NRC-2009-0279, Comment (14) of Susan Reese on Behalf of South Carolina Electric & Gas Company Supporting Potential Changes to Radiation Protection Regulations
| ML100960273 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 03/31/2010 |
| From: | Reese S South Carolina Electric & Gas Co |
| To: | Rulemaking, Directives, and Editing Branch |
| References | |
| 74FR32198 00014, NRC-2009-0279 | |
| Download: ML100960273 (1) | |
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April 02, 2010 Received: March 31, 2010 Status: Pending-Post PUBLIC SU3BMISSION Tracking No. 80acdOd5 Comments Due: March 31, 2010
,Submission Type: Web Docket: NRC-2009-0279 Potential Changes to Radiation Protection Regulations; Solicitation of Public Comment Comment On: NRC-2009-0279-0001 Solicitation for Public Comment on Potential Changes to the Agency's Radiation Protection Regulations Document: NRC-2009-0279-DRAFT-0010 Comment on FR Doc # E9-15950 C:
- 77 Submitter Information Name: Susan Reese Address:
P. O. Box 88 Jenkinsville, SC, 29065 Organization: South Carolina Electric & Gas Company/V. C. Summer Nuclear Station KCJ General Comment South Carolina Electric & Gas Company (SCE&G) has reviewed the potential changes to the NRC's Current Radiation Protection Regulations and the 2007 Recommendations of the International Commission on Radiological Protection (ICRP) and has the following comments:
- 1. SCE&G agrees with the NRC's position that the current regulations provide adequate protection.
- 2. The recommendations should be adopted as constraints and not regulatory limits.
- 3. If implemented as regulatory limits, the burden to licensees would be significant. Licensees would have to consider impact to bases documents, procedures, exposure tracking software, etc. Reporting requirements that were recently changed to lessen the burden on licensees would revert back to previous requirements.
- 4. Declared Pregnant Workers (DPW). If the constraint/limit changes to 100 mrem (or less for the gestation period), licensees implementing INPO's05-008 recommendation to treat workers who declare "their intent to become pregnant" the same as a DPW could face resource issues from applying the more restrictive limit. The ICRP strongly recommends that the same constraints be applied to workers who are breast feeding. The need to obtain this type of information from workers may not be well received and/or raise privacy issues for licensees.
- 5. Constraint vs. Limit. Overall, the industry has seen a reduction in source term and a decline in doses.
Licensees have implemented more measures to maintain lower doses without enforcement. The ICRP recommendations could be used as constraints to support this effort.
- 6. Regulatory Guide 1.109 should be updated with new dose factor methodology.
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04/02/2010