ML19327C043
| ML19327C043 | |
| Person / Time | |
|---|---|
| Issue date: | 11/07/1989 |
| From: | Camper L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Surmeier J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| REF-WM-3 NUDOCS 8911150131 | |
| Download: ML19327C043 (17) | |
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M LC SURMEIER 10/20 3
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MEMORANDUM FOR: John J. Surweier,' Chief
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Technical Branch
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Division of Low. Level Waste Manageserit l
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s and Decosuiissioning, NMSS i
TNRU:-
Rob MacDougall, Section Leader Low. Level Waste Section, Operations Branch" '
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Division of Low. Level Weste Management
,,?P and Decosmissioning, NMSS 1 3EL,"
" FROM:
Larry Camper, Project Manager
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_ Operations Branch
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Division of Low. Level Waste Management and Decomunissioning, NMSS i
SUBJECT:
BGV PLASAR COMMENTS ON SECTION 7.0 j
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The attached document is the completed Q-1 phase of the BGV PLASAR for J
Section 7, 'Occupetional Radiation Protection." The comments include input t
from Dennis Sollenberger, Yvonne Young and John Stanner.
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.If you have any questions, or require further clarification, please advise.
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La h h,II b N ader Operations Branch, LLWM/NMSS r
Enclosure:
As. stated l
' Distribution: -. -
I 4 Centret FMeT 21414#
NMSS r/f RBangart, LLWM JGreeves,ll, LLOB MBell, LLRB JStainer, LLTB i
LLWM RMacDouga LCamper, LLOB JKane, LLTB PLohaus, LLOB DSollenberger LLRB YYoung, LLTB JJones, LLOB r/f PDR YES C PDR NO O Category: Proprietary C or CF Only C.
ACNW YES C NO O SUBJECT ABSTRACT:
BGV PLASAR REVIEW m.
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OttICIAL REGURD UUrT 8911150131 891107 PDR WASTE WM-3 PDC
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i 7 OCCUPATIONAL RADIATION PRO 7ECTION I
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Coment _
- Section 7 (p.71 thru 7-17) l The occupational radiation protection program described in Section 7 of the F
BGV PLASAR consists of generic coments apparently designed to address key components of that section as set forth in the Standard Format and Content j
Guidance (NUREG-1199), However, the prograd (particularly Sections 7.1 i
t and 7.4) scarcely provides as much information as is presented in the NUREG.
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In many instances, references are made to related information contained in l
AppendicesortheSupportingInformationPackages(SIP's). However, these references are not detailed enough to facilitate line. item review as required in a license application process.
l An actual license application would require more detailed information than is i
presented in Section 7.
FUREG/CR-3343, NUREG-1199, Revision 1 and NUREG-1200, i
Revision 1 provide guidance on the level of detail expected in an actual license application. Similarly, the organization of.Section 7.0 in an actual license application should be developed in sufficient detail to ensure j
implementation of the radiation safety program. Section 7.0 of.the BGV PLASAR does not describe a program readily allowing implementation, nor.is it j
necessarily specific to a BGV facility.
t Consequently, not enough information is presented to allcw a' thorough and independent technical assessment, since the intent of NRC's review of the I
L BGY PLASAR,
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SGV PLASAR is to critique the caliber of the information submitted in the t
context of a license application. Regardless, the NRC Staff has undtrtaken to the extent practicable, a review of the submitted program in order to l
facilitate the PLASAR process.
Review comments are identified and elaborated upon in the following subsections which track the BGV PLASAR's, submission for l
Section 7.
Section 7.1.1 ALARA POLICY l(p. 7-1)
Comment (a) The first paragraph of this section sets forth a general commitment to maintainingradiationexposuresaslowasisreasonablyachievable(ALARA) as required in 10 CFR 20.1(C).
In addition, a commitment to ALARA will
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supposedly be expressed in various policy statements to'be issued by site i
i and corporate management. However, insufficient detail is provided regarding achievement of these objectives through an interface between l
policy considerations, design considerations and operational j
considerations.
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'(b) The second paragraph states that the proposed facility organizational structure for achieving ALARA considerations is' described by reference to Chapter 8 (conduct of Operations). However, that section of the BGV PLASAR application contains a major caveat warning of its incomplete statu s.
