ML20235V078
| ML20235V078 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 07/13/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| References | |
| EA-87-007, EA-87-7, NUDOCS 8707230045 | |
| Download: ML20235V078 (5) | |
See also: IR 05000395/1986022
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JUL 131987
Docket No. 50-395
License No. NPF-12
EA 87-07
South Carolina Electric and Gas Company
vATTN: Mr. D. A. Nauman, Vice President -
-Nuclear Operations
P. O. Box 764 (167)
Columbia, SC 29218
Gent?emen:
SONECT:
NOTICE OF VIOLATION:
EA 87-07
Our letter dated April 16, 1987, in response to your letter of April 9,1987,
stated that we were evaluating your response to the Notice of Violation trans-
mitted with Inspection Report Nc. 50-395/86-22, and that we would notify you of
the. acceptability of your responsa in the near future.
With regard to Violation A, after ccreful review of the bases for your denial,
we have concluded, for the reasons presented in the Enclosure to this letter,
that the violation occurred as stated in the Notice of Violation (N0V). We
have also considered your view that the proposed Severity Level for both
violations is not warranted, but we conclude that the violations were appro-
priately categorized as a Severity Level III problem as stated in our
March 10, 1987, NOV. Therefore, in accordance with 10 CFR 2.201(a), please
submit to this office within 30 days of the date of this letter, a written
statement describing corrective steps which will be utilized to avoid further
violations, and the date when full compliance will be achieved.
In your
response, you may reference the briefing paper presented at the Enforcement
Conference held on December 16, 1986, and attached to Inspection Report
No. 50-395/86-22 to meet specific elements of the response required by this
letter.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosure
will be placed in the NRC Public Document Room.
The responses directed by this letter and its enclosure are not subject to the
clearance procedures of the Office of Management and Budget as required by the
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Paperwork Reduction Act of 1980, PL 96-511.
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d707230045 870713
ADOCK 05000395
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South Carolina Electric
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JUL13 $$7
and Gas Company
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We appreciate your cooperation in this matter.
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Sincerely,
J. Nelson Grace
Regional Administrator
Enclosure:
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Staff Assessment of Licensee Response
to Notice cf Violation
cc w/ encl:
Mf. S. Bradham, Director, Nuclear Plant
Operations
I L. Skolds, Deputy Director
Operations and Maintenance
J. B. Knotts, Jr.
)I.DebevoiseandLiberman
A. Williams, Jr., Special
Assistant, Nuclear Operations -
Santee Cooper
A. M. Paglia, Jr. , Manager
Nuclear Licensing
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JUL 13198/
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ENCLOSURE
Staff Assessment of Licensee Response to
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Violation A (50-395/86-22-02) involved the failure to control licensed material
in such a manner as to limit the occupational dose to an individual's extremities
to less than 18.75 rems per calendar quarter as required by 10 CFR 20.101(a).
1.
Licensee Comment
South Carolina Electric and Gas (SCE&G) understands the staff position
that NRC regulations are currently based on the recommendations of NBS
Handbook 59; however, significant advancements in the field of Health
Physics have been achieved since the publication of Handbook 59 in 1954.
Most notable of these advancements was the publication of Report 26 by the
International Commission on Radiation Protection (ICRP) in 1977.
Recominendations contained within Report 26 have subsequently been endorsed
by the international radiation protection community as well as proposed
for incorporation into Federal Regulations (Federal Register, January 9,
)
1986, Page 1092, Volume 51, No. 6). The Commission stated that the intent
of the proposed revision to 10 CFR Part 20 is to improve NRC radiation
protection standards by reflecting developments in the principles that
underlie radiation protection and advances in related sciences that have
occurred since the promulgation of 10 CFR Part 20 thirty years ago.
Report 26 recommends a system of dose limitation which requires assessment
of dose equivalent proportional to the risk of adverse health effects to
the individual, either for medically discernable (non-stochastic) damage
in the short term or the risk of cancer-(stochastic) in the long term.
