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| | number = ML20086R743 | | | number = ML20086R743 |
| | issue date = 12/12/1991 | | | issue date = 12/12/1991 |
| | title = Comment on Draft Reg Guide DG-8006, Control of Access to High & Very High Radiation Areas in Nuclear Power Plants. | | | title = Comment on Draft Reg Guide DG-8006, Control of Access to High & Very High Radiation Areas in Nuclear Power Plants |
| | author name = Johnson A | | | author name = Johnson A |
| | author affiliation = NORTHERN STATES POWER CO. | | | author affiliation = NORTHERN STATES POWER CO. |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20210E5881999-06-30030 June 1999 Comment Supporting Draft Reg Guide DG-1074, Steam Generator Tube Integrity. Northern States Power Endorses Comments Transmitted by NEI Ltr ML20199C2721997-10-27027 October 1997 Comment Supporting Proposed Rules 10CFR50 & 73, Proposed Amends to NRC Requirements for Emergency Preparedness & Security DD-97-18, Director'S Decision DD-97-18 Re 970528 Petition Filed by Prairie Island Indian Community Requesting That USNRC Take Action to Determine That NSP Violated Requirements of 10CFR72.122(i).Request Denied Due to Listed Reasons1997-08-29029 August 1997 Director'S Decision DD-97-18 Re 970528 Petition Filed by Prairie Island Indian Community Requesting That USNRC Take Action to Determine That NSP Violated Requirements of 10CFR72.122(i).Request Denied Due to Listed Reasons ML20216G2821997-08-26026 August 1997 Petition for Rulemaking PRM-72-4 to Suspend for Cause Northern Station Power Co Matl License SNM-2506 Needed to Operate Independent Spent Fuel Storage Installation at Prairie Island Nuclear Generating Plant ML20148Q5641997-06-23023 June 1997 Order Prohibiting Involvement in NRC Licensed Activities (Effective Immediately).Prohibits Jl Barnhart from Any Involvement in NRC-licensed Activities for Period of 5 Yrs from Date of Order ML20140E4721997-05-28028 May 1997 Petition by Prairie Island Indian Community,Per 10CFR2.206, Requesting That NRC Determine That NSP Violated Requirements of 10CFR72.122(I) by Using License SNM-2506 for ISFSI Prior to Establishing Conditions for Safely Unloading TN-40 ML20138K1511997-05-0606 May 1997 Comment Supporting Proposed Rule 10CFR73 Re Changes to Nuclear Power Plant Security Requirements ML20148R2451997-04-24024 April 1997 Demand for Info Re Jl Barnhart Contract Employee at NSP, Working Under Temporary Unescorted Access Authorization. NRC Needs Info to Determine Whether Enforcement Action Should Be Taken to Ensure Future Compliance W/Requirements ML20134P6241996-11-26026 November 1996 NRC Staff Response to Florence Township Motion for Dismissal & Request for Hearing.Concludes That Motion Should Be Denied for Reasons Set Forth.W/Certificate of Svc ML20129D4771996-10-15015 October 1996 NRC Response to Petition for Leave to Intervene of Minnesota Dept of Public Svc.* Dept Should Be Permitted to Participate as Interested State,If Another Petition Granted. W/Certificate of Svc & Notice of Appearance ML20117E4051996-08-0909 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Rule ML20117K0031996-05-0101 May 1996 Order,Granting Dismissal of Motions by Nsp,Public Utilities Commission & Environ Quality Board for Protective Orders Per Discovery & Plaintiff Motion for Temporary Injunction ML20094J0471995-10-11011 October 1995 Comment on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Fuel or High Level Radwaste ML20085E5261995-06-0606 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20083K2731995-04-28028 April 1995 Comment on Proposed Rule 10CFR50 Re Primary Reactor Containment Leakage Testing for water-cooled Power Reactors. Urges NRC to Support Rev to NEI 94-01 Which Will Allow Use of Two Reduced Pressure Type a Tests as Prerequisites ML20077M6181994-12-30030 December 1994 Comment Re Proposed Rule 10CFR50 Re Low Power Operations for Np Reactors.Util Believes That Pr Will Have Higher Impact than Described in Regulatory Analysis,As Pr Will Extend Refueling Outages at All Plants ML20071H4161994-06-30030 June 1994 Comment