In fact, the only information on organizational structure provided in that section is a reference to line items set forth in NUREG-1199, Revision 1 and NUREG-1200, Revision 1.
Therefore, na review r
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.l BGV PLASAR i I
I of the organizational structure to be utilized to achieve ALARA in this j
i BGV f acility is possible.
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(c) The fifth paragraph contains management responsibilities which are l
primarily a recapitulation of primary program elements ide,ntified in NRC Regulatory Guide 8.8 (RG 8.8) and !!UREG-1199, Revision 1.
In an actual license application, these responsibilities and all aspects of the ALARA i
policy must be cle,arly identified in written akinistrative procedures and instructions for operations involving potential exposure of personnel to i radiation.
l (d) The sixth paragraph, identified as Personnel Qualifications, states that f
qualificationsforthtsiteRadiation'SafetyOfficer(RS0)arecontained l
in Section 8 of the PLASAR, and are based upon recossendations in i
ANSI /ANS-3.1-1981 and Regulatory Guide 1.8.
This presents two major problems. First, Chapter 8 is an incomplete submission and does not j
contain any information regarding qualifications for the RSO. Second, the I
criteria? set forth in the cited documents are designed primarily for i
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reactorifacilities rather than low-level waste burial sites.
In an actual y.
i license application, it would be necessary to identify min'imum acceptable I
l trainingandexperiencecriteriaforthesiteRSOandotheg. technical personnel.
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L Commnt
- Section 7.1.2 ALARA DESIGN (p. 7-2) l i
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The information in this section primrily focuses upon radiation safety J
training. A few examples of design criteria are mentioned, e.g., thick blanket of cover over waste before roof construction etc., but, this information is of minimal value for BGV design considerations to achieve the ALARA. concept.
In an actual licente appitcation, detailed information clarifying facility design f
. features and radioactive wacte handling procedures'would be required.
l Typically, such information should be presented in detail within Section 7.3 with a summary of the impact on ALARA provided in this section.
Comunent Section 7.1.3 OPERATIONAL ALARA (p. 7-3)
This section provides a few general comunents for implementing an operational e
ALARA program and references the use of Regulatory Guides 8.8, 8.10 and NVREG/0R-3343 for additional guidance. Although previous operational experience is referenced as a basis for implementing the ALARA program, the source of the applicant's experience is nut clarified.
The implementation of operations in an ALARA program begins with the development of site-specific operating procedures endorsed by management and carried out by the Facility Radiation Safety Officer (FRS0)., Standard operating procedures (SOP's) must be developed and submitted with the licenso application for all phat9s of waste handling. $0P's should include a detailed description of the constraints on their use, e.g., when special work permits
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BGV PLASAR !
f (SWP's) should be used, etc. The discussion of an operational ALARA program
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must consider:
(1)personnelawareness;(2)performanceaudits;(3) radiation protection capability; (4) training; (5) RSO authority; and (6) modifications I
i to operations, j
Furthermore, prograsunatic information in a license application should be self-contained where possitae. The application may incorporate by reference Information contained e,1sewhere.. such as'in ' previous applications, statements, l
or reports filed with the Commission, only if these references are clear and i
specific.
Comment Section7.1.4RADIATIONPROTECTIONCONSIDERATIONS(p.74) 1 This section merely references a connitment to a radiation protection plan consistent with the recommendations of NUREC/CR-3343. The actual radiation l
protection plan is to be described in Section 7.4.
In an actual application, this subsection would describe how the radiation protection program in p
Section 7.4 will p ovide the information and controls. to maintain occupational l
doses ALARA.
l Comment Section7.2RADIATIONSOURCES(p.7-4) i This section of the BGV PLASAR references Section 6.1.1, Appendix A, and the Supporting Information Package (SIP 1) to include radiological source term information.
Contrary to NUREG-1199, Revision 1 and NUREG-1200, Revision 1,
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Section 7.2 of the applicant's BGV PLASAR does not adequately describe i
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. radiation sources that are the design basis of the BGV facility radiation protection program for such considerations as:
shielding; ventilation systems; special storage locations and conditions; traffic or access control; special plans; monitoring equipment; establishing facility design features; plans and procedures development; and occupational radiation exposure assessments.
Nor does this section consWer all of the radionuclides (e.g., Uranium-234 and I
Thorium-230 etc.) in th,e source term invento'ry or justification for the use of average radionuclide concentration and content values as input in the design i 1
t process shielding codes.
