ML21104A411

_Nrc_Nei Comments Public Rad Safety SDP (1)

ML21104A411
Person / Time
Site:	Nuclear Energy Institute
Issue date:	04/09/2021
From:	Phalen M Nuclear Energy Institute
To:	Matthew Smith Office of Nuclear Reactor Regulation
Smith M
References
Download: ML21104A411 (4)

Text

MARTIN J. PHALEN Senior Project Manager, Radiation Safety 1201 F Street, NW, Suite 1100 Washington, DC 20004 P: 202.891.8508 mjp@nei.org nei.org April 9, 2021 Mr. Micheal R. Smith Health Physicist Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

Subject:

Industry Comments on Proposed Revisions to Inspection Manual Chapter 0609 Appendix D, Public Radiation Safety Significance Determination Process, and Inspection Manual Chapter 0308 , Appendix D, Technical Basis for Public Radiation Safety Significance Determination Process Project Number: 689

Dear Mr. Smith:

On behalf of the Nuclear Energy Institutes (NEI) 1 members, we provide the following comments for the U.S. Nuclear Regulatory Commissions (NRC) consideration, regarding the proposed revisions to Inspection Manual Chapter (IMC) 0609 Appendix D, Public Radiation Safety Significance Determination Process, and IMC 0308 Attachment 3, Appendix D, Technical Basis for Public Radiation Safety Significance Determination Process. We appreciate the related public meeting that was held on February 24 and look forward to discussing our comments at the upcoming public meeting on April 21.

We support revisions to the aforementioned IMCs that strive to achieve a more risk-informed, performance-based Significance Determination Process (SDP). We appreciated the previous opportunities afforded by the NRC to provide input into the radiation safety SDPs 2. However, in the interest of full transparency and predictability of implementation, we have attached some additional comments that aim to add clarity and specificity to the proposed changes. Specifically, these comments do not change the intent of the draft documents, as written. However, the comments do provide additional context, such that implementation of the public radiation safety SDP is consistent across all NRC Regions, and for all stakeholders.

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.

2 ML18264A305

Mr. Micheal R. Smith April 9, 2021 Page 2 We look forward to future discussions on this matter. Please do not hesitate to reach out to me with any questions on the content of this letter or the attached comments.

Sincerely, Martin J. Phalen Attachment c: Kevin Hsueh, Branch Chief NRR/DRA/ARCP Steven Garry, NRR/DRA/ARCP

Attachment 1: Summary of Industry Comments In order to provide full transparency and predictability in the SDP, we provide the following feedback in the interest of providing more specificity and definition in the use of qualitative terms.

Location - NRC Proposed Text in NRC Industry Comment Draft Draft IMC 0609 App D RADIOACTIVE Comment: The Effluent Release General Industry EFFLUENT Program section is silent on Solid Comment RELEASE Radwaste Effluent Reporting.

PROGRAM If this is the intent of the NRC, recommend that the IMC explicitly state that all findings on Solid Radwaste Effluent reporting would be Green.

IMC 0609 App D, Typos re: First bullet:

Bottom of p. 12 Significant Failures establish and maintain deficiencies in Recommendation: Failure to physical protection establish and maintain of Category 2 Last paragraph:

material Failure establish and maintain Recommendation: Failure to establish and maintain IMC 0609 App D If the licensee has a Recommendation: Insert the word Section 02.01, Page 2 substantial failure to radiological as shown below implement the radioactive effluent release program, Failure to identify a radiological then the finding would be release event WHITE. Failure to identify a release event, or assess the dose consequences 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.

IMC 0609 App D Examples of a Comment: Need more specificity in Section 02.01, Page 2 substantial failure to using qualitative words. Specifically, implement the significant and gross inability are radioactive effluent subjective and subject to broad release program inspector interpretation.

are:

Recommendation:

a) Significant 1) Bring over the corresponding or deficiency in summary wording from the basis implementing the document IMC 0308 Attachment 3

Summary of Industry Comments Page 2 effluent release Appendix D on page 3; or at a program as minimum, cross-reference the reader defined in the to the basis document.

plants Technical Specifications, resulting in the gross inability or gross inaccuracy in characterizing an effluent release.

b) Significant deficiency in evaluating an effluent release (either planned or unplanned) where the resulting dose has been grossly underestimated.

c) Significant deficiency in calibrating effluent monitors used to assess effluent releases, resulting in a gross inability or gross inaccuracy in characterizing an effluent release.