ML17306A388
| ML17306A388 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 01/08/1992 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| RTR-REGGD-08.025, RTR-REGGD-8.025, RTR-REGGD-8.038, RULE-PR-20-MISC, TASK-DG-8003, TASK-DG-8004, TASK-DG-8005, TASK-DG-8006, TASK-RE 161-04558-WFC-G, 161-4558-WFC-G, NUDOCS 9201150093 | |
| Download: ML17306A388 (22) | |
Text
ACCELERATED DISTI+UTION DEMONSTPWTON SYSTEM REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9201150093 DOC DATE ~ 92/01/08 NOTARIZED:
NO DOCKET
~1T FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi 05000528 AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Arizona Public Service Co.
(formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Regulatory Publications Branch R
SUBJECT:
Provides comments re draft Reg Guides DG-8003,DG-8004, DG-8005 6 DG-8006.
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Arizona Public Service Company P.O. BOX 53999
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PHOENIX, ARIZONA85072<999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 161-04558-WFC/GAM January 08, 1992 Docket No.
STN 50-528 U.
S. Nuclear Regulatory Commission Attn:
Regulatory Publications Branch DFIPS, Office. of Administration Washington, D.C.
20555
Dear Sirs:
Sub) ect:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 Comments concerning draft Regulatory Guides DG-8003, DG-8004, DG-8005 and DG-8006 File: 92-056-026; 92-005-419.5 The Nuclear Regulatory Commission recently issued for public comment drafts of several Regulatory Guides related to the recently revised 10 CFR part 20, Standards for Protection Against Radiation.
Enclosed with this transmittal are comments from the Arizona Public Service Company on the following draft Regulatory Guides:
2.
3.
Regulatory Guide DG-8003:
Regulatory Guide DG-8004:
Regulatory Guide DG-8005:
Regulatory Guide DG-8006:
"Air Sampling in the Workplace,"
(Revision 1)
"Radiation Protection Programs for Nuclear Power Plants" "Assessing External Radiation Doses from Airborne Radioactive Materials" "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants" If you should have any questions, please contact Michael E. Powell of my staff at (602) 340-4981.
Sincerely, WFC/GAM/gam Enclosure cc:
J.
B. Martin D. H.
Coe A. C. Gehr A. H. Gutterman 9201'1 0+000528 920108 pDp POOC p
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t 161-04558-WFC/GAM January 08, 1992 Comments on Draft Regulatory Guide DG-8003 Proposed Revision 1 to Regulatory Guide 8.25 AIR SAMPLING IN THE WORKPLACE Page 4
Section 1.
TYPES OF AIR SAMPLING NEEDED
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The last sentence of this section would appear to say that the section is not applicable to nuclear power plants.
Nuclear power plants have procedures specifying when and what air sampling must be done.
- Further, whatever is adopted from this regulatory guide must also be put into procedures, adding additional specificity to the procedures.
Accordingly, there would be "no reason to use the methods described in this section".
Clarification is needed as to whether this is the intent.
Page 4
Section 1.1 Whe to Evaluate the Need for Air Sam lin
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1E4 times the ALI should read 1E6 times the ALI.
The factor lE4 is only consistent with the Brodsky observation if ALI is expressed in percent.
Such is not the case here; percent ALI is not introduced until the next page.
In any event, there is an implication in this section that intakes exceeding one-millionth of the material used are unlikely and that air sampling is not required for intakes of 0.01 ALI or exposures of 20 DAC-h.
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The phrase "existing operations" can be subject to interpretation.
Would all normal activities at a nuclear power plant be, considered existing operations or would each establishment of a contamination
- area, for example, require a'eparate calculation of hazard index2 We suggest that this section specify that proposed evolutions subject to Part 50 (everything in a nuclear-power plant), of a type already described in plant procedures, have air sampling needs determined by previous air sampling results when available.
Page 4
Section 1.2 Hazard Index I'
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The concept of hazard index only addresses intakes.
In a nuclear power plant one also samples noble gas to determine skin dose.
If the airborne activity is strictly noble gas in uniform concentrations, the results can also be used to assess deep dose equivalent and eye dose equivalent.
The section should mention the noble gas considerations.
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161-04558-NFC/GAM January 08, 1992 Page 5
Section 1.3 Calculatin a Hazard Index
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This is not a suitable model for a nuclear power plant; where the worker goes to various work areas during the workday, there is no radioactive material throughput as
- such, and confinement is much better than 10.
It may be appropriate where the worker is more stationary and the radioactive material is processed at or through work stations; that is not usually the case at a nuclear power plant.
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The Hazard Index (HI) to evaluate the need for air sampling in an area is subjective and too cumbersome for use in nuclear power plants.
Professional judgement by the health physicist or health physics technician as to air sampling requirements has worked well.
