ML091900366
| ML091900366 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Kewaunee, Surry, North Anna  |
| Issue date: | 06/23/2009 |
| From: | Funderburk C Dominion, Dominion Resources Services |
| To: | Rulemaking, Directives, and Editing Branch, NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 73FR03811 00036, DG-4014, GL09-025, PR-20, PR-30, PR-40, PR-50, PR-70, PR-72, FOIA/PA-2011-0115 | |
| Download: ML091900366 (5) | |
Text
PR 20,30,40,50,70 and 72 I;no.
173FR0381 1)
D)orminion Resources Services, Inc.
,1)oniion BouleAd Glen Allen, Dominion.
.\ h ,ddress: www.dorn.com June 23, 2009 DOCKETED USNRC July 8, 2009 (3:04pm)
Office of Administration OFFICE OF SECRETARY GL09-025 RULEMAKINGS AND U. S. Nuclear Regulatory Commission ADJUDICATIONS STAFF Washington, D.C. 20555-0001 ATTN: Rulemaking, Directives, and Editing Branch COMMENTS ON DRAFT REGULATORY GUIDE DG-4014.
"RADIOLOGICAL SURVEYS AND MONITORING DURING OPERATIONS" The proposed revision to Draft Regulatory Guide DG-4014, "Radiological Surveys and Monitoring During Operations" describes a method acceptable to the NRC staff for use in the implementation of revisions to Title 10, Section 20.1406(c), "Minimization of Contamination," and Section 20.1501 (a-b) of Subpart F "Surveys and Monitoring," of the Code of Federal Regulations during the operational phase of plant life. Dominion Resources Services, Inc. (Dominion) appreciates the opportunity to comment on this regulatory guide.
The draft regulatory guide includes requirements and programs associated with previously committed industry initiatives. Where previously defined industry standards and programs exist, DG-4014 should reference those guidelines, such as the NEI Groundwater Protection Initiative for groundwater monitoring (NEI 07-07), rather than establish duplicate requirements since application of the existing standard is already understood.
.Detailed comments are attached.
If you would like further information on our comments, please contact:
Carl Tarantino Carl.Tarantino@dom.com or (804) 273-3068 Respectfully, C.uL. Fn erbur Director Nuclear Licensing & Operations Support Dominion Resources Services, Inc. for Virginia Electric and Power Company, Dominion Nuclear Connecticut, Inc. and Dominion Energy Kewaunee, Inc.
Attachment
-F- Plc1 3CJ- hJ
Dominion Comments on Draft Regulatory Guide DG-4014 "Radiological Surveys and Monitoring During Operations" 1 In Section A, Introduction, page 2 of 18, the top sentence mentions "...the above stated numbers..." pertaining to on-site concentrations recorded for use in planning decommissioning activities and costs. Section A should be clarified by identifying the limits or values which are being referred to in the context of decommissioning activities.
- 2. In the third paragraph under Section B, Background Section, page 3 of 18, identification of contamination above background by the licensee is discussed. While the context of this section infers that the areas being addressed are within a licensee's Protected Area (PA) or Restricted Area boundary, explicit clarification of the specific areas being considered would be useful. For example, if the contamination above background is referring to areas, including the subsurface, located within the Radiological Control Area (RCA), inside plant structures, or within the licensee's PA, the level of remediation activities that may apply would be different from that which would take place where contamination is found outside the PA. Contamination in RCAs is currently addressed in decommissioning records and should not need to be included in this regulatory guide.
- 3. The first sentence under Section C.1 on page 6 of 18 states the requirement for licensees to identify source, location, and amount of contamination resulting from leaks or spills. The extent of evaluation for leaks or spills should be commensurate with the level of detection. The fifth paragraph of this same section discusses the identification of "large" leaks and spills inside and outside of facilities, for decommissioning records. The scope of evaluation and documentation for spills and leaks and characterization of the spill or leak should align with the accepted guidance for spills and leaks contained in NEI 07-07.
- 4. In Section C.2.1 on page 7 of 18, the areas a licensee should evaluate where radioactivity may accumulate or concentrate is discussed. Included are areas of crud accumulation inside pipes and tanks. It would not seem necessary to perform a separate evaluation for such areas because these areas would be addressed as part of the tank or pipe evaluation.
- 5. Section C.2.3 on page 11 of 18 presents evaluation measures for process configuration of operating facilities. The design of a facility calls for certain instruments to perform measurements and process monitoring, including area moisture detectors and sump level indicators. Area moisture detectors for outside tanks or underground piping may not be applicable or feasible for many applications, especially where rainfall or groundwater may present significant interference.
- 6. In the fifth paragraph on page 2 of 18, the last sentence refers to what is considered a "significant" amount of subsurface residual radioactivity, but does not provide any objective value as to what constitutes "significant." For purposes of remediation during decommissioning to meet the unrestricted use criteria of 10 CFR 20.1402, it would be helpful to provide values which are considered "significant" according to the definition provided in this section.
- 7. Figure 1-2b, Implementing Monitoring Plan, includes a decision box for contamination levels, referring to action or regulatory limits, without providing values corresponding to these action levels or limits. It would be useful and appropriate to include numerical values in this decision tree matrix.
- 8. The first paragraph of Section 2.4 on page 12 of 18 discusses criteria and limits for conducting prompt cleanup and for entering information into decommissioning files, however no values are provided. The information described in Section 2.4 is intended *to be used in the site's operating procedures and numerical values corresponding to the criteria included in this section would be useful.
- 9. On page 17 of 18, Paragraph 4.2 states, "The licensee should consider the following parameters to determine an appropriate level of effort to model groundwater in response to a contamination event." The word model is subject to the interpretation that modeling or a computer simulation is required. Rather than using "model", Dominion recommends using "characterize" or "assess" as a substitute.
Rulemaking Comments From: Gallagher, Carol Sent: Wednesday, July 08, 2009 11:08 AM To: Rulemaking Comments
Subject:
FW: Comments on Draft Regulatory Guide DG-4014 Attachments: GL09-025_Response_LtrOnly.pdf From: NRCREP Resource Sent: Wednesday, July 08, 2009 10:44 AM To: Shepherd, James; Ngbea, Evangeline Cc: Gallagher, Carol
Subject:
FW: Comments on Draft Regulatory Guide DG-4014 Good morning Van.... The attached file contains the comment from Dominion that Carol Gallagher discussed with you for docketing under the Decommissioning Planning Rule (AH45)- published on January 22, 2008; 73 FR 3812.
Thank you and have nice day.
Doris From: Vicki.Hull@dom.com [1]
Sent: Tuesday, June 23, 2009 3:32 PM To: NRCREP Resource
Subject:
Comments on Draft Regulatory Guide DG-4014 Attached are Dominion comments on the above subject.
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