ML20086T843

Comment on Draft Reg guides,DG-8003,DG-8004,DG-8005 & DG-8006.Proposed Rev to Reg Guide 8.25 Recommends Specific Air Sampling Practices Not Suited to Commercial Power Reactor Industry

ML20086T843
Person / Time
Site:	Davis Besse
Issue date:	12/26/1991
From:	Shelton D CENTERIOR ENERGY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
FRN-56FR52078, RTR-NUREG-0006, RTR-NUREG-1400, RTR-NUREG-6, RTR-REGGD-08.025, RTR-REGGD-08.XXX, RTR-REGGD-8.025, RTR-REGGD-8.038, RTR-REGGD-8.XXX, TASK-DG-8003, TASK-DG-8004, TASK-DG-8005, TASK-DG-8006, TASK-RE 2002, 56FR52078-00017, 56FR52078-17, NUDOCS 9201070081
Download: ML20086T843 (7)

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RE GUL. AT OP,Y PUP.! !".ATIDu'i t'"- 300 Maison Avenue Doned C. Shelton at yu pg. Nuclear Toledo OH 43652 0001 Davis Besse (419)249 2300

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Docket Number Sn-346 fN '?-[f/ /y.

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Serial Number 2002 December 26, 1991 United States Nucleat Regulatory Commiulon Regulatory Publications Branch, DFIPS Ltshington, D C. 20555

Subject:

Comments on Draft Regulatoty Guide Dm 8003, DC-8004, DG 8005, and DG-8006 Gentlemen:

The attached comments are submitted by Toledo Edison in response to the t e< pies t of the U.S, Nuclear Regulatory Commission (NRC) for comments on _

Draft Regulatory Guides DG-8003, DG-8004, DG-8005, and DG-8006. These Draft Regulatory Guides are intended to ass!st in irnplementat ion of the requitements of the revision to 10 CFR Pait 20, " Standards for Protection Against Radiation," that was published in the Federal Register (56 FR 23360) on May 21, 1991.

Toledo Edison, a subsidiary of Centetlot Enetgy. is partial ovner of and is responsible for operation of the Davir-Besse Nuclear Power Station. Toledo Edison has been authori:ed foi povet operation of the Davis-Besse Nuclear Power Station since April'1977. As a 10 CFR 50 licensee, Toledo Edison has a vested intm est in any policies the NRC may adopt which can affect the management and operation of a commercial nuclear power plant.

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-Docket Number 50-346 License Number NPF-3 Sertal. Number 2002

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Please refer any questions regntdit-x these comments to Mt. R. V.

Schrauder at_ (419) 321-2366.

Very'truly yours.

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Attachments cc: A. B. Davis, Regional Administrator, NRC Region III l J. B. !!opkins, NRC Senior Project Manager '

V. Levis, DB-1 NRC Senior Resident Inspector S. McQuire USNRC A. K. Roccklein, USNRC USNRC Document Control Desk Utility Radiological Safety Board 4 i

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Docket Number 50-346 License Number NPF-3 Serial Number 2002 Attachment 1 Page 1 Comments On Draft Regulatory Guide DC-8003 Proposed Revision 1 To Regulatory Guide 8.25-Air Sampling In The Votkplace

GENERAL COMMENT

S The ptoposed revision to Regulatory Guide 8.25 tecommends specific alt sampling practices which-are not suited to the commercial power reactor industry. The guidance in this draft is directed at installations with a f actory and/or production laboratory environment where better air samplirg techniques may be required. These sampling techniques are not necessary for operating commercial nuclean power plants since power teactor licensee's technical specifications and operating procedures already prescribe adequate air sampling requirements. Therefore, the proposed revisions to Regulatory Guide 8.25-vould be more appropriately incorporated as revisions to the following Regulatory Guides.

Regulatory Guide 8.2% " Health Physics Surveys for By-product Material at NRC-Licensed Processing and Manufacturing Plants".

Regulatory Guide 8.24, " Health Physics Surveys During Enrichad Uranium-235 Processing and fuel Fabrication".

- Regulatory Guide 8.30, " Health Physics Surveys in Uranium Hills".

The above-Regulatory Guides discuss air sampling in general terms and could be improved by adding the in-depth guidance contained in this draft. The existing Regulatory Guide 8.25 should be maintained as a-general guide vhich applies to all licensees. The following comments are made in support of this position.

SPECIFIC COMMENTS i-Section C.l.2 --Hazard Index ,

While the concepts in_the proposed Hazard Index ate useful, when properly calculated, they are applicable only_to new facilities; facilities with relatively fixed vork locationst or facilities where historical air sampling data is not available. None of these criteria

apply to power reactor facilities. Guidance-which is intended to be applicable _to all licensees should not include iirections to use and document an analytic method which is not app 12 cable-to all licensees.

