 the processor who sends the waste to the low-level 17 waste disposal facility, that processor is the one 18 that's going to classify the waste. As a result, we 19 have removed from the Reg Guide the table that tells 20 us what the waste classification is. So, that's one 21 concept.
22 Another concept is, we had a couple of 23 licensees who did not want to report the waste shipped 24 from the plant. They wanted us to track the waste 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
47 that's actually disposed in the low-level waste 1
disposal facility. Well, there's two problems with 2
that.
3 First of all, that waste is already being 4
tracked by DOE. The Department of Energy tracks the 5
low-level waste disposals into the licensed low-level 6
waste disposal sites. So, we did not want to have 7
redundant requirements with DOE to track the amount of 8
waste going into the landfill.
9 And the second thing is we want to know 10 what waste is being generated at the plant and is out 11 on the public roads. So, if there was a rad waste 12 shipping accident on the roadway, whatever, if we got 13 asked by politicians or someone as to, hey, how much 14 waste is leaving these nuclear power plants, we would 15 have a reporting of the waste shipped from the plants.
16 So, we clarified that again in the Reg Guide.
17 CHAIR BALLINGER: This is Ron Ballinger 18 again.
19 Is there any -- and it's probably from my 20 ignorance -- a risk of losing track of who owns what 21 waste when they ship stuff to a processing facility?
22 Does the processing facility maintain -- what do you 23 want to call it? -- a unique chain of custody and not 24 combine waste from individual plants as they 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
48 incinerate?
1 MR. GARRY: Once the waste goes to the 2
processing plant, my understanding is that the waste 3
is now transferred to the waste processing, and it, 4
essentially, becomes the -- first of all, the 5
processors are licensed by the states. Most of the 6
processing is in the State of Tennessee, and the State 7
of Tennessee has licensed the waste processors to 8
receive the waste. They have waste acceptance 9
criteria saying you can only receive it if it's in the 10 proper shipping container, if the VOP shipping 11 categories are properly completed, the waste manifest 12 forms are completed.
13 And there's quite detailed tracking of 14 this waste. It starts with the waste manifest forms.
15 That's the NRC Forms 540, 541, 542 that identify the 16 radionuclides, the quantity of the radionuclides, the 17 LLDs. It's very well-tracked.
18 A lot of these requirements are in 19 10 CFR 20, which is the standards for protection 20 against radiation. It's, specifically, in Appendix G, 21 golf, Appendix golf, which has the manifesting and 22 shipping requirements. And that establishes the 23 tracking and the traceability of the waste.
24 CHAIR BALLINGER: Okay. Thank you.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
49 MR. GARRY: Uh-hum.
1 And then, just to make it a little 2
simpler, in the Reg Guide, we generalize the 3
description of the rad waste into wet waste, dry 4
waste, activated waste, and other waste. So, that's 5
a change, although it's not a big change. It just 6
makes it a little more intuitive as to how to report 7
which shipments as which category.
8 Okay. Environmental monitoring. We 9
updated the environmental monitoring requirements.
10 Most of the effluent and environmental requirements 11 originated in a couple of documents back in the late 12
'70s called NUREG-1301 and -1302. And that laid out 13 a minimally acceptable environmental monitoring 14 program.
15 And part of that was a criteria for 16 sampling for iodine-131 in drinking water. Now that 17 is not a cheap analysis to do. That costs -- I don't 18 know -- $3,000 per analysis, something like that. And 19 it needs to be done if it's appropriate.
20 And the guidance on whether it's 21 appropriate was a little confusing. So, basically, we 22 have simplified it and said, basically, that in order 23 to do this expensive analysis -- we don't use the word 24 in the Reg Guide -- iodine-131 in drinking water, you 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
50 need to do it if the estimated dose is more than 1 1
millirem per year. You need to do it every two weeks.
2 If you don't expect to see iodine-131 in drinking 3
water, then you can change that to a monthly analysis.
4 So, that should clarify and remove a lot 5
of the environmental sampling frequencies for 6
iodine-131 and allow them to do the analysis using a 7
gamma spect system rather than a resin column.
8 Next slide, please.
9 Okay. Leaks and spills. I think, as 10 everyone knows, there's been a lot of attention in the 11 last 15 years on leaks and spills. And one question 12 that continually got asked is, do they have to clean 13 it up? And so, we wrote a SECY paper back in 2013 14 entitled something like "Remediation of Residual 15 Radioactivity During Operations."
16 And basically, the guidance or the 17 consideration that we gave in the SECY paper was that 18 it could be detrimental to the operation of the plant 19 to have them try to remediate leaks and spills 20 underneath the plant. With all the electrical wires 21 and the conduits and the piping, and everything else, 22 we don't really want them digging up dirt because 23 there's a little bit of tritium, or mostly tritium, 24 maybe a little strontium, in there.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
51 So, the Commission agreed with us that 1
what we should do is have them evaluate the 2
feasibility of prompt remediation. So, for example, 3
if there was a spill that -- at a plant where I used 4
to work, there was a small oil spill. It wasn't 5
radioactivity, but it was an oil spill. It went down 6
the storm drain, but it sat in the sump at the bottom 7
of the storm drain. So, it was feasible to take the 8
cover off of that manway and go down and recover that 9
oil, so that it didn't get discharged out into the 10 environment. So, similarly, evaluate the feasibility 11 of prompt remediation.
12 In the radioactive world, that, basically, 13 has been done at several plants where they have 14 established groundwater monitoring wells. And they 15 have taken some of those wells and, using those wells, 16 they have pumped back the tritium from the groundwater 17 back to the plant, so that it could be monitored and 18 discharged into the approved discharge pathways.
19 So, there are several plants that have 20 done that. Brunswick is pumping back, and so forth.
21 There's several plants that are pumping back and 22 monitoring, and then, releasing.
23 But there is no specific prompt 24 remediation requirement. That should be evaluated, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
52 but you don't necessarily have to remediate it.
1 MEMBER HALNON: Steve, this is Greg.
2 Just be de fact -- and I'm just looking, 3
I think it's on page 17, and it may not be a new issue 4
-- but the statement is, "If the spill's properly 5
remediated" -- the example, within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> -- la, la, 6
la, it doesn't have to be reported in the annual 7
report. Is that a new issue or is that something that 8
has been existing for --
9 MR. GARRY: Well, that's kind of guidance 10 that we have given over the last 14 years to public 11 meetings, and so forth, that we want to, basically, 12 give them the incentive to capture it, if they can.
13 And the incentive is you don't have to report it if 14 you can get it cleaned up right away.
15 MEMBER HALNON: So, isn't that kind of de 16 facto setting a requirement of some type? I mean, by 17 putting it within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, I can just see a CNO or a 18 site VP driving his team to take actions to clean 19 things up within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />, just so that they can stay 20 within the non-reporting requirement.
21 MR. GARRY: Yes, that's kind of the 22 objective, is to encourage them, so to speak. If they 23 can clean it up right away, they don't have to report 24 it. The 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is arbitrary, as you well point out, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
53 but that's the guidance that we had issued back in 1
2009.
2 MEMBER HALNON: Okay. It just seems a 3
little soft and ambiguous to say that's just an 4
example. And then, you say prompt remediation is not 5
a requirement. However, it looks like it's being 6
strongly encouraged through this --
7 MR. GARRY: That's about right.
8 CHAIR BALLINGER: Yes, this is Ron again.
9 Along those lines, in the spirit of risk-10 informing something, might the time to clean up or 11 requirement to clean up a spill be dependent on the 12 severity of the consequences?
13 MR. GARRY: Sure.
14 MEMBER HALNON: I mean, why just put 48 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> on the thing and just leave it at that?
16 MR. GARRY: Well, first of all, a Reg 17 Guide is an acceptable method. It's not a 18 requirement. It's, like you say, encouraged or it's 19 guidance on what we find is appropriate. Can the 48 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> be, you know, three days or four days? Yes.
21 So, it's not a hard-and-fast requirement. It's 22 guidance.
23 CHAIR BALLINGER: Yes, yes, I hear you, 24 but in the military we call that being "volun-told."
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
54 (Laughter.)
1 MR. GARRY: Well, there's probably some 2
similarities there.
