ML21244A321

Transcript for the Advisory Committee on Reactor Safeguards Radiation Protection & Nuclear Materials Subcommittee Meeting, August 18, 2021, Pages 1-92

ML21244A321
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Issue date:	08/18/2021
From:	Advisory Committee on Reactor Safeguards
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Brown, C, ACRS
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NRC-1633
Download: ML21244A321 (145)

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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

1 1

2 3

4 DISCLAIMER 5

6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9

10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.

16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.

20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +

7 RADIATION PROTECTION AND NUCLEAR MATERIALS 8 SUBCOMMITTEE 9 + + + + +

10 WEDNESDAY 11 AUGUST 18, 2021 12 + + + + +

13 The Subcommittee met via Video 14 Teleconference, at 9:30 a.m. EDT, Ron Ballinger, 15 Chairman, presiding.

16 COMMITTEE MEMBERS:

17 RONALD G. BALLINGER, Chair 18 VICKI BIER, Member 19 CHARLES H. BROWN, JR. Member 20 GREG HALNON, Member 21 WALTER L. KIRCHNER, Member 22 JOSE MARCH-LEUBA, Member 23 JOY L. REMPE, Member 24 MATTHEW W. SUNSERI, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 ACRS CONSULTANT:

2 STEVE SCHULTZ 3

4 DESIGNATED FEDERAL OFFICIAL:

5 CHRISTOPHER BROWN 6

7 ALSO PRESENT:

8 STEVEN GARRY, NRR 9 SCOTT MOORE, Executive Director, ACRS 10 JENNIFER WHITMAN, NRR 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.

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3 1 CONTENTS 2

3 Opening Remarks and Objectives . . . . . . . . . 4 4 Staff Opening Remarks . . . . . . . . . . . . . . 6 5 Jennifer Whitman, Acting Deputy Division 6 Director, NRR/DRA . . . . . . . . . . . . . 6 7 Reason for the Revision and Key Changes . . . . . 8 8 Steve Garry, NRR/DRA . . . . . . . . . . . 8 9 Public Comments on Key Changes . . . . . . . . . 64 10 Steve Garry, NRR/DRA . . . . . . . . . . . 64 11 Opportunity for Public Comments (No comments) . . 75 12 Committee Discussion . . . . . . . . . . . . . . 75 13 Adjourn . . . . . . . . . . . . . . . . . . . . . 92 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.

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4 1 P R O C E E D I N G S 2 9:30 a.m.

3 CHAIR BALLINGER: Good morning, everyone.

4 The meeting will now come to order.

5 This is a meeting of the Radiation 6 Protection and Nuclear Materials Subcommittee of the 7 Advisory Committee on Reactor Safeguards. I'm Ron 8 Ballinger, Chairman of today's Subcommittee meeting.

9 ACRS members present are Charles Brown, 10 Greg Halnon, Jose March-Leuba, Walt Kirchner, Joy 11 Rempe, and our consultant, Steve Schultz. If I've 12 missed anybody, please let me know, but I think I have 13 everybody.

14 During today's meeting, the Subcommittee 15 will discuss Draft Regulatory Guide DG-1377, 16 Measuring, Evaluating, and Reporting Radioactive 17 Material in Liquid and Gaseous Effluents and Solid 18 Waste, Revision 3, which is Revision 3 of Regulatory 19 Guide 1.21. The Subcommittee will hear presentations 20 by and hold discussions with the NRC staff from NRR 21 and other interested persons regarding this matter.

22 The rules for participation in all ACRS 23 meetings, including today's, were announced in The 24 Federal Register on June 13th, 2019.

25 The ACRS section of the U.S. NRC public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 website provides our Charter, Bylaws, agendas, letter 2 reports, and full transcripts of all full and 3 subcommittee meetings, including slides presented 4 there.

5 The meeting notice and agenda for this 6 meeting were posted there. We have received no 7 written statements or requests to make an oral 8 statement from the public.

9 The Subcommittee will gather information, 10 analyze relevant issues and facts, and formulate 11 proposed positions and actions, as appropriate, for 12 deliberation by the full Committee.

13 The rules for participation in today's 14 meeting have been announced as part of the notice of 15 this meeting previously published in The Federal 16 Register.

17 A transcript of the meeting is being kept 18 and will be made available, as stated in The Federal 19 Register notice.

20 Due to the COVID pandemic, today's meeting 21 is being held over Microsoft Teams for ACRS and the 22 NRC staff. There is also an MS Teams telephone bridge 23 line allowing participation of the public.

24 When addressing the Subcommittee, the 25 participants should, first, identify themselves and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 speak with sufficient clarity and volume, so that they 2 may be readily heard. When not speaking, we request 3 that participants mute your computer microphone or 4 phone.

5 We will now proceed with the meeting, and 6 I would like to start by calling on -- let's see, 7 Jennifer Whitman is, I hope, here.

8 MS. WHITMAN: Yes.

9 CHAIR BALLINGER: Jennifer, are you here?

10 MS. WHITMAN: I am here.

11 Good morning, Mr. Chairman and Members of 12 the ACRS.

13 Can you not hear me?

14 CHAIR BALLINGER: Jennifer, are you here?

15 MS. WHITMAN: I am here.

16 MR. BROWN: I'm going to call Ron.

17 CHAIR BALLINGER: Yes, she is.

18 MS. WHITMAN: All right. Can you hear 19 now?

20 CHAIR BALLINGER: I'm going to call on 21 Jennifer Whitman, Acting Deputy Division Director, 22 NRR/DRA, for opening remarks.

23 So, Jennifer, the floor is yours.

24 MS. WHITMAN: Okay. Can everybody hear me 25 now?

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7 1 MR. ROCHE-RIVERA: Yes, we can.

2 MS. WHITMAN: All right. So, good 3 morning, Chairman and Members of the ACRS. I'm 4 Jennifer Whitman, the Acting --

5 CHAIR BALLINGER: Hello. Yes.

6 MS. WHITMAN: -- Deputy Director of the 7 Division of Risk Assessment in NRR. I want to thank 8 you all for allowing us to present to you today the 9 changes we've proposed as Revision 3 to Reg Guide 10 1.21, Measuring, Evaluating, and Reporting Radioactive 11 Material in Liquid and Gaseous Effluents and Solid 12 Waste.

13 The Division of Risk Assessment has the 14 technical lead for the Agency in the areas of 15 radiation protection and radioactive consequence 16 analysis. Our staff develops and updates guidance 17 documents, performs technical reviews of licensing 18 applications, and oversees the implementation of the 19 reactor oversight process in the radiation safety 20 areas. DRA staff provides guidance and support to our 21 regional inspection staff in addressing complex 22 radiation safety technical and policy issues.

23 And Reg Guide 1.21 was last updated nearly 24 12 years ago, and our staff identified a need to bring 25 our guidance up-to-date with current standards and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 practices. So, today, you'll hear from the staff how 2 the updates to the Reg Guide provide detailed guidance 3 on how to meet NRC radioactive effluent control 4 program requirements and how we addressed the public 5 comments that were received on the draft when we 6 published it for public comment.

7 Now, I'll introduce the technical lead for 8 this Reg Guide revision, Steve Garry. He's a Senior 9 HP in DRA in NRR and has been with the NRC since 2006.

10 He has more than 25 years of experience in HP work, 11 including work at several nuclear power plants. And 12 while Steve was the lead for this project, I want to 13 note and thank the many other HPs in NRR, NMSS, 14 Research, and the Regions that have supported this Reg 15 Guide update.

16 We're looking forward to answering any of 17 your questions that you may have. And with that, I 18 will turn it over to Steve.

19 MR. GARRY: Okay. Thank you, Jennifer.

20 Yes, welcome, everyone, and thank you for 21 the opportunity to kind of showcase our radioactive 22 effluent and environmental monitoring programs.

23 As Jennifer said, this is Revision of Reg 24 Guide 1.21. This will be Revision 3. Revision 2 was 25 issued in 2009.

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9 1 And with that, we'll go to the next slide, 2 Mike.

3 Okay. So, what we're going to talk about 4 today, we're going to talk about the purpose of Reg 5 Guide 1.21. We're going to review the effluent 6 regulations, the effluent Tech Specs, the effluent 7 reports that are submitted by the licensees, the 8 analysis of those reports generated into effluent 9 trends, and then, we're going to discuss important 10 changes to the Reg Guide. And then, we're going to 11 discuss the resolution of public comments, as time 12 permits.

13 Next slide.

14 Okay. So, the purpose of Reg Guide 1.21 15 is, as the title says, measuring, which means that the 16 plant has the requirements to measure the radioactive 17 effluents, to evaluate the impact of those effluents, 18 and to report the amount of radioactivity that's 19 discharged in liquid and gaseous effluents.

20 In addition, we're going to discuss the 21 reporting of solid rad waste shipments, and then, 22 finally, we're going to discuss the assessment and 23 reporting of public dose as a result of the release of 24 those effluents.

25 Next slide.

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10 1 Okay. We use a risk-informed, 2 performance-based approach in this. We started that 3 back in 2009. The regulations talk about principal 4 radionuclides. And in 2009, those principal 5 radionuclides were identified as those radionuclides 6 that contribute more than 1 percent of the dose or 1 7 percent of the total activity released.

8 We offer the aspect that the licensees can 9 select their lower limits of detection. And there are 10 acronyms at the end of this slide, if anyone would 11 like those, or please feel free to speak up and I will 12 explain any acronym. LLD is the lower limit of 13 detection; in other words, how sensitive the 14 instruments are to be able to measure the 15 radioactivity.

16 And there's, basically, two criteria for 17 that. There's the original LLDs that the NRC issued 18 back 30 years ago, all of the more updated MARLAP 19 system of determining lower limits of detection. And 20 briefly, MARLAP is the Multi-Agency Radiation 21 Laboratory Accreditation Protocols, which basically 22 originate or use the concept of a data quality 23 objective. In other words, what are you trying to do 24 with this measurement? And based on what you're 25 trying to do with it, that kind of drives how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 sensitive your instruments need to be to achieve that 2 objective.

3 We incorporate the risk-informed 4 decisionmaking on residual radioactivity. And 5 basically, what we're saying there is that if there's 6 a leak or a spill or some residual radioactivity on 7 the site, that the licensee should do an evaluation of 8 the risk involved with cleaning up that residual 9 activity.

10 CHAIR BALLINGER: This is Ron Ballinger.

11 I'm sorry, I was "Lenovo'ed" originally with my 12 computer.

13 But, in looking at this, is there any risk 14 of what I would call creeping sensitivity, where 15 instrumentation sensitivity becomes better with time?

16 And is there any risk of the licensees being racheted 17 by this?

18 MR. GARRY: No, because they're allowed to 19 use -- you know, a Reg Guide is one acceptable method.

20 Other methods are acceptable, but a Reg Guide provides 21 acceptable methods. And if licensees want to use a 22 different method, they're allowed to do that. They 23 just need to have a good technical basis for that.

24 And we're actually offering more 25 flexibility by offering the selection of the LLDs NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 based on more current guidance given in MARLAP.

2 CHAIR BALLINGER: Thank you 3 MEMBER KIRCHNER: Ron, this is Walt 4 Kirchner.

5 CHAIR BALLINGER: Yes?

6 MEMBER KIRCHNER: I was going to ask the 7 same question, too. And I'll construct an analogy.

8 About a decade or so ago, I was much involved in the 9 Great Lakes and water quality standards. And what 10 evolved over time was that the capability of the 11 measuring technology just increased and increased.

12 That was all for the better. But it did result, Ron, 13 in just what you're proposing or supposing. And that 14 is that one started getting at detection levels that 15 set limits for releases that were well below what 16 naturally occurred in the Great Lakes, notwithstanding 17 the pollutants, and so on and so forth. And then, you 18 had -- how should I say? -- a situation where the 19 technology was driving the regulatory system to 20 standards that were, basically, in some cases perhaps 21 not achievable.

22 CHAIR BALLINGER: Yes, I think I would 23 agree with that. I mean, I think Joy would probably 24 chime in, because I think something similar to that is 25 happening at Fukushima.

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13 1 MS. WHITMAN: This is Jennifer Whitman.

2 I'd ask that we let Steve continue because 3 he does discuss the regulations, and we're aren't 4 changing the regulations and that's where the limits 5 are derived from. And so, if we let him continue 6 through, I think you'll see that, with no changes to 7 the regulations, I don't think what you're talking 8 about will be a concern.

