2014 RETS-REMP & Groundwater Workshop, June 23-27, 2014, Westin Savannah, Savannah, GA
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From the 2001 Workshop

Questions to ask the NRC

1. Using the historical meteorology that's used in the ODCM for estimating dose and end of year dose assessment for the annual radiological effluent report, how often should the  meteorology be updated, is one year of data adequate or should X number of years be averaged.  If so, how many years?

2. On site recreational doses for the general public - are these necessary, and why or why not (10CFR20, 100 millirem for general public)?

3. Total estimated errors for the annual radiological effluent report - propagating all errors by taking the particle derivatives of all inputs in determining the curies released and dose comes out as high as 1000%. Is there a recommended NRC acceptable method for determining the error to be used in the effluent report?

4. For reporting the offsite dose in the annual report, should all pathways be included?  For example: if there are no milk pathways within 5 miles of the site, should the milk pathway be included in the dose?

5. TMI had high tritium and had to evaporate to get rid of it after their accident. Being on the coast, they probably had fairly good meteorology. If an inland plant wanted to do the same thing, and build a stack to take advantage of mixed mode release, would this require a public hearing?

6. What is additional guidance (beyond "unplanned or uncontrolled" given in RG 1.21) for reporting of abnormal releases?

7. To avoid numerous trivial reports, is a threshold allowed for reporting abnormal releases? What should be the threshold?

8. What does NRC do with reports of abnormal releases?

9. Are the number of abnormal release events being used for performance tracking?

10. Can a plant be penalized for reporting an excessive number of abnormal releases because of a low threshold?

11. We have a building onsite that was converted from a warehouse-type structure to contain a carbon dioxide decontamination/blasting unit. Even though the decon unit was intended for equipment and scrap metals with a maximum of only a few tens of thousands of dpm/100 cm2, the unit has not been operated because the building has no installed ventilation system and no installed radiological air monitoring equipment. Although the potential for release of airborne radioactive material was low, and the decon process was to be filtered through portable HEPA units, it was felt that, because of the lack of installed ventilation and air monitoring equipment, there was the possibility for unmonitored release. This building is not identified as an effluent pathway.

Can this decontamination unit be operated in its current configuration and remain within regulatory bounds?

12. The reactor buildings onsite each have an equipment hatch (EH) for loading and unloading equipment during reactor unit outage. There are specific evolutions, such as fuel movement, during which the EH is required by Technical Specifications to be closed. The EH remains closed for much of the remainder of the outage. However, there are periods during which the EH remains open. During some time periods in which the EH is open, air sampling identifies small amounts of activity on the outside of the EH. Activity has been identified even when the reactor building purge is operating. In all likelihood, outside wind currents draw small amounts of air out of the reactor building via the EH. While it is believed that this activity "falls out" before leaving site, the activity is accounted as having been released. The reactor building purge, which discharges to the unit vent, is an identified effluent pathway and is continuously monitored and sampled.

Has this phenomenon been observed at other sites? What is the regulatory perspective regarding the "release" of activity in this manner?

13. If during an RFO, gaseous release process flow is secured, do you continue to run your sampling system? The prudent answer would be "Yes", in the event that: (1) the isolation wasn’t fully effective; (2) you had some unknown input to the system; or, (3) you had to immediately start the system to respond to some event. What do you assume for the ratio of sample flow rate to process flow rate, which technically becomes infinity?

14. If you measure NDA on noble gas grab samples, but have sporadic low level increases in PRM response, do you still assume no release, since there was no detectable activity in the sample by which to weigh/partition releases?

15. How do you determine noble gas conversion factors in which the PRM is exposed to a mix that is dominated by short –lived nuclides (e.g., Kr-90, T1/2=32 sec), which are absent from the mix when the gas sample is analyzed by gamma spectroscopy? The PRM is responding to a concentration that may be 10-20 times higher than what remains in the grab sample upon analysis. Do you adjust the PRM to account for the unknown/undetermined activity? Do you calculate the conversion factor based on only the identified/measured activity, since that is what is being released, and that which would contribute to offsite dose?

16. Do rigorous, hard-fast definitions of surveillance frequency intervals apply to collection of REMP samples? Do the hard-fast ‘rules’ of <1.25 * interval between successive samples, and <3.25 between third successive samples apply?

17. Inspection Procedure 71122.01 defines dose values below the design objectives of Appendix I to 10 CFR Part 50 and 40 CFR Part 190 as ALARA. 10 CFR 20.1101 (b) states: "The licensee shall use, to the extent practical, procedures and engineering controls based upon sound radiation protection principles to achieve occupational does and doses to members of the public that are as low as is reasonably achievable (ALARA)".
Questions are:
a. Would the NRC ever consider using a three year rolling average on releases to determine if a plant is operating in an ALARA manner?
b. If a plant has an increase in release rates from the previous year but below the plant's Technical Specifications and ODCM limits, would the NRC
consider that this plant is non-ALARA? If the answer is yes, then at what fraction of an increase would be considered non-ALARA?



North American Technical Center
Last Updated 02/22/2004

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