3 MEMBER HALNON: I was more concerned with 4
the fact that it provides just some ambiguity to what 5
goes into the annual report and what doesn't. You 6
know, what if it is three days or four days? Who 7
makes the decision that it was promptly remediated, so 8
that it doesn't have to be reported? So, to me, it 9
muddies up what is in the annual report and what is 10 not.
11 MR. GARRY: Yes, you could also consider 12 it flexibility. I understand what you're saying. No 13 matter what number we put there, we wanted to give 14 some kind of guidance. We wouldn't want to just say, 15 "prompt" and have somebody say, "What does that mean?
16 In the current shift? Or does that mean in the next 17 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />? What do you mean `prompt'?" Because we --
18 MEMBER HALNON: Yes, I agree, and that's 19 why maybe the time to do is, for lack of a better 20 term, a deterministic period, as opposed to risk-21 informed, which looks at consequences, as Ron 22 mentioned. So, it just seems to me that you might 23 want to take a look at that and see if there's an 24 opportunity to better the language in a risk-formed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
55 way as opposed to a deterministic way.
1 MR. GARRY: Okay. We can discuss that, 2
yes. It's something I haven't really thought much 3
about. So, thanks for pointing that out.
4 MS. WHITMAN: And, hey, Steve, this is Jen 5
Whitman.
6 I don't think we've received any public 7
comments on this, and I don't know that there's been, 8
I guess, questions or concerns from industry about 9
this threshold of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. Is that correct?
10 MR. GARRY: That may be a reflection of 11 the fact that the industry has gotten so much better 12 at minimizing release and dealing with spills, that as 13 a practical matter, it doesn't happen very often.
14 Something that I haven't discussed is we 15 do on our web page provide a list of leaks and spills 16 at each of the plants with the maximum contamination 17 levels measured and the current levels, the current 18 maximum level. So, we're transparent with the public 19 about leaks and spills.
20 And when we talk about leaks and spills, 21 we're basically talking water leaks with tritium in 22 it.
23 MEMBER HALNON: Yes, you know, I guess I 24 wasn't implying there's a problem. I'm implying that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
56 you may not know there's a problem because you don't 1
know what's not being reported in the annual report 2
because people may be cleaning up some significant 3
leaks fast enough, promptly enough, that they can say, 4
okay, we got that one done; we don't have to report 5
it. Thank you.
6 MR. GARRY: Yes. You know, we rely a lot 7
on the Resident Inspectors and the daily review of the 8
Corrective Action Program entries, and the expectation 9
that, if there's a leak or spill, right away they 10 would put it into the Corrective Action Program. It 11 would get reviewed by the Resident within a day or 12 two, and then, the Resident has good contacts with the 13 Regional HP Inspectors. So, if we had a massive leak, 14 or whatever, that we would quickly know about it, and 15 not wait for the annual report.
16 MEMBER HALNON: Okay. Well, I agree that 17 the parallel path is there. However, the data 18 reduction in the annual reports, does it take that 19 into consideration?
20 MR. GARRY: Yes, we have a Reg Guide on 21 reporting or measuring the impact of these leaks and 22 spills. It's Reg Guide 4.25, which is a method of 23 estimating the offsite impact of an onsite leak.
24 MEMBER HALNON: Okay. Well, I think the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
57 comment still stands. Maybe that's an opportunity 1
there that we can clarify in the future. If it's not 2
a problem, you know, a pervasive problem, I'm sure 3
that it's certainly been part of the discussions in 4
the site VP office when a leak occurs.
5 MR. GARRY: Yes, yes.
6 Okay. Any other discussion of that?
7 CHAIR BALLINGER: Yes, this is Ron again.
8 We have a break that's scheduled for now, 9
but I see there's only a few slides left, except for 10 the backup slides. And there were very few public 11 comments. So, I would propose that, unless other 12 members want to have a break now, that we just 13 continue to the discussion and have our break before 14 we have the going-around-the-table discussion.
15 MEMBER HALNON: I'm fine with that, Ron.
16 This is Greg.
17 CHAIR BALLINGER: Yes, I don't hear a 18 groundswell of objection. So, thanks.
19 MR. GARRY: Okay. All right, great.
20 So, like I say, we've had several requests 21 from licensees and inspectors as to what are they 22 supposed to do when we go into decommissioning. And 23 the first thing I want to point out is that the NRC's 24 reactor oversight process transitions from NRR to NMSS 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
58 for decommissioning inspections. So, I work in the 1
Office of Nuclear Reactor Regulation. So, this goes 2
over to the decommissioning group. However, we still 3
get the calls because the plant's typically still 4
operating when they want to know, hey, we're going to 5
be headed into decommissioning; what should we be 6
doing?
7 And as you know, the NRC has got a new 8
rule coming on decommissioning and the criteria for 9
going into decommissioning. And that's mostly 10 security-related and some of the revision of Tech 11 Specs and the requirements for surveillances, and so 12 forth. It really doesn't affect the effluent program 13 as much as you might expect because we have the 14 effluent program already set up to be flexible. The 15 Tech Specs require the licensees to maintain their 16 ODCM, and that means, when significant plant changes 17 occur, they need to update the ODCM accordingly.
18 So, the second bullet here, then, is that 19 the licensees need to update their ODCM to 20 decommissioning status. They need to evaluate the 21 effluent release pathways. We're going to talk about 22 that a little bit more in the next slide.
23 They need to update the source term, 24 because the principal radionuclides are likely to have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
59 changed. The radioactive iodines have decayed.
1 They're going to decay off in the first 30 to 60 days.
2 Most of the noble gases have been released or decayed 3
off.
4 So, the effluent monitoring needs to 5
recognize that, and you need to update the ODCM and 6
determine whether or not you want to continue, or when 7
you want to discontinue, iodine monitoring, and when 8
you can discontinue noble gas monitoring. You need to 9
recognize that krypton-85 is likely a new principal 10 noble gas radionuclide. And then, you need to 11 maintain your Part 72 ISFSI effluent reporting.
12 Next slide, please.
13 So, what does the update to the ODCM 14 involve? Well, the old effluent release pathways are 15 being dismantled. Ventilation systems are being 16 removed. Fans are being shut down. New effluent 17 release pathways -- I noted the word "effluent release 18 pathway" -- how is it getting out? Well, you've got 19 to open hatches, roll up doors, and demolition 20 activities.
21 You've got new principal radionuclides.
22 We talked about that a little bit. We're approaching 23 zero releases of iodines and noble gases. We're going 24 to, basically, particulate and alpha activity. As 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
60 you're cutting open primary systems, there may be 1
alpha activity that's now in a form that can be 2
released; whereas, previously, it was contained inside 3
of an operating system, an operating pipe.
4 Particulates, which you can think of as 5
dust, radioactive dust, is being released. So, you 6
need to think about how you're going to be monitoring 7
particulate activity.
8 You can reevaluate your radiation exposure 9
pathways. So, for example, there's no iodine milk 10 pathway anymore because there's no iodine. They're 11 still drinking milk, but there's no iodine in it. So, 12 you don't need to be monitoring for environmental 13 iodine.
14 But you need to continue your normal 15 exposure pathways, which are the primary ones. What 16 are you breathing, what are you eating, and what is 17 the direct radiation? And then, you need to identify 18 if there are any new, significant exposure pathways, 19 created by the fact that you're now in a
20 decommissioning mode rather than an operating mode.
21 Next slide.
22 But the point, then, is that it doesn't 23 take a rule change to do this. We've already got in 24 Tech Specs a system set up on how to modify your ODCM.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
61 And basically, it's very simple. You do an evaluation 1
and you get the plant manager to approve it. And 2
then, you need to submit that revised program to the 3
NRC, along with the next annual environmental report.
4 Next slide.
5 Okay. Then, we've got Regulatory Issue 6
Summary 2008-3. The background on this is that Wolf 7
Creek had discharges to, what I'll call -- I think 8
it's a Coffey County Lake -- I'll just call it the 9
Wolf Creek Lake. So, they discharged tritium into the 10 lake, and then, the intake structure takes suction 11 from that lake and brings that radioactive tritium 12 back into the plant. And Wolf Creek used that lake 13 water in their fire tanks.
14 And as you would expect, they run fire 15 drills. The fire team will come out and use water 16 from those fire tanks and spray it around the site in 17 a drill. And the inspector said, well, you know, 18 you're spraying tritium around here.
