View source for NRC-2017-0205, Comment (3) of Jack Kraus on Instructions for Recording and Reporting Occupational Radiation Dose Data

{{Adams
| number = ML17355A127
| issue date = 12/15/2017
| title = Comment (3) of Jack Kraus on Instructions for Recording and Reporting Occupational Radiation Dose Data
| author name = Kraus J
| author affiliation = FirstEnergy Corp
| addressee name = 
| addressee affiliation = NRC/ADM/DAS/RADB
| docket = 05000346
| license number = 
| contact person = 
| case reference number = 82FR48125 00003, NRC-2017-0205
| document type = General FR Notice Comment Letter type:NRC
| page count = 3
}}

=Text=
{{#Wiki_filter:Page 1 of2 As of: 12/18/17 4:32 PM Received: December 15, 2017 Status: Pending_Post PUBLIC SUBMISSION                                                                                                                             Tracking No. lkl-90d6-le6p Comments Due: December 15, 2017 Submission Type: Web Docket: NRC-2017-0205 Instructions for Recording and Reporting Occupational Radiation Dose Data Comment On: NRC-2017-0205-0001 Guidance: Instructions for Recording and Reporting Occupational Radiation Dose Data Document: NRC-2017-0205-DRAFT-0004 Comment on FR Doc #NIA Submitter Information                                                                                   J() /; (?)   #,!JI I  I Name: Jack Kraus                                                                                                                                                             g- ~ FJZ JJ-f'"; ~..!J-Address:
5501 N. State Route 2 MS: A-DB-1029 Oak Harbor, OH, 43449 Email: jgkraus@firstenergycorp.com j ___ .,,_ ***--*** --*-**--*-----**-*-----~ ,--------- - - - - - * * - * - - - - ~ * * * - ----. *-* - - - - - - - -*- --------*--------*-&#xa5;--------------------------* **------------~------~----------------*- '
General Comment In DG-8056, Section 1.1 (If Monitoring is Not Required), the following is stated:
     "If monitoring of the occupational intake of radioactive material and assessment of the CEDE is not being performed, then licensee* evaluations of subsequent minor intakes that were anticipated based on the prospective dose evaluation or pre-job evaluations is not required monitoring. However, dose assessments performed to quantify unanticipated intakes or exposures are considered required monitoring, regardless of the magnitude of the resulting doses, and results must recorded and reported accordingly."                                                                                                           .
Specifically,the statement on recording and reporting dose assessments for quantifying unanticipated intakes or exposures should be revised. This section states it is required "regardless of the magnitude of the resulting doses". This appears to be a contradiction of Regulatory Guide 8.34, Section 1.4. This section states, "Surveys and monitoring results that serve as confirmatory measures are not subiect to thejndividu_al recQrdkeeping requirements SUNSI Review Complete
* Template = ADM - 013 E-RIDS= ADM-03 https://www.fdms.gov/fdms/getcontent?objectld=0900001                                                                                                                                                          12/18/2017 Ad.d=

Page 2 of2 of 10 CFR 20.2106(a) provided such results confirm that actual individual doses are less than 10% of the limits."
While "confirmatory measures" is not defined in 10 CFR 20, the term "survey" is defined.
Specifically, the definition of survey'is "an evaluation of the radiological conditions and potential hazards incident to the production, use, transfer, release, disposal, or presence of radioactive material or other sources of radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present."
Through these definitions, it appears the two Regulatory Guides contradict                                r on whether or not doses for such confirmatory measurements and calculations are required to be assigned.
Industry practice on this topic is also not consistent with what is stat~d in the draft guidance presented. Since the requirements in 10 CFR 20.1502 have not been revised, it is unclear why the interpretation of this regulation is being revised through this draft guidance. Therefore, the draft guidance should be revised to remove the requirement for recording calculated doses "regardless of the magnitude" (as described above) and reflect what is found in Reg Guide 8.34, 10 CFR 20.1502 and industry practice.
NOTE: one additional, non-technical error was identified. Also in the statement quoted above from Section 1.1 ofDG-8056, the last sentence appears to be missing th~ word "be" between "must" and "recorded".
Currently: "... regardless of the magnitude of the resulting doses, and results must recorded and reported accordingly."
Corrected: "...regardless of the magnitude of the resulting doses,* and results must be recorded and reported accordingly."
Comments also attached via Word document.
L-*--- - - , - - - - - - - - - . ------*------------~------------~------------*-* --------------*-----------------------*----*---*-_.i Attachments DG-8056 Comments - Jack Kraus DBNPS https://www.fdms.gov/fdms/getcontent?objectld=0900006482dl5679&format=xml&showorig=false                                            \ 12/18/2017

In DG-8056, Section 1.1 (If Monitoring is Not Required), the following is stated:
"If monitoring of the occupational intake of radioactive material and assessment ofthe CEDE is not being performed, then licensee evaluations of subsequent minor intakes that were anticipated based on the prospective dose evaluation or pre-job evaluations is not required monitoring. However, dose assessments performed to quantify unanticipated intakes or exposures are considered required monitoring, regardless of the magnitude of the resulting doses, and results must recorded and reported accordingly."
Specifically, the statement on recording and reporting dose assessments for quantifying unanticipated intakes or exposures should be revised. This section states it is required "regardless of the magnitude of the resulting doses". This appears to be a contradiction of Regulatory Guide 8.34, Section 1.4. This section states, "Surveys and monitoring results that serve as confirmatory measures are not subject to the individual recordk~eping requirements of 10 CFR 20.2106(a) provided such results confirm that actual individual doses are less than 10% of the limits."
While "confirmatory measures" is not defined in 10 CFR 20, the term "survey" is defined. Specifically, the definition of survey is "an evaluation of the radiological conditions and potential hazards incident to~
the production, use, transfer, release, disposal, or presence of radioactive material or other sources of*
radiation. When appropriate, such an evaluation includes a physical survey of the location of radioactive material and measurements or calculations of levels of radiation, or concentrations or quantities of radioactive material present."
Through these defin.itions, it appears the two Regulatory Guides contradict on whether or not doses for such confirmatory measurements and calculations are required to be assigned. Industry practice on this topic is also not consistent with what is stated in the draft guidance presented. Since the1requirements in 10 CFR 20.1502 have not been revised, it is unclear why the interpret~tion of this regulation is be(ng revised through this draft guidance. Therefore, the draft guidance should be revised to remove the requirement for recording calculated doses "regardless of the magnitude" (as described above) and reflect what is found in Reg Guide 8.,34, 10 CFR 20.1502 and industry practice.
NOTE: one additional, non-technical error was identified. Also in the statement quoted above from Section 1.1 of DG-8056, the last sentence appears to be missing the word "be" between "must" and "recorded".
Currently: " ... regardless of the magnitude of the resulting doses, and results must recorded and reported accordingly."
Corrected: " ... regardless of the magnitude of the resulting doses, and results must be recorded and reported accordingly."
Comments respectfully submitted by:
Jack Kraus Supervisor, Radiation Protection Services Davis-Besse Nuclear Power Station Oak Harbor, OH}}