9 MEMBER REMPE: So, this is Joy, since my 10 name was mentioned.

11 As you go forward, when I looked at the 12 Reg Guide and slides, there's very little discussion 13 about the amount of tritium that's released, the 14 limits on that. And if you could discuss a little bit 15 about how you selected your limits for the amount of 16 tritium in releasable water, I would appreciate it.

17 And also, if you considered what is being done 18 internationally with other plants, because that is the 19 biggest concern with what Ron is mentioning, with the 20 water that's been released and how the Japanese are 21 dealing with it. The other isotopes they've taken 22 care of. Okay?

23 CHAIR BALLINGER: In deference to the 24 staff, they actually in the Reg Guide use tritium as 25 an example of activity versus does, which is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 important.

2 MEMBER REMPE: Right.

3 MR. GARRY: Yes, tritium is actually 4 fairly easy to detect. You can use liquid 5 scintillation counting and get down to something like 6 500 picocuries per liter pretty easily. With advanced 7 techniques, you can go lower. But we don't drive them 8 lower and lower on that. We have an LLD that was 9 established back in the late 1970s of 10,000 and 10 20,000 and 30,000 picocuries per liter. You know, the 11 EPA Drinking Water Standard is 20,000 picocuries per 12 liter.

13 MEMBER REMPE: That's the point I wanted 14 to get to. So, I'm glad you mentioned that, because 15 EPA actually has a very limiting value. And they 16 thought about that they could raise it, is my 17 understanding, and they left it at the 20,000 18 picocuries per liter. And I just am wondering how the 19 NRC compares to what EPA is requiring, and was that 20 thought about much in your preparation of this Reg 21 Guide update?

22 MR. GARRY: No, because we stayed with the 23 standard that was set back in the late '70s, which is 24 20,000 and 30,000 picocuries per liter for 25 environmental monitoring.

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15 1 MEMBER REMPE: Okay. Because, yes, the 2 EPA actually acknowledged that they could have gone 3 higher and they left at 20,000. But I just was 4 curious if you thought about increasing things at all, 5 but I guess you didn't?

6 MR. GARRY: Well, we're trying to provide 7 stability as much as we can without making the 8 licensees rachet back and forth to different values, 9 and so forth. And the 20,000 is, obviously, the EPA 10 Drinking Water Standard. So, my thought is that there 11 really is no need to drive that --

12 MEMBER REMPE: Oh, we definitely don't 13 want to go lower, but, I mean, you could have gone a 14 little higher, I guess is the question, but I guess 15 you didn't think about doing that at all?

16 MR. GARRY: No, because we wanted 17 stability, and there was no need. It's readily 18 detectable at 20 and 30 thousand picocuries per liter.

19 So, we don't need to drive it higher to save any costs 20 by the licensees.

21 MEMBER REMPE: Thank you.

22 MR. GARRY: Okay. So, moving on, then, we 23 adopted the MARSSIM, which is the federal agency 24 Multi-Agency Radiation Survey and Site Investigation 25 Manual data quality objectives. So, we're allowing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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16 1 licensee flexibility to go review the other federal 2 agencies' standards and reevaluate the program, if 3 they wanted to, based on data quality objectives.

4 And then, with tritium leaks and spills, 5 there's always an issue of risk communication and 6 notification of local authorities of spills and leaks.

7 So, that's another aspect of our risk-informed, where, 8 basically, some jurisdictions want to know a lot about 9 leaks and spills. Some jurisdictions don't need as 10 much information. So, risk-informed allows them to 11 choose when they need to be making those 12 communications.

13 Next slide, please.

14 Okay. So, I want to briefly review our 15 regulations. We have quite detailed regulations.

16 Some confusion has been generated in the fact that 17 there are two separate sections of the regulations.

18 There's 10 CFR 50.36, and for lack of a better word, 19 I'll call those general Tech Specs that apply to the 20 operation of the plant with limiting conditions of 21 operation, and so forth. And that's what people 22 commonly refer to as Tech Specs.

23 But, after that section, 10 CFR 50.36, at 24 the very end of that section, there's a new section, 25 another section. And that section is commonly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 confused, but that's because it's labeled 10 CFR 2 50.36a, where that "a" is not in parentheses. It's 3 part of the title. And so, that's where the 4 regulations requiring Tech Specs on effluents 5 originate.

6 And what it says there in 10 CFR 50.36a(a) 7 is, basically, the objective to keep the releases to 8 unrestricted areas as low as reasonably achievable.

9 In order to do that, each licensee and each applicant 10 for a design certification or a manufacturing license 11 has to include Tech Specs that, in addition to 12 complying with the applicable provisions the dose 13 limits -- and 10 CFR 20 is the standards for 14 protection against radiation. Paragraph 1301 of this 15 chapter is the dose lots. So, bottom line is, there 16 is a regulation saying, licensees, you need Tech Specs 17 on effluents, and they need to be incorporated in Tech 18 Specs as part of the general Tech Specs.

19 Next slide, please.

20 So, what 10 CFR 50.36a, then, also says, 21 that not only do you have to have Tech Specs, you have 22 to submit a report to the Commission annually. You 23 have to tell us the quantity of each of the principal 24 radionuclides released to unrestricted areas in liquid 25 and gaseous effluents in a previous 12 months. So, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 there's a transparency aspect here where the licensees 2 have to submit a report to the NRC. And I'll show you 3 what we do with those reports.

4 Next slide, please.

5 Okay. So, let's talk about what the 6 public dose limits are now. Now this is a very 7 sensitive issue because this is release of radioactive 8 material into the unrestricted area. And the 9 consequences of those releases, then, we have a series 10 of limits to control the dose to members of the 11 public. The NRC establishes a highest level of 100 12 millirem of total effective dose equivalent, and that 13 applies to not only nuclear power plants, but to 14 materials licensees as well. So, that's a general 15 high-level number that applies to any NRC licensee.

16 In addition to that, EPA has regulations.

17 And in 40 CFR 190, the EPA established a limit of 25 18 millirem to the whole body and organs, with the 19 exception for thyroid of 75 millirem. And again, 20 that's the EPA high-level value.

21 Okay. So, under the regulations, the 22 licensees needed to propose, and we accepted, Tech 23 Specs. In Tech Spec 5.5.4 in the administrative 24 section of the Tech Specs, we set the nuclear power 25 plant annual dose criteria. And what that criteria NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 is, now that's not a limit, but that's a criteria. We 2 expect them to operate within these criteria. If they 3 don't, then we have exceptions in what they need to 4 do. But they need to operate within the 10 CFR 50, 5 Appendix I, ALARA design criteria.

6 Now, just briefly, 10 CFR 50, Appendix I, 7 is a requirement by the NRC that, when they propose a 8 new nuclear plant, they have to add enough rad waste 9 processing systems to keep the doses to the members of 10 the public as low as reasonably achievable. So, they 11 then specify specific limits.

12 So, for air dose, which would be the dose 13 at the site boundary, even if there's not a person 14 there, it's an air dose limit of 10 millirem gamma or 15 20 millirem beta. And then, to locations where there 16 are actually people, the liquid effluents can result 17 in no more than 3 millirem total body dose or 10 18 millirem to any organ. And for gases, radioactive 19 gases, there's a specific limit on iodines and 20 particulates of 15 millirem. So, those are, call them 21 "the operating criteria" that the plants need to meet 22 in order to be deemed the effluents are as low as 23 reasonably achievable.

24 Next slide.

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20 1 lay out that licensees are required to have a 2 radioactive effluent controls program. And it 3 specifies that that program should be put into an 4 offsite dose calculation manual. In other words, you 5 can consider that a licensee procedure that says:

6 Here's how we will control effluents. Here's how we 7 will measure them. Here's how we will report them.

8 And this effluent controls program needs 9 to conform to the regulations. 10 CFR 50.35a has to 10 be implemented by procedures, maintain doses to the 11 public as low as reasonably achievable, and if the 12 program limits are exceeded, to take specific remedial 13 actions to get back into compliance with -- not 14 compliance -- conformance with Appendix I.

15 Next slide, please.

16 Okay. So, let's take a look at -- and 17 this is all laid out in Tech Specs. Now I'm taking 18 these slides from NUREG-1431, which are 10 standard 19 Tech Specs for a Westinghouse-designed plant. So, the 20 Tech Specs require, 554, maintain monitoring 21 instrumentation. Okay, so the plants have 22 requirements to keep their equipment working and to 23 perform surveillance tests, and use set points that 24 are calculated in accordance with the ODCM. But this 25 program will limit the instantaneous release of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 radioactive effluents to concentrations within 10 2 times the 10 CFR 20, Appendix B, annual average 3 concentrations. So, they are allowed a short-term 4 higher-level release than the annual average, but only 5 for a short period of time. And that's based on the 6 10 times Appendix B.

7 There was a change to the NRC regulation 8 10 CFR 20 back in 1991 where the old public dose 9 limits were 500 millirem. That got lowered to 100 10 millirem. And as a result, we had to change Tech 11 Specs and we maintained the same level of effluent 12 control as was there previously, in spite of the fact 13 that the dose limits had been reduced; that the 14 program needs to monitor, sample, and analyze liquid 15 and gaseous effluents, as you would expect.

16 Next slide.

17 The controls program continued here, that 18 the liquid effluents, they need to limit the public 19 dose to 1.5 millirem per quarter or 3 millirem per 20 year. The idea being there that, if you have a 21 release rate early in the year, you need to get back 22 into an averaging system to where you're going to end 23 up at the end of the year with no more than 3 millirem 24 to the total body.

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22 1 track of the doses on a 31-day basis. And every 2 month, they have to calculate the doses from their 3 effluent releases and make sure they're in compliance 4 and cumulate those doses, so that, as they go, we know 5 where they are as they approach the end of the year.

6 And on a monthly basis, they need to use their rad 7 waste effluent treatment systems to keep the releases 8 every 31 days, not to exceed more than 2 percent of 9 Appendix I. So, we're establishing Tech Specs that 10 are more and more stringent and more and more 11 guaranteeing that they're going to be able to meet the 12 design criteria at the end of the year.

13 Next slide, please.

14 Okay. For gaseous effluents, to limit the 15 instantaneous dose rate, so if they're releasing the 16 waste gas decay tank noble gases, the instantaneous 17 dose rate can be no more than 500 millirem per year 18 or, in hourly terms, .057 millirem per hour. And for 19 iodines and particulates, the releases can be no more 20 -- iodine and tritium and particulates, the releases 21 can be no more dose rate than .17 millirem per hour.

22 Next slide, please.

23 So, we have the air doses then, the 5 24 millirem gamma and 10 millirem beta. That's the 25 quarterly limits. The annual limits are the ones we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 talked about earlier from Appendix I, 10 millirem 2 gamma, 20 millirem beta.

3 The organ doses, the quarterly doses are 4 limited to 7.5 millirem, the annual doses to 15 5 millirem.

6 And I think just to comment, back in the 7 early days in the late '70s, or whatever you consider 8 early days, there was a lot of concern about the 9 release of iodine. And so, they were tracking here 10 the quarterly and annual doses to make sure that no 11 member of the public exceeded the ALARA criteria. And 12 then, again, the Tech Specs require the compliance 13 with the EPA dose limits, which rarely get challenged 14 because the Appendix I limits are much more 15 restrictive.

16 Next slide, please.

17 Okay. And ODCM, the Offsite Dose 18 Calculation Manual, has to be established, 19 implemented, and maintained. Now these ODCMs are 20 pretty comprehensive. They're typically 2 to 5 21 hundred pages procedure, instructing the plant staff 22 how to measure and do these dose calculations, and not 23 only on effluent controls, but it also establishes the 24 environmental monitoring program. So, they calculate 25 the potential impact, based on the effluent release NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 rates, and then, they go out in the environment and 2 they take samples and they measure the radioactive 3 effluents that could exist out in the environment.

4 The ODCM has all these equations, methodologies, 5 parameters to calculate the dose, and it contains a 6 description of what information needs to be reported 7 to the NRC in the annual effluent and environmental 8 reports.

9 Next slide, please.

10 Okay. So, once the licensees complete an 11 annual cycle, they're required to submit these annual 12 effluent and environmental reports. And they submit 13 them annually to the NRC. The environmental report 14 has to be reported to the NRC by May 15th, and the 15 effluent report has to be reported to prior to May 16 1st.

