ML19327A380

Comments on Proposed Rule 10CFR20:limits of Contamination for Disposal of Matl as Nonradioactive Waste & Release of Matl for Unrestricted Use Should Be Developed & Incorporated W/Proposed Rule

ML19327A380
Person / Time
Site:	Monticello
Issue date:	07/08/1980
From:	Windschill J NORTHERN STATES POWER CO.
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-45FR26072, RULE-PR-20, TASK-ES-725-1, TASK-OS 45FR26072-5, NUDOCS 8008060111
Download: ML19327A380 (3)

Text

NORTHERN STATES POWER COMPANY MONTICELLO NUCLEAR GENERATING PLANT Monticello, Minnesota 55362

• XX2B IWMBER N DPOTED RULE - ,

July 8, 1980 @ 4

// DOCKETED b USNRC Secretary of the Commission 0[ JUL 161980 > -4 .

U. S. Nuclear Regulatory Commission Om:e cf the Secretary

• Washington, D. C. 20555 .jn 8 g, 6 Attn: Docketing & Service Branch U q) ~e

.J MONTICELLO NUCLEAR GENERATING PLANT Docket No. 50-263 License No. DPR-22 10CFR20 Request for Public Comment It is desired to comment on two specific subjects concerning the proposed 10CFR20 revision. These are:

1) Limits of contamination, in terms of concentration and total activity, for disposal of material as non-radioactive waste and release of material for unrestricted use.

2) Limits of exposure of individuals to concentrations of radioactive materials in air in restricted areas.

In regard to subject 1), we urgently feel such limits should be developed and incorporated to 10CFR20. Presently, there is no clear regulation for the industry concerning this. As a result, site specific criteria are used at each facility, and when the various site's criteria are compared, they are frequently confusing and sometimes conflicting. Also, the equipment / personnel release limits at an individual facility may be arbitrary and hard to justify. Uniform standards would ensure consistency throughout the industry and greatly effect planning, decontamination work, waste disposal, and other activities.

There is some guidance in present regulations which can be used to help arrive at reasonable concentration and total activity limits.

49CFR173.389(e) defines radioactive n.s t eriti as anything greater'than 2 nano curies per gram specific activity, but this ir just in regard to shipping.

10CFR20, Appendix B also has linits, ici. just ier water and air. 10CFR30, Schedules A S. E he.vr. r e c r il ed :. -. .. " 12 ... ,; ut. e w , a 11. m c is still required to obtain troterials below %eae i : .i t s Raguiatory fivide 1.f#, han 4

g,g,,c.4edg W D f cud . . N . Nw 8008060///

a , limits, but they apply only if a plant is being decommissioned. NSP's release limit is 100 cpm above background using a thin windoyed GM counter, for personnel and equipment or material, and 100 dpm/100 cm smearable for equipment or material.

In order to compare to these limits, three different cases will be reviewed. ,

Case one is the human body, case two is a standard 8.5" x 11" piece of paper, and case three is a 1/4" thick by 8.5" x 11" piece of steel.

" Releasable" activity, pCi (unidentified beta gamma emitters, except where noted otherwise):

1 2 3 49CFR173 N/A 0.009 6 10CFR30 Sh. A (Co-60) N/A 0.002 1.5 10CFR30 Sh. B (Co-60) N/A 1.0 1.0 10CFR30 (releasable) N/A (Note a) (Note a)

Reg. Guide 1.86 N/A 0.027 0.027 NSP (smearable) N/A 0.005 0.005 NSP (fixed) 0.8 (Note b) 0.05 0.05 NOTES: a) There is no lower limit specified in which a license is not required in order to possess byproduct material.

Therefore, the sensitivity, or detection limit capability of the instrument used becomes the lower limit.

b) This assumes contaminatica is uniformly spread over entire body surface, and a thin windowed GM counter is used to

" frisk" individual. Our portal monitors have roughly the same sensitivity.

There is a wide range of values in this table, and probably a much wider range than can be justified by health effects only. If the material desired to be given unconditional release is not water or air, or not amenable to being smeared (e.g. bottle of oil, barrel of sand, etc.) a GeLi analysis must be done. This is an extremely sensitive analysis, and levels well below anything that could affect the health and safety of the public can be detected. The smallest 100% organ burden for a common isotope at Monticello is 1.5 pC1 for Co-60. Clearly, a limit 100 times lower than this, or 15 nano Curies, should be reasonable. If a concentration limit is necessary, a limit of 1.5 pCi/1000 per gram, or 1.5 nano Curies / gram would clearly be defensible.

In regard to subject 2), we feel the limiting of personnel to 40 MPC hours per week, and then only - allowing one occurrence per quarter is unduly restrictive. This restriction should dm?ir.itely be abolished. All exposure limits are essentially based upon 5 Rer9 per year. It f.ces not make sense to place limits on internal crposure being a we':hly chrcnic exposure t.itustion.

Altaost all inter.id pnuct ca r..... alle ..

s.4e, and eve.1'il Gey were chronic, there is no retson Gr li e .ng .

"i sfiduu ori e vecicly tesis, an 0004K

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, long as the yearly internal deposition equivalent of 5 Rem to the whole body, or the applicable organ limit, is not exceeded.

The practice of back-calculating to determine MPC hours from Body Burden Analysis data is equally ridiculous. What is important is the dose that will be received from an internal deposition. This should be added to any ,

external dose, and the appropriate whole body or organ limit should not be exceeded. The MPC's should also be revised to reflect the recommendations .

contained in ICRP 26, which changed the whole body and organ yearly dose limits.

It is recommended that 10CFR20 internal limits be expressed in terms of organ dose, instead of MPC hours, and allow the licensee to develop his own method of assuring compliance.

Respectfully Submitted, W. A. Shamla Plant Manager s

By:

J. 14 Windschill Health Physicist WAS/ JEW /kik cc: file 0004K