19 So, we did an evaluation and we worked 20 with our Office of General Counsel, and we put out 21 this Regulatory Issue Summary 2008-3 that, basically, 22 said that, if you have properly discharged radioactive 23 tritium, and subsequently, returned that liquid 24 effluent, you do not need to double-count it as a new 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
62 effluent discharge, but you do need to take a look and 1
see if, as a result of a new activity, such as 2
spraying water around, is there a new, significant 3
exposure pathway? And if there is, then you need to 4
include it in your dose assessments.
5 And we do not expect a thorough, high-6 level, detailed calculation. You can use a bounding 7
assessment because we know in the first place that 8
you're spraying water around that, if somebody were to 9
drink it, it would get 4 millirem a year. So, we 10 understand that the risk of there being a new, 11 significant exposure pathway is pretty minimal. And 12 so, you can use a bounding assessment.
13 Next slide, please.
14 Okay. So, Ron, how would you like to 15 handle this? Would you like to take a break now or 16 would you like to go ahead and discuss this? Or would 17 you rather just have a roundtable discussion?
18 CHAIR BALLINGER: I guess I would ask, is 19 there a discussion that's going to take place related 20 to the public comments? This is the only slide that 21 says 31 public comments, et cetera, et cetera. Is 22 there a significant amount of discussion that's going 23 to take place here? If that's true, then we should 24 probably take a break. If it's going to take very 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
63 little time, then this is the last slide, right?
1 MR. GARRY: Yes. Yes.
2 CHAIR BALLINGER: So, what's your opinion?
3 MR. GARRY: Well, I think we've mostly 4
discussed the public comments that we've already gone 5
through to a certain extent. We have the time. I'm 6
happy to go through all of the public comments in 7
detail or we can go straight to ACRS discussion.
8 CHAIR BALLINGER: I guess 16 of 31 9
comments were minor. That means that the rest of them 10 were not minor. I think maybe it's probably best, so 11 that we don't just tax people's ability to sit here, 12 I would suggest that we take a 15-minute break and 13 come back at -- what time is it? 10:55. So, 10 14 minutes after the hour. So, we will recess until 15 11:10.
16 (Whereupon, at 10:53 a.m., the foregoing 17 matter went off the record and went back on the record 18 at 11:10 a.m.)
19 CHAIR BALLINGER: Okay. It is 11:10. So, 20 we're back in session.
21 So, can we get the presentation back up on 22 the screen?
23 MR. GARRY: Okay. Thanks, Mike.
24 How would you like to do this, Ron? Would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
64 you like me to go through each of the slides?
1 CHAIR BALLINGER: At your discretion. I 2
would think we would want to focus on any public 3
comments that were significant and how they were 4
resolved.
5 MR. GARRY: Okay. That's fine. I 6
wouldn't say they're significant. I'd say they're 7
more than minor. So, let's go through them.
8 CHAIR BALLINGER: Okay.
9 MR. GARRY: Okay. The Public Comment 4.1, 10 this individual's comment was: "When evaluating new, 11 significant exposure pathways" -- and this is during 12 decommissioning -- "given that the effluent doses are 13 ever decreasing, what is the words in Reg Guide `total 14 dose reference value' to be used in determining if 15 there is a new, significant exposure pathway?"
16 Okay. Some of these comments took a 17 little more explanation. So, we started by saying 18 that the common exposure pathways, and the primary 19 ones, if you want to consider that, are the 20 inhalation, breathing, eating, and direct radiation, 21 as described in Reg Guide 1.109.
22 Reg Guide 1.109 was written back in 1974, 23 I think, and revised in 1979. And it gave all the 24 mathematical equations on how to calculate the doses 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
65 from each of the radionuclides through each of the 1
primary or common exposure pathways.
2 Within the exposure pathway, there's 3
different routes of exposure. So, for example, under 4
ingestion, you could be ingesting water, fish, meat, 5
or vegetables. So, there are equations on how to 6
calculate each of these.
7 In addition, a site may have unique 8
specific exposure pathways, such as if there was a 9
local farmer who was eating his goat meat or chicken 10 meat, that might need to be evaluated. The whole 11 criteria here in the first place was, basically, under 12 your land use census, to evaluate the exposure 13 pathways, and if you find something, for lack of a 14 better word, important, then you should include it.
15 And so, we've given a criteria of 10 percent of 16 Appendix I is a criteria, which it's acceptable value 17 to see if there's a new, significant exposure pathway.
18 Now significance is relative. It's 19 significant with respect to the ALARA criteria. It's 20 not significant with respect to a dose limit. So, 21 that's how we resolved that comment.
22 Next slide.
23 Solid waste reporting.
- Again, we 24 discussed this during the presentation, but the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
66 licensees wanted us to ask them to report the solid 1
waste disposed, not the waste shipped. And it's very 2
clear that standard Tech Specs require reporting of 3
the solid waste released from the plant, not the waste 4
disposed. Previous versions of the Reg Guide said the 5
same thing, that you need to report the waste shipped.
6 And we note that DOE already tracks the solid waste 7
disposed in the licensed waste disposal sites. So, 8
really, there was no change needed to the Reg Guide 9
because it was correct in the first place. We just 10 didn't meet the objectives of the licensee to change 11 the reporting requirement.
12 Next slide.
13 Waste classification. We talked about 14 that as well. We removed the reporting of waste 15 classification because it was pretty much immaterial 16 anymore, because the waste is primarily being shipped 17 for waste processing. So, we accepted that comment 18 and removed the reporting of waste classification.
19 Next slide.
20 Iodine sampling. We talked about that.
21 Again, the comment was to give more detail on the 22 iodine-131 sampling frequency, what LLD should be 23 used, which receptor age group. Should it include 24 ingestion of fish? And how is it different than 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
67 calculating doses from effluents based on projected 1
31-day doses?
2 And we clarified it by saying that, if the 3
calculated dose is more than 1 millirem -- and then, 4
we had to go into detail -- to a person in the most 5
sensitive age group, then perform environmental 6
sampling analysis twice monthly with a low limit of 7
detection of 1 picocurie per liter, which, basically, 8
means they need to do the resin column analysis, but 9
that's only if the calculated dose is more than 1 10 millirem per year. If it's not, then sample and 11 analyze monthly using a gamma spect analysis with a 12 higher LLD. So, I think that will answer the public 13 comment.
14 Next slide.
15 Okay. There was a comment -- and this was 16 kind of arbitrary or semantics -- they wanted the term 17 "release and discharged" reversed. They wanted the 18 release to be to the offsite environment and a 19 discharge to be onsite. But we did not accept that 20 comment. We note that the terms are arbitrary. We 21 wanted to remain consistent with the previous revision 22 of the Reg Guide, in that we're going to call it 23 discharge is a effluent discharge to the offsite area, 24 and an effluent release is a release from the plant 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
68 system structures and components to the onsite area.
1 MEMBER HALNON: Hey, Steve, this is Greg.
2 I got a little bit confused on definitions 3
for onsite and offsite. Is it consistent through the 4
Reg Guides? Does this change any of the definitions 5
for onsite/offsite?
6 MR. GARRY: Not that I'm aware of.
7 MEMBER HALNON: Okay. It may have just 8
been me, but I'll go back and look at it again. But 9
there's a couple of places that use onsite and 10 offsite, and it seemed like it wasn't consistent, but 11 I may have read it wrong. Just check out line 997 and 12 2571 and make sure that you're satisfied it's 13 consistent.
14 MR. GARRY: Okay. Give me those numbers 15 again?
16 MEMBER HALNON: I think it's 997 and 2571, 17 or thereabouts.
18 MR. GARRY: Okay. Great.
19 MEMBER HALNON: How's that?
20 MR. GARRY: All right.
21 MEMBER HALNON: It's as precise as I can 22 get.
23 MR. GARRY: That's good. Thanks.
24 Okay. Next slide.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
69 Okay. This is a public comment on 1
licensed versus unlicensed radioactive material. The 2
commenter said that, look, we're not doing it the way 3
you really describe it. We're doing doses -- we're 4
not calculating dose from prior year effluents. We're 5
only calculating doses based on current year 6
effluents.
7 So, the comment "not accepted" means that 8
I did not need to revise the Reg Guide to challenge 9
him on calculating prior year doses. Because it's 10 kind of an indirect calculation, and I'll explain that 11 here now.