Supporting Petition for Rulemaking PRM-20-23 Re Reduction of Radioactive Emission from 100 Mrems to 1 Mrem/Yr ML20059K5201994-01-26026 January 1994 Demand for Info to Determine Whether Commission Can Have Reasonable Assurance That Other Burns Employees & Managers Will Carry Out Licensed Activities W/O Discriminating Against Individuals Re Safety Issues ML20062M4001993-12-30030 December 1993 Comment Supporting NUMARC Position on Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPPs ML20045G0941993-04-21021 April 1993 Comment on Proposed Rules 10CFR50,52 & 100 Re Nuclear Power Plant Instrumentation for Earthquakes.Nothing Exists Between Monitor Recording Time & CAV Methodology ML20090J9581992-03-12012 March 1992 Comment on Proposed Rule 10CFR51 Re Environ Review of Applications to Renew Operating Licenses for Nuclear Plants. Licensee Endorses NUMARC Comments ML20087F7221992-01-14014 January 1992 Comments on Draft Reg Guide DG-8005, Assessing External Doses from Airborne Radioactive Matls. Disagrees W/Statement That Airborne Concentration Measurements Unreliable ML20086R7431991-12-12012 December 1991 Comment on Draft Reg Guide DG-8006, Control of Access to High & Very High Radiation Areas in Nuclear Power Plants ML20246D8811989-06-30030 June 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T7391989-02-23023 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants ML20210B8061987-05-0101 May 1987 Order.* NRC 861020 Order Directing Licensee to Show Cause Why OL Should Not Be Modified to Prohibit Use of Radios,Tapes,Television Sets or Other Audible Entertainment Devices Recinded & Proceeding Dismissed.Served on 870501 ML20212N5501987-03-0606 March 1987 NRC Staff Explanation of Health & Safety Basis for Prohibition of Electronic Entertainment Devices in Nuclear Power Plant Control Rooms.* ML20212N5771987-03-0606 March 1987 Affidavit of Jm Taylor Re Health & Safety Basis for Staff Prohibition on Electronic Entertainment Devices in Control Rooms.* Certificate of Svc Encl ML20211D0291987-02-13013 February 1987 Order.* Staff Directed to File W/Commission & Serve on Petitioners & Licensees Detailed Explanation of Health & Safety Basis for 861020 Order Re Use of Audio Equipment in Control Rooms by 870306.Carr Views Encl.Served on 870217 ML20214C4131986-11-12012 November 1986 Affidavit of DE Gilberts Re Enforcement Action 86-164 & NRC 861022 Order to Show Cause Concerning Use of Radios in Control Rooms ML20215J1421986-10-20020 October 1986 Order to Show Cause Why Radios or Other Electrical/ Electronic Equipment Used to Provide Background Music in Control Rooms Should Not Be Removed (Ref IE Info Notice 85-053 & Circular 81-02) ML19332A0381980-09-0404 September 1980 Response in Opposition to State of Mn 800828 Motion to Hold Spent Fuel Pool Mod Proceeding in Abeyance Pending Mn Pollution Control Agency Board 800923 Meeting.Accepting Settlement During Meeting Very Remote.W/Certificate of Svc ML19331D8841980-08-28028 August 1980 Motion to Hold Proceedings in Abeyance Until 800923,when Mn Pollution Control Agency Will Act on Settlement. Settlement,If Adopted,Would Result in Withdrawal of Hearing Request ML19331D8861980-08-28028 August 1980 Affidavit Stating That Proposed Settlement Will Be Placed on Next Mn Pollution Control Agency Monthly Meeting Agenda or Considered at Special Meeting for Affirmative Majority Vote of Board Members ML19321B2701980-07-25025 July 1980 Responds to State of Mn 800424 Suppl to Petition to Intervene & 800721 Amended Contentions.Supporting Documentation,Notices of Appearance of Je Siberg & Dl Bernstein on Behalf of Util & Certificate of Svc Encl ML19321B0571980-07-21021 July 1980 Amended Contentions 1 & 2 & Withdrawal of Contention 3.Amend Request Does Not Contain Safety Analysis Re Spent Fuel Storage & Does Not Contain Analysis of Spent Fuel Pool Expansion Consequences.Certificate of Svc Encl ML19316A8941980-04-24024 April 1980 Suppl to 800408 Petition to Intervene Stating Contentions Alleging Absence of Safety Analysis in License Amend Request.Loss of Water in Spent Fuel Pool Is Not Analyzed in Application