ML15068A440
| ML15068A440 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 01/13/2015 |
| From: | Lougheed V NRC/RGN-III |
| To: | Bacquet J - No Known Affiliation |
| Lougheed | |
| References | |
| EA-14-168 | |
| Download: ML15068A440 (4) | |
Text
From:
Lougheed, Patricia To:
"Jim Bacquet"
Subject:
RE: Reg conference File EA-14-168 Date:
Tuesday, January 13, 2015 5:30:00 PM Attachments:
EA-14-168 Palisades Meeting Feedback Form.pdf Mr. Bacquet,
I apologize. We did have your questions and they were provided to the technical staff to answer at the meeting. There may have been some confusion in that when you spoke on the phone, we may have considered that you were asking all your questions so that there was no need to read them.
I will also be documenting your written questions in the conference summary report, which will be out within 30 days of the conference.
Finally, Ive attached a meeting feedback form. I would be interested in any comments that you have about the meeting. This is also available on the NRC meeting notice.
Thank you.
Patricia Patricia Lougheed Senior Enforcement Coordinator Nuclear Regulatory Commission, Region III 2443 Warrenville Rd, Lisle IL 60532, Suite 210 (630) 810-4376 Patricia.Lougheed@nrc.gov
From: Jim Bacquet [1]
Sent: Tuesday, January 13, 2015 4:55 PM To: Lougheed, Patricia
Subject:
Re: Reg conference File EA-14-168
- Patricia, May I assume my submitted questions were not considered to be within the scope of this regulatory meeting as they were not addressed? Perhaps I misunderstood the process you described concerning public questions.
Jim Bacquet On Jan 8, 2015, at 10:44 AM, Lougheed, Patricia <Patricia.Lougheed@nrc.gov> wrote:
Thanks Mr. Bacquet. I will forward these questions to the technical staff.
From:Jim Bacquet [2]
Sent:Thursday, January 08, 2015 9:14 AM To:Lougheed, Patricia
Subject:
Fwd: Reg conference File EA-14-168
- Patricia, Please review and forward the questions below. If clarification is required please feel free to contact me via email or phone.
A) Is there regulatory guidance (similar to that in IP 71124.01 03.05c) available to clarify when the dose gradient across the compartment would require relocation of a compartment dosimeter?
B) Given the complex radiological conditions, hot spot locations both above and below the work platform, the constant movement of temporary shielding during the job, and the unlimited number of possible body positions, what was the potential gradient over the compartments and why does the NRC believe that the utility failed to ensure dosimeters were located at the highest exposed portion of the respective compartment?
C) Had EDEx not been in use and only one WB dosimeter was used to monitor the entire body, where would the regulator have recommended placing this dosimeter?
D) Radiation shielding, whether placed on plant components, used in the form of shield walls, or worn by a nuclear maintenance worker, creates dose rate gradients in the work area and therefore affects the dose absorbed by the various compartments of the workers body. The inspector gave his opinion to the utility prior to the maintenance activity that the use of the personnel shield vest as shown by the excerpt below. The mention of additional weight and worker fatigue, dynamic worker orientation and non uniform fields would all be applicable had the shielding been installed in the area instead of attached to the worker and appears to show a predisposition to view the use of the shield vest in a negative manner.
The use of tungsten shield vests was a specific point of discussion between the inspectors and plant management in January 2014. Specifically, the inspectors identified several vulnerabilities regarding the use of tungsten shield vests when used in industrial settings and non-uniform radiation fields coincident with the application of EDEX. Other issues identified by the inspectors included the weight (~30 pounds) of the shield vest itself and the associated impact on worker fatigue, gaps in shielding protection that occur around the neck/thorax while in use, and dynamic worker orientations in relation to the sources of radiation in non-uniform radiation fields.
If the application of a shield vest on a radiation worker reduces exposure why would the regulator not embrace the ALARA concept by advocating its use and provide guidance on monitoring exposure rather than simply identifying vulnerabilities and accepting the additional, avoidable personnel exposure?
E) Concerning the additional weight and worker fatigue, fire brigade personnel wear turnout gear weighing ~50#, the shield vest weighs ~30#, the only difference is you can see the bodily damage inflicted by the heat, the cell damage inflicted by radiation is not as apparent. Are we no longer using the linear model for radiation exposure effects?
Thank you for your assistance Jim Bacquet 479 857 1236 Begin forwarded message:
From: Jim <bacquet_consulting@hotmail.com>
Subject:
Re: Reg conference File EA-14-168 Date: January 7, 2015 at 3:38:54 PM CST To: "Lougheed, Patricia" <Patricia.Lougheed@nrc.gov>
I will phrase my questions in a more concise manner and email them to you tomorrow so the panel can prepare their response beforehand. I will have to teleconference in so I won't need a badge.
Thank you Jim Bacquet Sent from my iPhone On Jan 7, 2015, at 3:33 PM, Lougheed, Patricia <Patricia.Lougheed@nrc.gov> wrote:
Thank you for your e-mail and your interest in the Palisades Regulatory Conference.
First off, if you are planning on participating via the telephone bridge, the number is 888-810-3950 and passcode "5477675."
If you plan to attend in person, please let me know so that I can have a visitor badge made up for you.
In regard to questions (relating to the regulatory conference radiation protection technical issue), you can do one of three things:
- 1) ask them now, and I will provide them to the technical participants prior to the conference;
- 2) ask them in the form of a e-mailed question during the conference and I will provide them to the technical participants during the question and answer portion of the conference; or
- 3) ask them directly during the question and answer portion of the conference.
From your writeup below, I believe that I could phrase your questions as:
A) Where is the guidance (similar to that in IP 71124.01 03.05c) found for when the dose gradient across the compartment would require relocation of a compartment dosimeter?
B) What was the potential gradient over the compartments and why does the NRC believe that the utility failed to ensure dosimeters were located at the highest exposed portion of the respective compartment?
C) How will workers know that they won't face an arbitrary regulator determination of which portion may have been exposed to the highest dose which will affect their livelihood?
Original Message-----
From: Jim Bacquet [3]
Sent: Wednesday, January 07, 2015 12:04 PM To: Lougheed, Patricia
Subject:
Reg conference File EA-14-168
- Patricia, I would like to be a participant in the upcoming enforcement conference as a member of the public. I have several questions to submit to the panel members concerning the lack of guidance in determining the highest portion of the exposed compartment when assigning external exposure using effective dose equivalent external using the seven compartment model. Guidance is provided in IP 71124.01 03.05c for determining when relocation of whole body dosimetry is required in non uniform fields, however there is no similar guidance for each compartment as to when the dose gradient across the compartment would require relocation of a compartment dosimeter. A statement is made repeatedly in the inspection report 05000255/2014010 that the utility failed to ensure dosimeters were located at the highest exposed portion of the respective compartment with no mention of what the potential gradient might have been.
I would appreciate it if you could provide me the most efficient method to submit and address my questions.
I am also concerned with the potential chilling effect, if using reg guide 8.40 to more accurately determine worker exposure, the user will be faced with enforcement action based on arbitrary regulator determination of which portion may have been exposed to the highest dose. The effect on the industry could include assigning higher exposures by relocating whole body dosimeters rather than by using a more scientific and accurate EDEx method. Assigning higher, more conservative exposure could potentially affect a nuclear workers ability to work the entire year thereby preventing them from providing a means of earning a living. This would be more significant for workers employed in high dose jobs early in the year.
Jim Bacquet 479 857 1236