12 NRC and EPA dose limits apply to both 13 licensed and unlicensed material. It includes current 14 year effluents which release this year; current year 15 direct radiation, which you could give someone from 16 storage of radioactive material onsite or from BWR 17 SHINE, and prior year accumulated radioactivity in the 18 environment. So, the dose limit does apply to prior 19 year effluents.
20 Now environmental monitoring programs are 21 designed to monitor the environment, which includes 22 both current year discharges and any, let's call it, 23 leftover prior year accumulated radioactivity. And 24 the environmental monitoring program has a reporting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
70 requirement that says that, if you detect radioactive 1
material in the environment at a level that exceeds 2
reporting requirements, then you need to inform the 3
NRC. And those reporting requirements, the levels of, 4
basically, tritium in the environment are based on the 5
Appendix I dose criteria.
6 So, the bottom line is, if they have an 7
environmental monitoring program that detects tritium 8
in a lake that were to exceed 20,000 picocuries per 9
liter of tritium, if that lake is used for drinking 10 water, then they need to send us a report saying that 11 we are starting to push the Appendix I criteria of 3 12 millirem. So, 3 millirem is 3 percent of the NRC dose 13 limit and, roughly, 10 percent or 12 percent of the 14 EPA dose limit.
15 So, although the licensees are not 16 calculating dose from previous year effluents, they 17 are monitoring for it and are reporting to us if the 18 levels start approaching Appendix I. And this is 19 explained in our public comment response matrix.
20 So, what we do is we take a list of all 21 the public comments and we answer each of those 22 comments, and we put that in ADAMS and make that 23 publicly available as to how we resolved those public 24 comments. If I were to try to put too much detail in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
71 the Reg Guide, then it gets real wordy.
1 Okay. Next slide, Mike.
2 Okay. Updating chi-over-Qs and D-over-Qs.
3 There was an inconsistency in the timeframes specified 4
for updating long-term chi-over-Qs and D-over-Qs. One 5
paragraph said five years, and later it said five or 6
more years. So, they say that it should be based on 7
five or more years. We accepted that comment and 8
revised the text accordingly.
9 Okay. The reporting in Tables A-1 and A-2 10 had a carryover from, basically, back in 1975 saying:
11 report the percent of the limit. But it never said 12 what limit you're talking about. And the licensees 13 had questions saying, report of what limit? And we've 14 changed it to remove the percent of a release rate and 15 percent of a concentration, because it's, basically, 16 way, way lower than those limits, and replaced it with 17 Tables A-4 and A-5, which require reporting of the 18 percent of the dose limit of the dose criteria that 19 the limit -- the dose criteria in 10 CFR 50, Appendix 20 I, and EPA dose limits.
21 We looked at the previous effluent 22 reports, and licensees were confused. They put 23 asterisks in there, and they didn't how to calculate 24 that; how to report that. So, we intended, back in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
72 2009, to get rid of it back then. And when we added 1
the Tables A-4 and A-5, in the last few minutes or the 2
last few days, we didn't get that removed from the 3
table. So, we accepted the comment, deleted the 4
percent of the release rate, and replaced it with 5
reporting the percent of the ALARA criteria and the 6
EPA dose limits.
7 Okay. Reporting of solid waste. We've 8
talked about that. No, this is a little bit 9
different. They said there was an inconsistency.
10 There's two sections of the Reg Guide that talk about 11 reporting of solid waste, and one included the "green 12 is clean" solid waste shipments and the other one did 13 not. So, we accepted the comment. We revised Section 14 9.3 to exclude solid materials such as "green is 15 clean" waste that is accepted in Section 6 of the Reg 16 Guide.
17 I think as you know, "green is clean" 18 waste is waste that is potentially contaminated, but 19 it really can't be identified as to whether it is or 20 not at the plant because the levels are so low. So, 21 they ship it as "green is clean" to a waste processor, 22 and there's no need for them to report to us the 23 shipments of the "green is clean" waste.
24 The next slide.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
73 Solid waste descriptions. They're not 1
consistent. Again, we've generalized that to be wet 2
waste, dry waste, activated or contaminated waste, and 3
other radioactive waste.
4 The next slide.
5 Reporting of ISFSI effluents. There was, 6
in Rev. 2 of it, there was text deleted with respect 7
to the reporting of effluents from independent spent 8
fuel storage installations. And we didn't delete it.
9 There is a section of the Reg Guide on reporting ISFSI 10 effluents. It's in Section 9 of the report. So, we 11 added a footnote back at the front of the Reg Guide on 12 the objectives that we're not removing the requirement 13 for or the guidance on reporting ISFSI effluents.
14 It's that that guidance is provided in Section 9.
15 Okay. Carbon-14 doses. This was an 16 important comment. The question is, how do we report 17 carbon-14 doses? That's the basic question. And do 18 we need to include those doses in Appendix I?
19 Now, just to explain that, Appendix I is 20 an appendix that tells you how good your rad waste 21 processing systems need to be. They need to be good 22 enough that the doses from those effluents do not 23 exceed Appendix I. And the Appendix I calls out 24 specific radionuclides; namely, noble gases, iodines, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
74 particulates, and tritium. Carbon-14 is not included 1
in that. Carbon-14, as you know, is part of a global 2
warming situation. It comes out as carbon dioxide.
3 You really can't filter it. You can't absorb it.
4 You can't remove it. And therefore, a rad waste 5
processing system is not going to reduce the amount of 6
carbon-14. And it's not included in Appendix I 7
because of that.
8 However, it is included in the public dose 9
limits of EPA, 25 millirem per year, and NRC of 100 10 millirem per year. So, the licensees need to 11 calculate carbon-14, let's call it, separately and put 12 it into the total dose that could be compared to the 13 EPA and the NRC dose limits. So, that was a real nice 14 cleanup that I think we did there.
15 Okay. I guess that's the end of the slide 16 show. With that, I'll turn it back over to Mr.
17 Ballinger.
18 CHAIR BALLINGER: Thank you very much.
19 If there are not other immediate comments 20 from the members or our consultant, I think we need to 21 now get the public line open for public comments.
22 Tom, can you get the public line open?
23 MR. MOORE: So, Member Ballinger, this is 24 Scott Moore. We're doing public lines in this meeting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
75 by them calling directly into --
1 CHAIR BALLINGER: Ah.
2 MR. MOORE: And I'm not sure who is the 3
one telephone number that's called in, but if that 4
isn't a member of the public, then maybe if it's a 5
member of the staff or somebody else, then we don't 6
have any public callers.
7 CHAIR BALLINGER: Ah, so the 707 is the 8
call-in number? Yes, yes. Okay. Well, I guess we 9
waited a little bit and nobody has made a comment.
10 So, I guess there aren't any public comments. So, I 11 guess the next thing to do is to have discussion 12 amongst the members.
13 When I reviewed this document to see if we 14 should have a presentation, the risk-informing issue 15 was important, but, as it turns out, the risk-16 informing aspect was incorporated in Revision 2. And 17 as far as I know, we never wrote a letter on this 18 document, on Revision 2.
19 It doesn't change much in terms of the 20 wording in Revision 3. And so, that's my current 21 comment. I'd be curious about whether the members 22 think we should write a letter or not. So, are there 23 members that would like to make a comment? In 24 particular, should we write a letter, and if so, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
76 what's important?
1 MEMBER HALNON: Ron, this is Greg. I've 2
got a few questions for Steve. But, to answer your 3
question, I don't think that we need a letter on this, 4
but, you know, I'm pretty new on the ACRS. So, I'm 5
not sure of all the background, why we would need one.
6 It seems like it's pretty comprehensive and a good 7
job.
8 So, let me get through just a couple of my 9
questions, and then, you can clear my list of items.
10 None of them will take very long.
11 Steve, we're doing a lot of work on Part 12 53, and it's got a lot of references to ALARA. I just 13 wanted to put that in your head to make sure that, 14 somewhere around line 1728, I just made a note that it 15 drew me to think about how we're using ALARA in the 16 Part 53 regulations and whether or not this Reg Guide 17 would be part of that discussion. So, just keep that 18 in your mind. It's not anything that I think you have 19 to take any action on, but --
20 MR. GARRY: Okay.
21 MEMBER HALNON: But it does talk about 22 ALARA levels and we're using ALARA in a more distinct 23 regulatory way in Part 53.