17 Now what we do with these reports is we 18 make them all publicly available. So, they're posted 19 on our NRC public website. And here's an excerpt 20 below. The excerpt below shows each plant with a 21 hyperlink to their reports. So, for example, ANO-1 22 and -2, you could click on that link, and it will take 23 you to their reports.

24 So, next slide, please.

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25 1 be the ANO annual reports. And you can see, for each 2 calendar year, you can see what they released and what 3 the doses from those releases are by clicking on these 4 hyperlinks.

5 And similarly, the environmental reports.

6 If you want to see the sampling and the analysis and 7 the concentrations that are being measured in the 8 environment, you can click on whichever year you'd 9 like, whichever plant, and you can see this data.

10 Next slide, please.

11 So, here's a typical effluent report. It 12 includes an introduction, supplemental information, 13 but it has a section on gaseous effluents, liquid 14 effluents, and solid waste. And it's got a section on 15 doses, the radiological impact to man. And it's got 16 a compilation of the meteorological data. Not all of 17 them have that, but that's available in the ANO 18 report.

19 Next slide, please.

20 And here's the annual environmental 21 report. So, Section 3 here will cover the sampling 22 program that tells you what samples are being 23 collected. Typically, it's grass, milk, water, 24 drinking water, vegetables, direct radiation. There's 25 a whole slew, whatever they're monitoring for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 environmental program, they're describing it here.

2 Then, they analyze it and interpret the 3 trends of those results and report those. And then, 4 they put together a radiological environmental 5 monitoring program summary. And then, they report, 6 for example, some of the samples might get lost.

7 Maybe the milk cow stopped milking, the garden didn't 8 produce in the winter, whatever. If there were any 9 deviations, they explain the justification why they 10 had to deviate from the required program.

11 And then, there's the monitoring results.

12 That will give you the concentrations of each 13 radionuclide that's detected. And the Tech Specs 14 require them, the ODCM requires them to do an inter-15 laboratory comparison result and a dosimetry 16 comparison report.

17 Next slide, please.

18 And again, all these detailed reports are 19 available on our website that you can look at any 20 plant for any of the more recent years.

21 Okay. Once we get all those reports, we 22 compile a summary of all those reports in this 23 document called NUREG/CR-2907, Radioactive Effluents 24 Summary Report from Nuclear Power Plants.

25 Next slide, please.

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27 1 Okay. So, here's what's in this summary 2 report. And this is a very well-designed and very 3 explanatory discussion of what's happening. So, in 4 the introduction, we talk about the purpose and the 5 scope. We talk the source of the data is directly 6 from the plants. We talk about the limitations of the 7 data. Then, we go into a description of the data; the 8 measuring of radioactivity in effluents; the dose 9 units and limits; the radiation dose to the public, 10 and other sources. And then, we get into the detail:

11 the effluent data, the radioactive material, and 12 liquid and gaseous effluents, short-term trends, long-13 terms trends, a summary reference. And again, this is 14 all put together, essentially, as a summary report for 15 not only NRC staff, but for the public and, also, for 16 the plants to use to compare it to other plants.

17 Next slide, please.

18 So, you might ask, what has been the trend 19 of the releases of radioactive effluents over the last 20 35 or 40 years? You can see, back in 1975, that the 21 BWR gases were approximately 50,000 curies per year, 22 and the current is about -- I don't know; what is 23 that? -- it's 50 curies. And PWRs, similarly, went 24 from about 5,000 curies down to about 1 curie.

25 Now this is a phenomenal decrease in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 amount of radioactive effluents by, roughly, a factor 2 of 100 to 1,000 decrease in the amount of radioactive 3 effluents. You can see the continuing progress that 4 the plants have made in reducing their radioactive 5 effluents.

6 You may ask, what is the cause of that; 7 what happened? Well, there are basically two criteria 8 for the noble gases. First of all, fuel performance.

9 In the early days, the fuels had a lot of leakers, and 10 when a fuel leaks, it releases noble gas into the 11 reactor coolant system, and that ultimately has to be 12 degassed and ultimately released. So, there were a 13 lot of fuel leakers, so there was a lot of noble gas 14 to deal with. Those fuel pens, the fuel engineering 15 has improved dramatically, and the number of fuel 16 leakers now and the foreign material control programs, 17 and so forth, have really cleaned up the reactor 18 coolant system gases and led to a decrease.

19 A second reason is the additional, 20 especially for the BWR, the advanced off-gas systems, 21 the charcoal delay systems that hold up these gases.

22 Now some of these gases are very short-lived, like two 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> or four hours, or so forth. So, a holdup of 5 24 or 10 days will do a great deal in reducing the amount 25 of radioactivity that's released. So, a lot of credit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 goes to the plants and the plant design that have 2 added these new effluent processing systems. And 3 that's why PWRs have a waste gas decay tank, and the 4 BWRs have the charcoal delay systems. So, I just 5 wanted to acknowledge the decrease by a factor of 100 6 to 1,000 over the last 40 years.

7 Next slide, please.

8 Similarly, liquid effluents. Look what's 9 happened with the liquid effluents. They have 10 decreased by, roughly, a factor of 100 to 1,000. And 11 again, the same reasons. If the fuel is not leaking, 12 then you don't have as many particulates to deal with.

13 You still have activation products, but you don't have 14 as many fission products. So, the fuel performance 15 has led to a decrease.

16 In addition, the plants have added better 17 liquid rad waste processing systems. They've gone to 18 better resins, so that the resins will absorb these 19 particulates before they get released. And they've 20 gone to reverse-osmosis systems to, again, filter the 21 release as much as you can. And as you know, tritium 22 cannot be filtered, and it really doesn't do a lot of 23 good to hold up tritium because it's got like a 11-24 year half-life. So, nevertheless, there's been a 25 factor of 100 to 1,000 decrease as well in the liquid NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 effluents. So, the sophistication of the radiological 2 effluent monitoring and control programs at the plant 3 have really improved over the last 40 years.

4 Next slide, please.

5 CHAIR BALLINGER: This is Ron. This is 6 Ron.

7 So, the clear message here is don't fail 8 the fuel?

9 MR. GARRY: That's the No. 1 message, yes.

10 CHAIR BALLINGER: But, for comparison 11 purposes, I think -- and my memory escapes me here --

12 a nuclear power plant can only result in a dose to the 13 public which is some fraction of a number. And so, my 14 question is, for the fleet, how do the annual releases 15 compare, annual dose -- excuse me -- compare with the 16 average annual dose from background radiation to the 17 public compared to that rule limit? I think it's 18 1/10th?

19 MR. GARRY: Well, we don't have a criteria 20 as compared to background. We have a criteria as 21 compared to our most restrictive limit, which is the 22 10 CFR 50, Appendix I, criteria.

23 CHAIR BALLINGER: Yes, I understand that, 24 but I guess what I'm trying to get a feeling for is 25 the actual impact of the fleet on the annual dose that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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31 1 the public would receive in any case.

2 MR. GARRY: Okay. Well, basically, the 3 tritium doesn't cause very much dose. It takes a lot 4 of tritium to cause dose, especially when you consider 5 the fact that a lot of the tritium is released in the 6 liquid effluents to rivers or lakes. So, when it's 7 released to a river, it, basically, flows downstream 8 quite quickly and you don't get a buildup in the 9 environment. However, if they're discharging to a 10 lake, then there is a buildup of residual tritium in 11 that lake. And nevertheless, the licensees still need 12 to meet the regulatory limits on doses. And we're 13 going to discuss that in a little more detail here in 14 a few minutes.

15 CHAIR BALLINGER: Thank you.

16 MR. GARRY: Okay. So, why do we need to 17 revise Reg Guide 1.21? Well, first of all, we have a 18 process called a periodic review, where we look at the 19 existing Reg Guides that we have issued and we review 20 them and determine if there's a need for an update.

21 And in our review, periodic review of Reg Guide 1.21, 22 we identified that we needed to provide an update.

23 And there are basically six areas that were driving 24 the need for that update.

25 We, one, needed to provide guidance and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 acceptable methods for calibration of the accident 2 range containment radiation monitors and the accident 3 range effluent monitors. That guidance had been 4 contained in an old NUREG, and we wanted to bring it 5 forward to the current Reg Guide that would be a 6 little more publicized.

7 MEMBER REMPE: So, this is Joy.

8 On this first one, after what happened at 9 Fukushima, it was difficult to use the monitors 10 because there was so much release. And so, when you 11 think about your accident range effluent monitors, and 12 they did say in the Reg Guide that you had to consider 13 a core melt, do you consider what needs to be done in 14 such extreme situations? Or how do you take into 15 account the difference in isotopic content that might 16 occur and the changes because, suddenly, your 17 background's higher and to monitor additional 18 releases? Have those types of considerations been 19 considered?

20 MR. GARRY: Yes. As far as Fukushima 21 goes, you know, that, basically, was a disaster. They 22 lost electrical power. They didn't have monitored 23 effluent release paths because the buildings, 24 basically, blew up. So, the scope of that accident 25 was far in excess of a smaller accident where the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 accident range monitors would be useful, because they 2 lost electrical power; they didn't have a monitor 3 release path.

4 MEMBER REMPE: So, in your accident 5 release -- this is, again, the Reg Guide says you 6 consider a core melt accident -- what kind of 7 frequency do you have for a cutoff frequency for how 8 far down you go?

9 MR. GARRY: Well, I don't know how to 10 exactly answer that. What we have is like Three Mile 11 Island was a core melt, and in that there was a 12 release of noble gases, and those noble gases, 13 basically, bypassed containment. Basically, some of 14 the gases were absorbed in the water that was on the 15 floor. The reactor coolant drain tank overflowed to 16 the floor of the reactor building. The sump filled 17 out. They pumped the water over to the aux building.

18 They have valve leakage, and so forth, that the gas 19 came out of the water, and then, got exhausted from 20 the auxiliary building and went past the accident 21 range effluent monitors. So, that was a monitored 22 release of a core melt. And that's, basically, the 23 design of this.

24 Similarly, if there was a different type 25 of accident -- let's say a LOCA -- where you have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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34 1 double-ended pipe break, or whatever, then the later 2 is going to be released to the reactor building and 3 the radiation is going to be released to the (audio 4 interference), sitting there watching and monitoring.

5 And that happened at TMI. The TMI containment high-6 range monitor went to about 800R per hour. So, they 7 knew, basically, how severe the gas was in the reactor 8 building, and they knew that the noble gas being 9 bypassed through either the letdown system or through 10 the containment sump was monitored as well by the aux 11 building exhaust ventilation.

12 MEMBER REMPE: Now again, we're supposed 13 to be going to a risk-based regulatory regulator, and 14 I guess what I'm hearing is, well, we've looked at, 15 basically, what we saw at TMI and we think we can 16 accommodate that or design basis accidents such as the 17 LOCA.

18 MR. GARRY: Right. The General Design 19 Criteria 60 and 64, essentially, established design 20 requirements where the plant has to have this type of 21 instrumentation.

22 MEMBER HALNON: Hey, Steve, this is Greg 23 Halnon.

24 Wasn't this No. 1 the subject of some 25 industry interaction and some white findings in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 1 last, say, three or four or five years?

2 MR. GARRY: Yes. Vogtle got a white 3 finding for their containment high-range monitor 4 calibration.

5 MEMBER HALNON: Does this resolve the --

6 I guess I don't say "misunderstanding" -- but the lack 7 of clarity in the industry, so it will be clear for 8 what has to happen to present that?

9 MR. GARRY: Well, we gave a training 10 course to our NRC inspectors on how to inspect the 11 containment high-range monitor calibration. The basic 12 mistake made at Vogtle was that they changed the 13 calibration geometry. They had a misconception that 14 the monitor should be checked at 17R per hour. Now, 15 as their source decayed, they couldn't get 17R per 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. So, they mistakenly said, well, we know how to 17 get that back up to 17R per hour; we'll just slide the 18 source closer to the instrument. Well, when the plant 19 does a calibration, they're really doing a calibration 20 check, and a calibration check is, hey, is that 21 instrument working properly? That's the real 22 question.

23 So, to know if it's working properly, you 24 have to compare it to something. And you should 25 compare it to what the manufacturer told you was the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 right comparison, the right conventionally true value.

