ML22062A531

Comment (4) of Hilary Lane on Industry Comments on Nrc'S Draft Regulatory Guide (Dg), DG-8060, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses

ML22062A531
Person / Time
Site:	Nuclear Energy Institute
Issue date:	03/02/2022
From:	Lane H Nuclear Energy Institute
To:	Office of Administration
References
87FR4059 00004, DG-8060, NRC-2021-0217
Download: ML22062A531 (4)

Text

HILARY LANE Director, Fuel and Radiation Safety 1201 F Street NW, Suite 1100 SUNI Review Complete Washington, DC 20004 Template=ADM-013 P: 202.341.7951 E-RIDS=ADM-03 hml@nei.org nei.org ADD: Bridget Curran, Harriet Karagiannis, Mary Neely Comment (4)

Publication Date: 1/26/2022 Citation: 87 FR 4059 March 02, 2022 Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 ATTN: Program Management, Announcements and Editing Staff

Subject:

Industry Comments on NRCs Draft Regulatory Guide (DG), DG-8060, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses, Docket ID NRC-2021-0217 Project Number: 689 Program Management, Announcements, and Editing Staff:

On behalf of its members, the Nuclear Energy Institute (NEI) 1 appreciates the opportunity to provide comments on the proposed Revision 1 of RG 8.34, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses. Revision 1 describes an approach that is acceptable to the staff of the U.S.

Nuclear Regulatory Commission (NRC) to meet the requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 20, Standards for Protection Against Radiation, (Ref. 1), for monitoring and determining the radiation dose to occupationally exposed individuals.

The purpose of Revision 1 is to provide guidance:

• to revise the definition of the total effective dose equivalent (TEDE) as the sum of the effective dose equivalent (for external exposure) (EDEX) and the committed effective dose equivalent (CEDE),

• to provide guidance on performing prospective dose evaluations to determine the need for required monitoring to meet the occupational dose monitoring requirements of 10 CFR 20.1502,

• to provide guidance on monitoring of unplanned, unintended doses when monitoring was not performed,

• to provide guidance on monitoring dose from hot particles or contamination on or near the skin, 1 The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on behalf of its members on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

Program Management, Announcements, and Editing Staff March 02, 2022 Page 2

• to define the term dosimetry processing and explain when there are requirements for processing by an accredited National Voluntary Laboratory Accreditation Program (NVLAP) processor,

• to provide guidance on assessing dose from intakes of radioactive material by wound injuries, and

• to provide guidance on calculating soluble uranium intakes.

We appreciate the NRCs 30-day extension to this comment period to provide stakeholders additional time to review this revision, considering the original Regulatory Guide was last issued in July 1992. We refer you to the attachment for our detailed comments.

We appreciate your consideration of these comments. Please contact me if you require further information or clarification.

Sincerely, Hilary Lane Attachment c: Mr. Steven Garry, NRC/NRR Ms. Harriet Karagiannis, NRC/RES

Attachment 1: NEI Comments on DG-8060, Monitoring Criteria and Methods to Calculate Occupational Radiation Doses Section Comment Proposed Resolution 2.1 (Page 10) Footnote 1 appears to have a typo in the phrase Revise the footnote to use the term the term should denote a denotes instead of denote recommendation 2.5 (Page 12) The following sentence appears to contain a The phrase unplanned, intended typo (emphasis added): exposures seems to be a typo which These scenarios do not involve required needs to be corrected. Based on the monitoring because the prospective dose guidance in the DG it appears that the evaluation determined that these types of phrase should say unplanned, unplanned, intended ex posures may occur unintended exposures If this is not a and were not likely to exceed occupational dose typo, additional guidance is needed on limits. what this term means.

3.2 (Page 13) The last two sentences of this Section appear to NRC should revise the last two contradict each other: sentences of the section to clarify that At the end of the year, doses from each the DDE is the sum of each location location would be summed. The DDE to be with the highest dose per wear period.

recorded would be that of the dosimeter location Currently, the draft as written does not receiving the highest dose. convey that meaning.

It is not possible to sum each location while also only recording the highest location. Clarification on this statement is needed.

3.4 (Page 13), The following sentence contains unclear For clarity, we recommend not and similar language (emphasis added): referring to a specific revision of wording in For hot particles or contamination on or near NUREG/CR-6918 and deleting the Section 4.5 the skin, SDE may be calculated using methods words or more updated versions.

described in NUREG/CR-6918, R evision 4, VAR SK I N + 1.0, A Computer Code for Skin Contamination and Dosimetry Assessments issued in 2021 (Ref. 25) or m ore updated versions.

The reference to a specific revision of NUREG/CR-6918 and the terminology or more updated versions appears to be limiting and may confuse the reader to infer or interpret that an earlier version of Varskin (e.g., Varskin 5, etc.) cant be used.

Appendix A In the Appendix A example, it is not clear to all It would be helpful if the RG provided readers how the uranium calculations are some additional, more straightforward performed. I.e., from the calculations of intake calculations of other scenarios.

masses (Table A-2) to the calculation of CEDE (Table A-3) 1

Section Comment Proposed Resolution It would also be helpful to include an example, or additional guidance, on an acceptable situation for documenting a prospective evaluation for the need for monitoring, and how to properly evaluate and document the situation.

Appendix A The last sentence before Table A-2 appears to Revise the language to change the (Page A-2) have typo in the language If bioassay word intake to intakes.

monitoring indicates additional intake occurred Appendix A It appears that the statement Table A-2 shows Revise this to correctly refer to Table (Page A-3) the data used in calculating CEDE incorrectly A-3 instead of Table A-2.

refers to Table A-2 when it should refer to Table A-3.

Appendix A The Committed Dose Equivalent (CDE) section Revise this to correctly refer to Table (Page A-3) at the end of page A-3 appears to incorrectly A-4 instead of Table A-3.

refer to Table A-3 when it should refer to Table A-4.

Appendix A The sentence below Table A-4 appears to Revise this to correctly refer to (Page A-4) incorrectly refer to Equation A.3 instead of Equation A.4 instead of Equation A.3.

Equation A.4.

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