ML17221A246
| ML17221A246 | |
| Person / Time | |
|---|---|
| Issue date: | 05/31/2018 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Shared Package | |
| ML17221A239 | List: |
| References | |
| RG-8.007, Rev 4 DG-8056 | |
| Download: ML17221A246 (7) | |
Text
Response to Public Comments on Draft Regulatory Guide DG-8056, Instructions for Recording and Reporting Occupational Radiation Dose Data (Proposed Revision 4 of Regulatory Guide 8.7)
On October 16, 2017, the Nuclear Regulatory Commission (NRC) published a notice in the Federal Register (82 FR 48125) announcing that Draft Regulatory Guide 8056 (DG-8056, proposed Revision 4 of Regulatory Guide (RG) 8.7) was available for public comment. The published version of DG-8056 was made available in the NRCs Agencywide Document Access and Management System (ADAMS) under accession number ML17144A182. The public comment period ended on December 15, 2017. The NRC received comments from the organizations listed below.
The bracketed identifiers at the end of each comment relate to annotations the NRC applied to the received comment documents. The complete versions of the received comment documents are available in ADAMS under the indicated accession numbers below. The following table documents the public comments and NRC staffs responses.
The NRC received comments from the following:
Mr. Stephen Cowne Mrs. Ellen Anderson Mr. Jack Kraus URENCO USA < exa@nei.org > < jgkraus@firstenergycorp.com >
LES, PO Box 1789 Nuclear Energy Institute First Energy Corporation Eunice, NM 88231 1201 F Street, NW Suite 1100 5501 N. State Route 2 Dated: December 13, 2017 Washington, DC 20004 Mail Stop: A-DB-1029 Dated: December 15, 2017 Oak Harbor, OH 43449 ADAMS Accession No.: Dated: December 15, 2017 ML17355A125 ADAMS Accession No.:
ML17355A126 ADAMS Accession No.:
Number Commenter Specific Comments NRC Resolution UUSA-1 URENCO Regarding the statement, However, dose assessments performed The NRC agrees in part and disagrees in part with the comment.
USA to quantify unanticipated intakes or exposures are considered The NRC decided to delete this sentence in the final RG because required monitoring, regardless of the magnitude of the resulting the staff determined that clarifying language to address the doses, and results must be recorded and reported accordingly, in comment would be beyond the scope of RG 8.7. Instead, the staff Section 1.1 of DG 8056 If Monitoring is Not Required, UUSA intends to revise RG 8.34, Monitoring Criteria and Methods to believes that minor doses should not be included up to a total of 10 Calculate Occupational Radiation Doses, in the near future and mrem per year. will revisit this staff position during that effort.
Our concern with this issue is on the definition of unanticipated As background, the NRC staff believes that the position in the intakes. UUSAs protocol would include writing a dose statement is consistent with existing staff positions (e.g.,
evaluation for any urinalysis >0.27 mg/L which requires to 0.50 NUREG/CR-6204, Question 212, and letter Final Response to mrem of committed effective dose equivalent (CEDE). The Task Interface Agreement 2014-09 dated June 13, 2016 conservatism from the draft RG lies in events where there would ADAMS ML15187A388). The terminology unanticipated refers only be a fraction of a mrem, for instance 0.03 mrem CEDE. The to situations that a licensee has not included within the scope of the RG states unanticipated intakes that are found during a routine prospective evaluation to determine the need to monitor in bioassay would be recorded and reported. UUSA finds it accordance with 10 CFR 20.1502. In this context unanticipated unreasonable to record and report an intake of less than 10 mrem. does not include discreet events that occur within the scope of the prospective evaluation but may be violations of licensee procedures or situations where an employee unintentionally receives a dose or receives a dose in excess of what was predicted for a particular activity. In the commenters example, if one assumes that the licensee has determined that internal monitoring is not required and documented that conclusion in a prospective evaluation and that the licensee has elected to perform voluntary monitoring, then, unless the results of the voluntary monitoring exceed the criteria of 10 CFR 20.1502, the results of this voluntary monitoring are not subject to recording and reporting requirements of 10 CFR 20.2106 and 20.2206. However, if a licensee did not perform a prospective evaluation for internal exposure to determine the likeliness of exceeding the internal monitoring criteria of 10 CFR 20.1502, then any internal monitoring the licensee performs, including calculations, associated with assessing internal exposures would be considered required monitoring. The results of required monitoring shall be recorded and reported to the NRC pursuant to 10 CFR 20.2106 and 20.2206, respectively.
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Number Commenter Specific Comments NRC Resolution NEI-1 Nuclear For guidance consistency, we suggest that the requirements for The NRC disagrees with the comment. RG 8.7, Section 1 contains Energy monitoring only be included in RG 8.34 and not in RG 8.7 because a short discussion pertaining to the monitoring requirements of Institute it is out of scope for RG 8.7. 20.1502 that is necessary to effectively convey the overall regulatory requirements for recording and reporting of occupational dose data. The discussion in Section 1.1 was verified to be consistent with previous staff positions and the guidance contained in RG 8.34. No changes were made in response to this comment.
NEI-2 Nuclear Section 1, top paragraph, last sentence of page 7 reads in part The NRC agrees in part and disagrees in part with the comment.
Energy However, once a licensee has determined to monitor the Institute occupational dose the licensee must meet the requirement of 10 The final RG was revised to remove the discussion of 10 CFR CFR 20.1201(f) to reduce the dose that the individual may be 20.1201(f) from section 1 because it is already included in the first allowed to receive in the current monitoring year by the amount of paragraph of Section 1.3, where this type of discussion is more occupational dose the individual received while employed by any appropriate.
other person.