2 Well, Vogtle didn't do that. They didn't understand 3 the calibration process. And so, they slid that 4 source closer to the detector, so that they finally 5 got it to read 17R per hour, which was not the 6 objective. The objective is to see if it's operating 7 properly.

8 MEMBER HALNON: So, the guidance you have 9 here will clarify or at least prevent that from 10 happening in the future?

11 MR. GARRY: Well, it will provide them as 12 much guidance as we can as to how to get that. Now we 13 may in the future give more guidance on calibration of 14 instrumentation, but, for now, what we did is we 15 carried forward the calibration criteria that's laid 16 out in NUREG-0737 into this Reg Guide, so that it's 17 prominent information.

18 MEMBER HALNON: Okay.

19 MEMBER REMPE: Does the information 20 indicate how often the calibration has to be done and 21 that it has to be in this traceable source, and all of 22 that type of information?

23 MR. GARRY: Yes. The only time the 24 containment high-range monitors can be calibrated are 25 during outages. So, that's the periodicity of it.

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37 1 And typically, the plants are on an 18-month or a two-2 year fuel cycle. So, that's how often it's 3 calibrated.

4 Most of these containment high-range 5 monitors are very good, stable instruments. They're 6 ion chambers that perform well for a long period of 7 time. So, fortunately, the calibration check, all 8 they have to do is verify that it's still working 9 right.

10 MEMBER REMPE: And so, you have something 11 that says you've got to do it at least every two years 12 to give them that flexibility and they do have to show 13 that their source is -- I mean, we used to have to buy 14 or send back our sources to show that they were NIST 15 traceable when we were doing checks on monitors. Do 16 you guys have those kind of requirements?

17 MR. GARRY: Yes. Well, Tech Specs 18 themselves have a criteria on post-accident monitoring 19 systems, and that includes a containment high-range 20 monitor, that they need two of them and they need to 21 be recalibrated or they need to have a calibration 22 check every refueling outage.

23 MEMBER REMPE: Okay.

24 MR. GARRY: Okay. Another update we 25 wanted to give in the Reg Guide is on recommendations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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38 1 for reviewing and updating the long-term annual 2 average chi-over-Q and D-over-Q values. As we all 3 know, with climate change and so forth, the weather is 4 changing, or at least some people believe it is. So, 5 we wanted to have better guidance on updating their 6 long-term annual average chi-over-Qs and D-over-Qs.

7 So, we'll talk about that a little later.

8 There has been some confusion in the 9 industry on reporting of low-level waste, two aspects 10 of that: the classification of the waste and the 11 reporting of the shipments. So, we're going to talk 12 about that in more detail in a little bit, too.

13 We wanted to clarify environmental 14 guidance for monitoring iodine in drinking water.

15 We're going to talk about these things in more detail.

16 We need to provide guidance on making 17 changes to the effluent and monitoring environmental 18 programs when transitioning to decommissioning. We've 19 had several calls from licensees saying, hey, what do 20 we need to do with our ODCM now that we're going into 21 decommissioning? So, we wanted to give some guidance 22 on that.

23 And then, we wanted to incorporate 24 guidance from Regulatory Issue Summary 2008-3 on the 25 return and the reuse of previously discharged NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 radioactive effluents.

2 Next slide, please.

3 We're going to go into detail on some of 4 these things.

5 Okay. The calibration of the accident 6 range monitors. Post-TMI, NUREG-0737 has item II.F.1, 7 Additional Accident Monitoring Instrumentation.

8 There's three sections of it: how to monitor noble 9 gas; how to monitor iodine and particulates, and how 10 to do the containment high-range monitoring.

11 Next slide.

12 So, we carried that guidance from 13 NUREG-0737 into the Reg Guide. And basically, on the 14 high-range noble gas effluent monitor, it's typically 15 monitored with an ion chamber or GM detector which 16 read out in units of dose or count rate, MR per hour 17 or counts per minute. And we're explaining that the 18 manufacturer performs the initial design calibration.

19 The manufacturer provides the instrument response 20 factor based on xenon-133, and that the licensees, all 21 they need to do is this periodic calibration check 22 with a solid source to ensure proper operation.

23 Next slide.

24 We have iodine and particulate sampling 25 and analysis. The NUREG-0737 recognizes that real-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 time, live monitoring of iodine and particulates is 2 not practical. Therefore, licensees need to have 3 procedures for the collection and analysis of charcoal 4 cartridges.

5 Now, remember that the normal operating 6 plant never has to do iodine/particulate sampling 7 using their emergency instrumentation systems. They 8 need to have procedures on how to collect a hot sample 9 and how to analyze it; and that the iodine releases 10 during a dose assessment during the first few hours of 11 an accident can be calculated based on petitioning or 12 scaling factors to the noble gas. And we give some 13 references in there as to how to determine those 14 scaling factors.

15 Next slide, please.

16 And finally, the containment high-range 17 monitor. The high-range reading is 10 million R per 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. Remember, TMI went up to 800 R per hour. And 19 this monitor is used for two purposes.

20 The first purpose is in the core damage 21 assessment models. Now I think you probably know 22 pretty well the TMI history, but the bottom line was, 23 in the first few hours of TMI, they did not know what 24 the status of the core was. They didn't know if the 25 plant was going to blow up. They didn't know if they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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41 1 needed to evacuate. They didn't know what they needed 2 to do.

3 As a result of that, NRC issued some post-4 accident sampling criteria, and that sampling criteria 5 required the plants to have to go grab reactor coolant 6 samples and analyze them. There was a lot of 7 technical difficulties with that.

8 As a result of that, the vendors, a couple 9 of years later, made some Topical Report submittals to 10 the NRC saying, "We don't really need to do all that 11 post-accident sampling if we have an alternative 12 method." And that alternative method is a core damage 13 assessment model, and that takes input like core exit 14 thermocouple temperature readings, reactor coolant 15 system pressure and temperature. And one of the 16 inputs is the containment high-range monitor. So, 17 we're describing that in the Reg Guide.

18 But the manufacturer is going to do the 19 primary initial calibration for this, and then, the 20 manufacturer is going to give the instrument response 21 factor. And then, the value is 1 times (audio 22 interference); it's 11 amps per hour.

23 But the licensees need to just perform 24 this periodic solid source calibration in the 1-to 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> range, and the I&C staff will do the electronic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 calibration above 10R per hour.

2 Next slide, please.

3 Okay. Chi-over-Qs and D-over-Qs. As you 4 know, chi-over-Q is the dispersion factor, how the 5 radioactive effluent disperses after it's released 6 from the plant vent, and the D-over-Qs, which are the 7 deposition rates of the iodines and the particulates.

8 The previous guidance was, if the chi-over-Q changed 9 in a non-conservative direction by 10 percent, then 10 the licensee should go back and adjust their computer 11 codes to use a more updated chi-over-Q.

12 So, our meteorological staff reviewed this 13 and approved the change. That's going to be, for lack 14 of a better word, ratcheting the licensees to making 15 changes to the computer codes too often. The whole 16 overall accuracy of this whole system is not within 17 plus or minus 10 percent. So, we allowed in the 18 revised Reg Guide that they need to update the 19 computer codes if the dispersion factor increases, or 20 decreases in a non-conservative direction by 20 or 30 21 percent. So, that will give them a little better 22 relief from ratcheting their changes to their computer 23 programs just based updated weather patterns.

24 Next slide.

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43 1 Halnon again.

2 On that last slide, there's a Reg Guide 3 4.28 coming out using the ARCON model for offsite. Is 4 there any effect or is there a synchronization needed 5 to be done, or at least a reference between those two 6 before that Reg Guide gets issued?

7 MR. GARRY: The meteorological staff put 8 out that, and I looked at that this morning, Draft Reg 9 Guide 4.28. That's for control room doses and onsite 10 dispersion.

11 MEMBER HALNON: Okay. Well, the new 12 revision is looking at being able to use that for the 13 new reactors, SMs, for offsite.

14 MR. GARRY: Right.

15 MEMBER HALNON: So, I just wanted to make 16 sure that those two don't conflict with each other, 17 once they get issued.

18 MR. GARRY: Yes, this is for offsite 19 dispersion during routine effluent releases. The 20 other is for onsite dispersion during accidents.

21 MEMBER HALNON: Okay.

22 MEMBER KIRCHNER: But I think Greg is 23 right that the proposal is to use the other for the 24 small reactors, small modular reactors, because of the 25 anticipation that they're going to pull in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 exclusionary boundaries and such. So, the (audio 2 interference) would be used once you've crossed the 3 site boundary.

4 MEMBER HALNON: Correct. That's right.

5 Thanks, Walt.

6 MR. GARRY: Okay.

7 MEMBER HALNON: Yes, I think you've got to 8 look at it from the perspective of it being broader 9 than what it has been traditionally been used as. So, 10 my question was just to make sure they're synchronized 11 and that there's no conflict there.

12 MR. GARRY: Okay. No, I reviewed it this 13 morning. I didn't see a conflict in it. And it was 14 prepared by the meteorologist group.

15 MEMBER HALNON: Okay. We'll be doing 4.28 16 in the future, when it gets through public comment, 17 and we'll look back at this to make sure and just give 18 you a second check on it.

19 MR. GARRY: Okay. Thanks.

20 Next slide.

21 Okay. Low-level waste shipment.

22 Basically, there's two changes that aren't being made 23 here. One is reporting waste classification. I'd 24 like to describe waste classification.

25 That is a concept of how, for lack of a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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45 1 better word, risky or dangerous this rad waste is to 2 be disposed into a licensed low-level waste disposal 3 facility. So, that lift into the ground as a rad 4 waste needs to be determined when the waste is in its 5 final form.

6 As you know, most or a lot of the waste 7 from a nuclear power plant is now sent to a rad waste 8 processor. In the old days, the waste was sent for 9 direct disposal. It was put into 55-gallon drums, a 10 lot of it, and taken to a landfill and it was direct 11 disposal. The truck went from the power plant to the 12 waste disposal facility. In most cases, the waste 13 could be classified because it was in final form. It 14 was in the 55-gallon drum. That was the final form.

15 The resin was in a 55-gallon drum.

16 Currently, due to the cost of low-level 17 waste disposal, most waste is sent from the power 18 plant to a waste processor, and they will process that 19 waste into a lower volume for volume reduction. And 20 they've achieved some huge volume reductions. Resin, 21 for example, is essentially melted or burned down into 22 ashes. And so, the volume is, let's just say, a 23 factor of 100 decrease in the volume. At the same 24 time, there's a factor of 100 increase in the 25 concentrations of the radioactive materials in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 ash. So, the waste classification can be much 2 different after waste processing.

3 Similarly, for dry active waste, which is, 4 basically, SeaLand containers of clothing and 5 paperwork and garbage coming out of the plant that's 6 slightly contaminated. That, again, is incinerated.

7 So, you get a SeaLand container which is roughly 1,000 8 cubic feet. When they get done incinerating that, 9 that's going to be down to 3 or 4 cubic feet, and the 10 concentrations will have increased by a factor of 100 11 or so. So, the waste cannot be classified until it's 12 in final form.

13 The previous version of the Reg Guide 14 asked the licensees to report the waste 15 classification. And the licensees have told us, hey, 16 we can't do that because it's not in final form. And 17 the processor who sends the waste to the low-level 18 waste disposal facility, that processor is the one 19 that's going to classify the waste. As a result, we 20 have removed from the Reg Guide the table that tells 21 us what the waste classification is. So, that's one 22 concept.

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47 1 that's actually disposed in the low-level waste 2 disposal facility. Well, there's two problems with 3 that.

4 First of all, that waste is already being 5 tracked by DOE. The Department of Energy tracks the 6 low-level waste disposals into the licensed low-level 7 waste disposal sites. So, we did not want to have 8 redundant requirements with DOE to track the amount of 9 waste going into the landfill.

10 And the second thing is we want to know 11 what waste is being generated at the plant and is out 12 on the public roads. So, if there was a rad waste 13 shipping accident on the roadway, whatever, if we got 14 asked by politicians or someone as to, hey, how much 15 waste is leaving these nuclear power plants, we would 16 have a reporting of the waste shipped from the plants.

17 So, we clarified that again in the Reg Guide.

18 CHAIR BALLINGER: This is Ron Ballinger 19 again.

20 Is there any -- and it's probably from my 21 ignorance -- a risk of losing track of who owns what 22 waste when they ship stuff to a processing facility?

