ML20095C820
| ML20095C820 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 05/12/1986 |
| From: | Koester G KANSAS GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML19346A656 | List: |
| References | |
| FRN-50FR51992, FRN-56FR23360, RULE-PR-19, RULE-PR-2, RULE-PR-20, RULE-PR-30, RULE-PR-31, RULE-PR-32, RULE-PR-34, RULE-PR-35, RULE-PR-39, RULE-PR-40, RULE-PR-50, RULE-PR-61, RULE-PR-70 50FR51992-00261, 50FR51992-261, AA38-2, AA38-2-0424, AA38-2-424, KMLNRC-86-088, KMLNRC-86-88, NUDOCS 9204240174 | |
| Download: ML20095C820 (12) | |
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KANSAS GAS AND ELECTRIC COMPANY m nacinecccwsv May 12, 1986 fi. ~
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h Secretary of the Ccmnission
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Washington, D.C. 20555 KMLNRC BG-088 Re:
Docket !b. STN 50-482 Subj Ccmnents on Proposed Pevision to 10 CFR 20, Standards for Protection Against Radiation
Dear Sir:
On January 9,
- 1986, a proposed revision to 10 CFR 20 was published for ecmnent ( 51FR1092).
The Nuclear Regulatory Ccmnission's expectation of the proposed revision is to provide inproved assurance of protection and to establish a clear health protection basis for limits and other actions taken to protect the public health.
Attached are Kansas Gas and Electric's (8G&E) specific etnnents on the proposed legislation.
KG&E believes that the proposed changea will have adverse effects on radiation protection practices.
It is difficult to assess the full impset of the proposed Part 20 without knowing the manner in which this document will be implemented.
It is KG&E's position that a cceplete set of Regulatory Guides must be developed and distributed for public ccnnent, along with the proposed Part 20.
In ' addition, KG&E believes it is imperative that a backfit analysis be empleted and made available for public ccmnent prior to finalizing any revisions to these regulations.
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l If you have any quesitons concerning this matter, please contact me or Mr.
O. L. Maynard of my staff.
Very truly yours, 0 j Glenn L.Koester Vice President - Nuclear CLK:see Attach cc: PO'Connor (2)
JCunrnins 9204240174 920225 20 E 6F 3360 PDR
P Mt N. Market - Wictuta. Kansas - Mad Address: PO. Bos 2061 %: twin, Kansas 67201 - Telephone: Arsa Code (316) 2616451
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Attachment to PMIERC 86-088 Page 1 of 11 INTRODUCTION Over the past several years the NTC has been developing a proposed revision to 10CFR20, Standards for Protection Against Radiation.
It appears that the NBC's min reasons for changing Part 20 aret 1) to t:pdate the basis of exposure limits,
- 2) to reduce the number of workers exposed in the higher exposure categories, and 3) to reduce the industry average to 0.5 ren per year.
It is both interesting and irrportant to note that the NRC, in their own sunmary of the proposed rule, admits that the reductions aM the nt:nber of workers exposed to higher levels tray not in itself justify a part 20 revision.
Although it rray be based on newer scientific research, the ability of the proposed Part 20 to protect the individual is not significantly different from the current regulation.
The proposed Part 20 does not appear to improve or increase the health and safety of the worker or the public.
Current practices meet or exceed the intent of the proposed changes.
'1his is attributed in part to the increased emphasis on radiation protection, worker awareness, and the continuous process of regulatory updates and revisions.
Chairman Palladino's and Comnissioner Zech's ccxunent that this is the first revision to Part 20 in over 20 years is not entirely ectrect.
10CFR20 has undergone a continuous process of updates ad revisions.
It nust be noted that a conplete revision is not necessary to incorporate the main ideas presented in the proposed Part 20.
Kansas Gas and Electric (KG&E) is willing to support changes which are based on sound scientifie work if, and when, it can be shown that new proposals provide significant irrprovements from cur, rent regulation and will rake significant improvements in Radiation Protection practices.
In the proposed Part 20 KG&E believes that the exansion of AR:endix B to include more isotopes,
and the definitions of Annual uimit on Intakt, (ALI) aM Derived Air Concentrations (DAC) are the strongest points.
Additional KG&E ccmnents on general areas of change are discussed in Section 1
and contnents to specific paragraphs which would have significant implications are discussed in Sectior. 2.
