ML17306A450
| ML17306A450 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 02/04/1992 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-56FR65278, RTR-REGGD-08.007, RTR-REGGD-8.007, TASK-DG-8007, TASK-RE 161-04610-WFC-G, 161-4610-WFC-G, 56FR65278-00013, 56FR65278-13, NUDOCS 9202130050 | |
| Download: ML17306A450 (8) | |
Text
FQRD-1 REGULA INFORMATION DISTRIBUTIO YSTEM (RIDS)
ACCESSION NBR:9202130050 DOC.DATE: 92/02/04 NOTARIZED:
NO FACIL:STN-50-528 Palo Verde Nuclear Station, Unit 1, Arizona Publi STN-50-529 Palo Verde Nuclear Station, Unit 2, Arizona Publi STN-50-530 Palo Verde Nuclear Station, Unit 3, Arizona Publi AUTH.NAME AUTHOR AFFILIATION CONWAY,W.F.
Arizona Public Service Co. (formerly Arizona Nuclear Power RECIP.NAME RECIPIENT AFFILIATION Regulatory Publications Branch DOCKET 05000528 05000529 05000530
SUBJECT:
Comment on draft reg guide task DG-8007 (proposed rev 1 to reg guide 8.7) re instructions for recording a reporting occupational radiation exposure data.
DISTRIBUTION CODE:
DS09D COPIES RECEIVED:LTR ENCL SIZE:
TITLE: SECY/DSB Dist: Public Comment on Proposed Rule (PR)-Misc Notice;Reg G X NOTES:STANDARDIZED PLANT Standardized plant.
Standardized plant.
05000528 13 05000529 05000530 RECIPIENT ID CODE/NAME INTERNAL: OGC
-B-18 FILE 01 COPIES LTTR ENCL 1
1 1
1 1
1 RECIPIENT ID CODE/NAME OGC/SAIP15-B-18 RES DIR COPIES LTTR ENCL 1
1 1
1 EXTERNAL: NRC PDR 02 1
1 NOTES:
1 1
TOTAL NUMBER OF COPIES REQUIRED:
LTTR 7
ENCL 7
I
<4F/H 879 l&//$jipg Arizona Public Service Company P.O. 8OX 53999
~
PHOENIX. ARIZONA85072-3999 WILLIAMF. CONWAY EXECUTIVEVICEPRESIDENT NUCLEAR 161-04610-WFC/GAM February 04, 1992
'ocket Nos.
STN 50-528/529/530 U. S. Nuclear Regulatory Commission Attn:
Regulatory Publications Branch DFIPS, Office of Administration Washington, DC 20555
Dear Sirs:
Sub] ect:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3
Comments on Draft Regulatory Guide DG-8007 File: 92-056-026; 92-005-419.5 Enclosed are Arizona Public Service Company's comments on draft Regulatory Guide DG-8007, "Instructions for Recording and Reporting Occupational Radiation Exposure Data (Revision 1)."
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 I3ra o~
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161-04610-WFC/GAM February 04, 1992 Comments on Draft Regulatory Guide DG-8007 (proposed Rev.
1 to Regulatory Guide 8.7)
INSTRUCTIONS FOR RECORDING AND REPORTING OCCUPATIONAL RADIATION EXPOSURE DATA Page 2
Part B
DISCUSSION 0
The last sentence at the bottom of the page says that it is not necessary to update NRC Form 4 annually.
This needs clarification.
Based on a
review of the form and on the instructions on page A-2 for item 7 of NRC Form 4, it appears to be necessary to update the form every year to record continued monitoring.
Page 3
Part C
REGULATORY POSITION
~ "', The reporting of hot,particle exposure is not addressed in this guide.
In the NRC Policy Statement, "Enforcement Policy Regarding Occupational Doses from Hot Particles,"
the NRC stated that in evaluating whether a hot particle exposure has exceeded the limits of 10 CFR 20.101, they will not add hot particle exposures to skin doses from sources other than hot particles.
Also, hot particle exposures from different particles willnot be additive, unless, the particles were found in the same location of the
, body.
With no guidance herein, hot particle exposures will continue to be recorded and totalled as regular skin dose.
- Thus, a stochastic limitwill continue to be applied to nonstochastic exposures.
Page 3
Section 1
LIFETIME OCCUPATIONAL RADIATION EXPOSURE HISTORY NRC FORM 4 0
Footnote 4 to 10 CFR 20.2104 (d) states that "occupational exposure histories obtained and recorded on NRC Form,4 before January 1,
- 1991, would not have included effective dose equivalent, but may be used in the absence of specific information on the intake of radionuclides by the individual." This section of the Regulatory Guide should provide guidance for occupational exposure histories obtained and recorded on NRC Form 4 between January 1,
- 1991, and the implementation date of the revised 10 CFR 20, which may not be until the required date of January 1,
1993.
't I
t 161-04610-WFC/GAM February 04, 1992 Page 5
Section 1.4 NRC FORM 4 WITH MISSING BACKUP DOCUMENTATION 0
10 CFR 20.2104 (c)(1) provides for the use of a signed statement from the individual worker.
This provision needs to be included and discussed in this Regulatory Guide.
~
If there is an intention that licensees prorate annual dose limits for individual
- organs, eyes,
- skin, and extremities to comply with 10 CFR 20.2104 (e)(1),
as indicated in the answer to question 55, this should be explicitly stated in this Regulatory Guide (see question and answer number 55 in letter dated December 9,
- 1991, from Frank J.
- Congel, Director, Division of Radiation Protection and Emergency Preparedness, Office of Nuclear Reactor Regulation, U. S. Nuclear Regulatory Commission, to John F. Schmitt of Nuclear Management and Resources Council).
Page 7
Section 2.3 ACCEPTABLE SIMPLIFICATION FOR CALCULATING NONSTOCHASTIC DOSES Near the bottom of the page, the sentence beginning "The highest committed dose equivalent..."
should end with "CEDE", so that it reads:
"The highest committed dose equivalent to any organ is obtained by applying the most restrictive weighting factor of 0.03 to the CEDE."
0 On both NRC Form 4 and NRC Form 5, if the Total Committed Effective Dose Equivalent (TCEDE) is less than or equal to 1.2 rem and the Total Effective Dose Equivalent (TEDE) is less than 10 rem, then the licensee is not required to record the Committed Dose Equivalent (CDE) and the Organ Dose Equivalent.
Assuming the most limiting weighting factor of 0.03, a
TCEDE of 1.2 rem woul'd result in an exposure of 40 rem to the thyroid or to the surfaces of the bone.
An exposure of 40 rem represents 80% of the 10 CFR 20.1201 (a)(1)(ii) nonstochastic dose limit of 50 rem.
Monitoring of internal exposure,
- however, is required at 10% of the nonstochastic dose limit per 10 CFR 20.1502 (b)(l) ~
A TCEDE of 1.2 rem could more appropriately be used as a flag to alert licensees that exposures to individual organs may be approaching their respective nonstochastic dose limit of 50 rem when combined with the deep-dose equivalent.
Page B-6 Item 29 Information on NRC Form 5
~
The sentence comprising item 29 has a typographical error and a missing word.
It should read:
"Enter the total shallow-dose equivalent to the skin of the whole body of item 22a entries."
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