24 The other question I had was just 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
77 editorial. And when you went through the Reg Guides 1
at the beginning -- I'm trying to find the line 2
reference -- but you just had a list of Reg Guide 3
numbers. Normally, we see the titles next to them, 4
just for your editorial completion.
5 MR. GARRY: Okay.
6 MEMBER HALNON: It's the related ones, 7
yes.
8 And then, finally, I just had a question.
9 Did you have an opportunity to tabletop this with the 10 industry working group on this?
11 MR. GARRY: No, but we did communicate 12 with NEI, and NEI did a really good job of sending it 13 out to the plants for discussion. And that's why we 14 received so many comments, is that the document was 15 well-reviewed by the industry, particularly effluent 16 group.
17 There are two groups within rad protection 18 and the industry. The occupational and, basically, 19 the public are the effluent group. We call the 20 occupational group the NEI Radiation Protection Forum 21 and their Task Force, and then, we also have what used 22 to be called RETS REMP, the Radiological Effluent 23 Technical Specifications Radiological Environmental 24 Monitoring Program group, which got renamed to be the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
78 REEW, the Radiological Effluent and Environmental 1
Working Group.
2 And so, they have task forces and this 3
document was sent to that task force and to their 4
members for their review. So, we got a really good, 5
thorough industry review of the document.
6 MEMBER HALNON: Okay, yes, and that was my 7
impression, reading the detailed comments, that 8
certainly there was some really brainiacs behind the 9
comments. So, that's good.
10 That reference I was mentioning to you, 11 it's in the background section starting at 436, line 12 436.
13 MR. GARRY: Okay.
14 MEMBER HALNON: It's just you've got five 15 Reg Guides or three Reg Guides and two NUREGs there.
16 That's it.
17 Ron, in my personal opinion, I wouldn't 18 necessarily think a letter would be written. And 19 then, I'll leave it to the other members to also make 20 the comments.
21 MEMBER MARCH-LEUBA: Hey, Ron, this is 22 Jose.
23 You guys know I
have a
different 24 philosophy. I think positive letters also have value.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
79 And in my opinion, there should be a record that the 1
ACRS looked at this guide and approves of it. It 2
doesn't need to be a 12-page letter. I mean, let's 3
write a half-a-page letter where it says: we reviewed 4
this guide. This guide is intended to calculate doses 5
to the public in place of reuses. And we lead with 6
the staff approach. That doesn't take that much to 7
do.
8 MEMBER HALNON: Yes, I agree, Jose. This 9
is Greg. I didn't even think about that, but I agree 10 with you.
11 MEMBER MARCH-LEUBA: Yes, let's get into 12 the business of writing short letters. You don't need 13 to cut and paste the whole SER or Reg Guide into a 14 letter. That's my opinion.
15 Thank you.
16 MEMBER REMPE: So, this is Joy.
17 If we are going to go along that path, I 18 guess I'd like to have the staff comment on whether 19 waiting -- because our next meeting is September --
20 does that adversely affect any of the planned schedule 21 for issuing a Reg Guide? Because having to suddenly 22 wait for a, quote, "positive letter," where somebody 23 who is not present at today's meeting might come up 24 with a last-minute non-positive comment, I don't know.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
80 I mean, can this adversely affect things, is one 1
question I have.
2 And then, I guess I just want to follow up 3
on what I mentioned about the EPA Drinking Water 4
Standard. I guess the 4 millirem per year is based on 5
a maximum contamination level of 20,000 picocuries per 6
liter for tritium. And I guess, in 1991, the EPA said 7
that if they used better ways of calculating the dose 8
calculations, they could actually have a much higher, 9
a factor three higher, concentration of tritium per 10 liter.
11 And again, I guess I've heard from some 12 folks offline here that the staff doesn't usually 13 challenge the EPA standards. But did the staff 14 discuss this and say, "Yeah, we know it's still kind 15 of low, but we're just going to go with the flow 16 because of regulatory stability."?
17 And I guess no one from industry was 18 concerned about it, but it can raise some concerns 19 later if you have some sort of event. I mean, at TMI, 20 they had to do something about the tritium 21 concentrations in the water. And was this discussed, 22 and they just decided, "Well, we hope we don't have 23 another accident," and cross our fingers and move on?
24 Or did it just not get to that level?
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
81 MR. GARRY: Well, the gist of the Reg 1
Guide is to do the measurement and do the calculation.
2 They use the dose methodologies that are described in 3
the ODCMs. And those dose methodologies are, 4
basically, based on the ICRP 2
international 5
recommendations, which establish a
method of 6
calculating the dose.
7 They are required to use the 10 CFR 20 8
organ weighting factors, but the organ weighting 9
factor for tritium for the whole body is one. So, it 10 really doesn't matter too much there.
11 Like you said, the EPA has looked at the 12 way to calculate the dose. Particularly the radiation 13 weighting factor for tritium I think is based right 14 now on an RBE at 1.7, and EPA has determined that the 15 correct value should be 1.0.
16 But, then, more recent in this literature 17 says that, well, that may not be true; that's only for 18 non-organically bound tritium. Organically bound 19 tritium has that higher dose factor. So now, you're 20 having to divide the tritium intake into two 21 components to calculate the dose each way. So, it's 22 never been challenged and never been a limitation on 23 effluents. So, we haven't really addressed that, Joy.
24 MEMBER REMPE: Okay. So, I guess, again, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
82 I thinking on factors beyond this Reg Guide or about 1
issues beyond this Reg Guide. But I guess what you're 2
trying to tell me is that there's still a lot of 3
uncertainty in this, and that's why you just left it 4
alone?
5 MR.
GARRY:
- Well, I
wouldn't say 6
uncertainty, as much as there is precedence.
7 MEMBER REMPE: Okay. And then, what about 8
if ACRS decides to write a letter? Does that impact 9
anything that you have planned in your schedule for 10 getting this out the door? Does it matter if you have 11 to wait until after September, for example?
12 And actually, right now, I don't know; I 13 guess we can add something and change our agenda, but 14 that does require making changes to our agenda, if we 15 wait until September. So, it might be October. And 16 I just am kind of trying to understand how a decision 17 to write a letter impacts things for ACRS as well as 18 the staff.
19 MR. BROWN: So, if I can just -- Joy, 20 Chris Brown.
21 Currently, I have been in contact with 22 Research. We have it scheduled right now for October, 23 but if we could move it up to September, it really 24 depends on the schedule and the members.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
83 MEMBER REMPE: Okay. So, does that impact 1
things if you guys have to wait until October, just 2
because we've decided we want to write a nice letter?
3 That's a Steven question, by the way.
4 MR. GARRY: Okay. Well, I'm not sure. I 5
think that I'm not real familiar with how the ACRS 6
impacts our schedule. I think that if you said, okay, 7
we have issues with this Reg Guide and we want to 8
discuss it at the full Committee meeting, then that 9
would definitely impact our schedule. If, on the 10 other hand, I don't hear any objections, I think we 11 would proceed. We would probably issue the Reg Guide 12 in September-October.
13 MEMBER REMPE: So, you're planning to 14 issue this Reg Guide in September, and it would be an 15 after-the-fact thing.
16 And Scott, I see, has his hand up. And 17 so, Scott, can you answer or provide comments on this 18 topic?
19 MR. MOORE: Yes. We've already published 20 the September agenda in The Federal Register. And, 21 Larry, you can correct me if I'm wrong, but we can't 22 add items to the agenda once we've published it. We 23 can take items off, but we can't add new items to it.
24 MEMBER REMPE: So, we're waiting until 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
84 October. And then, I understand what your point is, 1
Jose, but, again, this is not the full Committee 2
that's here today. And I just want to kind of bring 3
that point up, as we go around the table, because I'm 4
not hearing any concerns expressed by members about 5
what's in this Reg Guide. So, that's why I'm 6
thinking, naw, I don't think we need to do this 7
because the letter is just a nice letter, but there is 8
always some risk that somebody may think about it and 9
come up with something at the last minute. Plus, the 10 agenda for October is full.
11 MR. GARRY: Yes, I think the first 12 question is, does the Subcommittee want this to go to 13 make another presentation to the full Committee?
