ML18152B445
| ML18152B445 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/17/1999 |
| From: | Mccarthy J VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-64FR41604, RTR-REGGD-XX.XXX 64FR41604-00001, GL-98-33, NUDOCS 9909030076 | |
| Download: ML18152B445 (3) | |
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mns/Jrook Technical Center 5000 Dominion Boulevard Glen Allen, Virginia 23060 August 17, 1999 1999 AUG 23 AH 6: SLJ RULES & DIR. BRANCH US NRC Office of Administration U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attn: Rulemakings and Directives Branch DRAFT REGULATORY GUIDE, DG-4006; DEMONSTRATING COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION GL98-033 Virginia Power appreciates the opportunity to comment on the NRC's draft regulatory guide on how to demonstrate compliance with the radiological criteria at the sites of licensees who wish to terminate their licenses and release their sites. Notice of the issuance and availability of DG-4006 was published in the Federal Register (Vol. 63, No. 149) on August 4, 1998.
Virginia Power's comments are included in the attachment to this letter.
If you need further information, please contact either:
Alan Stafford Gwen Newman Alan_Stafford@vapower.com or (804) 894-5151 Gwen_Newman@vapower.com or (804) 273-4255
~(),e:
mes H. McCarthy, Manager Nuclear Licensing and Operations Support Attachment 9909030076 990817 PDR REGGD XX.XXX C PDR
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VIRGINIA POWER COMMENTS DRAFT REGULATORY GUIDE DG-4006; DEMONSTRATING COMPLIANCE WITH THE RADIOLOGICAL CRITERIA FOR LICENSE TERMINATION
- 1. Overall, this document is very general in nature. Many issues are left to the licensee's professional judgement. This document should be used for guidance, as is the case for all NUREGs.
- 2. The release criteria for a licensed site is heavily based on the DCGL, the Derived Concentration Guideline. The DCGL is the concentration, of residual radioactivity distinguishable from background that would result in a total effective dose equivalent (TEDE) of 25 mrems/year to a member of the critical group. It is unclear from this NUREG what criteria the NRG staff would require to approve the DCGL. Clearer guidance/requirements should be included in this NUREG.
- 3. Section 2.1, Para.3, p. 6.
A licensee should be able to change a classification after the final survey.
- 4. Section 2.2,
- Para.2.
When estimating survey areas/units of 100 square meters in buildings, one should include the surface areas of piping, cable trays, tanks, grating, etc.
A considerable amount of surface area that may be contaminated is not addressed by this section and needs to be.
- 5. Section 2.3.1.,Para. 1, line 7. If Ra-226 is used as a surrogate for natural uranium as recommended by this section, the equilibrium,
- concentration, and activity of daughter isotopes in the radium decay chain must be considered and verified against the concentration of natural uranium to assure a representative ratio of activity and potential exposure. If this verification is not done, an entirely different
- source term, and thus dose contribution, may result.
- 6.
Section 2.3.4., Para.3.
The method for determining background contamination given in this section may result in releasing material that is contaminated or borderline contaminated. The error used should be either the conventionally accepted 2 - 3 sigma of the measurement(s).
- 7. Table 2.2. The scanning coverage fractional for Classes 1 and 2 is termed "judgemental". This is very subjective. More specific guidance should be given.
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- 8. Section 2.10.1, Para. 1, last sentence.
This sentence states that survey results for residual radioactivity beneath the surface should be interpreted in accordance with dose modeling. The method of dose modeling should be defined or recommended.
This is quite subjective.
- 9. Section 3.1.2. The cost equation includes a variable for an estimate of waste disposal costs. No reliable method to estimate waste disposal costs exists, given the current state of the burial sites and associated regulations.
Therefore, this cost equation is extremely variable, unpredictable, and unreliable to the extent that is usefulness is doubtful. Also, there is no cost estimate for environmental factors in this equation; that variable should be included.