Comment
- Section7.2.1CONTAINEDSOURCES(p.7.-4) i (a) This section describes the daily through put of waste handled at the I
BGV facility based on the source term description identified in l
l Section 6.1.1.
The evaluation of the source term inventory is discussed in the NRC staff comments on Chapter 6 of the PLASAR. However, des,criptfoinTof contained sources, applicable to. the Radiation Safety Program desc'r'ibed in SRP 7.2, should include: '(1) scaled drawings of the facility that can be related to tables containing the pertinent quantitative source parameters; (2) descriptions of the positions of the sources, including their locations, approximate sizes and ghapes, and relevant operating experience.
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BGV PLASAR i (b) The 86V PLASAR should provide clear justification for: (1) the use of average concentrations and nuclide content values (discussed in various sectionsofthePLASAR)asinputtoshieldingdesign;(2)thesignificance of exposure rates discussed in other sections of the BGY PLASAR such as those listed in Section 7.3; and (3) the exposure rate distribution of the packages at the highest and lowest extremes of the ranges discussed in Appendix F (i.e., 110 R/hr, and <10 mR/hr, respectively).
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Comment Section7.2.2AIRBORNERADIDACTIVEMATFRIALSOURCES(p.7-5)-
l This section of the BGV PLASAR assumes that except for airborne releases from a i
significant suspendible component of Class A dry waste, or from, sources involving damaged or non-compliant container waste packages. accident conditions will be rare since all waste classes are solidified or shipped in i
high integrity containers (HIC's).
Based on'this assumption, minimal information is provided about the design of ventilation systems or personnel protective measures, although certain areas of the B6V, e.g. decontaaiination I
area or container inspection areas, should be designed with airborne contamination in mind.
Bounding cares for operational. occurrence and accident conditions,are discussed in Section 6.
The NRC staff has included a nusber. of comments in' its review of that section regarding dose factors and justification of assutytions used for dose assessments to workers.
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Comunent Section 7.3 RADIATION PROTECTION DESIGN FEATURES (p. 7-5)
This section of the BGV PLASAR provides descriptions of the radiation
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protection design features to ensure ALARA occupational exposures at the BGV facility. However, it does not provide adequate descriptions of the objectives l
t of the radiation design features as delineated in NUREG-1199, Revision 1, and r
NUREG-1200, Revision 1.-
In addition, the description of radiation design l
features should consider the need to allow quick entry and easy access to ensure ALARA occupational exposures. This section should also include adequate descriptions of:
(1)transportvehicledecontaminationfacilities;(2)the health physics facility; (3) the disposal bunker facilities;.(4) other facility i
designs to ensure ALARA occupational exposures; (5) radiation zo'e designations n
and related design dose rates; and (6) descriptions of radioactive monitoring j
equipment in accordance with RG 8.8.
The design and operation of the BGV l
facility appears to be somewhat independent of the radiation sources identified
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in Section 7.2.
f Coseent
- Section 7.3.2 SHIELDING (p. 7-10)
This section of the B6V PLASAR describes shielding as an additional benefit to the ALARA design process and specifies the MICR0 SHIELD computer. code for use in determining the shielding calculations.. However; this section does not provide the assumptiens and the parameters chosen for the shielding calculations.
Adequate shielding descriptions would include discussions of:
(1)theshield thicknesses for gassa ray sources determined from the calculational codes;
BGV PLA$AR !
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'o (2) why guideia.e on the fabrication and installation of concrete shields for f
occupational radiation pratection at the BGV facility was or was not followed t
in accordance with RG 1,69 and ANSI N101.6-1972; amt (3) why additional l
applicable criteria on shielding and isolation in radiation protection were or were not followed in accordance with any other guidance (i.e.,,RG 8.9). Also,
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there is not a clear discussion of the dose reduction resulting from the shielditg designed into the facility.
Comment _
- Section7.3.3 VENTILATION-(p.7-11) i I
I This section does not provide information on ventilation, except for a l
statement that a negative pressure ventilation with HEPA filtrat' ion of the i
1 In exhaust is provided for all areas of the Receiving and Storage Building.
fact, this section contains a major caveat warning that such information is omitted due to its leck of relevance as an assessment of disposal technology.
