ML19344F474
| ML19344F474 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/12/1980 |
| From: | Curtis N PENNSYLVANIA POWER & LIGHT CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| RTR-REGGD-08.XXX, RTR-REGGD-8.029, RTR-REGGD-8.XXX, TASK-OH-902-4, TASK-OS ER-100450, PLE-216, NUDOCS 8009150309 | |
| Download: ML19344F474 (2) | |
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ppal TWO NORTH NINTH $TREET, A L L E N TOWN, PA. 18101 PHONE: (215) 821 5151 00CW.ET MUMBER )
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Secretary of the Commission
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Docketing and Service Branch I:
SUSQUEHANNA STEAM ELECTRIC STATION COMMENTS ON REGULATORY GUIDE OH 902 g ER 100450 FILE 841-9 PLE 216
Dear Sir:
Pennsylvania Power and Light Compan on Draft Regulatory Guide OH 9024,y has the following comments
" Instruction Concerning Risk from Occupational Radiation Exposure":
o Pg. 5 Item 2
Cataracts have not been demonstrated as a stochastic effect resulting from exposure to low LET radiations (See ICRP 26).
o Pg. 6 Item 4
The sequence of the first two statements would lead the reader to conclude that there have been accidents in the nuclear industry which resulted in overexposures of the magnitude to cause early health effects.
This is simply not the case in the Commercial Nuclear Power Industry.
o Pg. 7 Item 6
It is the cancer activation that is not well understood.
The basic mechanisms that could potentially leru to a cancer are well understood.
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Pg. 7 Item 7
he analogy between cigarette smoking and radiation exposure is inappropriate because the cigarette smoking risk is significantly greater than the radiation exposu ris Ackncyrtedged trf card.~.E6[
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8 Item 7
Skin cancer due to radiation exposure (i.e. non UV) is a nonstochastic effect.
Conse-quently, one must exceed a threshold level to produce the risk of induction (See ICRP 26).
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o Pg. 15 Item 13 The statement "every activity...
should be planned" is inappro-priate.
It would be impossible to generate power from a Nuclear i
Facility based upon this premise.
The lower dose activities have been designed in such a manner to
!g avoid planning efforts during op-eration.
This whole section E
needs re-work in that designation of a cost-benefit analysis for every single endeavor would be counter-productive.
o Pg. 25 Item 30 The statement of reliability is not an accurate reflection of the TLD or Pocket Dosimeter's intended purpose.
Both are reliable if utilized properly. It is the cumu-lative nature of the TLD as opposed to the time and dose dependent measurements of the Pocket Dosimeter that cause the TLD to provide a more accurate accounting of an in-dividual's total exposure.
Very truly yours, 0
m A d.
I N. W. Curtis Vice President, Engineering and Construction - Nuclear