ML18153A792

Submits Comments Re Proposed Revs to Guidance Provided to Federal Agencies on Radiation Protection

ML18153A792
Person / Time
Site:	Surry, North Anna
Issue date:	04/12/1995
From:	BOWLING M L VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	ENVIRONMENTAL PROTECTION AGENCY
References
GL-95-012, GL-95-12, NUDOCS 9504180322
Download: ML18153A792 (3)

Text

April 12, 1995 Central Docket Section (6102) Attn: Docket No. A-83-41 U.S. Environmental Protection Agency Washington, D.C. 20460 Gentlemen:

COMMENTS ON NOTICE 5000 Dominion B011lemrd Gll'II Allen. Fi1~i11ia 23060

• VIRGINIA POWER Serial No. GL 95-012 NL&P/EJW FEDERAL RADIATION PROTECTION GUIDANCE FOR EXPOSURE OF THE GENERAL PUBLIC In the December 23, 1994 Federal Register (page 66414), the U. S. Environmental Protection Agency (EPA) solicited comments concerning proposed revisions to guidance provided to Federal agencies on radiation protection.

The proposed revisions are intended to provide a com*mon framework to help ensure that the regulation for exposure of the general public to ionizing radiation is implemented by Federal agencies in a consistent and adequately protective manner. Based upon our review, the following comments and concerns with the revisions proposed by EPA are hereby submitted:

• The time provided for comments by the EPA was not sufficient considering the scope, complexity, and potential impact of the proposed guidance.

• The term "general public" is used extensively throughout the EPA's proposed radiation protection guidelines without an appropriate definition.

The revised 10 CFR 20, Nuclear Regulatory Commission (NRC) licensee technical specifications, and other regulatory documents such as 10 CFR 50, Appendix I, use and define the term "member of the public." The various agencies should adopt the same terminology and definition.

• The radiation protection guidelines proposed by the EPA should exempt power reactor licensees in a manner similar to the 40 CFR 61 National Emission Standards for Hazardous Air Pollutants (NESHAPs) rule which is currently stayed for 10 CFR 50 licensees.

These proposed regulations are a source of confusion and redundancy to power reactor licensees and do not improve their radiation protection programs.

Additionally, EPA's 40 CFR 190, which most 10 CFR 50 licensees are obligated to meet by Appendix A to their NRC license, is not being revised. Therefore, another set of dose limits, which is inconsistently stated in terms of whole body and critical organ, continue to exist in the radiation protection regulations . .,,, on.G-86 1 uu t r;~ _,,-------------

9504180322 950412 PDR ADOCK 05000280 .J P PDR

..... .. .,. Federal Register notice 59 FR 66414 provides seven recommendations for implementing the basic principles of radiation protection.

The following comments concern those recommendations:

• Recommendation

1. 1 states that "there should be no exposure of the general public to ionizing radiation unless it is justified by the expectation of an overall benefit from the activity causing the exposure." The proposal states that determining the overall benefit of an activity which causes radiation exposure to the general public can be a complex process which may eventually involve congressional, executive, and judicial inputs. Recommendation

1. 1 should also provide examples of exposures which are "justified" (e.g., nuclear power) along with a summary of the reasoning behind such determinations and the level of government involvement required.

(59 FR 66418 through 59 FR 66419)

• Recommendation

1. 2 addresses maintenance of doses to members of the public as low as reasonably achievable (ALARA). This is redundant with the requirements of 10 CFR 50, Appendix I and associated licenses which already require licensees to maintain exposure to members of the public ALARA due to effluents.

(59 FR 66419 through 59 FR 66420)

• Recommendation

1. 4 states that the EPA has established source-specific dose limits for all radionuclides, combined via all air pathways

• from individual sources of radionuclide emissions, including all Federal facilities, in 40 CFR 61. This refers to the NESHAPs rule, which is being stayed for power reactor licensees.

The 10 mrem annual effective dose equivalent limit does not apply to 10 CFR Part 50 licensees at this time. Therefore, the discussion in the EPA guideline should be augmented to clarify that the source-specific dose limits for all radionuclides in 40 CFR 61 are not applicable to 10 CFR 50 licensees.

(59 FR 66424t We appreciate the opportunity to comment on the Federal Register Notice. If you have any questions, please contact us. Very truly yours, ~/j~ M. L. Bowling, Manager Nuclear Licensing and Programs

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/ Attention:

Document Control Desk Washington, D.C. 20555 e Docket Nos. 50-280, 50-281, 50-338, and 50-339 License Nos. DPR-32, DPR-37, NPF-4, and NPF-7 Mr. M. W. Branch NRC Senior Resident Inspector Surry Power Station Mr. R. D. McWhorter NRC Senior Resident Inspector North Anna Power Station Mr. John F. Schmitt, Director Radiological Protection, Emergency Preparedness, and Waste Regulation Nuclear Energy Institute 1776 I Street, Suite 400 Washington, D. C. 20006-3708