23 Does the processing facility maintain -- what do you 24 want to call it? -- a unique chain of custody and not 25 combine waste from individual plants as they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 incinerate?

2 MR. GARRY: Once the waste goes to the 3 processing plant, my understanding is that the waste 4 is now transferred to the waste processing, and it, 5 essentially, becomes the -- first of all, the 6 processors are licensed by the states. Most of the 7 processing is in the State of Tennessee, and the State 8 of Tennessee has licensed the waste processors to 9 receive the waste. They have waste acceptance 10 criteria saying you can only receive it if it's in the 11 proper shipping container, if the VOP shipping 12 categories are properly completed, the waste manifest 13 forms are completed.

14 And there's quite detailed tracking of 15 this waste. It starts with the waste manifest forms.

16 That's the NRC Forms 540, 541, 542 that identify the 17 radionuclides, the quantity of the radionuclides, the 18 LLDs. It's very well-tracked.

19 A lot of these requirements are in 20 10 CFR 20, which is the standards for protection 21 against radiation. It's, specifically, in Appendix G, 22 golf, Appendix golf, which has the manifesting and 23 shipping requirements. And that establishes the 24 tracking and the traceability of the waste.

25 CHAIR BALLINGER: Okay. Thank you.

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49 1 MR. GARRY: Uh-hum.

2 And then, just to make it a little 3 simpler, in the Reg Guide, we generalize the 4 description of the rad waste into wet waste, dry 5 waste, activated waste, and other waste. So, that's 6 a change, although it's not a big change. It just 7 makes it a little more intuitive as to how to report 8 which shipments as which category.

9 Okay. Environmental monitoring. We 10 updated the environmental monitoring requirements.

11 Most of the effluent and environmental requirements 12 originated in a couple of documents back in the late 13 '70s called NUREG-1301 and -1302. And that laid out 14 a minimally acceptable environmental monitoring 15 program.

16 And part of that was a criteria for 17 sampling for iodine-131 in drinking water. Now that 18 is not a cheap analysis to do. That costs -- I don't 19 know -- $3,000 per analysis, something like that. And 20 it needs to be done if it's appropriate.

21 And the guidance on whether it's 22 appropriate was a little confusing. So, basically, we 23 have simplified it and said, basically, that in order 24 to do this expensive analysis -- we don't use the word 25 in the Reg Guide -- iodine-131 in drinking water, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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50 1 need to do it if the estimated dose is more than 1 2 millirem per year. You need to do it every two weeks.

3 If you don't expect to see iodine-131 in drinking 4 water, then you can change that to a monthly analysis.

5 So, that should clarify and remove a lot 6 of the environmental sampling frequencies for 7 iodine-131 and allow them to do the analysis using a 8 gamma spect system rather than a resin column.

9 Next slide, please.

10 Okay. Leaks and spills. I think, as 11 everyone knows, there's been a lot of attention in the 12 last 15 years on leaks and spills. And one question 13 that continually got asked is, do they have to clean 14 it up? And so, we wrote a SECY paper back in 2013 15 entitled something like "Remediation of Residual 16 Radioactivity During Operations."

17 And basically, the guidance or the 18 consideration that we gave in the SECY paper was that 19 it could be detrimental to the operation of the plant 20 to have them try to remediate leaks and spills 21 underneath the plant. With all the electrical wires 22 and the conduits and the piping, and everything else, 23 we don't really want them digging up dirt because 24 there's a little bit of tritium, or mostly tritium, 25 maybe a little strontium, in there.

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51 1 So, the Commission agreed with us that 2 what we should do is have them evaluate the 3 feasibility of prompt remediation. So, for example, 4 if there was a spill that -- at a plant where I used 5 to work, there was a small oil spill. It wasn't 6 radioactivity, but it was an oil spill. It went down 7 the storm drain, but it sat in the sump at the bottom 8 of the storm drain. So, it was feasible to take the 9 cover off of that manway and go down and recover that 10 oil, so that it didn't get discharged out into the 11 environment. So, similarly, evaluate the feasibility 12 of prompt remediation.

13 In the radioactive world, that, basically, 14 has been done at several plants where they have 15 established groundwater monitoring wells. And they 16 have taken some of those wells and, using those wells, 17 they have pumped back the tritium from the groundwater 18 back to the plant, so that it could be monitored and 19 discharged into the approved discharge pathways.

20 So, there are several plants that have 21 done that. Brunswick is pumping back, and so forth.

22 There's several plants that are pumping back and 23 monitoring, and then, releasing.

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52 1 but you don't necessarily have to remediate it.

2 MEMBER HALNON: Steve, this is Greg.

3 Just be de fact -- and I'm just looking, 4 I think it's on page 17, and it may not be a new issue 5 -- but the statement is, "If the spill's properly 6 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, 7 la, it doesn't have to be reported in the annual 8 report. Is that a new issue or is that something that 9 has been existing for --

10 MR. GARRY: Well, that's kind of guidance 11 that we have given over the last 14 years to public 12 meetings, and so forth, that we want to, basically, 13 give them the incentive to capture it, if they can.

14 And the incentive is you don't have to report it if 15 you can get it cleaned up right away.

16 MEMBER HALNON: So, isn't that kind of de 17 facto setting a requirement of some type? I mean, by 18 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 19 site VP driving his team to take actions to clean 20 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 21 within the non-reporting requirement.

22 MR. GARRY: Yes, that's kind of the 23 objective, is to encourage them, so to speak. If they 24 can clean it up right away, they don't have to report 25 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, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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53 1 but that's the guidance that we had issued back in 2 2009.

3 MEMBER HALNON: Okay. It just seems a 4 little soft and ambiguous to say that's just an 5 example. And then, you say prompt remediation is not 6 a requirement. However, it looks like it's being 7 strongly encouraged through this --

8 MR. GARRY: That's about right.

9 CHAIR BALLINGER: Yes, this is Ron again.

10 Along those lines, in the spirit of risk-11 informing something, might the time to clean up or 12 requirement to clean up a spill be dependent on the 13 severity of the consequences?

14 MR. GARRY: Sure.

15 MEMBER HALNON: I mean, why just put 48 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on the thing and just leave it at that?

17 MR. GARRY: Well, first of all, a Reg 18 Guide is an acceptable method. It's not a 19 requirement. It's, like you say, encouraged or it's 20 guidance on what we find is appropriate. Can the 48 21 hours2.430556e-4 days <br />0.00583 hours <br />3.472222e-5 weeks <br />7.9905e-6 months <br /> be, you know, three days or four days? Yes.

22 So, it's not a hard-and-fast requirement. It's 23 guidance.

24 CHAIR BALLINGER: Yes, yes, I hear you, 25 but in the military we call that being "volun-told."

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54 1 (Laughter.)

2 MR. GARRY: Well, there's probably some 3 similarities there.

4 MEMBER HALNON: I was more concerned with 5 the fact that it provides just some ambiguity to what 6 goes into the annual report and what doesn't. You 7 know, what if it is three days or four days? Who 8 makes the decision that it was promptly remediated, so 9 that it doesn't have to be reported? So, to me, it 10 muddies up what is in the annual report and what is 11 not.

12 MR. GARRY: Yes, you could also consider 13 it flexibility. I understand what you're saying. No 14 matter what number we put there, we wanted to give 15 some kind of guidance. We wouldn't want to just say, 16 "prompt" and have somebody say, "What does that mean?

17 In the current shift? Or does that mean in the next 18 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 --

19 MEMBER HALNON: Yes, I agree, and that's 20 why maybe the time to do is, for lack of a better 21 term, a deterministic period, as opposed to risk-22 informed, which looks at consequences, as Ron 23 mentioned. So, it just seems to me that you might 24 want to take a look at that and see if there's an 25 opportunity to better the language in a risk-formed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 way as opposed to a deterministic way.

2 MR. GARRY: Okay. We can discuss that, 3 yes. It's something I haven't really thought much 4 about. So, thanks for pointing that out.

5 MS. WHITMAN: And, hey, Steve, this is Jen 6 Whitman.

7 I don't think we've received any public 8 comments on this, and I don't know that there's been, 9 I guess, questions or concerns from industry about 10 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?

11 MR. GARRY: That may be a reflection of 12 the fact that the industry has gotten so much better 13 at minimizing release and dealing with spills, that as 14 a practical matter, it doesn't happen very often.

15 Something that I haven't discussed is we 16 do on our web page provide a list of leaks and spills 17 at each of the plants with the maximum contamination 18 levels measured and the current levels, the current 19 maximum level. So, we're transparent with the public 20 about leaks and spills.

21 And when we talk about leaks and spills, 22 we're basically talking water leaks with tritium in 23 it.

24 MEMBER HALNON: Yes, you know, I guess I 25 wasn't implying there's a problem. I'm implying that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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56 1 you may not know there's a problem because you don't 2 know what's not being reported in the annual report 3 because people may be cleaning up some significant 4 leaks fast enough, promptly enough, that they can say, 5 okay, we got that one done; we don't have to report 6 it. Thank you.

7 MR. GARRY: Yes. You know, we rely a lot 8 on the Resident Inspectors and the daily review of the 9 Corrective Action Program entries, and the expectation 10 that, if there's a leak or spill, right away they 11 would put it into the Corrective Action Program. It 12 would get reviewed by the Resident within a day or 13 two, and then, the Resident has good contacts with the 14 Regional HP Inspectors. So, if we had a massive leak, 15 or whatever, that we would quickly know about it, and 16 not wait for the annual report.

17 MEMBER HALNON: Okay. Well, I agree that 18 the parallel path is there. However, the data 19 reduction in the annual reports, does it take that 20 into consideration?

21 MR. GARRY: Yes, we have a Reg Guide on 22 reporting or measuring the impact of these leaks and 23 spills. It's Reg Guide 4.25, which is a method of 24 estimating the offsite impact of an onsite leak.

25 MEMBER HALNON: Okay. Well, I think the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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57 1 comment still stands. Maybe that's an opportunity 2 there that we can clarify in the future. If it's not 3 a problem, you know, a pervasive problem, I'm sure 4 that it's certainly been part of the discussions in 5 the site VP office when a leak occurs.

6 MR. GARRY: Yes, yes.

7 Okay. Any other discussion of that?

8 CHAIR BALLINGER: Yes, this is Ron again.

9 We have a break that's scheduled for now, 10 but I see there's only a few slides left, except for 11 the backup slides. And there were very few public 12 comments. So, I would propose that, unless other 13 members want to have a break now, that we just 14 continue to the discussion and have our break before 15 we have the going-around-the-table discussion.

16 MEMBER HALNON: I'm fine with that, Ron.

17 This is Greg.

18 CHAIR BALLINGER: Yes, I don't hear a 19 groundswell of objection. So, thanks.

20 MR. GARRY: Okay. All right, great.

21 So, like I say, we've had several requests 22 from licensees and inspectors as to what are they 23 supposed to do when we go into decommissioning. And 24 the first thing I want to point out is that the NRC's 25 reactor oversight process transitions from NRR to NMSS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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58 1 for decommissioning inspections. So, I work in the 2 Office of Nuclear Reactor Regulation. So, this goes 3 over to the decommissioning group. However, we still 4 get the calls because the plant's typically still 5 operating when they want to know, hey, we're going to 6 be headed into decommissioning; what should we be 7 doing?

8 And as you know, the NRC has got a new 9 rule coming on decommissioning and the criteria for 10 going into decommissioning. And that's mostly 11 security-related and some of the revision of Tech 12 Specs and the requirements for surveillances, and so 13 forth. It really doesn't affect the effluent program 14 as much as you might expect because we have the 15 effluent program already set up to be flexible. The 16 Tech Specs require the licensees to maintain their 17 ODCM, and that means, when significant plant changes 18 occur, they need to update the ODCM accordingly.

19 So, the second bullet here, then, is that 20 the licensees need to update their ODCM to 21 decommissioning status. They need to evaluate the 22 effluent release pathways. We're going to talk about 23 that a little bit more in the next slide.

24 They need to update the source term, 25 because the principal radionuclides are likely to have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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59 1 changed. The radioactive iodines have decayed.

