The State of the ODCM 2004 RETS/REMP Workshop Jim Key Key Solutions, Inc.

Where Are We Now? Majority Have Implemented –GL –“New” 10 CFR 20 Industry is Doing a Good Job!! –Demonstrated by REMP Programs –App I Limits Rarely Challenged

Current Concerns Insufficient Resources Disappearing Information Misunderstanding of ODCM Purpose Miscellaneous Missing Methodologies The Ugly ODCM Virtual Dose

Insufficient Resources Expertise Being Lost –Regulators –Licensee Reduction in Staffing –Regulator –Licensee Seeing High Personnel Turnover Reduction in Funding –Regulator –Licensee

Disappearing Information Loss of Technical Bases Section of Old RETS Loss of Supporting Documents Inability to Reproduce ODCM Dose Factors Removal of Calculation Details/Parameters to Procedures

Loss of Technical Bases Section of Old RETS Per 10 CFR – Bases Required for Tech Specs GL Removed RETS to ODCM (No longer part of Tech Specs) Bases No Longer Required!?!?

Loss of Technical Bases Section of Old RETS Bad Idea Bases Contain Information Found Nowhere Else –Bases for Noble Gas Concentration Limit in Liquids –Guidance for Dose and Dose Rate Calculations –Rationale for Setpoints –Etc.

Establish ODCM Technical Bases Document Rather Than Make “RETS Technical Bases” Disappear, Place in ODCM Tech Bases Document Document all Revisions/Decisions Related to ODCM/REC/REM Programs Good Idea for Litigation Defense

Misunderstanding of ODCM Purpose ODCM Is Not –Tech Spec –Procedure ODCM Is a Different Animal –Intended To Be Dynamic –Should Reflect Changes in Environment and Pathways

Misunderstanding of ODCM Purpose ODCM Shall Contain the Methodology and Parameters Used in the Calculation of: –Offsite Doses –Gaseous and Liquid Monitor Setpoints These Details Belong in ODCM NOT in Procedures

Misunderstanding of ODCM Purpose NRC Expects Changes to ODCM, REC and REM Programs to be Approved at Highest Level Danger If Details in Lower Tier Documents Changes Take Place Without Sufficient Technical (and Political) Consideration

Missing Miscellaneous Methodologies Radwaste Treatment System Operability Dose Projections “New” 10 CFR 20 Compliance 40 CFR 190 Compliance Direct Radiation Dose Dose to Member of Public While Onsite  /Q and Met Data

Radwaste Treatment System Operability Requirement Based Upon 31 (or 60 or 90) Day Dose Projection No Guidance Given on How To Project Dose “Doses Due to Releases Shall Be Projected in Accordance With the Methodology and Parameters in the ODCM” (NRC NUREGs) Is the 31 (or 60 or 90) Day Dose Projection Methodology in Your ODCM?

Determination of Compliance with 10 CFR 20 New 10 CFR 20 Dose in Terms of TEDE Still Required to Report Organ Dose Because Of: –10 CFR 50, Appendix I –40 CFR 190 Demonstrate Compliance Through –Appendix I –40 CFR 190 ODCM Needs to Clearly State How 10 CFR 20 Compliance is Demonstrated

Determination of Compliance with 40 CFR 190 Total Dose to Member of Public from Uranium Fuel Cycle Sources Does Not Distinguish Between Liquid or Gaseous Release Pathways

Determination of Compliance with 40 CFR 190 “Cumulative dose contributions from liquid and gaseous effluents shall be determined in accordance with the methodology and parameters in the ODCM” (NRC NUREGs) Does Your ODCM Address How Liquid, Noble Gas, Iodine-Tritium-Particulate and Direct Radiation Doses Will Be Used to Determine Total Dose?

Determination of Direct Radiation Dose “Cumulative dose contributions from direct radiation … shall be determined in accordance with the methodology and parameters in the ODCM.” (NRC NUREGs) Does Your ODCM Address How Direct Radiation Dose Will Be Determined?