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This section of the BGY PLASAR should describe:
(1)personnelprotection features of the ventilation system design; (2) design aspects applicable to airborne radioactivity,emoval from equipment, corridors, and operating areas including disposal units occupied by personnel; (3) design features for controlling concentration levels for the above areas; (4) cleaning system design illustrative samples and layout (i.e., filters, mount.ings, access doors, services galleries, etc.); and (5) provisions for testing, isolation and decontamination, etc.
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Comment
- Section 7.3.4 AREA RADIATION AND AIRBORNE RADIOACTIVITY MONITORINGINSTRUMENTATION(p.7-11)
Except for the assertion that area radiation monitors and airborne radioactivity monitoring are provided in the receiving and inspection, decontamination / repackaging, and storage areas, the BGV PLASAR does not provide I
information on area radiation and airborne radioactivity monitoring instrumentation. Again, this section contatns a major caveat warning that detailedinformationasrequestedinNUREG-1199,Revisionl'isomittedasnot; necessary for the assessment of disposal technology.
This section should provide information on radiation protection 'acilities, f
instrumentation, and equipment as requested in NUREG-1200 Revision 1, NUREG-1199 l'.evision 1, and the RG 8.8, pages 8.14 - 8.15 (i.e., the ranges for portable instruments and personnel monitoring instrumentation, and a complete listofinstrumentsandequipment).
It would be helpful in the review process if this data were provided in tabular form.
Comment Section 7.3.5 DOSE ASSESSMENT (p. 7-11)
This section of the BGV PLASAR briefly describes the shielding calculation code IS0 SHIELD used for dose assessments to LLW workers. While this.section references Appendices F and G.and SIP'.s 4 and 5, the assumptions contained in l
the references are not clear. Also, a summary of exposure c'alculations was referenced but not clearly identified.
It is assumed that the cited
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BGV PLASAR '
information is set forth in Tables 7.3-2, 7.3-3, and 7.3-4.
An adequate dose assessment would include documentation of all assumptions presented, calculations used in the assesssents, radiation zone results including numbers and types of workers, expected ano design dose rates, and projected person-rem doses, including legible information that can easily be related to the applicable tables provided.
Further, it is not clear in the SIP!s how the exposures from emplaced or stored waste were included in the dose assessment of l
i workers.
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j Comment Section7.3.5.1SOURCETERMFORWORKERDOSES(p.7-12) l l
This section references Section 6.1.1 of the BGV PLASAR to descr'ibe the source term. However, Section 6.1.1 contains only background information which is j
inadequate for determination of worker doses.
Information on source term is f
I found throughout Section 6 (e.g., information on waste packages is provided in Section 6. Table 6.19), whereas, information on the source terms for workers is provided in various other sections (Appendices and SIP's) of the BGV PLASAR.
Therefore, it is unclear what information is utilized in determining occupational source ters for the different aspects of facility operation. The few example sheets of the MICROSHIELD provided, and some of the'. computations produced from this code, can not be easily related to tables containing pertinent quantitative source parameters. The BGV PLASAR plans,and drawings t
should include source descriptions tha.t can be easily identified and related to information provided on the source term's quantitative parameters. Also, the BGV PLASAR should adequately describe shapes and approximate sizes of the
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BGV PLASAR '
sources, using operating experience where applicable.
In addition, the BGV's operational procedures to ensure ALARA compliance for radiation exposures to workers must be addressed. However, the operations procedures are to be set forth in Section 4 which contains a major caveat warning of their omission due to the hypothetical nature of this application.
i Comment
- Section 7.3.5.2 COMPilTER MODELS FOR WORKER DOSES (p. 7-12) f
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This section of the BGV PLASAR discusses the computer model'used for worker occupational dose assessments. Reference is made to an electronic spread sheet identifying numbers of workers, durations of each activity, and dose rates at i
various distances from the waste. However, some of the data (e.g., Table G1-1) on the " spreadsheet" are not easily related to the discussion in the text of the BGV PLASAR, and are not presented in a systematic way for considering and evaluating dose-reducing changes in facility operations and design.
Documentation requirements, review procedures, and the principal dose assesssents related to ALARA changer, should be specifically identified.