The HI example of a nuclear power plant situation, in NUREG-1400, is an example of this process being unnecessary and too complex. It is unnecessary since an air sample would always be taken under the radiological conditions given in the example.
To calculate all of the contamination on the floor in addition to the contamination on and in the valve is unrealistic and would not provide meaningful information.
The assumption that a possible intake of 0.05 ALI is acceptably low is naive; this corresponds to a dose of 250 mrem. It would be difficult to back calculate the activity inside the valve, and probably inaccurate in the field.
The more complex geometries
'would be impossible 'to calculate in the field.
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Q for one-time jobs should be the material present, not a year' worth of material which will pass through the component.
This is particularly true if F is set equal to 50 for the one-time job.
Also Q for one-time jobs should be determined after hot spots are flushed prior to opening the system.
R and C are precise only to orders of magnitude.
This can result in the calculated Hazard Index being imprecise by a factor of 100.
This illuminates the fact that the hazard index is based on intuition, and is no substitute for experience and air sampling measurements as-you-go.
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Hazard Index determination is nuclide-specific.
In a nuclear power plant this would require nuclide identification, e.g.
via gamma spectroscopy, prior to each system breach.
This has never been necessary for internal exposure control in an intact nuclear power plant.
Utilities have internal exposure control progra'ms currently in place that do an excellent j'ob of preventing uptakes without this requirement.
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161-04558-MFC/GAM January 08, 1992 Page 8
Section 2.2 Observation of Airflow Patterns Evaluation of airflow patterns could require significant program modifications and resource commitment, without commensurate benefit.
Observation of airflow patterns involves fairly lengthy studies, and seems more suited to manufacturing-type work of a routine, continuing nature.
Page 9
Section 2.7 Use of Res irator Protection E ui ment 0
Please describe here the impact, if any, of the new Part 20 on the application of protection factors for respirators.
In the prefatory comments in the Federal Register of May 21,
- 1991, page
- 23377, there appears a
confusing statement which 'can, be at least, partially clarified,here:'
,",...the concentrations to be used 'for evaluating monitoring 'thre'sholds are those of the ambient atmosphere before credit is taken for respiratory protection factors."
(This also deserves, attention, in Regulatory Guide -8.15.)
i' Page ll Section 3.4 Location of Sam le Points f
0 This section: has limited ap'plicability in a'nuclear power plant, as the majority of the work is not.done at a "frequently occupied work station".
Page 11 Section 3.7 Ad ustin DACs for Particle Size
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This will probably have no application at nuclear power plants.
At Palo Verde the air concentrations of particulates and iodines are typically below 25% of MPC and probably also below 10% of DAC, and this is probably common at other nuclear power plants.
Further, if it were applied at a nuclear power plant, numerous AMAD assessments would be involved.
The staffing necessary to support DAC adjustment cannot be justified with such low levels of exposure.
DAC adjustment is more applicable to routine factory work stations where airborne materials are generated the same ways continually.
Page 14 Section 4.4 Prom t Anal sis 0
This
- section, as well as the entire regulatory
- guide, needs to specifically exclude byproduct material noble gas from the scope.
Xenon and krypton nuclides have DAC values, but no ALI values.
As currently written, this section would require shiftly containment atmosphere samples whenever we are working for extended. periods in noble gas.
Page 14 Section 4.5 Alarm Set Points 0
The recommended set point value of 8 DAC-'h for CAMs is too high.
161-04558-VFC/GAM January 08, 1992 Page 17 Section 5.4 Pressure-Tem erature Correctio
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The 5S value given should be changed to 10%.
In most cases, the pressure-temperature correction will be insignificant by itself. It will also be insignificant in comparison to other errors in the estimation of internal dose.
Page 18 Section 6.4 Demonstration that Breathin Zone Sam lin Is Re resentative
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The one-foot criterion applies to exposure situations where the potential release point is at the work location.
When the exposure comes from more generalized
- sources, the one-foot criterion is overly restrictive.
See comment on section 3.4, above.
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161-04558-WFC/GAM January 08, 1992 Comments on Draft Regulatory Guide DG-8004 also known as Regulatory Guide 8.N.1 RADIATION PROTECTION PROGRAMS FOR NUCLEAR POWER PLANTS Page 4
Figure l.
ELEMENTS OF AN EFFECTIVE R P PROGRAM 0
There is an error under the box labeled "Control of the Workplace":
the entry "Compliance Evaluation" should be "Individual Responsibility", to be consistent with the outline used for the text which follows Figure 1.
K Page 5
Section 2.1 Or anization and Administration Item 4 calls for details on RP functions performed by contractor services.
No rationale is given, and no requirement exists in the regulations, for requiring this information to be included in the radiation protection program.
Item 4 is unduly restrictive and should be deleted.
Page 6
Section 3.1.1 Radiation Source Control 0
This section appears to be requiring certain ALARA program aspects that up to now have been voluntary measures.