S crION 1 PROPOS!D 5 REM PER YYAR LIMIT /FCANNED SPtCIAL f:XPOSURE NUREG-J713 Volume 5 contains information which is directly relsted to the 5 rem annual limit (see Table 1).
From 1977 to 1982 there was an annual sverage of 66,544 personnel in the nuclear power industry with measurable exposure. Of these workers, an average of 240 workers received greater than 5 ren in one year.
This represents 0.4% of the work force.
If data were available for 1983, 1984, aM 1985 it is strongly believed that this low percentage would continue, and further, it is believed that the percentage of workers with exposures greater than 5 rem in one year would be even less than th 0. 4% reported from 1977 to 1982.
That is, a few workers in isolats cases are receiving exposures in excess of 5 rem per yeaT~
I There 3, it is readily apparent that the industry is meeting the intent of the prop; sed rule.
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Attachment to KMIMC 86-088 Page 2 of 11 4
Initially, the Planned Special Exposure provision sounds like a reasonable replacmenit to the 5(N-18) rule.
KG&E believes that the NR9s refusal to accept the 10 rem Planned Special Exposure reemmended by ICRP 26 is reasonable and truly in the best interest of the individual worker (the proposed 10CFR20 revision would allow 5 rm).
KG&E also agrees that this provision should not be taken lightly or used frequently.
However, with the wording in 20. 206(a) it is highly unlikely that Planned Special Exposures will ever be used.
Phrases such as " exceptional situation (s) " and
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" alternatives which...
are unavailable or irtpractical" are extreely subjective.
It is difficult to envision any situation where licensees would be able to ' justify' the use of Planned Special Exposures.
Without an appropriate draft Pegulatory Guide available for revi..i and cortment along with the proposed Part 20, the implementatica by the licensee and enforcement by the !mC is totally uncertain. At most, the proposed Part 20 would have prevented six workers (from 1969-1983) from receiving a dose in excess of 10 rm in one year.
The lack of a Regulatory Guide, in this instance and throughout Part 20, is seen as a nujor deficiency.
S3fRTION OP !!fl'ERNAL A*O EXTERNAL EXPOSURES Information from AIF/NESP-030,
" Dosimetry and Recordkeeping Inglications of the Proposed Pavisions to 10CFR20",
states "that fewer than 1% of the industry workers will exceed both 101 of the external limits and 30% of the internal limits".
Surming of the doses will therefore be required for only a few, while records will probably be naintained for many to sinply shcw statistically insignificant 'less than' values.
The AIF report also states that the annual internal effective dose equivilent for nuclear power plant workers is 0.008 rem and 0. 220 rem for fuel fabrication facility workers.
The 0.008 rem is trivial when conpared to the nuclear pcuer industry average of 0.660 rem external exposure.
As with the proposed elimination of the 5(N-18) rule, the sunmation of internal and external exposures will obviously have no significant impact upon wo;ker exposure reduction, health, or safety.
If the imC has information thae a particular licensee or class of licensees is having difficulties or probles in a particuler area, then a: rending those licenses only, as per the current 10CFR20.502, would avoid f
i unnecessary impact on the rest of the industry.
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REDUCTION CF EXTREMITY EXPOSURE While the exposure reduction itself may bo justified, a severe penalty is paid in requiring monitoring at 10% of its annual limit (5 rem per year).
Obvicusly, this is equal to the whola body annual dose limit.
Since extreatity exposures are almost ge ranteed to be slightly alove the whole body exposure, any worker with the 93tential for receiving slightly le3s than
- .he annual whole body linat will be required to wear utremity dosimetry at all times.
This will result in issuing, processing, and recording a large amount of addjtional dosimetr year will likely be found to have been unnecessary,y which at the end of the tstablishing a level that requires tronitoring at 50% of the annual limit ;25 rem per year) would allow discrimination between contact (extrenity) and general area (whole body) dose rates. That is, in a non-uniform field, if the contact dose rate is greater than five times the general area dose rate, then extr mity dosimetry would be required.
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Attactsnent to 10GC 86-088 Page 3 of 11 AEARA PROGRAM KG&E supports the corv::ept of reducing personnel exposures to levels 'as low as reasonably achievable (AIARA)'.
KG&E does not support the ALARA program as described in the proposed Part 20 because its interpretation and enforement will be extremely subjective.
AIARA is a philosophy of good work practice and cannot be readily governed by regulation.