ML19309G1141980-04-17017 April 1980 Response in Opposition to State of Mn 800409 Request for Hearing & Petition to Intervene.No Rationale or Supporting Authorities Cited as Basis for Request Not to Issue Amend Until State Proceedings Are Completed.W/Certificate of Svc ML19305E1941980-03-31031 March 1980 Notice of Appearance in Proceeding ML19305E1761980-03-31031 March 1980 Request for Hearing and Petition to Intervene Re Spent Fuel Pool Mod.License Amend Should Not Be Issued Until State of Mn Administrative Proceedings Are Completed Re Licensee Application for Certificate of Need & Environ Evaluation ML19249D6901979-07-10010 July 1979 Requests That Decision in State of Mn Vs NRC Be Implemented. Holding Affirms ALAB-445 Decision Re Consideration of Storage of Radwaste During Licensing Proceedings 1999-06-30
[Table view] Category:PUBLIC COMMENTS ON PROPOSED RULES & PETITIONS FOR
MONTHYEARML20210E5881999-06-30030 June 1999 Comment Supporting Draft Reg Guide DG-1074, Steam Generator Tube Integrity. Northern States Power Endorses Comments Transmitted by NEI Ltr ML20199C2721997-10-27027 October 1997 Comment Supporting Proposed Rules 10CFR50 & 73, Proposed Amends to NRC Requirements for Emergency Preparedness & Security ML20138K1511997-05-0606 May 1997 Comment Supporting Proposed Rule 10CFR73 Re Changes to Nuclear Power Plant Security Requirements ML20117E4051996-08-0909 August 1996 Comment Supporting Proposed Rule 10CFR26 Re Fitness for Duty Rule ML20094J0471995-10-11011 October 1995 Comment on Proposed Rules 10CFR60,72,73 & 75 Re Safeguards for Spent Fuel or High Level Radwaste ML20085E5261995-06-0606 June 1995 Comment Supporting Proposed Rule 10CFR73 Re Changes to NPP Security Requirements Associated W/Containment Access Control ML20083K2731995-04-28028 April 1995 Comment on Proposed Rule 10CFR50 Re Primary Reactor Containment Leakage Testing for water-cooled Power Reactors. Urges NRC to Support Rev to NEI 94-01 Which Will Allow Use of Two Reduced Pressure Type a Tests as Prerequisites ML20077M6181994-12-30030 December 1994 Comment Re Proposed Rule 10CFR50 Re Low Power Operations for Np Reactors.Util Believes That Pr Will Have Higher Impact than Described in Regulatory Analysis,As Pr Will Extend Refueling Outages at All Plants ML20071H4161994-06-30030 June 1994 Comment Supporting Petition for Rulemaking PRM-20-23 Re Reduction of Radioactive Emission from 100 Mrems to 1 Mrem/Yr ML20062M4001993-12-30030 December 1993 Comment Supporting NUMARC Position on Proposed Rule 10CFR73 Re Protection Against Malevolent Use of Vehicles at NPPs ML20045G0941993-04-21021 April 1993 Comment on Proposed Rules 10CFR50,52 & 100 Re Nuclear Power Plant Instrumentation for Earthquakes.Nothing Exists Between Monitor Recording Time & CAV Methodology ML20090J9581992-03-12012 March 1992 Comment on Proposed Rule 10CFR51 Re Environ Review of Applications to Renew Operating Licenses for Nuclear Plants. Licensee Endorses NUMARC Comments ML20087F7221992-01-14014 January 1992 Comments on Draft Reg Guide DG-8005, Assessing External Doses from Airborne Radioactive Matls. Disagrees W/Statement That Airborne Concentration Measurements Unreliable ML20086R7431991-12-12012 December 1991 Comment on Draft Reg Guide DG-8006, Control of Access to High & Very High Radiation Areas in Nuclear Power Plants ML20246D8811989-06-30030 June 1989 Comment Supporting Proposed Rule 10CFR50, Acceptance of Products Purchased for Use in Nuclear Power Plant Structures,Sys & Components ML20235T7391989-02-23023 February 1989 Comment Opposing Proposed Rules 10CFR50 & 55 Re Educ & Experience Requirements for Senior Reactor Operators & Supervisors at Nuclear Power Plants 1999-06-30
[Table view] |
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Welch fAnnesota %0R9 Y IR 27 p2 34 December 12, 1991 Regulatory Publications Branch DFIPS, Office of Administration U.S. Nuclear Regulatory' Commission Washington, DC 20555 Chief, Thank you for the opportunity to comment on Draft Regulatory Guide DG-8006, Control of Access to High and Very High Radiation Areas in Nuclear Power Plants.
