[ RadSafe ] Stack Emission Limits

[Bryan Bagg]

Wes:

The "ALARA constraint" in 10 CFR 20.1101(d) is 0.1 mSv, not 1.0 mSv.  As I 
understand this relatively new "ALARA constraint", the limit is 0.5 mSv as 
you indicate from Appendix B, but a licensee must also show that they meet 
the "ALARA constraint" of 0.1 mSv.  This constraint is on air emissions 
only.  If the licensee exceeds the constraint, then it is reportable to the 
NRC (or Agreement State) and controls must be enacted to prevent recurrence.

- Bryan
----- Original Message ----- 
From: "Wesley" <wesvanpelt at verizon.net>
To: "'Bryan Bagg'" <bjbagg at sbcglobal.net>; "'Otto Raabe'" 
<ograabe at ucdavis.edu>; "'Franz Schönhofer'" <franz.schoenhofer at chello.at>; 
"'RADCHEM-LIST (RADCHEM-LIST)'" <RADCH-L at in2p3.fr>; "'RADSAFE'" 
<radsafe at radlab.nl>
Sent: Thursday, February 08, 2007 8:39 AM
Subject: RE: [ RadSafe ] Stack Emission Limits


Bryan, Otto and All,

The annual average air concentration limits in Appendix B of 10CFR20 can be
used to demonstrate compliance with the TEDE of 1 mSv to the individual
member of the public likely to receive the highest dose.

Curiously, the Appendix B air concentration, if breathed continuously by an
adult member of the public for a year, will result in a dose of 0.5 mSv, not
1.0 mSv! I quote from 10CFR20 below:

"The concentration values given in Columns 1 and 2 of Table 2 are
equivalent to the radionuclide concentrations which, if inhaled or ingested
continuously over the course of a year, would produce a total effective dose
equivalent of 0.05 rem (50 millirem or 0.5 millisieverts)."

I am not really sure why NRC publishes tables of concentrations to meet the
1.0 mSv limit that actually result in a dose of 0.5 mSv. Perhaps it is so
that a licensee could emit BOTH to the air and water at the maximum allowed
concentrations and still be below 1.0 mSv per year.

Comments?

Wes

[New email address:  WesVanPelt at verizon.net]
Best regards,
Wes
Wesley R. Van Pelt, PhD, CIH, CHP
Wesley R. Van Pelt Associates, Inc.

-----Original Message-----
From: Bryan Bagg [mailto:bjbagg at sbcglobal.net]
Sent: Wednesday, February 07, 2007 11:43 PM
To: Wesley; 'Otto Raabe'; 'Franz Schönhofer'; 'RADCHEM-LIST (RADCHEM-LIST)';
'RADSAFE'
Subject: Re: [ RadSafe ] Stack Emission Limits

Note also that a licensee must demonstrate that air emissions of radioactive

material (excluding Rn-222 and its daughters) to the environment will not
exceed a TEDE of 0.1 mSv to the individual member of the public likely to
receive the highest dose.  This is found in 10 CFR 20.1101 (d), Radiation
Protection Programs, and most if not all equivalent Agreement State
regulations.

- Bryan Bagg





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