ML20086R743

Comment on Draft Reg Guide DG-8006, Control of Access to High & Very High Radiation Areas in Nuclear Power Plants

ML20086R743
Person / Time
Site:	Prairie Island
Issue date:	12/12/1991
From:	Andrea Johnson NORTHERN STATES POWER CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
FRN-56FR56671, RTR-REGGD-8.038, RTR-REGGD-XX.XXX, RULE-PR-MISC, TASK-DG-8006, TASK-RE 56FR56671-00004, 56FR56671-4, NUDOCS 9201020203
Download: ML20086R743 (3)

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Welch fAnnesota %0R9 Y IR 27 p2 34 December 12, 1991 Regulatory Publications Branch DFIPS, Office of Administration U.S. Nuclear Regulatory' Commission Washington, DC 20555 Chief, Thank you for the opportunity to comment on Draft Regulatory Guide DG-8006, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants.

C.2.1 requires surveys to be made and documented to evaluate the radiation hazards in the area prior to entry. This implies that surveys be made priot to each entry. This is not ALARA. We should be able to conduct and document surveys at a frequency dependent on the likelihood of change, inf orm perrannel entering the area of expected dose rates, and then requite them (after adequate training)-to monitor the area on entry and control their dose.

C.2.1 page 6 requires documentation of all entties into high rad areas. It should be adequate to documer- each entry with the RWP sign in procedure or when the key is iss'wd for entry to the area.

C.2.1 page 6 item 4 talxs about a warning device but it is never

. defined.

Appendix A requires that justification for using divers be inenrporated into the RWP. I agree with the justification but it should be part of the work control process and not on the RWP.

RWPs are already very detailed and can be codfusing if inappropriate information is added to them. This information should be part of the ALARA review program.

Aprendix A.3 requires documentation of location of objects that produce dose rates greater than 1 rad per hour en contact. The term rad is not consistent with dose terms used in 10CFR20.

10CFR20 has specific statements that indicate that the only allowable term is rem.

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Appendix A.4' requires radiation surveys daily,-before and during diving operations. The daily survey should be removed as the before and during would satisfy the daily requirement. A separate daily survey could not be ALARA.

Also requiring '. redundant monitors during the diving operation is overkill as the diver has an alarming device.

Appendix A.6 requires a remote readout radiatien detector that is continuously monitored by RP personnel and item 4 of Appendix A requires two independent radiation exposure _ monitoring devices '

during diving _ operations,_this is too much. I can see doing two independent surveys prior to the work and having a dose rate monitoring device with remote readout on -the diver during the  ;

diving operation and an alar. ming device, but it is overkill and maybe not safe to have two dose rate monitoring devices dering the diving operations.

Appendix D _.

I realize that this section is an Acceptable method asid not necessarily a requirement, but NRC inspectors will use this as a rule and inspect to this level even if we have not had a problem in this area. I would like to see a statement that this is not a requirement but an acceptable method.

The first paragraph implies that health physics technicians are the only people that are qualified in radiation protection procedures.

It is not ALARA to send two people (the HP tech and the worker or i nspector- or. ope rator) into an area when only one person is needed.

If we train workers, operators or inspectors to do radiation surveys, how to minimize dose and control their dose, we should be able to-take credit for it.

The second to -last- _ paragraph requires that the stay times be .

dispinyed on the RWP.- The stcy time is dependent -on an individual's allowable dose and should not be npecified on. the RWP.

The time limit requirement can very easily be satisfied by using dose integrating and alcrming devices.

Thank you for stating in the ;.econd to the last paragraph that 30 '

cm or.12 inches- can be used.__ This- is not mentioned in the regulation but is needed.

The requirement to have the dose rates listed on the RWP-is also excessive. We post survey results at the entrance to these areas which will make it easier-for a person to determine the dose rate- .

than from an RWP. RWPs now require so much information that it is not possible to do a good job-on one page. Too much information at one-time is confusing and has caused problems at our facility and others. A floor plan at the area should be an acceptable-method.

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The last paragraph requires that we have a locking device or a red flashing light at entrances to areas greater than 1 r/hr. We have had good success using closed circuit / ideo cameras for controlling access to these areas, will we now have to change our methods?

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