2 They're going to decay off in the first 30 to 60 days.

3 Most of the noble gases have been released or decayed 4 off.

5 So, the effluent monitoring needs to 6 recognize that, and you need to update the ODCM and 7 determine whether or not you want to continue, or when 8 you want to discontinue, iodine monitoring, and when 9 you can discontinue noble gas monitoring. You need to 10 recognize that krypton-85 is likely a new principal 11 noble gas radionuclide. And then, you need to 12 maintain your Part 72 ISFSI effluent reporting.

13 Next slide, please.

14 So, what does the update to the ODCM 15 involve? Well, the old effluent release pathways are 16 being dismantled. Ventilation systems are being 17 removed. Fans are being shut down. New effluent 18 release pathways -- I noted the word "effluent release 19 pathway" -- how is it getting out? Well, you've got 20 to open hatches, roll up doors, and demolition 21 activities.

22 You've got new principal radionuclides.

23 We talked about that a little bit. We're approaching 24 zero releases of iodines and noble gases. We're going 25 to, basically, particulate and alpha activity. As NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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60 1 you're cutting open primary systems, there may be 2 alpha activity that's now in a form that can be 3 released; whereas, previously, it was contained inside 4 of an operating system, an operating pipe.

5 Particulates, which you can think of as 6 dust, radioactive dust, is being released. So, you 7 need to think about how you're going to be monitoring 8 particulate activity.

9 You can reevaluate your radiation exposure 10 pathways. So, for example, there's no iodine milk 11 pathway anymore because there's no iodine. They're 12 still drinking milk, but there's no iodine in it. So, 13 you don't need to be monitoring for environmental 14 iodine.

15 But you need to continue your normal 16 exposure pathways, which are the primary ones. What 17 are you breathing, what are you eating, and what is 18 the direct radiation? And then, you need to identify 19 if there are any new, significant exposure pathways, 20 created by the fact that you're now in a 21 decommissioning mode rather than an operating mode.

22 Next slide.

23 But the point, then, is that it doesn't 24 take a rule change to do this. We've already got in 25 Tech Specs a system set up on how to modify your ODCM.

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61 1 And basically, it's very simple. You do an evaluation 2 and you get the plant manager to approve it. And 3 then, you need to submit that revised program to the 4 NRC, along with the next annual environmental report.

5 Next slide.

6 Okay. Then, we've got Regulatory Issue 7 Summary 2008-3. The background on this is that Wolf 8 Creek had discharges to, what I'll call -- I think 9 it's a Coffey County Lake -- I'll just call it the 10 Wolf Creek Lake. So, they discharged tritium into the 11 lake, and then, the intake structure takes suction 12 from that lake and brings that radioactive tritium 13 back into the plant. And Wolf Creek used that lake 14 water in their fire tanks.

15 And as you would expect, they run fire 16 drills. The fire team will come out and use water 17 from those fire tanks and spray it around the site in 18 a drill. And the inspector said, well, you know, 19 you're spraying tritium around here.

20 So, we did an evaluation and we worked 21 with our Office of General Counsel, and we put out 22 this Regulatory Issue Summary 2008-3 that, basically, 23 said that, if you have properly discharged radioactive 24 tritium, and subsequently, returned that liquid 25 effluent, you do not need to double-count it as a new NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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62 1 effluent discharge, but you do need to take a look and 2 see if, as a result of a new activity, such as 3 spraying water around, is there a new, significant 4 exposure pathway? And if there is, then you need to 5 include it in your dose assessments.

6 And we do not expect a thorough, high-7 level, detailed calculation. You can use a bounding 8 assessment because we know in the first place that 9 you're spraying water around that, if somebody were to 10 drink it, it would get 4 millirem a year. So, we 11 understand that the risk of there being a new, 12 significant exposure pathway is pretty minimal. And 13 so, you can use a bounding assessment.

14 Next slide, please.

15 Okay. So, Ron, how would you like to 16 handle this? Would you like to take a break now or 17 would you like to go ahead and discuss this? Or would 18 you rather just have a roundtable discussion?

19 CHAIR BALLINGER: I guess I would ask, is 20 there a discussion that's going to take place related 21 to the public comments? This is the only slide that 22 says 31 public comments, et cetera, et cetera. Is 23 there a significant amount of discussion that's going 24 to take place here? If that's true, then we should 25 probably take a break. If it's going to take very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 little time, then this is the last slide, right?

2 MR. GARRY: Yes. Yes.

3 CHAIR BALLINGER: So, what's your opinion?

4 MR. GARRY: Well, I think we've mostly 5 discussed the public comments that we've already gone 6 through to a certain extent. We have the time. I'm 7 happy to go through all of the public comments in 8 detail or we can go straight to ACRS discussion.

9 CHAIR BALLINGER: I guess 16 of 31 10 comments were minor. That means that the rest of them 11 were not minor. I think maybe it's probably best, so 12 that we don't just tax people's ability to sit here, 13 I would suggest that we take a 15-minute break and 14 come back at -- what time is it? 10:55. So, 10 15 minutes after the hour. So, we will recess until 16 11:10.

17 (Whereupon, at 10:53 a.m., the foregoing 18 matter went off the record and went back on the record 19 at 11:10 a.m.)

20 CHAIR BALLINGER: Okay. It is 11:10. So, 21 we're back in session.

22 So, can we get the presentation back up on 23 the screen?

24 MR. GARRY: Okay. Thanks, Mike.

25 How would you like to do this, Ron? Would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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64 1 you like me to go through each of the slides?

2 CHAIR BALLINGER: At your discretion. I 3 would think we would want to focus on any public 4 comments that were significant and how they were 5 resolved.

6 MR. GARRY: Okay. That's fine. I 7 wouldn't say they're significant. I'd say they're 8 more than minor. So, let's go through them.

9 CHAIR BALLINGER: Okay.

10 MR. GARRY: Okay. The Public Comment 4.1, 11 this individual's comment was: "When evaluating new, 12 significant exposure pathways" -- and this is during 13 decommissioning -- "given that the effluent doses are 14 ever decreasing, what is the words in Reg Guide `total 15 dose reference value' to be used in determining if 16 there is a new, significant exposure pathway?"

17 Okay. Some of these comments took a 18 little more explanation. So, we started by saying 19 that the common exposure pathways, and the primary 20 ones, if you want to consider that, are the 21 inhalation, breathing, eating, and direct radiation, 22 as described in Reg Guide 1.109.

23 Reg Guide 1.109 was written back in 1974, 24 I think, and revised in 1979. And it gave all the 25 mathematical equations on how to calculate the doses NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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65 1 from each of the radionuclides through each of the 2 primary or common exposure pathways.

3 Within the exposure pathway, there's 4 different routes of exposure. So, for example, under 5 ingestion, you could be ingesting water, fish, meat, 6 or vegetables. So, there are equations on how to 7 calculate each of these.

8 In addition, a site may have unique 9 specific exposure pathways, such as if there was a 10 local farmer who was eating his goat meat or chicken 11 meat, that might need to be evaluated. The whole 12 criteria here in the first place was, basically, under 13 your land use census, to evaluate the exposure 14 pathways, and if you find something, for lack of a 15 better word, important, then you should include it.

16 And so, we've given a criteria of 10 percent of 17 Appendix I is a criteria, which it's acceptable value 18 to see if there's a new, significant exposure pathway.

19 Now significance is relative. It's 20 significant with respect to the ALARA criteria. It's 21 not significant with respect to a dose limit. So, 22 that's how we resolved that comment.

23 Next slide.

24 Solid waste reporting. Again, we 25 discussed this during the presentation, but the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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66 1 licensees wanted us to ask them to report the solid 2 waste disposed, not the waste shipped. And it's very 3 clear that standard Tech Specs require reporting of 4 the solid waste released from the plant, not the waste 5 disposed. Previous versions of the Reg Guide said the 6 same thing, that you need to report the waste shipped.

7 And we note that DOE already tracks the solid waste 8 disposed in the licensed waste disposal sites. So, 9 really, there was no change needed to the Reg Guide 10 because it was correct in the first place. We just 11 didn't meet the objectives of the licensee to change 12 the reporting requirement.

13 Next slide.

14 Waste classification. We talked about 15 that as well. We removed the reporting of waste 16 classification because it was pretty much immaterial 17 anymore, because the waste is primarily being shipped 18 for waste processing. So, we accepted that comment 19 and removed the reporting of waste classification.

20 Next slide.

21 Iodine sampling. We talked about that.

22 Again, the comment was to give more detail on the 23 iodine-131 sampling frequency, what LLD should be 24 used, which receptor age group. Should it include 25 ingestion of fish? And how is it different than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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67 1 calculating doses from effluents based on projected 2 31-day doses?

3 And we clarified it by saying that, if the 4 calculated dose is more than 1 millirem -- and then, 5 we had to go into detail -- to a person in the most 6 sensitive age group, then perform environmental 7 sampling analysis twice monthly with a low limit of 8 detection of 1 picocurie per liter, which, basically, 9 means they need to do the resin column analysis, but 10 that's only if the calculated dose is more than 1 11 millirem per year. If it's not, then sample and 12 analyze monthly using a gamma spect analysis with a 13 higher LLD. So, I think that will answer the public 14 comment.

15 Next slide.

16 Okay. There was a comment -- and this was 17 kind of arbitrary or semantics -- they wanted the term 18 "release and discharged" reversed. They wanted the 19 release to be to the offsite environment and a 20 discharge to be onsite. But we did not accept that 21 comment. We note that the terms are arbitrary. We 22 wanted to remain consistent with the previous revision 23 of the Reg Guide, in that we're going to call it 24 discharge is a effluent discharge to the offsite area, 25 and an effluent release is a release from the plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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68 1 system structures and components to the onsite area.

2 MEMBER HALNON: Hey, Steve, this is Greg.

3 I got a little bit confused on definitions 4 for onsite and offsite. Is it consistent through the 5 Reg Guides? Does this change any of the definitions 6 for onsite/offsite?

7 MR. GARRY: Not that I'm aware of.

8 MEMBER HALNON: Okay. It may have just 9 been me, but I'll go back and look at it again. But 10 there's a couple of places that use onsite and 11 offsite, and it seemed like it wasn't consistent, but 12 I may have read it wrong. Just check out line 997 and 13 2571 and make sure that you're satisfied it's 14 consistent.

15 MR. GARRY: Okay. Give me those numbers 16 again?

17 MEMBER HALNON: I think it's 997 and 2571, 18 or thereabouts.

19 MR. GARRY: Okay. Great.

20 MEMBER HALNON: How's that?

21 MR. GARRY: All right.

22 MEMBER HALNON: It's as precise as I can 23 get.

24 MR. GARRY: That's good. Thanks.

25 Okay. Next slide.

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69 1 Okay. This is a public comment on 2 licensed versus unlicensed radioactive material. The 3 commenter said that, look, we're not doing it the way 4 you really describe it. We're doing doses -- we're 5 not calculating dose from prior year effluents. We're 6 only calculating doses based on current year 7 effluents.

8 So, the comment "not accepted" means that 9 I did not need to revise the Reg Guide to challenge 10 him on calculating prior year doses. Because it's 11 kind of an indirect calculation, and I'll explain that 12 here now.

13 NRC and EPA dose limits apply to both 14 licensed and unlicensed material. It includes current 15 year effluents which release this year; current year 16 direct radiation, which you could give someone from 17 storage of radioactive material onsite or from BWR 18 SHINE, and prior year accumulated radioactivity in the 19 environment. So, the dose limit does apply to prior 20 year effluents.

21 Now environmental monitoring programs are 22 designed to monitor the environment, which includes 23 both current year discharges and any, let's call it, 24 leftover prior year accumulated radioactivity. And 25 the environmental monitoring program has a reporting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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70 1 requirement that says that, if you detect radioactive 2 material in the environment at a level that exceeds 3 reporting requirements, then you need to inform the 4 NRC. And those reporting requirements, the levels of, 5 basically, tritium in the environment are based on the 6 Appendix I dose criteria.

7 So, the bottom line is, if they have an 8 environmental monitoring program that detects tritium 9 in a lake that were to exceed 20,000 picocuries per 10 liter of tritium, if that lake is used for drinking 11 water, then they need to send us a report saying that 12 we are starting to push the Appendix I criteria of 3 13 millirem. So, 3 millirem is 3 percent of the NRC dose 14 limit and, roughly, 10 percent or 12 percent of the 15 EPA dose limit.

