ML18264A305

NEI Comments on Draft Public Radiation Safety SDP IMC 0609 App D September 20, 2018

ML18264A305
Person / Time
Site:	Nuclear Energy Institute
Issue date:	09/20/2018
From:	Hiatt J Nuclear Energy Institute
To:	Garmon D Office of Nuclear Reactor Regulation
Garmon-Candelaria D, NRR/DRA, 415-3512
References
Download: ML18264A305 (6)

Text

JERRY W. HIATT, CHP Senior Project Manager, Radiation Safety and Environmental Protection 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.739.8171 jwh@nei.org nei.org September 20, 2018 Mr. Dave Garmon, Health Physicist Radiation Protection and Consequence Branch U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Industry Comments on NRC Draft Revision to the Public Radiation Safety Significant Determination Process Project Number: 689

Dear Mr. Garmon:

On behalf of the Nuclear Energy Institutes (NEI)1 members, we provide the attached comments on the NRC Draft Revision to the Public Radiation Safety Significant Determination Process provided to external stakeholders.

We thank you for the opportunity to provide the nuclear energy industrys comments on the Draft Revision.

If you have any questions or require additional information, please contact me.

Sincerely, Jerry W. Hiatt, CHP Attachment c: Dr. Kevin Hsueh, NRR/NRC 1

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

Summary of Industry Comments 09.20.2018 USNRC PUBLIC RADIATION SAFETY SIGNIFICANCE DETERMINATION PROCESS DRAFT REVISION FOR EXTERNAL STAKEHOLDERS, Page-Location - Proposed Text in NRC Draft Industry Comment NRC Draft p.3, If the licensee has a substantial failure to Comment: Regarding the WHITE 1st full implement the radioactive effluent designation - Is there no consideration of paragraph release program, then the finding would the actual public dose resulting from the be WHITE failure? Should not a minimal dose consequence be considered GREEN?

p.3, If the licensee has a substantial failure to Recommendation: Insert the word 2nd paragraph implement the radioactive effluent radiological as shown below release program, then the finding would be WHITE. Failure to identify a release Failure to identify a radiological release event, or assess the dose consequences event and the impact to the environment in a timely manner, consistent with ODCM requirements, could be considered a substantial failure to implement the radioactive effluent release program.

Page 3, Examples of a substantial failure to The uses of the words significant and 3rd Paragraph implement the radioactive effluent gross inability are subjective and subject release program are: to inspector interpretation.

Recommendation:

• Significant deficiency in implementing

• Significant deficiency in implementing the effluent release program as defined the effluent release program as defined in the plants Technical Specifications, in the plant's Technical Specifications, resulting in the gross inability or gross resulting in the inability or inaccuracy inaccuracy in characterizing an effluent greater than a factor of 100 in release. characterizing an effluent release vs. an equivalent NRC. Calculation

• Significant deficiency in evaluating an

• Significant deficiency in evaluating a effluent release (either planned or radiological effluent release (either unplanned) where the resulting dose planned or unplanned) where the has been grossly underestimated. calculated dose has been underestimated by a factor of 100 vs. an equivalent NRC calculation

• Significant deficiency in calibrating

• Significant deficiency in calibrating effluent monitors used to assess effluent instrumentation or monitors used to P a g e l 1 of 3

releases, resulting in a gross inability or assess radiological effluent releases, gross inaccuracy in characterizing an resulting in an inability or inaccuracy effluent release. greater than a factor of 100 vs.

equivalent NRC calculation in characterizing an effluent release.

• Failure to have any data by which to

• Failure to collect and assemble data by assess the dose to a member of the which to assess the dose to a member of public from an effluent release (i.e., no the public from a radiological effluent monitor data, no independent sample release (e.g., no monitor data, no data, no actual release sample data, independent sample data, no actual etc.) release sample data, etc.)

Overall RADIOACTIVE EFFLUENT RELEASE Comment: The Effluent Release Program Section - PROGRAM section is silent on Solid Radwaste Effluent Reporting. It must be assumed that all General findings on Solid Radwaste Effluent Industry reporting would be Green.

Comment Since the last NRC Rad Effluent Report (2010, which is 7 years late) also excluded any Solid Radwaste Effluent information, this reporting must not be of safety significance. Commercial Solid Low Level Waste disposal data is obtained and stored in the National DOE Manifest Information Management System (MIMS).Therefore, NRR should follow up on its written promise dated June 18, 2015 to revise RG 1.21 with regard to solid radioactive waste shipped. That revision should eliminate the requirement to submit Solid Radwaste shipment quantities as part of the Annual Radiological Effluent Release Report (ARERR).

In addition, review of the ARERR for types and amounts of radioactive waste disposed should be deleted from Inspection Manual 71124.08-03 b.

pp. 6 & 7 C. SDP Determination Process Comment: Industry suggests that the definition of what constitutes 1 R/hr at 3 General a. Packaging meters be added asSection V C. b.

Industry Radiation Limits Exceeded. The draft Comment revision to this section already added clarification regarding averaging radiation levels over the area of a probe. Additional text should be added on averaging 3 meter dose rates from packages.

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Such guidance is needed in this document at this time because NUREG 1608 is not slated for revision for at least 2 years.

p. 9, 2 The loss of package contents means Comment/Question: what constitutes a footnote that radioactive material has been low background area? Is it intended to be released and can be detected and near the location of the potential release or distinguished in a low background area could the package be taken to another at a distance of 30 cm from the item location where the background could be with a micro-rem per hour-type lower? e.g., inside a separate building instrument, which typically uses a 1 inch by 1 inch scintillation detector.

p. 12, It is also expected that the inspector Comment/Question: This statement 2nd paragraph follows previous guidance concerning indicates that only a single finding would be multiple findings on a single incident. issued. In other words only a Yellow and That is, a finding with a package breach not a Yellow for the breach and a which resulted in a YELLOW Green for the documentation associated determination and a CoC deficiency with the CoC. Is this correct?

which resulted in a GREEN determination would be considered to be a YELLOW finding. This is because the YELLOW signifies a more serious problem with the package breach aspect of the finding, than the CoC deficiency aspect of the finding.

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