ML12208A091

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Comment (2) of Susan Reese, on Behalf of South Carolina Electric & Gas, on NRC-2012-0133-0001, NRC Form 5, Occupational Dose Record for a Monitoring Period
ML12208A091
Person / Time
Site: Summer South Carolina Electric & Gas Company icon.png
Issue date: 07/19/2012
From: Reese S
South Carolina Electric & Gas Co
To:
Rulemaking, Directives, and Editing Branch
References
77fr36583 00002, NRC-2012-0133-0001
Download: ML12208A091 (1)


Text

Page 1 of 1 As of: July 24, 2012 Received: July 19, 2012 PUBLIC SUBMISSION Status: PendingPost PUBLC SBMISIONTracking No. 810a5184 Comments Due: July 20, 2012 Submission Type: Web Docket: NRC-2012-0133 NRC Form 5, "Occupational Dose Record for a Monitoring Period" Comment On: NRC-2012-0133-0001 NRC Form 5, Occupational Dose Record for a Monitoring Period Document: NRC-2012-0133-DRAFT-0002 Comment on FR Doc # 2012-14872 (I.,

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Submitter Information Name: Susan Reese 7 "7 fFR3K.

Address:

P. 0. Box 88 MC 830 Jenkinsville, SC, 29065 Organization: South Carolina Electric & Gas Company/V. C. Summer Nuclear Station General Comment

-Layout of the proposed draft layout of NRC Form 5 No issues with the proposed layout of the new form.

-Estimated economic costs associated with modifying information technology (IT) systems to include EDEX field.

A total upgrade to the exposure tracking software would be required. The current version does not support this form and EDEX field. The estimated cost would be approximately $50,000.

-Estimated DOSE SAVINGS (not economic savings as incorrectly annotated in the Federal Register Notice - clarification received from NRC) associated with calculating EDEX for certain occupational employees.

EDEX has limited application but has the potential for significant dose savings with certain types of work; otherwise VCSNS does not expect much impact on dose savings from normal operations or refueling outages.

-Clarity of the instructions provided for completing the proposed draft NRC Form 5, specifically concerning the use of EDEX and new directions for blocks 1 A and 1 lB.

The instructions for block I1 a where it states " and the EDEX component estimated by the DDE..."

needs clarification. The term "estimated" lends to confusion because of its application in Block 9A.

Including examples for blocks 1 IA and 11LB in a separate guide could be beneficial.

-Other options, information or considerations.

Standard training and communication materials for all radiological workers and more detailed training with examples for radiation protection personnel would be beneficial.

-U https://www.fdms.gov/fdms-web-agency/component/contentstreamer?obj ectld=09000064... 07/24/2012