A mandatory ALARA program could become an area of continuous contention _between the licensee and the NIC.
In most cases it is possible after-the-fact to find i
' reasonable' items that wre not considered before a task was undertaken.
me decision as to what is ' reasonable' is highly subjective and depends on each individual's judgement.
We proposed Part 20 requires "Each licensee shall ensure that the dose... is as low as is reasonably achievab'.e... ".
In some portions of the proposed Part 20, such as the definitions for Radiation Area and High Radiation Area, the - rule has been clarified.
- However, the definition of ALARA remains ambiguous and i@ lies that scme form of cost-benefit, optimization, or other studies are performed to determine if each and every task, operation, design, ect.
is AIARA.
.We subjectiveness and ambiguity continues in the Supplementary Information Section VIII which reads in part, "However, the Part 20 revision would not require optimization studies, in the sense described below, because of the difficulties in performing the analyses and because it is recognized that the decisions must be largely judgmental in any event." -Additional regulation which by the Staff's own words_ is."largely judgmental" is not in the best interest cf^either the NRC or the utilities.
CONm0LS FOR AC '!O VERY HIG1 RADIATION AREAS Many of the new regulations appear to be aimed at research arri developnent, nedical, or irradiation facilities; for exag le, the requirement of primary controls for access to very high radiation areas.
B is is of particular concern for entries into the reactor containment building while at pcwer.
Entries of this nature are comon and serve in part to satisfy various technical specification requir ments.
Existing administrative controls and design features have proven to be more than adequate in restricting access to very high radiation areas.
The addition-of physical devices for controlling access to very high radiation areas would be very costly and seems to be unnecessary.
-Additional interlocks with the reactor protection syste will raise severe nuclear safety questions.
Regulations of this sort appear not to be practical for iglementation at comercial power reactors.
As a part of its backfit analysis, the NBC should examine-the i@ act of a large number of required engineering changes.
REPOSURE IN NTLC N THE I.IMITS KG&E believes.that the proposed Part 20 may create a new area of serious concern.
With the strict 5 ram annual limit and -provision-for exposure after exceeding the annual limit, a worker may be encouraged to l
intentionally exceed the annual whole_ body dose equivalent limit. As stated an individual is limited to 5 rem per year, provided he is below that level.
- Yet, if an individual does exceed the annual limit; - he is automatically allowed an additional 1: rem per quarter for the remainder of
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Attachment to KMUmC 86-988 Page 4 of 11 that year.
In the case where an individual receives a large portion of the annual limit early in the year and fears, justified or not, that he will beccme caenployable, that indivianal may surmiso that it is in his best interest to intentionally exceed the annual limit so that the additional exposure will becczne available to him.
Wis is a situation where the licensees would bear the responsibility, but would have limited control.
KC&E believes that at scxne point there is a final limit.
However, an acceptable Alternative would be a provision for case-by-case review by the NBC Hith additional exposure to be authorized. Since exposures in excess of the limits are very rare the latter method seems much more desirable (i.e.
autcmstic exposure authorizations in excess of the limita would be disallowed).
An additional benefit to this method would be that workers would not be confc. sed by an apparent change in philosophy frcrn the NBC, Alle giving the individual an 'out' if he were not in error.
Section 2 Listed below are individual ecmnents by paragraph number; tearagraph 29.3
_ Radiation Area and High Radiation Area definitions - KG&E concurs with the proposed definitions.
Wey are stated more precisely and not subject to individual interpetotion.
Very High Radiation Area definition - The word 'very' does not seen suited to convey the serious nature of radiation at this level.
As stated in the supplementary InfoEmation Section XXII, this tyoe of area could "present an imediate threat of lethality...".
KG&E recomenas changing the wording to Extrem High Radiation Area which would give a greater enphasis to the danger that is present.
This change is not just very inportant, it is extranely inportant.
l Dose term definitions - For those definitions for which terminology already exists the current industry accepted jargon should renain (i.e.
whale body l
dose instead of deep dose, skin cose instead of shallow dose, 50 year internal dose equivilent instead of comitted dose equivilent, etc.).
The t
clarity of a definition is critical when attarpting to teach the workers wnat Radiation Protection / Health Physics is and how it is used for their health and safety.
When terminology begins to get conplex the workers' are likely to give up trying to understand, and more inportantly, close the door on comunication with -Radiation Protection personnel.
