ML20065A082

From kanterella
Jump to navigation Jump to search
Comment Supporting Proposed Rule 10CFR19 & 20 Re Radiation Protection Requirements Amended Definitions & Criteria
ML20065A082
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 03/22/1994
From: Schofield B
TENNESSEE VALLEY AUTHORITY
To: Chilk S
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-59FR5132, RULE-PR-19, RULE-PR-20 59FR5132-00003, 59FR5132-3, NUDOCS 9403310024
Download: ML20065A082 (3)


Text

- -. _ -

=

l9,.20 (3'1 F R 5131)

~

3 DOCKETED A

USHRC

%smeown,emmsucm.

n-,w a 94 NAR 24 A10:44 March 22, im 0FFICE OF SECRETARY 00CKETiliG 1 SERVICE BR/WCH Mr. Samuel J.

Chilk Secretary of the commission ATTN Docketing and Service Branch U.S.

Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Chilk:

NUCLEAR REGULATORY COMMISSION (NRC) - REQUEST FOR COMMENT ON PROPOSED RULEMAKING 10 CFR PARTS 19 AND 20, RADIATION PROTECTION REQUIREMENTS -

AMENDED DEFINITIONS AND CRITERIA The Tennessee Valley Authority (TVA) has reviewed the subject proposed rulemaking, which was noticed in the February 4, 1994 Federal Reoister (59 FR 5132-5138), and is pleased to provide the following comments.

3 General comment:

For TVA nuclear facilities, the proposed revision would impose significant impact with little benefit.

Impact would include revisions to (1) technical specifications, (2) Offsite Dose Calculation Manuals, (3) site and corporate standards and procedures, 4) Final Safety Analysis Reports, (5) emergency action levels, and 6) monitor setpoints.

TVA recommends that the Unrestricted Area, Restricted Area, and controlled-Area definitions and concepts be retained in the regulation as presently written.

Specific Comments:

19.12 - Instructions to workers (a)

All individuals who in the course of employment in which the individual's assigned duties involve the potential for exposure to radiation and/or radioactive material shall be potential for exposure to radiation.

comment:

Use of the public dose limit (100 mrem / year) as a critorion to indicate " potentia'. for exposure" and thus require training, is ambiguous. A clear definition.of what constitutes " potential for exposure" that requires training is needed.

20.1003 - Definitions Member of the public means Comment:

Revised definition is acceptable.

h33 024 940322

[b 19 59FR5132 pyg

I' l

t-Mr. Samuel J.

Chilk Page 2 March 22, 1994 j

l occupational dose means Comment:

The proposed definition of " occupational dose" implies that it includes all dose received by individuale performing any type of work assigned by the licensee or contractor of the

.I licensee regardless of location. Dose received by

-l individuals on nuclear plant sites outside of normally l

restricted areas (i.e.,

outside of Radiologically Controlled Areas or Protected Areas) is typically a fraction of the public dose limits (100 meem/ year). Tasks such as mowing grass or working in office buildings are examples of " work" l

performed in these areas.

Training and monitoring of workers in these areas are impractical and not cost effective.

The new " occupational dose" definition should exclude dose received as discussed above.

Public dose means comment:

Revised definition is acceptable.

Unrestricted area means Comment:

Following the new definition will require either moving the effluent boundary (which is the Unrestricted Area boundary) to the existing Restricted Area boundary or moving the Restricted Area boundary to the existing Unrestricted Area boundary.

If the effluent boundary is moved, all operational flexibility for effluent releases (per 10 CFR 50, Appendix I) will be lost.

All effluent calculations will require revision (e.g., monitor setpoints, Offsite Dose-Calculation Manual, Emergency Action Levels, and Final Safety Analysis Reports).

If the Restricted Area boundary is moved, unwarranted training and monitoring requirements may be imposed based on proposed new definition of

" occupational dose."

We strongly recommend leaving the existing definition in place and retaining the " Controlled Area" concept.

20.1301 - Dose limits for individual members of the public (b)

If the licensee permits members of the public to have access to restricted areas Comment:

If the revised definitions are imposed, licensee procedures must be revised. We recommend leaving definitions as now prescribed.

20.1302 - Compliance with dose limits for individual members of the public (a)

The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted areas and comment:

We suggest this section should read, "The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in restricted and unrestricted areas and radioactive materials in effluents

Hr. Samuel J.

Chilk Page 3 March 22, 1994 20.1801 - Security of stored materials The licensee shall secure from unauthorized removal.

Comment:

Removal of " controlled area" from this section is the only change. As stated previously, our recommendation.is to retain this concept.

20.1802 - Control of material not in storage The licensee shall control and maintain constant surveillance of licensed material.

Comment:

Removal of " controlled area" from this section is the only change. As stated previously, our reccmmendation is to retain this concept.

20.2104 - Determination of prior occupational dose (a) For each individual who is likely to receive Comment:

Change has no impact on licensee programs or procedures.

20.2205 - Reports to individuals of exceeding dose limits When a licensee is required, pursuant to the provisions of.

Comment:

This requirement is new.* Its addition will require licensee procedures to be revised. -We do not recommend-inclusion of this requirement.

Sincerely, Q,)

' #"t?

-_, - un- - -

  1. ,A/a'ruce Scho' leld

- k Manager Nuclear Licensing and Regulatory Affairs cc Mr. R. V. Crlenjak, Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Alan K. Roecklein

.)

Of fice of Regulatory Research U.S.

Nuclear Regulatory Commission Washington, DC 20555 j

Hr. Thomas E..Tipton Nuclear Management and Resources Council 1776 Eye Street, NW Suite 300 Washington, DC 20006-3706 i

'i j

,