NUREG-0713, Comment on DSI-11, Operating Reactor Program Oversight. NRC Should Rewrite the RP Insp Procedure W/Assessment of Exposure Reduction/Control as Focus & Utilize NUREG-0713

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Comment on DSI-11, Operating Reactor Program Oversight. NRC Should Rewrite the RP Insp Procedure W/Assessment of Exposure Reduction/Control as Focus & Utilize NUREG-0713
ML20135D865
Person / Time
Issue date: 12/02/1996
From: Noggle J
NRC
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
RTR-NUREG-0713, RTR-NUREG-713 DSI-11-00019, DSI-11-19, NUDOCS 9612100217
Download: ML20135D865 (1)


Text

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James Noggle

  1. 2 To:

TWD1.TWP5.SECY 4

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WO yLi Date:

'12/2/9610:59am

Subject:

DSI NO.11, comment DEC 2 1996

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Operating Reactor Program Oversight, Section 2, inspection:

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i have an implementation suggestion in the reactor radiation protection 9)g g

inspection / assessment area.

Issue: The RP inspection thrust is outdated and emphasizes compliance with little assessment guidelines particularly in the ALARA arena.

Suggestion: Rewrite the RP inspection procedure with assessment of exposure reduction / control as the focus.

- utilize NUREG 0713 to make exposure comparisons against the industry. (Outage information is needed to improve the comparisons)

- utilize EPRI source term reports to make comparisons against the industry. This allows a further determination of high exposure causes to be determined. (EPRI reports are not complete. The dose rate information is available directly through GE and Westinghouse and should be captured for regular publication for use by the NRC and industry) l have recently led an ALARA team inspection at Oyster Creek (the highest dose plant in the US) and utilized the above mentioned reports as analytical tools to understand why exposure performance has been high, and then to measure licensee's actions relative to their exposure challenges.

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