ML20081G915

Comments on Draft Reg Guide DG-8012, Instruction Concerning Risks from Occupational Radiation Exposure

ML20081G915
Person / Time
Site:	Beaver Valley
Issue date:	03/15/1995
From:	George Thomas DUQUESNE LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-60FR3280, RTR-REGGD-08.029, RTR-REGGD-8.029, TASK-*****, TASK-DG-8012, TASK-RE 60FR3280-00011, 60FR3280-11, NUDOCS 9503240002
Download: ML20081G915 (2)

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. E"$.NNc"e'.****"' March 15, 1995 USb.kC Nuclear Powor Division (o85(o Chief, Rules Re"iew and Directives Branch looW33SO Division of Freedom ofInformation and Publications Services OyB '95 l Office of Administration U. S. Nuclear Regulatory Commission Ehf Qgf Washington, DC 20555-0001

Subject:

Proposed Revision 1 to Regulatory Guide 8.29, " Instruction Concerning Risks from Occupational Radiation Exposure"(DG-8012)

Duquesne Light Company (DLC) is responsible for the operation of Beaver Valley Power Station Units 1 and 2. DLC is submitting the attached comments on draft guide DG-8012 which is proposed Revision 1 to Regulatory Guide 8.29, " Instruction Concerning Risks from Occupational Radiation Exposure." This guide is being revised to provide guidance on the instructions and information that should be provided to workers by licensees about health risks from occupational radiation exposure.

Thank you for the opportunity to comment on this issue. If you have any questioris concerning the attached comments, please contact Mr. J. T. Lebda, Director of Radiological Services, (412) 393-5872.

Sincerely, l

o ,shne$

orge S. Thomas  !

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& 's' Attr. chm:nt Comments on Proposed Revision 1 to Regulatory Guide 8.29,

" Instruction Concernina Risks from Occupational Radiation Exposure" Page 3, Section C., Regulatory Positi6ti, Paragraph 2 which discusses instructions to workers -

Comment: The regulatoiy requirement for instmetion is "The extent of these instructions shall be commensurate with potential radiological health protection problems in the restricted area" The proposed action is valid for individuals who are likely to receive a radiation dose exceeding the limit for a member of the public. However, when it is likely that the individual will receive a veiy low or immeasurable dose, instruction commensurate with risk could be minimal and may not include all of the proposed material.

Appendix Page 10, Question #5 which discusses pregnancy declaration, and Page 19, Question #2 which discusses dose limits -

Comment: These sections imply that the occupationally exposed woman should declare pregnancy to the licensee. However, the regulations and draft Regulatory Guide 8.13, Rev. 3 state that declaration is made to the employer with no requirement to inform the licensee. The licensee is responsible for controlling dose and must be informed of the declaration.

Appendix Page 21, Question #14 which discusses average annual dose -

Comment: The listed reference (National Council on Radiation Protection and Measurements 93 Table 5.1) for Table 3 in the regulatory guide specifically excludes the radiation dose from smoking tobacco. Tabic 3, (footnote b) erroneously states that this dose is included in the Table 3 consumer product dose.

With the above exceptions, proposed Revision I to Regulatory Guide 8.29 is consistent with associated regulation and good health physics practice. The infonnation provided in the Appendix is appropriate for radiation workers.