Comment
- Section7.3.5.3WASTEHANDLINGACTIVITIES(p.7-12)
This section references the. process flowsheet for identifying waste receipt, handling, processing, and disposal activities at the BGV fac,ility as explained in Chapt 4tr 4.
However, neither Chapte.r 4 nor this section provides detailed operating procedures necessary in order for the NRC staff to' provide a comprehensive review of the management controlled waste handling activities
BGV'PLASAR within the BGV facility. The BGV PLASAR's descriptions of waste handling activities should be presented in detail in Section 4.2 with a suusnary of its impact on occupational exposure provided in this section.
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- Section7.3.5.4MANPOWERACTIVITIES(p.7-12),
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The BGV PLASAR describes estimates for the number and Classification of
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workers, including the, average distances fro's each ' radiation exposure source, and time spent on the operation at these distances.
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l The BGV PLAStR should clarify the discrepancy between information presented in l
Section 7.3.5.4, page 7-12 and Appendix G1.4, page G-20.
Specifically, Section 7.3.5.4 states.that there are 22 work activity classifications with f
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35 specific operations, whereas, Appendix G1.4, page 20, identifies 26 work activity classifications and 20 specific operations. Also,'this section should j
provide clear and more detailed explanations of information presented in the l
l example sheets.
1 Further, this section of the BGY PLASAR does not reference the fact that worker i
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exposure information is also contained in Appendix G.
Appendix' G contains differences in units for exposure calculations (i.e., R/hr or R/yr) which are L
not clarified in Section 7.3.5.4.
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- Section7.3.5.5DOSERATESFORHANCLINGACT!YITIES(p.7-12)
This section of the BGV PLASAR describes shielding / distance dose
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configurations. However, it does not adequately describe shielding / distance configurations, during "particular operations" in the presence,of an open call of enplaced waste in a disposal vault, or through the rocf of a closed vault, or for other configurations in terms of limiting worker exposure as recommended in NUREG-1200. This di,scussion also fails to describe implementation of ALARA i
design philosophy.
'j Cossnent
- Section7.3.5.6WORKERDOSEESTIMATES(p.7-14) f This section of the BGY PLASAR assumes that the performance objectives of the I
appropriate sections of 10 CFR will be met due to the detailed annual cumulative worker dose assessments for all routine disposal operations in l
Tables 7.3-2, 7.3-3, and 7.3-4.
This section should demonstrate that all I
assumptions are valid and reasonable, including referencing other sections l
regarding wor'ker dose estimates, as appropriate.
Information provided in l
various sections of the BGV PLASAR should be consistent.
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I Comment
. : Section 7.
3.6 REFERENCES
(p. 7-14) l This section identifies only three reference documents, and does not include all of the appropriate sections of the BGV PLASAR applicable'to this section.
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4 b4V PLASAR Commeht Section 7.4 RADIATION PROTECT 10N PROGRAM (p. 7-14)
Section 7.4 of an actual license application should include a detailed description of the administrative organization of the radiation protection i
program, including the authority and responsibility of the individual occupying each position.
In addition, it should provide a detailed description of all j
site-specific health physics procedures designed to satisfy guidelines contained in NUREG/CR-3343, NUREG-1199, Revision l'and NUREG-1200, Revision 1.
Such information should include a listing of all equipment,' instrumentation, ;
I and facilities used in conducting the program.
Substantial discussion should be devoted to internal and external personnel Tnitoring including methods of recording, reporting, and analyzing results as well as all requirements set forth in 10 CFR Part 2Q. Above all, the described radiation safety program must be capable of implementation within the BGV facility.
Comment Section 7.4.1 RADIATION PROTECTION (p. 7-14) l l
The information provided in this section is inadequat.e. This section states that the radiai; ion protection program is based on NUREG/CR-3343, but does not elaborate on the various program elements outlined in that document. The l
majority of the text for the section is a verbatim reiteration of the information contair.ed in Section 7.4 of.NUREG-1199, Revision,141though certain operational health physics concerns such as external exposure control are listed.
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Intentionally Omitted Information:
Revi_ew Topic PLASAR Page SRP NUREG-1200. Rev.1 (p. 7.3-2)
Section 7.3.3 P. 7-11 7.3.2.3 Ventilation n
'Section 7.3.4 (p. 7-11).
P. 7-11 7.3.2.4 Area Radiation and Airborne Radioactivity Monitoring Instrumeritat'icn e
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