14 MEMBER MARCH-LEUBA: This is Jose.
15 I am not proposing that the staff make 16 another presentation. I'm proposing that we write a 17 letter during the full Committee. And the reason is 18 ACRS only speaks through letters. So, it does appear 19 ACRS is silent on this Regulatory Guide. And I think, 20 I mean, it's a matter of process or administrative, if 21 you want to call it that way. But, as of today, the 22 ACRS is silent on this.
23 MEMBER REMPE:
What about this 24 alternative, where Ron comes to full Committee and he 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
85 says, "We had the meeting and the Subcommittee said 1
they're happy with the letter," and it's just some 2
sort of a notation in how we record what happens at 3
P&P?
4 MEMBER MARCH-LEUBA: If you remember, 5
that's what I proposed last P&P, that that would be 6
one way to do it. It's probably easier to write a 7
short letter, but I will love that: that in P&P, one 8
of the items comes and says, "As required by the 9
Bylaws, which were modified recently, I asked the 10 Subcommittee present in August, and we decided not to 11 write a letter, but we approve of the guide." And 12 that becomes a position of ACRS that the staff can get 13 from the record.
14 MEMBER REMPE: So, I would accept that 15 approach rather than having a letter.
16 CHAIR BALLINGER: That was what I was 17 actually planning on doing, should we not write a 18 letter. So, I'm fine with that.
19 MEMBER MARCH-LEUBA: I'm fine either way.
20 I'm just seeing that, as of today, the ACRS is silent 21 on this Reg Guide.
22 CHAIR BALLINGER: Now that I look at the 23 list, we have pretty much, except for Vesna, we have 24 everybody.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
86 MEMBER MARCH-LEUBA: Yes, but this is 1
Subcommittee. We cannot --
2 MEMBER REMPE: And Dave Petti is not here, 3
too, right?
4 CHAIR BALLINGER: Yes, yes, you're right.
5 You're right. You're right. Sorry.
6 MEMBER SUNSERI: So, this is Matt. Yes, 7
let me weigh in on this a little bit here.
8 What we're trying to do is we're trying to 9
create policy in a Subcommittee meeting, which isn't 10 going to work. So, whatever we do here won't be 11 sanctioned. We need to have this discussion during a 12 full Committee meeting.
13 In September, we're going to have an 14 opportunity to have a retreat. This would be a good 15 topic for it. Jose keeps bringing it up about these 16 good letters. We keep turning him away. So, we need 17 to get this finalized forever or change the way we're 18 doing business, but we can't do it during a 19 subcommittee meeting.
20 So, what I'm proposing is, we just conduct 21 business like we normally conduct it now, and that we 22 decide in the future whether or not we want to write 23 these beneficial letters.
24 And I would just remind everyone, a "no 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
87 review" has been perfectly acceptable, and, in fact, 1
we don't have to weigh in on every topic. Only when 2
we have issues is it necessary for us to weigh in.
3 CHAIR BALLINGER: Good idea.
4 MEMBER BROWN: Can I make an observation, 5
Matt? This is Charlie.
6 MEMBER SUNSERI: Sure.
7 MEMBER BROWN: I mean, I agree with you we 8
don't have to do something on everything, every item 9
we review in a subcommittee. I think I've made that 10 comment before because I've faced that on a number of 11 things that I've had to review.
12 I did do a comparison of Rev. 2 to Rev. 3 13 paragraph by paragraph. That took a while, but it 14 looked to me like, other than the stuff they brought 15 up in the meeting, it was just the accident range 16 stuff, which was a whole new paragraph on how to 17 address that, which they covered pretty thoroughly.
18 It didn't seem to plow any new ground relative to 19 doses or what people can have, you know, what they're 20 allowed to do or not do. So, everything seemed to be 21 fairly stable.
22 I may have stated that wrong because I 23 couldn't actually go look at everything they ever 24 talked about. That would have taken too much time.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
88 The other change was they had a new 1
Section 8 talking about changes to effluent and 2
environmental programs, which didn't really set any 3
limits. It just said, if you're going to change 4
stuff, here's some things to think about. I may have 5
paraphrased that a little bit too much. So, this was 6
a pretty benign set of changes to me relative to going 7
through a number of the items and some the tables.
8 If we don't do a letter, we ought to get 9
this issue set up for ourselves in terms of how we 10 want to handle these more benign reviews, if that 11 makes sense. I wouldn't do anything on this. I don't 12 think any major changes were made.
13 Could the staff confirm that I'm either 14 ignorant or one way or the other?
15 MR. GARRY: Yes, this is Steve Garry.
16 I don't think there were any real 17 significant changes. I think it was an improvement, 18 and I
don't think there was anything real 19 controversial. I think we had a good public licensee 20 review of the Reg Guide, and I think we responded to 21 their comments. So, as far as I'm concerned, I agree 22 that this is not a significant change.
23 MEMBER BROWN: I mean, no dose limits, no 24 absorb limits. We fundamentally are following 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
89 existing allowances. I didn't see you all change 1
anything from that standpoint.
2 MR. GARRY: No, that would require a 3
change to the regulations.
4 MEMBER BROWN: That's what I thought. So, 5
that's why think this is, from this standpoint, that's 6
the most important thing, is: did this review fall 7
out any things where we were far too restrictive or we 8
weren't restrictive enough? And what I got out of 9
your all's discussion was that there were no changes 10 in those types of calibrations relative to 11 restrictions.
12 MR. GARRY: Yes, I agree.
13 MEMBER BROWN: Okay. Thank you.
14 That's my observation, Matt.
15 CHAIR BALLINGER: Okay. Other member 16 comments?
17 Steve Schultz, do you have a comment that 18 you would like to make?
19 MR. SCHULTZ: Hi, Ron. Can you hear me?
20 CHAIR BALLINGER: Yes.
21 MR. SCHULTZ: Yes, I would just like to 22 weigh in, since it's Subcommittee, in a sense that the 23 overall evaluation by members here has indicated, and 24 through Steve's just recent comment associated with 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
90 what the intent was here with regard to update of the 1
Reg Guide, it's pretty clear to me that there were 2
some important issues that were addressed, identified, 3
and then, addressed in the revision.
4 You mentioned, Ron, earlier that, while 5
the risk-informed approach was done in Rev. 2, not so 6
much here. But I think in terms of what has been 7
done, risk-informed, performance-based changes have 8
been made, either subtle or not so subtle. I think 9
both the staff and industry have a
better 10 understanding of what needs to be done and what 11 improvements can be made. So, with regard to 12 regulatory guidance, I think it has been done in an 13 appropriate way with regard to a risk-informed 14 approach.
15 As Steve indicated, the good interchange 16 between NEI, interchange with regard to the public 17 comments, and then, I think the staff's response to 18 the public comments was extremely thorough, their 19 evaluation of them and how they handled it in terms of 20 changes and describing what would be done and what did 21 not need to be done with regard to the guidance 22 presentation as it stands.
23 So, I thought, overall, the work has been 24 really well done here in terms of identifying 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
91 regulatory changes, the Reg Guide changes, and this 1
has been an excellent exchange between the industry 2
and the staff on this.
3
- And, Steve, I
thought excellent 4
presentation today, very well-organized, and an 5
appropriate level of detail that really communicated 6
the whole picture of what needed to be done and what 7
has been done to better move forward with this.
8 And I'd agree with Greg that going forward 9
into Part 53 is an important transition. There's, 10 again, some subtle changes, or not so subtle changes 11 that are associated with that with regard to effluent 12 releases that are going to be important to both 13 maintain and perhaps change in some ways.
14 MR. GARRY: Yes, it's a significantly 15 different design.
16 MR. SCHULTZ: Definitely, 17 CHAIR BALLINGER: Yes. Thanks.
18 Okay. Jose, is your hand being up a 19 residual or is it up?
20 MEMBER MARCH-LEUBA: It's no longer up.
21 CHAIR BALLINGER: It's no longer up?
22 Okay. Other comments from members?
23 (No response.)
24 I'm getting the gist -- well, we'll have 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
92 to take this offline. But my general impression is no 1
letter. Unless there's an objection to that, we'll 2
have that discussion.