KG&E 'strongly believes that for workers to beccrne fully involved in Radiation Protection, they nust be able to understand basic definitions and practices.
Wese new definitions will not meet that objective.
KG&E believes our res.wmiation of using more familiar terms is more than reasonable given that ICRP forsaw I
different degrees of inplanentation of their recomendations.
ICRP 26 ptragraph 5 reads in part, "Because of differing conditions that apply in various countries, detailed guidance on the application of its L
reconmendations, either in regulation or in codes of practice, should be elaborated by the various international and national bodies that are
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Attachrnent to mZBRC 86-088 Page 5 of 11 familiar with what is best for their needs", and continues, "Because of this, the form in which the recamnendations are worded will not necossarily be s,uitable, and may often b2 inappropriate, for direct assimilation into regulations or codes of practice."
We NBC has already used this flexibility by keeping the 3 rem per quarter whole body dose limit.
ALARA definition - This definition would mke conpliance nearly inpossible since it uses the word 'every' in conjunction with a very subjective program.
Extranities definition - Inclusion of this definition is supported.
Occupational Dose definition - Delete the reference to " unlicensed sources of radiation" and possession by "other person".
As written these words do not inlong with the renainder of the definition.
Week _ definition - The bejinning of a week is somewhat arbitrary.
Licensees snoufd bs given flexibility to define what seven day interval constitutes m ir eek.
Changing the beginning of a week could require costly changes to establigaed camuter programs with no benefit receivad.
Reference Cavel definition The definition indicates that the reference level is not a limit although operationally it is a limit, as used in 20.303.
Paragraph 29.4(6) - his paragraph inplies that a licensee would be in violation it dose were expressed without the prefix, for exangle 1.65E-2 Sleverts or 0.03 Sleverts as in Paragraph 20. 201(a) (2).
.We paragraph inplies that the prefixes are not to be used for anything else.
Its presence is not necessary and should be deleted.
Paragraph 29.5(3) - Same convent as Paragraph 20. 4 (6).
Paragraph 29.192(a) and (a)(1) - For reasons daccribed earlier, KG&E opposes a mandatory ALAPA program as described in the proposed Part 20.
If
- approved, licensees will more than likely be continually cited for non-ccnpliance.
FiMings will be subject to each inspectors interpretation in accordance with his owa personal philosophy as to what constitutes ALARA.
is impossible to establish an absolute standard given the vague guidance It presented here.
Pamp isi 29.182(a) (2) - We extent of " examination and verification of program features" aM "achinistrative controls specifying investigation below the limits" is inpossible to determine without ' reviewing the-draft Regulatory Guide.
Proper camnents cannot be developed on this, (a)(3), and 1
(a) (4).
Paragraph 29.291 - For reasons described earlier, KG&E believes that the proposed Part 20 would not be any more effective in protecting individuals than the current regulation.
Were is no expected reduction in the collective whole body dose or internal dose.
It should be noted that during 1983 there were only seven (7) exposures in excess of the limits. - All seven cases occurred because of dose-tracking errors.
Even though internal doses are estimated ' to be quite small, the additional recordkeeping is likely to
$R Attachment to KMUGC 86-088 Page 6 of 11 result in more dose-tracking errors, thereby increasing the number of personnel with exposures in excess of the limits.
Foer of erceeding limits will more than likely cause licensees to use more workers to accanplish the same amount of work.
Practices of this kird are not ALARA and will cause a greater collective exposure total.
Paragrapi 29.2sl(c) - As described earlier, a blanket authorization for a worker to receive additional exposure after exceeding the annual limit does not appear to be a good rule.
It should be elfaivted ecopletely or replaced with an NBC case-by-case ex;msure authorization.
Paragraph 29.292 While this paragraph is understood in general, its inplementation and enforcement is difficult to interpret.
mis is another case where a draft Regulatory Guide is necessary.
As written, KG&E interprets this to nean any worket ingesting less than 30% DAC, respirator or not, would not have DAC-Hours kept for internal assessment.
This method would be an inprovement over the current regulation.
While KG&E understands the use of DAC-Hours in showing conpliance with the ALI, we believe that keeping records of fractions of DAC-Hours does not serve any useful purpose (i.e. less than 0.3 DAC-Hours per day).
r Paragraph 2s. 264 (e) - KG&E believes a licensee should be allowed to choose the most restrictive DN: for singler calculations rather than be forced to use fractional intakes of each lung class.