16 So, although the licensees are not 17 calculating dose from previous year effluents, they 18 are monitoring for it and are reporting to us if the 19 levels start approaching Appendix I. And this is 20 explained in our public comment response matrix.

21 So, what we do is we take a list of all 22 the public comments and we answer each of those 23 comments, and we put that in ADAMS and make that 24 publicly available as to how we resolved those public 25 comments. If I were to try to put too much detail in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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71 1 the Reg Guide, then it gets real wordy.

2 Okay. Next slide, Mike.

3 Okay. Updating chi-over-Qs and D-over-Qs.

4 There was an inconsistency in the timeframes specified 5 for updating long-term chi-over-Qs and D-over-Qs. One 6 paragraph said five years, and later it said five or 7 more years. So, they say that it should be based on 8 five or more years. We accepted that comment and 9 revised the text accordingly.

10 Okay. The reporting in Tables A-1 and A-2 11 had a carryover from, basically, back in 1975 saying:

12 report the percent of the limit. But it never said 13 what limit you're talking about. And the licensees 14 had questions saying, report of what limit? And we've 15 changed it to remove the percent of a release rate and 16 percent of a concentration, because it's, basically, 17 way, way lower than those limits, and replaced it with 18 Tables A-4 and A-5, which require reporting of the 19 percent of the dose limit of the dose criteria that 20 the limit -- the dose criteria in 10 CFR 50, Appendix 21 I, and EPA dose limits.

22 We looked at the previous effluent 23 reports, and licensees were confused. They put 24 asterisks in there, and they didn't how to calculate 25 that; how to report that. So, we intended, back in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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72 1 2009, to get rid of it back then. And when we added 2 the Tables A-4 and A-5, in the last few minutes or the 3 last few days, we didn't get that removed from the 4 table. So, we accepted the comment, deleted the 5 percent of the release rate, and replaced it with 6 reporting the percent of the ALARA criteria and the 7 EPA dose limits.

8 Okay. Reporting of solid waste. We've 9 talked about that. No, this is a little bit 10 different. They said there was an inconsistency.

11 There's two sections of the Reg Guide that talk about 12 reporting of solid waste, and one included the "green 13 is clean" solid waste shipments and the other one did 14 not. So, we accepted the comment. We revised Section 15 9.3 to exclude solid materials such as "green is 16 clean" waste that is accepted in Section 6 of the Reg 17 Guide.

18 I think as you know, "green is clean" 19 waste is waste that is potentially contaminated, but 20 it really can't be identified as to whether it is or 21 not at the plant because the levels are so low. So, 22 they ship it as "green is clean" to a waste processor, 23 and there's no need for them to report to us the 24 shipments of the "green is clean" waste.

25 The next slide.

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73 1 Solid waste descriptions. They're not 2 consistent. Again, we've generalized that to be wet 3 waste, dry waste, activated or contaminated waste, and 4 other radioactive waste.

5 The next slide.

6 Reporting of ISFSI effluents. There was, 7 in Rev. 2 of it, there was text deleted with respect 8 to the reporting of effluents from independent spent 9 fuel storage installations. And we didn't delete it.

10 There is a section of the Reg Guide on reporting ISFSI 11 effluents. It's in Section 9 of the report. So, we 12 added a footnote back at the front of the Reg Guide on 13 the objectives that we're not removing the requirement 14 for or the guidance on reporting ISFSI effluents.

15 It's that that guidance is provided in Section 9.

16 Okay. Carbon-14 doses. This was an 17 important comment. The question is, how do we report 18 carbon-14 doses? That's the basic question. And do 19 we need to include those doses in Appendix I?

20 Now, just to explain that, Appendix I is 21 an appendix that tells you how good your rad waste 22 processing systems need to be. They need to be good 23 enough that the doses from those effluents do not 24 exceed Appendix I. And the Appendix I calls out 25 specific radionuclides; namely, noble gases, iodines, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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74 1 particulates, and tritium. Carbon-14 is not included 2 in that. Carbon-14, as you know, is part of a global 3 warming situation. It comes out as carbon dioxide.

4 You really can't filter it. You can't absorb it.

5 You can't remove it. And therefore, a rad waste 6 processing system is not going to reduce the amount of 7 carbon-14. And it's not included in Appendix I 8 because of that.

9 However, it is included in the public dose 10 limits of EPA, 25 millirem per year, and NRC of 100 11 millirem per year. So, the licensees need to 12 calculate carbon-14, let's call it, separately and put 13 it into the total dose that could be compared to the 14 EPA and the NRC dose limits. So, that was a real nice 15 cleanup that I think we did there.

16 Okay. I guess that's the end of the slide 17 show. With that, I'll turn it back over to Mr.

18 Ballinger.

19 CHAIR BALLINGER: Thank you very much.

20 If there are not other immediate comments 21 from the members or our consultant, I think we need to 22 now get the public line open for public comments.

23 Tom, can you get the public line open?

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75 1 by them calling directly into --

2 CHAIR BALLINGER: Ah.

3 MR. MOORE: And I'm not sure who is the 4 one telephone number that's called in, but if that 5 isn't a member of the public, then maybe if it's a 6 member of the staff or somebody else, then we don't 7 have any public callers.

8 CHAIR BALLINGER: Ah, so the 707 is the 9 call-in number? Yes, yes. Okay. Well, I guess we 10 waited a little bit and nobody has made a comment.

11 So, I guess there aren't any public comments. So, I 12 guess the next thing to do is to have discussion 13 amongst the members.

14 When I reviewed this document to see if we 15 should have a presentation, the risk-informing issue 16 was important, but, as it turns out, the risk-17 informing aspect was incorporated in Revision 2. And 18 as far as I know, we never wrote a letter on this 19 document, on Revision 2.

20 It doesn't change much in terms of the 21 wording in Revision 3. And so, that's my current 22 comment. I'd be curious about whether the members 23 think we should write a letter or not. So, are there 24 members that would like to make a comment? In 25 particular, should we write a letter, and if so, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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76 1 what's important?

2 MEMBER HALNON: Ron, this is Greg. I've 3 got a few questions for Steve. But, to answer your 4 question, I don't think that we need a letter on this, 5 but, you know, I'm pretty new on the ACRS. So, I'm 6 not sure of all the background, why we would need one.

7 It seems like it's pretty comprehensive and a good 8 job.

9 So, let me get through just a couple of my 10 questions, and then, you can clear my list of items.

11 None of them will take very long.

12 Steve, we're doing a lot of work on Part 13 53, and it's got a lot of references to ALARA. I just 14 wanted to put that in your head to make sure that, 15 somewhere around line 1728, I just made a note that it 16 drew me to think about how we're using ALARA in the 17 Part 53 regulations and whether or not this Reg Guide 18 would be part of that discussion. So, just keep that 19 in your mind. It's not anything that I think you have 20 to take any action on, but --

21 MR. GARRY: Okay.

22 MEMBER HALNON: But it does talk about 23 ALARA levels and we're using ALARA in a more distinct 24 regulatory way in Part 53.

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77 1 editorial. And when you went through the Reg Guides 2 at the beginning -- I'm trying to find the line 3 reference -- but you just had a list of Reg Guide 4 numbers. Normally, we see the titles next to them, 5 just for your editorial completion.

6 MR. GARRY: Okay.

7 MEMBER HALNON: It's the related ones, 8 yes.

9 And then, finally, I just had a question.

10 Did you have an opportunity to tabletop this with the 11 industry working group on this?

12 MR. GARRY: No, but we did communicate 13 with NEI, and NEI did a really good job of sending it 14 out to the plants for discussion. And that's why we 15 received so many comments, is that the document was 16 well-reviewed by the industry, particularly effluent 17 group.

18 There are two groups within rad protection 19 and the industry. The occupational and, basically, 20 the public are the effluent group. We call the 21 occupational group the NEI Radiation Protection Forum 22 and their Task Force, and then, we also have what used 23 to be called RETS REMP, the Radiological Effluent 24 Technical Specifications Radiological Environmental 25 Monitoring Program group, which got renamed to be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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78 1 REEW, the Radiological Effluent and Environmental 2 Working Group.

3 And so, they have task forces and this 4 document was sent to that task force and to their 5 members for their review. So, we got a really good, 6 thorough industry review of the document.

7 MEMBER HALNON: Okay, yes, and that was my 8 impression, reading the detailed comments, that 9 certainly there was some really brainiacs behind the 10 comments. So, that's good.

11 That reference I was mentioning to you, 12 it's in the background section starting at 436, line 13 436.

14 MR. GARRY: Okay.

15 MEMBER HALNON: It's just you've got five 16 Reg Guides or three Reg Guides and two NUREGs there.

17 That's it.

18 Ron, in my personal opinion, I wouldn't 19 necessarily think a letter would be written. And 20 then, I'll leave it to the other members to also make 21 the comments.

22 MEMBER MARCH-LEUBA: Hey, Ron, this is 23 Jose.

24 You guys know I have a different 25 philosophy. I think positive letters also have value.

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79 1 And in my opinion, there should be a record that the 2 ACRS looked at this guide and approves of it. It 3 doesn't need to be a 12-page letter. I mean, let's 4 write a half-a-page letter where it says: we reviewed 5 this guide. This guide is intended to calculate doses 6 to the public in place of reuses. And we lead with 7 the staff approach. That doesn't take that much to 8 do.

9 MEMBER HALNON: Yes, I agree, Jose. This 10 is Greg. I didn't even think about that, but I agree 11 with you.

12 MEMBER MARCH-LEUBA: Yes, let's get into 13 the business of writing short letters. You don't need 14 to cut and paste the whole SER or Reg Guide into a 15 letter. That's my opinion.

16 Thank you.

17 MEMBER REMPE: So, this is Joy.

18 If we are going to go along that path, I 19 guess I'd like to have the staff comment on whether 20 waiting -- because our next meeting is September --

21 does that adversely affect any of the planned schedule 22 for issuing a Reg Guide? Because having to suddenly 23 wait for a, quote, "positive letter," where somebody 24 who is not present at today's meeting might come up 25 with a last-minute non-positive comment, I don't know.

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80 1 I mean, can this adversely affect things, is one 2 question I have.

3 And then, I guess I just want to follow up 4 on what I mentioned about the EPA Drinking Water 5 Standard. I guess the 4 millirem per year is based on 6 a maximum contamination level of 20,000 picocuries per 7 liter for tritium. And I guess, in 1991, the EPA said 8 that if they used better ways of calculating the dose 9 calculations, they could actually have a much higher, 10 a factor three higher, concentration of tritium per 11 liter.

12 And again, I guess I've heard from some 13 folks offline here that the staff doesn't usually 14 challenge the EPA standards. But did the staff 15 discuss this and say, "Yeah, we know it's still kind 16 of low, but we're just going to go with the flow 17 because of regulatory stability."?

18 And I guess no one from industry was 19 concerned about it, but it can raise some concerns 20 later if you have some sort of event. I mean, at TMI, 21 they had to do something about the tritium 22 concentrations in the water. And was this discussed, 23 and they just decided, "Well, we hope we don't have 24 another accident," and cross our fingers and move on?

25 Or did it just not get to that level?

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81 1 MR. GARRY: Well, the gist of the Reg 2 Guide is to do the measurement and do the calculation.

3 They use the dose methodologies that are described in 4 the ODCMs. And those dose methodologies are, 5 basically, based on the ICRP 2 international 6 recommendations, which establish a method of 7 calculating the dose.

8 They are required to use the 10 CFR 20 9 organ weighting factors, but the organ weighting 10 factor for tritium for the whole body is one. So, it 11 really doesn't matter too much there.

12 Like you said, the EPA has looked at the 13 way to calculate the dose. Particularly the radiation 14 weighting factor for tritium I think is based right 15 now on an RBE at 1.7, and EPA has determined that the 16 correct value should be 1.0.

17 But, then, more recent in this literature 18 says that, well, that may not be true; that's only for 19 non-organically bound tritium. Organically bound 20 tritium has that higher dose factor. So now, you're 21 having to divide the tritium intake into two 22 components to calculate the dose each way. So, it's 23 never been challenged and never been a limitation on 24 effluents. So, we haven't really addressed that, Joy.

25 MEMBER REMPE: Okay. So, I guess, again, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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82 1 I thinking on factors beyond this Reg Guide or about 2 issues beyond this Reg Guide. But I guess what you're 3 trying to tell me is that there's still a lot of 4 uncertainty in this, and that's why you just left it 5 alone?