Furthermore, this concept is codified in 10 CFR 20.4(c):
"The rem, as used
in this part, is a measure of the dose of any ionizing radiation to body
tissues in terms of its estimated biological effect relative to a dose of
one roentgen (r) of X-rays....The relation of the rem to other dose units
depends upon the biological effect under consideration and upon the
conditions of irradiation." Therefore, by regulation, dose-equivalent
must be proportional to biological risk.
NRC Response
Changes to NRC regulations are based not only on recommendations such as
those in ICRP 26, but also on Radiation Protection Guidances to Federal
Agencies (developed by EPA), current research by recognized experts, and
comments received during the public comment period for proposed rule
changes. The NRC recognizes that significant advances have been achieved
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in the field of Health Physics as noted in your response. The proposed
10 CFR Part 20 has been out for comment, and comments received are being
reviewed. The general points made by SCE&G and those provided by other
sources regarding the advancements in health physics will be considered
during the review. Nonetheless, the current regulations remain valid and
in effect.
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JUL 131987
Enclosure
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It should be noted that SCE&G's discussion of the rem was incomplete in
that it omitted the part of 10 CFR 20.4(c) which states that for the
purpose of the regulation in this part, a dose of 1 rad due to x-ray,
gamma or beta radiation is considered to be equivalent to a dose of 1 rem.
2.
Licensee Comment
The fraction of cells irradiated by a hot particle is an infinitesimal
fraction of the whole body with the majority of these cells being
destroyed by the high doses within the range of the beta particles.
Therefore, any real " dose-equivalent" from the beta component is
vanishingly small and implementation of IE Notice (IEN) 86-23 guidance
would, contrary to the regulation, not only overestimate the risk, but
would also give, in later years, a basis for an inaccurate probability of
causation for any cancer the' person might develop.
For this reason, SCE&G
considers IEN 86-23 guidance inappropriate for determining dose equivalent
due to hot particle contamination.
NRC Response
NRC recognizes the need for a current evaluation of the basis for dose
assignment due to very small, highly radioactive particles. Recently the
NRC formally requested the National Council on Radiation Protection and
Measurements (NCRP) to review and provide guidance on this issue. As
appropriate, when this guidance is received, the NRC will re-evaluate the
current basis of 10 CFR 20.101(a). However, until, and unless, the basis
of 10 CFR 20.101(a) is changed, the guidance in NBS Handbook 59 and
IE Notice 86-23 is to be used in determining compliance with the current
regulations.
IEN 86-23, rather than being contrary to the regulations, as
you indicated, represents the NRC position on how licensees should calcu-
late the dose to the skin from radioactive contamination. This guidance
is considered most appropriate at this time.
It is not at all clear, as
suggested by SCE&G, that the basis of 10 CFR 20.101(a) should be changed.
Recent scientific publications have indicated that the ICRP-26 guidance is
inadequate, particularly for non-uniform exposures, and have suggested
the continued use, as an interim measure, of the current practice of
determining skin dose at the basal layer of the epidermis (7 mg/cm2)
averaged over an area of one square centimeter.
3.
Licensee Comment
SCE&G has performed a dose assessment which incorporates the philosophy of
ICRP 26 and has assigned, as required by 10 CFR 20.4(c), a dose-equivalent
which is proportional to the biological risk incurred by the individual.
That dose equivalent is 0.43 rem and represents an estimate of the risk
for stochastic effects proportional to the number of basal cells which
received a radiation dose and survived (dose equivalent due to gamma rays
averaged over 100 square centimeters).
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Enclosure
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JUL 131987
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NRC Response
Based on previous guidance given in IEN 86-23 and as stated in our letter
of March 10, 1987, it is the NRC's position that the methodology SCE&G
used was inappropriate. The beta component cannot be ignored, nor is it
appropriate to average the dose over 100 cm .
Furthermore, ICRP-26 does
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not support the omission of the beta component, nor does it suggest that
the dose from the accidental contamination of individuals from small
particles should be averaged over any area larger than one square
centimeter.
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