A licensee must not be penalized if the assessment is conservative.
We wording in this paragraph should be similar to Paragraph 20.204(c).
Paragraph 2s. 295(b) (5)
No distinction is made between current and past arployees.
me licensee should not be required to report -to current mployees annually since those individuals may review their exposure records at any time.
Were is no requirement for the previous atployee to continue tU update his forwarding address, so it would be nearly inpossible for a licensee to comply.
KG&E also believes it is reasonable not to send corrections to those licensees who had been sent an earlier copy if the corrected values are less than those previously calculated or not greater
- than, say, 10% of the previously calculated exposure.
The paragraph as written adds administrative conpliance probles and yet provides no significant protection to the individual.
Paragraph 29.2G6 me following conments are in addition to the earlier conments regarding Planned Sp3cial Exposures:
(1)
Ir./erpetation of 206(d) nust not include exposures from previous years (under the 5(N-18) rule) which were greater than 5 rm.
(2) The-reporting requirenents of 206(g) and (h) appear to be auch too strict.
KG&E does not agree with, L or understand, the NBC's apparent sense ot ?rgency in this matter. An alternative would be to report the number of times during the year that Planned Special Exposures were used and the total dose incurred.
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AfD2 Attachment to IHIRIC 86-088 Page 7 of 11 (3) Another shortcoming of the Planned Special Exposure concept is that at the and of the year an individual may have received exposures, normal and planned special, that would not exceed the proposed 5 rm annual limit. mere is no provision for transfering the dose fr m the planned special exposure back to the ' norm 1' annual total.
In this situation a considerable amunt of effort, in addition to the normai controls, would have been unnecessarily expeMed to document the Planned Special Exposures, and would result in the workers' planned special exposure
' hank' being unjustly lowered.
Paragraph 29.393 - mere is an inconsistancy in the use of the " Reference level" terminology betwen the Suppimental' Informtion Section aM the proposed rule.
m e definition states that a reference level in not a limit and in Supplementary Information Section XVII, "It is sphas!. zed that the reference levels are not limits for permitted dose...".
However 20. 303 (c) requires a licensee to subnit an " application for (prior) authorization to operate in excess of the reference level Operationally and technically this is a limit.
We statement nude in Supplemental Informtion Section XVII that " reference levels are not limits" could have caused some conmenters to interpret Section 20.303(c) incorrectly.
KGE believes that the inconsistency in the use of the terms should be corrected and this section should be resubnitted for conment prior to issuance of the final rule.
If the NBC wants to include the reference level then it should have added the additional provisions frcrn ICRP 26.
- Finally, if the NIC belisves that the 'new' scientific evidence is superior to the basis of t1e previous regulation, then the EPA should be petitioned to change 40TR193.
Dose is dose no m tter where it comes from.
Uranium fuel cycle operation facilities appear to be regulated with a double standard empared to other licensees.
Paragraph 29.364 - Calculations of risk from low doses of radiation and variations in annual background radiation lavels sem to part company on the proposed cutoff of 0.001 rem per year dose evaluation level.
Minor changes in iMividual lifestyle, let alone location of residence, my cause a greater change in background radiation dose than the proposed cutoff level.
KC&E believes that a level. of 26 or 10% of the average riatural background would be a cuch note reasonable value.
mis value would still be below differences fr m various localities.
At this time, it is appropriate to respond to Cm missioner Asselstine's question about a collective deminimis level.
Establishing a collective d einimis level defeats the purpose of having an individual deninimis level at all.
As the affected populations increase, the individual deminimis level becomes vanishingly small.
Paragraph 29.591(a) (2) - Changing the requirement from evaluating radiation levels "that nay be present" to levels "that could be present" se es to j
inply a nuch broader scope.
If surveys were performed of radiation levels "that could be present",
then overprotection of the individual would be required.
This could lead to decreased work efficiency and increased exposures which would not be AIARA.
m is para 9: eh is seen as typical of the apparent attenpt to justify a conplete revision tu 10CFR20 when in fact no s'gnificant changes (changes that will make meaningful. improvements in radiat. ion protection) are being mde.
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'd Attachment to IHIJmC 86-088 Page 8 of 11 Paragraph 29.551(c)
Since this paragraph is indicated for separate rulemaking it should be deleted.
Nrwesi 29.542(a)(1) - As discussed earlier, monitoring of extremeties at 10% of the annual limit is unreasonable.