The examples given are all good aspects of ALARA, but the cost-benefit analysis results would vary widely from plant-to-plant.
Page 8
Section 3.1.4 Surveillance 0
Item 4 should be Tgge of Equipment to be used in the surveys".
There is no need to restrict the licensee to the exact equipment to be used.
Page 9
Section 3.2.1 Control of Radioactive Materials
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This section asks for too much detail in a program document.
The means for the control, etc. of radioactive materials and criteria for the release of materials are details which should be relegated to lower level documents, such as administrative controls and implementing procedures.
Page 9
Section 3.2.3 Work Practices
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This section also asks for too much detail for a program document.
The required information should be in lower tier documents.
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161-04558-WFC/GAM January 08, 1992 Page 12 Section 4
EVALUATE PROGRAM PERFORMANCE
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This section would mandate a Corporate assessment role.
The new 10 CFR 20 is silent on any implied changes to minimum staffing, and therefore the section should be deleted.
Page 13 Section 4.3 Reviews and Audits 0
The listed Radiation Protection su ervisor reviews and Cor orate or contract audits are both outside the requirements of current and new 10 CFR 20 and should be deleted.
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161-04558-NFC/GAM January 08, 1992 Comments on Draft Regulatory Guide DG-8005 also known as Regulatory Guide 8.N.8 ASSESSING EXTERNAL RADIATION DOSES FROM AIRBORNE RADIOACTIVE MATERIALS This Regulatory Guide does not appear to be necessary.
The proper assessment of external radiation exposure from airborne radioactive materials is already well known and does not need to be elaborated.
This draft contributes to confusion instead of providing useful guidance on the requirements of 10 CFR 20.1203.
For example, it states in section C that personnel dosimeters should not be used to measure exposure from noble
- gases, but later goes on to discuss dosimetry systems for the measurement of noble gases.
Nowhere in this draft guide is there mention that it is acceptable to calculate the shallow dose equivalent and eye dose equivalent based on air sample data.
The Regulatory Guide only discusses the need to ad]ust algorithms to properly measure airborne radionuclides using personnel dosimeters.
Current TLD technology does not allow for the accurate assessment of shallow dose equivalent from weak energy beta particles such as Xe-133.
Also, the assessment of eye dose equivalent by TLD in a mixed field of airborne radioactive material is extremely difficultand can result in error many times that which would result from using air sample data to perform the dose calculation.
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161-04558-MFC/GAM January 08, 1992 Comments on Draft Regulatory Guide DG-8006 also known as Regulatory Guide 8.N.10 CONTROL OF ACCESS TO HIGH AND VERY HIGH RADIATION AREAS IN NUCLEAR POWER PLANTS Page 1
Part A.
INTRODUCTION Aside from the new definition, of Very High Radiation Area and the revision in the definition of High Radiation'rea, there is little new guidance into areas not already addressed in current radiation protection programs.
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Section 1.
GENERAL
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This guide states that "an accessible area is defined as one that can reasonably be occupied by a significant portion of an individual's body."
A definition of "significant portion" is needed.
One possible definition might be "any and all portions of an individual's body".
Another possible definition is equivalency with "major portion" as that term is currently used.
Page 4
Section 1.5 Ph sical Controls It would be advisable to mention in this section that surveys of high radiation areas need to document the location and status of physical
- controls, in order to determine what would constitute reasonable occupancy vs. unreasonable occupancy, since "reasonable" is becoming part of the equation for determining radiation areas.
Survey documentation is discussed in the next section, but only in the context of a pending entry into the High Radiation Area.
Page 11 Section D.
IMPLEMENTATION
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Clarification needs to be provided in this section regarding 10 CFR 20.1008, "Implementation",
20.1008 gives the requirements and criteria for implementation.
Each plant in NRC Region V has the Technical Specification exemption from 20.203 (c)(2).
That Technical Specification is more than simply an exemption, however; it provides alternate means, via license requirements, for complying with 20.203 (c)(2),
and prescribes requirements.
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161-04558-NFC/GAM January 08, 1992 The High Radiation Area requirements in the Technical Specifications measurement distance 18 inches vs 30 cm. in the new art 20 The Technical Specifications also use the terminology "major portion" instead of "significant portion" as discussed earlier.
There is also a more-or-less-restrictive consideration for new Very High Radiation Area requirements vis-a-vis the Technical Specification requirements on Locked/Flashing Light High Radiation Areas.
Page D-1'ppendix D
Acce table Method for Control of Access to Hi h adiation Areas 0
Line 9 should have the words or symbols "per hour" inserted so that it reads
"...than 1.0 rem/hour...",
since the sentence is about exposure rates, not exposure.
The first line of the footnote should read "*In which the intensity of radiation is equal to or less than 1 rem/hr at..."
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