3 But, if that's all there is, I'd like to 4
personally thank the staff for doing a really great 5
presentation. In my time on the ACRS, we hadn't had 6
a presentation related to this. So, I thought it was 7
very informative and the Reg Guide was well-written.
8 So, if there aren't any other comments, we 9
are adjourned.
10 (Whereupon, at 11:51 a.m., the meeting was 11 adjourned.)
12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
Revision of RG 1.21, Rev. 3 ACRS Presentation Measuring, Evaluating, and Reporting Radioactive Material in Liquid and Gaseous Effluents and Solid Waste Steven Garry, MS, CHP Sr. Health Physicist Radiation Protection and Consequence Branch Division of Risk Assessment Office of Nuclear Reactor Regulation August 18, 2021 1
Table of Contents
- Purpose of RG 1.21
- Effluent Regulations
- Effluent Technical Specifications
- Effluent Reports
- Effluent Trends
- Important Changes to RG 1.21, Rev. 2
- Public Comments 2
Purpose of RG 1.21
- Provide guidance on:
- Measuring, evaluating, and reporting radioactivity in liquid and gaseous effluents
- Reporting solid radioactive waste shipments
- Assessing and reporting public dose 3
Risk-Informed and Performance-Based Approach
- Principal radionuclides > 1% by dose or activity
- Selection of LLDs (NRC or MARLAP)
- Risk-informed decisionmaking on residual radioactivity
- Environmental monitoring for I-131 if needed
- MARSSIM - may use Multi-Agency Radiation Survey and Site Investigation Manual - Data Quality Objectives
- Risk-communication - Notification of local authorities of spills and leaks 4
Effluent Regulations
- 10 CFR 50.36 (differs from 10 CFR 50.36a) 5
Effluent Regulations (Contd) 6
Public Dose Limits and Criteria
- 10 CFR 20.1301 Annual Public Dose Limits
- NRC - 100 mrem TEDE
- EPA
- 25 mrem whole body and organs, except
- 75 mrem thyroid
- Tech Specs 5.5.4 - NPP Annual Dose Criteria
- Operate within 10 CFR 50, Appendix I ALARA design criteria
- Air dose - 10 mrad gamma or 20 mrad beta
- Liquids -
3 mrem total body or 10 mrem any organ
- Gases -
15 mrem iodines and particulates 7
Standard Technical Specifications NUREG-1431 - Westinghouse 8
5.5.4 Radioactive Effluent Controls Program
- Contained in ODCM
- Conforms to 10 CFR 50.36a (Tech Specs for effluents)
- Implemented by procedures
- Maintain doses to public ALARA
- Remedial actions if program limits are exceeded
Standard Technical Specifications (Contd)
- 5.5.4 Radioactive Effluent Controls Program
- a. Maintain monitoring instrumentation functional with surveillance tests and setpoints per ODCM
- b. Limit instantaneous release concentrations to 10X the 10 CFR 20, Appendix B annual average concentrations
- c. Monitor, sample, and analyze liquid and gaseous effluents
Standard Technical Specifications (Contd) 10
- 5.5.4 Radioactive Effluent Controls Program (continued)
- d. Liquid effluents - Limit public dose to 1.5 mrem/qtr or 3 mrem/yr total body
- e. Determine doses on a 31-day basis and year-to-date cumulative doses f.
Use effluent treatment systems to keep releases per 31 days not to exceed 2% of App I
Standard Technical Specifications (Contd) 11
- 5.5.4 Radioactive Effluent Controls Program (continued)
- g. Gaseous effluents - Limit instantaneous dose rates:
- for noble gases to less than
- Whole body - 500 mrem/yr (0.057 mrem/hr)
- Any organ - 1500 mrem/yr (0.17 mrem/hr)
Standard Technical Specifications (Contd) 12
- 5.5.4 Radioactive Effluent Controls Program
- h. Air doses -
Limit quarterly dose to 5 mrem gamma and 10 mrem beta dose Limit annual dose to 10 mrem gamma and 20 mrem beta dose
- i. Organ doses - from iodine, tritium, and particulate doses Limit quarterly dose to 7.5 mrem Limit annual doses to 15 mrem j.
Limit doses per EPA standards 25 mrem/yr total body and any organ (except thyroid) 75 mrem/yr thyroid
Technical Specification 5.5.1 ODCM Offsite Dose Calculation Manual 13
- An ODCM
- shall be established, implemented and maintained
- contains effluent controls and environmental monitoring program
- contains methodologies and parameters to calculate dose
- contains description of information to be included in annual effluent and environmental reports
- Submitted annually to NRC
- Posted on NRC public web site 14
Annual Reports 15
Annual Effluent Report Typical Table of Contents 16
Annual Environmental Report Typical Table of Contents 17
18
NUREG/CR-2907 Annual Effluent Summary Report 19
Noble Gas Effluent Trend - Median 20 50,000 Ci 5,000 Ci 500 Ci 50 Ci 1 Ci 1980 2018 2000 1990 2010
Liquid Effluent Trend - Median Cr-51, Fe-55, Co-58, Co-60, Nb-95, Ag-110m, Sb-124, Cs-134, Cs-137 21 1 Ci 0.1 Ci 0.01 Ci 0.001 Ci
RG 1.21 - Reason for Revision The periodic review identified a need for an update:
1.
Needed guidance and acceptable methods for calibration of accident-range containment radiation monitors and accident-range effluent monitors, 2.
Needed updated guidance on recommendations for reviewing and updating long-term, annual average /Q and D/Q values, 3.
Needed to clarify reporting requirements for low level radioactive waste (LLW) classification and shipments, 4.
Needed clarification of environmental monitoring requirements for iodine (I) -131 in drinking water 5.
Needed to provide guidance on making changes to effluent and environmental programs when transitioning during decommissioning, and, 6.
Needed to incorporates Regulatory Issue Summary 2008-03, Return/Reuse of Previously Discharged Radioactive Effluents 22
Calibration of Accident Range Monitors Post-TMI - NUREG-0737
- Item II.F.1, Additional Accident Monitoring Instrumentation
- II.F.1-1, Noble Gas Effluent Monitoring
- II.F.1-2, Iodine and Particulate Effluent Monitoring
- II.F.1-3, Containment High Range Monitoring 23
II.F.1-1 Noble Gas Effluent Monitoring
- High range noble gas monitor
- Ion chamber or GM detector, mR/hr or CPM
- Manufacturer performs initial design calibration
- Manufacturer provides the instrument response factor based on Xe-133
/
/
/
(133)
- Licensees perform a periodic calibration check with solid source to ensure proper operation 24
II.F.1-2 Iodine and Particulate Sampling & Analysis
- Real-time (live) monitoring is not practical
- Licensees develop procedures for collection and analysis of charcoal cartridges
- Iodine releases can be calculated based on partitioning (scaling) factors to noble gas 25
ITEM II.F.1-3 Containment High Range Monitor
- High Range reading is 10 million R/hr
- Output used in Core Damage Assessment Models
- Manufacturer provides the instrument response factor ~ 1E-11
/
- Licensees perform a periodic solid source calibration check in the 1 - 10 R/hr range
- Perform electronic calibration above 10 R/hr 26
RG 1.21 - Meteorological Data Updating /Qs and D/Qs
- Revises guidance on recommendations for reviewing and updating long-term, annual average /Q and D/Q values
- Previously, update /Q if non-conservative by 10%
- Meteorological staff reviewed and approved change
- RG revised, update /Q if non-conservative by 20-30%
27
LLW Shipments
- Removes reporting of waste classification
- Clarifies reporting requirements for shipping low-level radioactive waste
- Generic description of waste types
- Wet waste (resins, filters, evaporator bottoms)
- Dry waste (dry active waste)
- Activated waste (irradiated components)
- Other waste (bulk, soil, rubble) 28
Environmental Monitoring
- Clarifies environmental monitoring requirements for iodine (I) -131 in drinking water
- Perform drinking water sample analysis:
- Monthly if estimated I-131 dose is < 1 mrem/yr
- Bi-weekly if estimated I-131 dose > 1 mrem/yr 29
Leaks and Spill Remediation
- SRM-SECY-13-108, Remediation of Residual Radioactivity During Operations
- Evaluate feasibility of prompt remediation
- Prompt remediation is not a requirement 30
Decommissioning Programs
- Update ODCM to decommissioning status
- Evaluate effluent release pathways
- Update source term
- Principal radionuclides are likely to have changed
- Iodines have decayed
- Most noble gases have been released or decayed off
- Kr-85 is likely a new principal noble gas radionuclide
- Maintain Part 72 ISFSI effluent reporting 31
Transition to Decommissioning
- Update ODCM
