ML19190A126

From kanterella
Jump to navigation Jump to search
Comment (1) of Ronald Lavera on Safety Related Concrete Structures for Nuclear Power Plants (Other than Reactor Vessels and Containments), DG-1283
ML19190A126
Person / Time
Issue date: 05/01/2019
From: Ronald Lavera
Office of New Reactors
To:
Office of Administration
References
84FR16897 00001, DG-1283, NRC-2019-0100
Download: ML19190A126 (2)


Text

Page 1 of 2 SUNSI Review Complete Template = ADM-013 E-RIDS=ADM-03 ADD: Tom (RES) Boyce As of: 5/2/19 1:25 PM Received: May 01, 2019 Status: Pending_Post PUBLIC SUBMISSION COMMENT (1)

PUBLICATION DATE:

4/23/2019 Tracking No. 1k3-99no-fnz2 CITATION 84 FR 16897 Comments Due: June 24, 2019 Submission Type: Web Docket: NRC-2019-0100 Safety Related Concrete Structures for Nuclear Power Plants (Other than Reactor Vessels and Containments),

DG-1283 Comment On: NRC-2019-0100-0001 Safety Related Concrete Structures for Nuclear Power Plants (Other Than Reactor Vessels and Containments)

Document: NRC-2019-0100-DRAFT-0001 Comment on FR Doc # 2019-08093 Submitter Information Name: Ronald LaVera Address:

U. S. NRC HQ Rockville, MD, 20555-0001 Email: ronald.lavera@nrc.gov General Comment Regulatory Guide (RG) 1.142 Revision 2 contains Regulatory Position 2, which states that:

"This position emphasizes the need to evaluate concrete structures for their effectiveness as radiation shields, when they are so intended.

Some specific guidance for this purpose may be obtained from ANSI/ANS 6.4-1997. This is the current ANSI standard for radiation shielding."

This proposed version of RG 1.142 deleted this statement.

Structural concrete is frequently used as radiation shielding to limit dose to members of the public, and plant workers, both during normal operation, as well as during design basis events.

The concrete, or other structural materials may not be explicitly identified in the FSAR as required radiation shielding material.

However, it may be used as part of the analysis used to demonstrate compliance with 10 CFR 20.1301(e), GDC 4, GDC 19, GDC 23, 10 CFR 50.49(d)(3),

https://www.fdms.gov/fdms/getcontent?objectId=0900006483c22a4e&format=xml&showorig=false 05/02/2019

Page 2 of 2 10 CFR 50.49(e)(4), 10 CFR 50.34(f)(2)(vii) ,

10 CFR 50.34(f)(2)(viii), 10 CFR 50.34(f)(2)(xxviii),

10 CFR 50.67(b)(2)(iii) and 10 CFR 50.44(b)(3).

The fact that these structures provide other protective functions of safety related structures systems and components, and protection of members of the public needs to be an integral part of guidance to users provided by the staff.

This position should be included in Revision 3.

"This position emphasizes the need to evaluate concrete structures for their effectiveness as radiation shields, when they are so intended.

Some specific guidance for this purpose may be obtained from ANSI/ANS 6.4-1997. This is the current ANSI standard for radiation shielding."

https://www.fdms.gov/fdms/getcontent?objectId=0900006483c22a4e&format=xml&showorig=false 05/02/2019