We believe that this sentence as written could cause licensee confusion. We suggest that this sentence be reworded for clarity.
Suggested wording is as follows: However, once a licensee has determined to monitor the occupational dose the licensee must meet the requirement of 10 CFR 20.1201(f). That licensee must account for and consider the dose already received while employed by any other licensee such that they do not exceed the occupational dose limit for that current year.
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Number Commenter Specific Comments NRC Resolution NEI-3 Nuclear DG-8056 now requires licensees to record and report dose when The NRC agrees in part and disagrees in part with the comment.
Energy dose assessments, e.g. calculations, are performed to quantify The NRC decided to delete this sentence in the final RG because Institute unanticipated intakes or exposures, regardless of the magnitude of the staff determined that clarifying language to address the the resulting dose. We note that there is nothing in 10 CFR comment would be beyond the scope of RG 8.7. The staff intends 20.1502 that requires monitoring of unanticipated dose. This is a to revise RG 8.34, Monitoring Criteria and Methods to Calculate new interpretation of the requirements of 20.1502 governing the Occupational Radiation Doses in the near future and will revisit monitoring of external and internal occupational doses in a way this staff position during that effort.
that is substantially different from the long-standing interpretation provided in previous versions of RG 8.7, as well as the current As background, the NRC staff believes that the position in the revision of RG 8.34. This interpretation is also inconsistent with statement is consistent with existing staff positions (e.g.,
decades of industry practice that the NRC has previously accepted NUREG/CR-6204, Question 212, and letter Final Response to as sufficient to meet the requirements of 20.1502, and represents an Task Interface Agreement 2014-09 dated June 13, 2016 unanalyzed backfit that does not meet the requirements within 10 ADAMS ML15187A388). The terminology unanticipated refers CFR 50.109. Industry urges NRC to remove all requirements to situations that a licensee has not included within the scope of the contained in DG-8056 for monitoring due to unanticipated intakes prospective evaluation to determine the need to monitor in or exposures because this requirement is not required per 10 CFR accordance with 10 CFR 20.1502. In this context unanticipated 20.1502. does not include discreet events that occur within the scope of the prospective evaluation but may be violations of licensee procedures or situations where an employee unintentionally receives a dose or receives a dose in excess of what was predicted for a particular activity. In the commenters example, if one assumes that the licensee has determined that internal monitoring is not required and documented that conclusion in a prospective evaluation and that the licensee has elected to perform voluntary monitoring, then, unless the results of the voluntary monitoring exceed the criteria of 10 CFR 20.1502, the results of this voluntary monitoring are not subject to recording and reporting requirements of 10 CFR 20.2106 and 20.2206. However, if a licensee did not perform a prospective evaluation for internal exposure to determine the likeliness of exceeding the internal monitoring criteria of 10 CFR 20.1502, then any internal monitoring the licensee performs, including calculations, associated with assessing internal exposures would be considered required monitoring. The results of required monitoring shall be recorded and reported to the NRC pursuant to 10 CFR 20.2106 and 20.2206, respectively.
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Number Commenter Specific Comments NRC Resolution NEI-4 Nuclear As defined in Part 20 and implemented by radiation protection Please see the responses to Comments Nos. UUSA-1 and NEI-3.
Energy programs for decades, industry believes surveys and monitoring The staff deleted the last sentence of the first paragraph of Section Institute results that serve as confirmatory measures also include dose 1.1 of DG-8056 (If Monitoring Is Not Required) in the final RG calculations, and therefore should not be subject to dose for the reasons stated in those comment responses.
recordkeeping requirements of 10 CFR 20.2106(a), provided such results confirm that actual individual doses are less than 10% of the annual limits. Dose calculations are performed subsequent to unanticipated intakes or exposures to confirm prospective dose evaluation assumptions that individuals will receive less than 10%
of the annual limits. We believe that performance of these calculations to confirm assumptions should not be considered monitoring nor should they be subject to the individual dose recordkeeping requirements of 10 CFR 20.2106(a) provided such results confirm that actual individual doses are less than 10% of the limits.
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Number Commenter Specific Comments NRC Resolution FE-1 First Energy The statement on recording and reporting dose assessments for Please see the responses to Comment Nos. UUSA-1 and NEI-3.
Corp quantifying unanticipated intakes or exposures should be revised.
This section states it is required regardless of the magnitude of the resulting doses. This appears to be a contradiction of RG 8.34, Section 1.4. This sections states, Surveys and monitoring results that serve as confirmatory measures are not subject to the individual recordkeeping requirements or 10 CFR 20.2106(a) provided such results confirm that actual individual doses are less than 10% of the limits.
While confirmatory measures is not defined in 10 CFR 20, the term survey is defined. Specifically, the definition of survey is an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation.
When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present.
Through these definitions, it appears the two RGs contradict on whether or not doses for such confirmatory measurements and calculations are required to be assigned. Industry practice on this topic is also not consistent with what is stated in the draft guidance presented. Since the requirements in 10 CFR 20.1502 have not been revised, it is unclear why the interpretation of this regulation is being revised through this draft guidance. Therefore, the draft guidance should be revised to remove the requirement for recording calculated doses regardless of the magnitude (as described above) and reflect what is found in RG 8.34, 10 CFR 20.1502 and industry practice.
FE-2 First Energy Also in the statement quoted above from Section 1.1 of DG-8056, The staff agrees with and appreciates this comment. This sentence Corp the last sentence appears to be missing the word be between has been deleted from the final RG for the reasons provided in the must and recorded.
responses to Comment Nos. UUSA-1 and NEI-3.
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