ML20237J624

Responds to NRC Re Notice of Violation on Enforcement Action 87-007.Justification for Disagreeing W/ Violation Listed.Corrective Actions Will Reduce Probability of Reccurrence of Exposure Due to Hot Particle

ML20237J624
Person / Time
Site:	Summer
Issue date:	08/07/1987
From:	Nauman D SOUTH CAROLINA ELECTRIC & GAS CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
EA-87-007, EA-87-7, IEIN-86-023, IEIN-86-23, NUDOCS 8708180261
Download: ML20237J624 (3)

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SCEAG August 7, 1987 37 MG 11 n 7 : 36 l

'Dr. J. Nelson Grace Regional. Administrator-U.S. Nuclear Regulatory Commission Region:II, Suite 2900 101 Marietta Street. N.W.

Atlanta,; Georgia 30323

Subject:

Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 Response to Notice of Violation:

EA 87-07

Dear Dr. Grace:

In your letter of July. 13, 1987, replying to our April 9,1987 response to Notice of' Violation EA 87-07, you concluded that the violation occurred as i

stated and was' properly assigned Severity Level III.

South Carolina Electric

& Gas Company (SCE&G) is not in agreement with your conclusions in that:

(a) 10CFR Part 20. does not prescribe a method of calculating non-uniform doses resulting from a " hot particle" on the skin of an extremity, and NRC IEN 86-23 is not a regulatory requirement which can be made the basis for a Notice of Violation.

(b) Calculational methods consistent with current good practice in the field of Health Physics, such as the method employed by SCE&G, should be accepted in the absence of a method prescribed, or incorporated by reference, in the regulations.

(c) The thirty year old method on which NRC interpretation is based (NBS Handbook No. 59) guidanceand regulatory results in significant ove'restimation of biological effects of such an exposure which is inconsistent with the philosophy of current recommendations, such as International Commission on Radiological Protection (ICRP) Publication 26 and the principles of ALARA.

(d) Based on recommendations of the ICRP and previous guidance provided by the NRC, SCE&G contends that guidance given in IEN 86-23 is inappropriate for determining dose equivalent Jue to hot particle contamination.

Regulatory Guide 8.23 (in a footnote to Table 2) states that for the hands, averaqing over the whole area of the hand is acceptable, nominally 300 cm2 Furthermore, ICRP-26 states in paragraph

183,

"...if the dose distribution is extremely non-uniform, as that from very small particles in contact with the skin, the local absorbed dose (rads due to beta and gamma components) should be assessed and used to predict possible local skin reactions."

SCE&G implemented this I

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Dr. J. Nelson Grace August 7, 1987 Page 2 recommendation to determine the potential for non-stochastic effects (cosmetic changes) and retained professional medical assistance to assure there were no local skin reactions.

The ICRP goes on to say that "It is inappropriate, however, to relate such localized absorbed doses to the absorbed doses corresponding to the dose-equivalent limit."

Regulatory interpretation as reflected in IEN 86-23 contradicts previous staff guidance, Regulatory Guide 8.23, while ignoring both current state-of-the-art and ICRP recommendations.

(e)

ICRP-26 does not, as pointed out by your response, support the omission of the beta component; however, paragraph 17 states that the absorbed dose is insufficient by itself to predict either the severity (non-stochastic) or the probability (stochastic) of the deleterious effects on health resulting from irradiation under unspecified conditions.

The dose equivalent unit, rem, was developed to correlate delayed stochastic effects with radiation exposure.

SCE&G has therefore assigned a doso equivalent which more appropriately correlates the probability of future stochastic effects due to the skin irradiation by this highly localized contamination.

That dose equivalent which reflects current understanding of the stochastic risks associated with skin dose, has been recorded as 0.43 rem and does not exceed the limits of 10CFR 20.101(a).

The corrective actions taken in response to the procedural aspects of this incident (Violation B) are as described in our April 9, 1987 respor.se to Notice of Violation EA 87 s7.

These corrective actions will reduce the probability of a recurrence of an exposure due to a " Hot Particle." Hr wever, these actions will in no way reduce the level of exposure and sub,equent violation of 10CFR20.101(a), given the current NRC interpretation of 10CFR20.4(c) and the single acceptable methodology suggested in IEN 86-23.

Based upon the above discussion and our firm belief in the validitl, of our application of the regulations, SCE&G respectfully requesv.s your reconsideration of the Notice of Violation relating to Violation (A),

i Should you have any further questions, please advise.

'Yery ul 'yours, j

OJJ W x.Wumn AMP / DAN:jez c:

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