C.2.1 requires surveys to be made and documented to evaluate the radiation hazards in the area prior to entry. This implies that surveys be made priot to each entry. This is not ALARA. We should be able to conduct and document surveys at a frequency dependent on the likelihood of change, inf orm perrannel entering the area of expected dose rates, and then requite them (after adequate training)-to monitor the area on entry and control their dose.
C.2.1 page 6 requires documentation of all entties into high rad areas. It should be adequate to documer- each entry with the RWP sign in procedure or when the key is iss'wd for entry to the area.
C.2.1 page 6 item 4 talxs about a warning device but it is never
. defined.
Appendix A requires that justification for using divers be inenrporated into the RWP. I agree with the justification but it should be part of the work control process and not on the RWP.
RWPs are already very detailed and can be codfusing if inappropriate information is added to them. This information should be part of the ALARA review program.
Aprendix A.3 requires documentation of location of objects that produce dose rates greater than 1 rad per hour en contact. The term rad is not consistent with dose terms used in 10CFR20.
10CFR20 has specific statements that indicate that the only allowable term is rem.
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Appendix A.4' requires radiation surveys daily,-before and during diving operations. The daily survey should be removed as the before and during would satisfy the daily requirement. A separate daily survey could not be ALARA.
Also requiring '. redundant monitors during the diving operation is overkill as the diver has an alarming device.
Appendix A.6 requires a remote readout radiatien detector that is continuously monitored by RP personnel and item 4 of Appendix A requires two independent radiation exposure _ monitoring devices '
during diving _ operations,_this is too much. I can see doing two independent surveys prior to the work and having a dose rate monitoring device with remote readout on -the diver during the ;
diving operation and an alar. ming device, but it is overkill and maybe not safe to have two dose rate monitoring devices dering the diving operations.
Appendix D _.
I realize that this section is an Acceptable method asid not necessarily a requirement, but NRC inspectors will use this as a rule and inspect to this level even if we have not had a problem in this area. I would like to see a statement that this is not a requirement but an acceptable method.
The first paragraph implies that health physics technicians are the only people that are qualified in radiation protection procedures.
It is not ALARA to send two people (the HP tech and the worker or i nspector- or. ope rator) into an area when only one person is needed.
If we train workers, operators or inspectors to do radiation surveys, how to minimize dose and control their dose, we should be able to-take credit for it.
The second to -last- _ paragraph requires that the stay times be .
- dispinyed on the RWP.- The stcy time is dependent -on an individual's allowable dose and should not be npecified on. the RWP.
The time limit requirement can very easily be satisfied by using dose integrating and alcrming devices.
Thank you for stating in the ;.econd to the last paragraph that 30 '
cm or.12 inches- can be used.__ This- is not mentioned in the regulation but is needed.
The requirement to have the dose rates listed on the RWP-is also excessive. We post survey results at the entrance to these areas which will make it easier-for a person to determine the dose rate- .
than from an RWP. RWPs now require so much information that it is not possible to do a good job-on one page. Too much information at one-time is confusing and has caused problems at our facility and others. A floor plan at the area should be an acceptable-method.
i .
The last paragraph requires that we have a locking device or a red flashing light at entrances to areas greater than 1 r/hr. We have had good success using closed circuit / ideo cameras for controlling access to these areas, will we now have to change our methods?
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