ML20091J157
| ML20091J157 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/26/1991 |
| From: | Shelton D CENTERIOR ENERGY |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-56FR23360, RTR-REGGD-08.025, RTR-REGGD-8.025, RTR-REGGD-8.038, TASK-DG-8003, TASK-DG-8004, TASK-DG-8005, TASK-DG-8006, TASK-RE 2002, NUDOCS 9201080187 | |
| Download: ML20091J157 (7) | |
Text
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4 6 l CENTERCR I
ENERGY Doneid C, SheMon
- M** A" y,,,g. gm foWo. OH 0%2K101 DM b (419)249 2303 Docket thimber 50-346 l.icense thimber NPF-3 Serial Number 2002 December 26, 1991 United States Nuclear Regulatory Commission Regulatory Publications Branch, DFIPS Vashington, D.C.
20555 Subj ec t :
Comments on Draft Regulatory Guide DG-8003, DG-8004, DG-8005,
.d DG-8006 Gentlemen The attached comments are submitted by Toledo Edison in response tc the request 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 assist in implementation of the tequirements of the revision to 10 CFR Pat t 20 " Standards for Protectior Against Radiation," that was published in the Federal Register (56 FR 23360) on May 21, 1991.
Toledo Edison, a subsidiary of Centerior Energy, is partial owner of and is responsible fot operation of the Davis-Besse Nuclear Power Station. Toledo Edison has been authorized for power operation of the Davis-Besse Nuclear Pover Station since April'1977.
As a 10 CFR 50 11ccnsee, Toledn Edison hat a ve::ted interest in any policies the NRC may adop'. which can affect the management and operation of a commercial nuclear power plant.
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Docket Nurnber 50 346 License Number NPT-3 Settal Number 2002 Page 2 Please refer any questions regarding these omments to Mr. R. V.
Schtauder at (419) 321-2366.
Very truly yours, f' D C d X t d -.
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MAT / 1m Attachments ect A. B. Davis. Regional Administratot, NRC Region III J. D. Ilopkins, NRC Senior Project Managet V. Levis DB-I NRC Senior Resident Inspector S. McQuire, USNRC A.
Y.. Roceklein, USNRC PDSNRC Document Control Desk Utility Radiological Safety Board
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Docket tJumb2r 50-346 License Numbar NPF-3 Serial Number 2002 Page 1 Comments On Draft Regulatory Guide DG-8003 Proposed Revision 1 To Regulatory Guide 8.25 Air Sampling In The Vorkplace i
GENERAL COMMENT
S The proposed revision to kegulatory Guide 8.25 tecommends specific air sampling practices which are not suited to the commercial power reactor industry. The guidance in this draft is directed at installations with a factory and/or production laboratory environment where better air sampling techniques may be required.
These sampling techniques are not necessary for operating commercisi nuclear power plants since power reactor licensee's technical specifications and operating procedures alteady 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 8.21, " Health Physics Surveys for By-product Haterial_at NRC-1.icensed Processing and Manufacturing Plants".
Regulatory Guide 8.24, " Health Physics Surveys During Enriched 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 which applies to all licensees. The following comments are made in support of this position.
SPECIFIC' COMMENTS Section C.1.2 - Hazard Index Vhile the concepts in the proposed 11azard Index are useful, when properly calculated, they are applicable only to new facilities facilities with relatively fixed _vork locational nr facilities where historical air sampling-data is-not available.
None of these criteria apply to pover reactor facilities. Guidance which is intended-to be applicable to all licensees should not include directions to use and document an analytte method which is not applicable to all licensees.
Therefore, either reference to Hazard Indices should be deleted or a categocical exemption should be placed in the Regulatory Guide stating which classes of licensees are not required to perform Hazard Index
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Docket Number 50-346 License Number NPF-3 Serial Number 2002 Page 2 Section C.4 - Early Varning Air Sampling Altborne radioactivity concentiations sufficiently elevated to cause immediate harm are detectable by the installed monitoring systems of commercial nucleat power plants. These systems are required by Technical Specifications and are operated according to vritten procedures.
Unless power reactors are expected to duplicate monitoring systems and/or records, this guidance does not apply.
Therefore, either the requirements for additional eatly warning monitoring should be deleted, or a clear exemption should be placed in the Regulatory Guide stating which classes of licensees nre not required to install and/or document additional monitors.
Section C.4.2
,A_irflov Patterns The sections concerning airflow pattern determinatian and/or observation are applicable to facilities with fixed work station and relatively fixed locations of vents and ducts.
Neither of these concepts apply directi; in a commercial nuclear power plant, where air flow patterns can change from day to day (in some cases hourly).
Determination of. alt 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 if not impossible. These requirements apply to fabrication, processing milling and production facilities but not to commercial power 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 reactors.
Conclusion The revision to <>gulatory Guide 8.25 and the supporting work (NUREG-1400 and huREG/CR.-0006) provide much useful information. The gutCnnce provided to use this infotmation 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 this, the revision should be withdrawn.
5 Docket Number 50-346 1,1 cense Number flPF-3 1
Serint Number 2002
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Comments On Draft Regulatory Guide DG 8004 Radiation Protection Programs for Nuclear Power Plants
GENERAL COMMENT
S Toledo Edison has reviewed Draft Regulatory Culde DG.8004 Radiation Protection Programs for Nuclear Pover Plants.
Based on reviw of this document, the Company does not believe issuance of the proposed Regulatory Guide is necessary.
The proposed Regulatory Guide restates existing requirements which can be found in Technical Specifications, e
existing Regulatory Guides, and consensus standards. The proposed Regulatory Guide provides no new information and remains vague on f
questions such as an appropriate self-audit frequency.
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I Docket Number 50-346 License Number NPF-3 Serial Number 2002 l
Page 1 Comments On Draft Regulatory Guide DG-8005 Assessing External Radiation Doses From Airborne lladioactive Matetlals
GENERAL COMMENT
S Toledo Edison reviewed Draft Regulatory Guide DG-8005, Assessi.1g External Radiation Doses From A1 barne Radioactive Haterials.
Based on Review of this document, the Company does not believe issuance of the proposed Regulatory Guide is necessary for power reactor licensees.
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 particular. adequately address these issues.
Docket Number 50-346 License Number HPF-3 Serial Number 2002 Page 1 Comments On Draft Regulatory Guide DG-8006 Control Of Access To High And Vety High Radiation Areas In Nuclear Power Plants
GENERAL COMMENT
S Toledo Edison has reviewed Draft Regulatory Guide DG-0006, control of Access To 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 discu.sion details Toledo Edison's recommendation.
1 SPECIFIC,COHHENTS Section C. Regulatory Position 1. General The proposed definition of accessible area as "one that can reasonably be occupied by a significant portion of an individual's body" le not-specific enough.
As vritten, it vill result in the need for case by case evaluations by licensees. Toledo Edison suggests that accessible area be defined as one that-can be occupied by an individual's trunk.
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