Dose to Members of the Public Due to Onsite Activities “For MEMBERS OF THE PUBLIC who may at times be within the SITE BOUNDARY…” (NRC NUREGs) “Examples of calculation for such MEMBERS OF THE PUBLIC, with the appropriate occupancy factors, shall be given in the ODCM” (NRC NUREGs)

Dose to Members of the Public Due to Onsite Activities Sample Calculations Residence Times National Guard (Regulatory Issue Summary )

NRC – Regulatory Issue Summary “National Guard and Other Emergency Responders Located in the Licensee’s Controlled Area” “… licensees should evaluate the requirements of their ODCM and make changes … to account for the deployment of National Guard troops and State police, the duration of their stay, and doses received from routine operation of the facility.”

 /Q and Met Data Guidance Found in Reg Guides 1.23, 1.111, and NUREG 2919 No Guidance on How Often to Update  /Q and D/Q Should be Reasonably Up-To-Date NOT FSAR/UFSAR Values –Based on Met Data Years Old

 /Q and Met Data Historical  /Q Based On: –1, 2, 3, … Years of Met Data –Worst Case One Year  /Q from Last 2, 3, 5, … Years –Rolling Average of Last 2, 3, 5, … Years ODCM Should Clearly State Philosophy –What Period of Met Data Used for  /Q –Rational for Updating ODCM  /Q Values

The UGLY ODCM Difficult to Maintain Overly Complex Methodology Virtual Dose

Difficult to Maintain Methodologies Not Explicitly Stated in Mathematical Form Parameters with Potential for Change Scattered Throughout ODCM Overly Complex Equations Poor Quality Diagrams and Maps

State Methodology in Explicit Mathematical Form BAD - “The allowable release rate is determined by substituting 1500 mrem/yr for the dose rate and solving for Q-dot”

State Methodology in Explicit Mathematical Form GOOD -

Bad Idea – Potentially Changing Numerical Values Scattered Throughout ODCM The alarm/trip setpoint based on the skin dose rate limit is: where:  /Q=3.2E-06 sec/m 3 L i =…. M i =….

Place Numerical Parameters with Potential for Changing in Table The alarm/trip setpoint based on the skin dose rate limit is: where:  /Q=Dispersion at site boundary in sec/m 3 from Table A-3. L i =…. M i =….

Put Parameters Into Tables

Overly Complex Equations BAD -

Needed - Simple Equations GOOD -

Superscript/Subscript Overload

Un-Clear Mathematical Equations

The Humongous Equation      am I v I gp II am I v I gp II am p v p gp pp p vf PPPfPPPfPPPfDQ              

Avoid “Magic” Numbers Purpose of 2.0 and 0.7 used in these equations not defined in ODCM.

Overly Complex Methodology Very Few Real Reasons to Use Reg Guide Equations Non-Standard Methodologies (NUREG 0133) –Stand Out –Subject To Questioning and Doubt Use NUREG 0133 Keep Setpoint Methodology Clean and Simple

Ugly Map

Un-Ugly Map

Beautific Map

Calculation of Virtual Dose Dose Calculated Based on Non-Existing Pathways Overly Conservative Assumptions –All Dose Received at Site Boundary –Combining Various Existing Pathways into Single Receptor Location

Calculation of Virtual Dose Radioiodine and Particulate Dose to be Determined in Unrestricted Area Where: “combination of existing pathways and receptor age groups indicates the maximum potential exposures.” (NUREG )

Calculation of Virtual Dose Overly Conservative Calculations OK For: –Demonstration of Compliance Bad Idea For: –Dose of Record –Benchmarking

Where Are We Going? When Do We TEDE? Vanishing Pathways Emerging Pathways

When Do We TEDE? Currently Calculating Organ (ICRP 2) Doses 10 CFR 20 Limits Dose in Terms of Total Effective Dose Equivalent (TEDE) 10 CFR 50, App I & 40 CFR 190 Require Reporting in Terms of Organ Dose

When Do We TEDE? Current Licensees –Continue to Report Organ Dose New Licensees –NRC Will Address Revision to Guidance (Reg Guide 1.109/ NUREG 0133) –Revision Expected to Address TEDE

Vanishing Pathways Many Facilities Initially Sited in Rural Areas Where Agricultural Pathways Represented Highest Public Dose Potential Very Significant Changes in Demographics and Land Use Agricultural Pathways Disappearing at Many Sites

Emerging Pathways Per App I - Tasked with Assessing Dose to Real Individual from Existing Pathways With the Disappearance of Agricultural Pathways, Other Pathways May Become More Significant Contributors to Actual Public –Ground Plane –Recreational –Commercial Food –?

That’s All Folks!