Therefore, either reference to llazard. Indices should- be deleted, or a categorica]' exemption should be placed in the Regulntory Guide stating-vhich classes of-licensees are not required to:perforra Hazard Index

! analyses.

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i Docket Number 50-346

'ticense Number NPF-3 Serial Number 2002

' Attachment 1  ;

Page-21 Section C 4 - Earlyy yarning Air Sampling Airborne radioactivity concentrations sufficiently elevated to cause immediate harm are detectable by the' installed monitoring systems of commercial nuclear power plants. These systems are required by Technical Specifications and are operated according to written procedures. -Unless power reactors ate expected to duplicate monitoring systems and/or. records, this guldence does not apply.

1 Therefore, either the requirements for additional early warning '

monitoring should be deleted, or a clear exemption should be placed in  !

the Regulatory l Guido stating which classes of licensees are not tequired to install l and/ot document additional monitors, j Secti,on C.4.2 - Airflow Patterns The sections concerning airflow pattern determination and/or observation are applicable to facilities with fixed work station and relatively fixed locations of vents and ducts. Neither of these concepts apply directly in a commercial nuclear power plant, where air

-flow patterns can change from day to day (in some cases hourly).

Determination of air flow patterns are performed for tasks for which no historical data is available on a case by case basis. A formal program with fixed frequency of testing and the associated documentation vould be unvieldy it-not impossible. These requirements apply to fabrication, processing milling and production facilities but not to commercial pover reactors. Guidance which is to be applicable to all

' licensees, should not include instructions to use, document and analyze the results of a methodology which is not directly applicable to some of the licensees. Therefore, these instructions should be preceded by a_ clear statement of their non-applicability to power reactois.

-Conclusion The revision to Regulatory Guide 8.25 and the supporting vork (NUREG-1400 and NUREG/CR-0006) provide much useful information. The guidance provided to use this information is not, however, directly.

applicable to commercial power reactor' licensees. It should be modified to clearly and categorically state that.it does not apply to these licensees. Failing thiss the~ revision should be withdrawn.

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Docket NumberJ50-346: ,

License Number NPF-3 Serial Number 2002 Attachment 2- .,

'Page 1 Comments On Draft Regulatory Guide DG-8004 Radiation Protection Programs Fot Nuclear Power Plants GENERAL, COMMENTS

• Toledo Edison has reviewed Draft Regulatory Guide DC-8004, Radiation Protect.lon Programs:for Nuclear Power Plants. Based on review of this document.-the Company does not believe issuance of the proposed Regulatory Guldt is necessary. The proposed Regulatory Guide t0atates existing requirements which can be found in Technical Specifications, existing Regulatory Guides, and consensus standatds. The proposed Regulatory Guide provides no new infotmation and temains vague on '

questions such as an appropriate self-audit frequency.

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- Docket Number'50-346 .

- License Number NPF - Serial' Number 2002 Attachment 3 7: Page 1--

Comments on Draft Regulatory Guide DG-8005 Assessing Extetnal Radiation Doses From Airbotne Radioactive Haterials GENERAL-COMMENTS ,

.s Toledo Edison _ reviewed Dratt Regulatory Guide DG-8005, Assessing External Radiation Doses From Aitborne Radioactive Materials. Based on  :

Review of this. document, the Comoany does not believe issuance of the proposed Regulatory Guide is necessary for power reactor licensees.  ;

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The requirements of the draft guide are routinely performed by these licensees._ The existing programs within the nuclear power industry as a whole, and at Davis-Besse in particulas, adequately addtess these issues.

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- Docket Number 50-346 License Number NPF-3 Serial Number 2002 Attachment 4 Page 1 Comments On Draft Regulatory Guide DG 8006 .

_. Control Of Access To liigh And Veiy liigh Radiation Atens In Nuclear Power Plants ,

GENERAL C0MMENTS _

Toledo Edison has revieved Draft Regulatory Guide DG-8006, Control of Access Te liigh And Very High Radiation Areas In Nuclear Power Plants.

Based on review of this document, the Company believes that the Draft Guide is acceptable with one exception. The following discussion

- details Toledo Edison't recommendation.

SPECIFIC COMMENTS Section C. Regulatory Position 1. General ,

The proposed definition of accessible atea as "one that csn reasonably be occupied by a significant portion of an individual's body" is not ,

specific enough. As vritten, it will-result in the need for case by case evaluations by licensees. Toledo Edison si r gests that accessible area be defined as one that can be occupied by an individual's ttunk.

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