6 MR. GARRY: Well, I wouldn't say 7 uncertainty, as much as there is precedence.

8 MEMBER REMPE: Okay. And then, what about 9 if ACRS decides to write a letter? Does that impact 10 anything that you have planned in your schedule for 11 getting this out the door? Does it matter if you have 12 to wait until after September, for example?

13 And actually, right now, I don't know; I 14 guess we can add something and change our agenda, but 15 that does require making changes to our agenda, if we 16 wait until September. So, it might be October. And 17 I just am kind of trying to understand how a decision 18 to write a letter impacts things for ACRS as well as 19 the staff.

20 MR. BROWN: So, if I can just -- Joy, 21 Chris Brown.

22 Currently, I have been in contact with 23 Research. We have it scheduled right now for October, 24 but if we could move it up to September, it really 25 depends on the schedule and the members.

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83 1 MEMBER REMPE: Okay. So, does that impact 2 things if you guys have to wait until October, just 3 because we've decided we want to write a nice letter?

4 That's a Steven question, by the way.

5 MR. GARRY: Okay. Well, I'm not sure. I 6 think that I'm not real familiar with how the ACRS 7 impacts our schedule. I think that if you said, okay, 8 we have issues with this Reg Guide and we want to 9 discuss it at the full Committee meeting, then that 10 would definitely impact our schedule. If, on the 11 other hand, I don't hear any objections, I think we 12 would proceed. We would probably issue the Reg Guide 13 in September-October.

14 MEMBER REMPE: So, you're planning to 15 issue this Reg Guide in September, and it would be an 16 after-the-fact thing.

17 And Scott, I see, has his hand up. And 18 so, Scott, can you answer or provide comments on this 19 topic?

20 MR. MOORE: Yes. We've already published 21 the September agenda in The Federal Register. And, 22 Larry, you can correct me if I'm wrong, but we can't 23 add items to the agenda once we've published it. We 24 can take items off, but we can't add new items to it.

25 MEMBER REMPE: So, we're waiting until NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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84 1 October. And then, I understand what your point is, 2 Jose, but, again, this is not the full Committee 3 that's here today. And I just want to kind of bring 4 that point up, as we go around the table, because I'm 5 not hearing any concerns expressed by members about 6 what's in this Reg Guide. So, that's why I'm 7 thinking, naw, I don't think we need to do this 8 because the letter is just a nice letter, but there is 9 always some risk that somebody may think about it and 10 come up with something at the last minute. Plus, the 11 agenda for October is full.

12 MR. GARRY: Yes, I think the first 13 question is, does the Subcommittee want this to go to 14 make another presentation to the full Committee?

15 MEMBER MARCH-LEUBA: This is Jose.

16 I am not proposing that the staff make 17 another presentation. I'm proposing that we write a 18 letter during the full Committee. And the reason is 19 ACRS only speaks through letters. So, it does appear 20 ACRS is silent on this Regulatory Guide. And I think, 21 I mean, it's a matter of process or administrative, if 22 you want to call it that way. But, as of today, the 23 ACRS is silent on this.

24 MEMBER REMPE: What about this 25 alternative, where Ron comes to full Committee and he NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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85 1 says, "We had the meeting and the Subcommittee said 2 they're happy with the letter," and it's just some 3 sort of a notation in how we record what happens at 4 P&P?

5 MEMBER MARCH-LEUBA: If you remember, 6 that's what I proposed last P&P, that that would be 7 one way to do it. It's probably easier to write a 8 short letter, but I will love that: that in P&P, one 9 of the items comes and says, "As required by the 10 Bylaws, which were modified recently, I asked the 11 Subcommittee present in August, and we decided not to 12 write a letter, but we approve of the guide." And 13 that becomes a position of ACRS that the staff can get 14 from the record.

15 MEMBER REMPE: So, I would accept that 16 approach rather than having a letter.

17 CHAIR BALLINGER: That was what I was 18 actually planning on doing, should we not write a 19 letter. So, I'm fine with that.

20 MEMBER MARCH-LEUBA: I'm fine either way.

21 I'm just seeing that, as of today, the ACRS is silent 22 on this Reg Guide.

23 CHAIR BALLINGER: Now that I look at the 24 list, we have pretty much, except for Vesna, we have 25 everybody.

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86 1 MEMBER MARCH-LEUBA: Yes, but this is 2 Subcommittee. We cannot --

3 MEMBER REMPE: And Dave Petti is not here, 4 too, right?

5 CHAIR BALLINGER: Yes, yes, you're right.

6 You're right. You're right. Sorry.

7 MEMBER SUNSERI: So, this is Matt. Yes, 8 let me weigh in on this a little bit here.

9 What we're trying to do is we're trying to 10 create policy in a Subcommittee meeting, which isn't 11 going to work. So, whatever we do here won't be 12 sanctioned. We need to have this discussion during a 13 full Committee meeting.

14 In September, we're going to have an 15 opportunity to have a retreat. This would be a good 16 topic for it. Jose keeps bringing it up about these 17 good letters. We keep turning him away. So, we need 18 to get this finalized forever or change the way we're 19 doing business, but we can't do it during a 20 subcommittee meeting.

21 So, what I'm proposing is, we just conduct 22 business like we normally conduct it now, and that we 23 decide in the future whether or not we want to write 24 these beneficial letters.

25 And I would just remind everyone, a "no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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87 1 review" has been perfectly acceptable, and, in fact, 2 we don't have to weigh in on every topic. Only when 3 we have issues is it necessary for us to weigh in.

4 CHAIR BALLINGER: Good idea.

5 MEMBER BROWN: Can I make an observation, 6 Matt? This is Charlie.

7 MEMBER SUNSERI: Sure.

8 MEMBER BROWN: I mean, I agree with you we 9 don't have to do something on everything, every item 10 we review in a subcommittee. I think I've made that 11 comment before because I've faced that on a number of 12 things that I've had to review.

13 I did do a comparison of Rev. 2 to Rev. 3 14 paragraph by paragraph. That took a while, but it 15 looked to me like, other than the stuff they brought 16 up in the meeting, it was just the accident range 17 stuff, which was a whole new paragraph on how to 18 address that, which they covered pretty thoroughly.

19 It didn't seem to plow any new ground relative to 20 doses or what people can have, you know, what they're 21 allowed to do or not do. So, everything seemed to be 22 fairly stable.

23 I may have stated that wrong because I 24 couldn't actually go look at everything they ever 25 talked about. That would have taken too much time.

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88 1 The other change was they had a new 2 Section 8 talking about changes to effluent and 3 environmental programs, which didn't really set any 4 limits. It just said, if you're going to change 5 stuff, here's some things to think about. I may have 6 paraphrased that a little bit too much. So, this was 7 a pretty benign set of changes to me relative to going 8 through a number of the items and some the tables.

9 If we don't do a letter, we ought to get 10 this issue set up for ourselves in terms of how we 11 want to handle these more benign reviews, if that 12 makes sense. I wouldn't do anything on this. I don't 13 think any major changes were made.

14 Could the staff confirm that I'm either 15 ignorant or one way or the other?

16 MR. GARRY: Yes, this is Steve Garry.

17 I don't think there were any real 18 significant changes. I think it was an improvement, 19 and I don't think there was anything real 20 controversial. I think we had a good public licensee 21 review of the Reg Guide, and I think we responded to 22 their comments. So, as far as I'm concerned, I agree 23 that this is not a significant change.

24 MEMBER BROWN: I mean, no dose limits, no 25 absorb limits. We fundamentally are following NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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89 1 existing allowances. I didn't see you all change 2 anything from that standpoint.

3 MR. GARRY: No, that would require a 4 change to the regulations.

5 MEMBER BROWN: That's what I thought. So, 6 that's why think this is, from this standpoint, that's 7 the most important thing, is: did this review fall 8 out any things where we were far too restrictive or we 9 weren't restrictive enough? And what I got out of 10 your all's discussion was that there were no changes 11 in those types of calibrations relative to 12 restrictions.

13 MR. GARRY: Yes, I agree.

14 MEMBER BROWN: Okay. Thank you.

15 That's my observation, Matt.

16 CHAIR BALLINGER: Okay. Other member 17 comments?

18 Steve Schultz, do you have a comment that 19 you would like to make?

20 MR. SCHULTZ: Hi, Ron. Can you hear me?

21 CHAIR BALLINGER: Yes.

22 MR. SCHULTZ: Yes, I would just like to 23 weigh in, since it's Subcommittee, in a sense that the 24 overall evaluation by members here has indicated, and 25 through Steve's just recent comment associated with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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90 1 what the intent was here with regard to update of the 2 Reg Guide, it's pretty clear to me that there were 3 some important issues that were addressed, identified, 4 and then, addressed in the revision.

5 You mentioned, Ron, earlier that, while 6 the risk-informed approach was done in Rev. 2, not so 7 much here. But I think in terms of what has been 8 done, risk-informed, performance-based changes have 9 been made, either subtle or not so subtle. I think 10 both the staff and industry have a better 11 understanding of what needs to be done and what 12 improvements can be made. So, with regard to 13 regulatory guidance, I think it has been done in an 14 appropriate way with regard to a risk-informed 15 approach.

16 As Steve indicated, the good interchange 17 between NEI, interchange with regard to the public 18 comments, and then, I think the staff's response to 19 the public comments was extremely thorough, their 20 evaluation of them and how they handled it in terms of 21 changes and describing what would be done and what did 22 not need to be done with regard to the guidance 23 presentation as it stands.

24 So, I thought, overall, the work has been 25 really well done here in terms of identifying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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91 1 regulatory changes, the Reg Guide changes, and this 2 has been an excellent exchange between the industry 3 and the staff on this.

4 And, Steve, I thought excellent 5 presentation today, very well-organized, and an 6 appropriate level of detail that really communicated 7 the whole picture of what needed to be done and what 8 has been done to better move forward with this.

9 And I'd agree with Greg that going forward 10 into Part 53 is an important transition. There's, 11 again, some subtle changes, or not so subtle changes 12 that are associated with that with regard to effluent 13 releases that are going to be important to both 14 maintain and perhaps change in some ways.

15 MR. GARRY: Yes, it's a significantly 16 different design.

17 MR. SCHULTZ: Definitely, 18 CHAIR BALLINGER: Yes. Thanks.

19 Okay. Jose, is your hand being up a 20 residual or is it up?

21 MEMBER MARCH-LEUBA: It's no longer up.

22 CHAIR BALLINGER: It's no longer up?

23 Okay. Other comments from members?

24 (No response.)

25 I'm getting the gist -- well, we'll have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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92 1 to take this offline. But my general impression is no 2 letter. Unless there's an objection to that, we'll 3 have that discussion.

4 But, if that's all there is, I'd like to 5 personally thank the staff for doing a really great 6 presentation. In my time on the ACRS, we hadn't had 7 a presentation related to this. So, I thought it was 8 very informative and the Reg Guide was well-written.

9 So, if there aren't any other comments, we 10 are adjourned.

11 (Whereupon, at 11:51 a.m., the meeting was 12 adjourned.)

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.

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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 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 8

Standard Technical Specifications (Contd)

NUREG-1431 - Westinghouse

• 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 9

Standard Technical Specifications (Contd)

• 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 10

Standard Technical Specifications (Contd)

• 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)

• For iodines, tritium, and particulates

- Any organ - 1500 mrem/yr (0.17 mrem/hr) 11

Standard Technical Specifications (Contd)

• 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) 12

• 75 mrem/yr thyroid

Technical Specification 5.5.1 ODCM Offsite Dose Calculation Manual

• 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 13

• 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 50,000 Ci 5,000 Ci 500 Ci 50 Ci 1 Ci 1980 1990 2000 2010 2018 20

Liquid Effluent Trend - Median Cr-51, Fe-55, Co-58, Co-60, Nb-95, Ag-110m, Sb-124, Cs-134, Cs-137 1 Ci 0.1 Ci 0.01 Ci 0.001 Ci 21

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

• DOE tracks LLW disposals

• 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

• ROP oversight transitions to NMSS for decommissioning inspections

• 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 32 pathways greater than 10% of App I

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 37 Analytical Protocols

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 38 for Consequence Analysis

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 51

• NRC public dose limits (100 mrem/yr)