Paragraph 29.582(a)(3) - Change 'very high' to ' extreme high' as discussed in Paragraph 20.3.
Parwtdi 29. 562(b) (1)
- As previously discussed, KG&E believes that this proposed rule unnecessarily comits resources. to an area of radiation protection that is already achieving a high level of performance.
Paragraph 29. 562 (b) (3)
Proper conment is not possible without a draft Regulatory Guide for review.
Paragraph 29.692 (Paragraph Heading) - Change-very high radiation area to exttme high radiation area as discussed in paragraph 20.3.
Parws4i 29.692 - In the current 10CFR20 a si:nilar provision does not apply to power reactors. For reasons discussed earlier KG&E does not believe this paragraph should be directed toward all classes of license holders.
For power reactors, either massive design and installation charges would be necessary (with attendant nuclear safety issues) or an exenption would be required.
Neither of these options are justified-in light of the present administrative contro?.s.
Parwe gi 29.793 KG&E applauds the NiC for allowing the selection of a respirator to be based upon the
' average' concentrations of radioactive materials rather than the expected peak concentrations.
The deletion of 2 MPC-Hours per day or 10 MIC-Hours per 7 consecutive days is also a welcomed change.
Paragraph 29.794 - mis paragraph should be deleted as it adds nothing that the Comission cannot inpose by proposed Paragraph 20.1302.
Paragraph 992(c) - Change 'very high' to ' extreme high'.
Subpart K - KG&E disagrees with the NRC's reasoning and its decision to place the waste disposal information in Appendix F.
This information is no-different in intent than paragraphs 20.202, 20.203, 20.204, 20.205, and 20.206.
Paragraph 29.1182(a) (1) and (2) - As stated in 20.102(a) and (a) (2),
KG&E does not agree with the mandatory requirement of a subjectively inplemented and subjectively enforced program.
Paragraph 29. llf2(b) mis paragraph, which in part is repeated in 20.1103(a) and 20.1104(c), would be difficult-to inplement in that a licensee mw have difficulty knowing when 'the " proper inspe.ction had occurred.
As previously indicated in our conments.
to paragraph i
- 20. 501(a) (2),
KC&E believes this type of wording within a regulation is not appropriate.
KG&E recmmends setting the retention time at two years to remove ambiguity from the paragraph.
- Dfa Attactment to KMIMC 86-988 Page 9 of 11
' hragraph 29.n94'> 2) and 29.1196(a) - Up to this point the proposed Part 20 has been very careful not to use the term ' overexposure', but rather
' exposure in excess of the limits'.
We latter expression should be used in these paragraphs.
Paragraph 29.US4(d) - KG&E believes an individual should be able to certify that his exposure history is true and correct without a counter signature by his current or most recent enployer.
However, if an individual's mployer chooses to keep a written record then a counter signature by the sployer would seem to be that conpany's prerogative.
Historically, occupational and non-occupational exposure has always been ephasized as being the individual's responsibility.
We feel that this responsibility has justly been and should continue to be placed with the individual.
(Also see ccmnents on Form 4)
The sentence describing the assessment of dose when monitoring was not required has a najor shortcoming in that it does not -adequately address situations where an individual is allowed entry in a visitor's status.
This is an exanple of a situation actually encountered on a frequent basis when an individual would not be monitored at a licensed facility.
A station enployee sent to witness an activity at another facility would have 0.5 rem unnecessarily assessed to his exposure.
Althoug', it is possible for the originating licensee to provide dosimetry for its own people, it lacks the sinplicity of allowing personnel to travel as visitors without being penalized. Also, vendor representatives or radioactive waste truck drivers would be allowed only six visits per quarter, or ten visits per. year.
mis paragraph contains at. least three separate thoughts which confuse one another. This paragraph should be clarified by restructuring or dividing it into subsections.
mis is p.eticularly true of the transition from the case where it was determined that monitoring was not required to the case where the licenseo is unable to obtain reports.
Paragraph 29.1195 - In conjunction with earlier conments, KG&E believes that the emC's proposed requirement for reporting and justification on Planned Special Exposure is unwarranted.
While KG&E recognizes the need for documentation, it is feared that different subjective criteria will be used, after the fact, to cite a licensee.
The need for a draft regulatory guide, released for public emment before futher action on the proposed 10CFR20, is reiterated.
Paragrapn 29.1196(a) & (b) - Wese paragraphs seem to be similar enough that they could be canbined into a single paragraph.