- Old effluent release pathways are being dismantled (e.g., ventilation systems being removed)
- Evaluate new effluent release pathways
- open hatches, rollup doors, demolition
- Identify new principal radionuclides
- approaching zero releases (Iodines, noble gases)
- Particulates and alpha activity may dominate
- Re-evaluate radiation exposure pathways
- Continue normal exposure pathways (Inhalation & ingestion, and direct radiation
- No iodine-milk pathway
- Identify (bound) any new significant exposure pathways greater than 10% of App I 32
Decommissioning Programs
- Groundwater monitoring may need to be increased in support of license termination
- Maintain and update 10 CFR 50.75(g) record keeping for leaks and spills
- Decommissioning-related RGs
- RG 4.22, Decommissioning Planning During Operations
- RG 1.185, Standard Format and Content for Post-Shutdown Decommissioning Activities Report
- NUREG-1757, Consolidated Decommissioning Guidance 33
Regulatory Issue Summary 2008-03, Return/Reuse of Previously Discharged Radioactive Effluents
- Informs licensees that discharged and subsequently returned liquid effluents to do not to be double-counted as a new effluent discharge
- A new significant exposure pathway is a pathway that exceeds 10% of 10 CFR 50, App I criteria
- Bounding assessments may be used 34
Public Comments
- 31 public comments received
- 16 of 31 comments were minor editorial comments
- Detailed comment-response information will be published with the final revision of RG 1.21, Rev. 3 35
CLOSING DISCUSSION Questions and Comments 36
Acronyms 10 CFR 20 - Standards for Protection Against Radiation ALARA - As Low As Is Reasonably Achievable Appendix I to 10 CFR 50 - Design Criteria for keeping effluents ALARA C carbon-14
/Q - concentration of effluents at downwind location, (uCi/cc), per unit release rate (uCi/sec)
D/Q - Deposition rate of effluents at downwind location, (uCi/m2-hr) per unit release rate (uCi/sec)
DOE - U.S. Department of Energy RG - Regulatory Guide MARLAP - Multi-Agency Radiological Laboratory Analytical Protocols 37
Acronyms (Contd)
ISFSI - Independent Spent Fuel Storage Installation mrad - radiation (energy) absorbed dose mrem - a measure of radiation dose in tissue (roentgen equivalent man)
NPP - nuclear power plant ODCM - Offsite Dose Calculation Manual STS / TS - Standard Technical Specifications / Technical Specifications TEDE-Total Effective Dose Equivalent LLW - Low Level Waste GM detector - Geiger-Muller radiation detector RASCAL - Radiological Assessment System for Consequence Analysis 38
Backup Slides 39
Exposure Pathways Public Comment # 4.1
- Comment:
- When evaluating new significant exposure pathways, with the effluent doses ever diminishing, what is the total dose reference value to be used in determining if a new significant exposure pathway exists?
- Resolution: Comment accepted.
- The common exposure pathways are inhalation, ingestion and direct radiation, as described in RG 1.109.
- There are routes of exposure within those exposure pathways; e.g.,
ingestion of water, fish, meat, and vegetables
- A site may have a unique specific exposure pathways; e.g., such as ingestion of goat meat or chicken that may need to be evaluated
- A total dose reference value of 10% of Appendix I (consistent with RIS 2008-03) is an acceptable value for determining if a new significant exposure pathway exists 40
Solid Waste Reporting Public Comments # 5, 6, 7
- Comment:
- Licensees should report solid waste disposed, not solid waste shipped from the plant
- Resolution: Comment not accepted.
- STS require reporting of solid waste released (shipped)
- Previous versions of RG1.21 also provide guidance that the solid waste shipped from the plant should be reported
- Note: DOE tracks solid waste disposed in licensed waste disposal sites.
41
Waste Classification Public Comment # 8
- Comment:
- Waste classification (for disposal) should not be reportable.
- Resolution: Comment accepted.
- Waste cannot be classified until processed and ready for disposal.
- Formerly (1970s, 1980s), solid waste was processed on-site, and then sent for direct disposal (without off-site processing). In this case of on-site processing and direct disposal, waste classification was performed and could be reported.
- More recently,
- waste disposal fees have increased to the point where off-site waste processing is cost effective
- Off-site processing has become technologically enhanced and effective
- Therefore, licensees do not need to report waste classification.
42
I-131 Environmental Sampling Public Comments # 9 and # 21
- Comment:
- Explain I-131 sampling frequency, LLDs, receptor age group, fish ingestion, calculating dose from effluents, projecting 31-day doses
- Resolution: Comment accepted.
- If calculated dose is greater than 1 mrem/yr to a person in the most sensitive age group, perform environmental sampling and analysis twice monthly with a 1 pCi/L LLD.
- If not, sample and analyze monthly with a 15 pCi/L LLD 43
Terminology - Release vs Discharge Public Comment # 10
- Comment:
- A release should be to the off-site environment
- A discharge should be to on-site areas
- Resolution: Comment not accepted.
- Note: The terms are somewhat arbitrary
- Consistency with Rev. 2 is important
- Discharge is to off-site
- Release is to on-site 44
Licensed vs Unlicensed Material Public Comment # 12
- Comment:
- Doses from prior year effluents are not calculated
- Doses are only calculated based on current-year effluents
- Resolution: Comment not accepted.
- NRC and EPA dose limits are from licensed and unlicensed material
- Includes current-year effluents, current-year direct radiation, and prior-year accumulated radioactivity in environment
- Environmental monitoring program monitors both current-year discharges and prior-year accumulated radioactivity
- Environmental monitoring program has reporting requirements based on Appendix I criteria 45
Updating X/Qs and D/Qs Public Comment # 13
- Comment:
- Inconsistent time-frames specified for updating long-term X/Qs and D/Qs
- One paragraph says 5 years vs later paragraph says 5 or more years
- Should be based on 5 (or more) years of data
- Resolution: Comment accepted.
- Text has been revised accordingly 46
Tables A-1 and A-2 Reporting Public Comment #14
- Comment:
- Reporting % of limit
- Recommend deleting % of limit
- Resolution: Comment accepted.
- The reporting of % of release rate and % of concentration have been deleted and replaced by Tables A-4 and A-5 which require reporting % of NRC 10 CFR 50 Appendix I and EPA dose limits.
47
Reporting of Solid Waste Public Comment # 15
- Comment:
- There is inconsistency between Section 6 and Section 9 on reporting of Green-Is-Clean solid waste shipments
- Resolution: Comment accepted.
- RG section 9.3 has been revised to exclude solid materials (such as Green-Is-Clean waste) that are excepted by RG Section 6 48
Solid Waste Description Public Comment # 16
- Comment:
- Solid waste descriptions are not consistent between Section 6 and Section 9.3
- Resolution: Comment accepted.
- Waste categories have been generalized to:
- Wet radioactive waste
- Dry radioactive waste
- Activated or contaminated radioactive waste material
- Other radioactive waste 49
Reporting of ISFSI effluents Public Comment # 17
- Comment:
- Why was text deleted in the Objectives with respect to reporting 10 CFR 72.44(d) ISFSI effluent reports?
- Resolution: Comment accepted.
- Reporting of ISFSI effluents is contained in RG 1.21, Section 9.0
- A footnote has been added to the Objectives that provides a pointer to ISFSI reporting guidance in Section 9.0 50
Carbon-14 doses Public Comments # 27 and # 28
- Comment:
- Are C-14 doses to be included in the dose calculations for compliance with TS, 10 CFR 50, Appendix I?
- How are carbon-14 doses to be reported?
- Resolution: Comment accepted.
- C-14 is not included in 10 CFR 50, Appendix I ALARA criteria:
- Air dose of 10 mrad gamma and 20 mrad beta
- 15 mrem from radioactive iodine and particulates
- C-14 doses are reported separately, and are included in dose limits when demonstrating compliance with both:
- EPA 40 CFR 190 limits (25 mrem/yr) and
- NRC public dose limits (100 mrem/yr) 51