Parws..ph 29.n96(c) - Wis is another case where a draf t Regulatory Guide is necessary.
Parws.@ 29. H99 KG&E reconmends addressing the issue of conputer records.
In order to conply with -the large number of regulatory l
requirements, conputers are a necessity.
Parws. 4 29.1292 -' KG&E agrees with the deletion of loss of operating-time of a facility and monetary value on damage to property.
[.-g Attachment to IMERC 86-088 Page 10 of 11 pai a.gd 28.1293 - Change "overexposures" to "...
Exposures in Excess of the limits..." in the title.
Prcposed Fota 4 and S We paragraph leading to the proposed Form 4(51FR1212) is inco,
':ent with the requirenents in the proposed Part 20.
Paragraph 20.1104 through 20.502 and 20.201, requires use of the form at 10% of the annual limits and with Planned Special Exposures.
We Form 4 paragraph requires the form to be used at 300 J the limits in 20.201.
mis area needs to be clarified.
As discussed in our ccrmnts on Paragraph 20.'3 (Dose Terms) KGE strongly agrees with the use of the terms:
Lens of Eye, Skin, Extremities, and Whole Body.
ConTnitted Effective Dose DIuivilent shc;"ld be charyged to layman's terms.
As discussed in our comments on Pa:agraph 20.1104 (a)(2) and 20.1106(a) the term ' overexposure' should be changed to ' exposures in excess of the l imi ts '.
- Finally, KC& E concurs with the NRC position on individual responsibility for naintaining exposure history.
As discussed in the Statements of Consideration,
" Control of Exposure to Transient Workers",
10CFR19 and 20 (44FR32349) the NRC has said, "It is recognized that the proposed method of controlling total occupational dose depends upon cooperation by the anployee with the licensee in providing information on previous and on-going erployment involving radiation dose.
The NRC does not exercise direct regulatory control over individual workers, and therefore cannot r2 quire individual workers to provide accurate dose information to licensees, and the NRC will not take enforcemnt action against a licensee solely because an individual worker withholds or falsifies information.
While recognizing the potential of econcrnic incentive for a worker to withhold or otherwise falsify dose information, the Cccmission believes that most individuals who have been instructed in the health protection problen's associated with exposure to radiation and radioactive materials pursuant to Paragraph 9.12, 10 CFR Part 19, will recognize the benefit to their health and will cooperate with licensees.
Further, NRC does not regulate all of the sources of occupational dose.
A suggested requirement for licensees to provide monitoring information to subsequent licensee-enployers would not apply to operations not licensed by NRC and would, therefore, provide only partial infornation."
SmMMtr At present, KGE believes that the proposed 10CFR20 should not be inplemented.
We newer inplicit risk based values are not significantly different frcxn the inplied risk based values.
Licensee performance shows that the atterpt to reduce the number of workers at higher exposure levels affects very few individuals.
Any benefit to be received by reducing the few workers at the high end will be offset by the exposure of more workers to middle ranges of exposure.
Licensees will be afraid to allow an exposure near the 5 rem annual limit for fear of exceeding that limit; therefore, more workers will be used.
As greater numbers of workers are used, the levels of their skills are likely to decrease.
Hence, greater collective
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expoture will follow recardless of the integrity of the efforts of the licensM.
AIARA is supposed to be a reduction of both collective and individuni exposure.
As written, the proposed Part 20 wi1T not be AtARA.
KGE believes that the resources expended to coup 1'i with arti the expected outccne of this revision will not be in the best interest of the worker, the f
public, the licensees, or the NRC.
We concur with the NBC's decision to perform a Backfit Analysis (1K7R50.109) as we believs it should
- f. ave been performed prior to publication of the proposed 10CFR20 revision.
The analysis should be made available for review and ccument prior to taking further regulatory action on the proposed Part 20.
KGE requests -detailed information on the NRC's cost estimates, as shown in.the Supplementary Information Section XXXV, to be included as part of the backfit analysis.
A cmplete set of draf t regulatory guides cust also be made available for review and corrment before any further action is taken on Part 20.
KGE recognizes that the proposed Part 20 is the result of a major effort from the NPC.
Unfortunately, it is our belief that this legislation would not be beneficial as it currently stands.
It is KGE's ultimate desire to have the above issues properly addressed and have the corrected Part 20 be reissued for public ccrment.
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