[ RadSafe ] Offsite Dose Calculation Manual & Reg. Guide 1.109

[Victor Anderson]

John,

I've done some further research.  The requirement to maintain records to
demonstrate compliance with doses to the public (both internal and external)
is in 10CFR20.1302.  Remember that the regulatory guides are just that
guides.  The only way that a guide becomes a requirement is if the licensee
commits to that particular regulatory guide in the licensing documents.
Unless the NRC specifically grants an exemption, that does not get the
licensee out having to maintain records of doses due to alpha emitters.
Reports of such records should be complete.  For example, annual reports of
releases.  This is where it gets tricky.  Let us assume for arguments sake,
that while measured for, there were no detected releases of alpha emitters.
The first question is what commitments were made by the licensee in
licensing documents, technical specifications, and the ODCM?  Did the NRC
specifically exempt reports of alpha emitters? (Not likely, but one never
knows).  The safest thing to do is report the minimum sensitivity of all
radionuclides measured and calculate doses as being less than or equal
appropriately.  For those radionuclides that you have positive results,
calculate the radiation doses.  Add them all up (detects and non-detects)
(alpha emitters included) and you should be able to demonstrate compliance
with dose limits for the public. The only way that you should not report
alpha emitters is if your facility does not have alpha emitters and
therefore cannot release them or the NRC has given a specific exemption for
not reporting alpha emitters.  To look into this thing further, I would need
copies of the offsite dose calculation manual, license, tech specs, etc.
The facility would also need to hire me at my usual rates as this problem is
going take more than an hour or two.  If interested, please e-mail me at
victor.anderson at frontier.com.


Victor

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of Victor Anderson
Sent: Thursday, March 07, 2013 5:03 PM
To: 'The International Radiation Protection (Health Physics) MailingList'
Subject: Re: [ RadSafe ] Offsite Dose Calculation Manual & Reg. Guide 1.109

John,

I'll go back and check guidance more closely, but dose is dose.  I wouldn't
leave offsite doses due to alpha emitters out of reports on offsite dose
calculations for any reason.  The whole point of doing offsite dose
calculations is to demonstrate compliance with regulations and technical
specifications.  In my opinion reporting alpha doses should be done and
those reports will be part of showing compliance with regulations and
technical specifications.  I'll look further into the reporting
requirements.

Victor

-----Original Message-----
From: radsafe-bounces at health.phys.iit.edu
[mailto:radsafe-bounces at health.phys.iit.edu] On Behalf Of
JOHN.RICH at sargentlundy.com
Sent: Thursday, March 07, 2013 4:34 PM
To: radsafe at health.phys.iit.edu
Subject: [ RadSafe ] Offsite Dose Calculation Manual & Reg. Guide 1.109

Radsafers

It appears that the (US) Offsite Dose Calculation Manuals (ODCM) and Reg. 
Guide 1.109 do not address doses from airborne release and subsequent 
ingestion of alpha emitting nuclides (e.g., U, Pu, Am, etc.).  I haven't 
been able to find any guidance that explains why alpha doses do, or do 
not, need to be calculated.  It's clear that the quantity of alpha 
emitting nuclides need to be measured and reported.  However, nothing is 
said about what is supposed to be done with this information, other than 
reporting it. 

Anyway, this is a long-winded request for help.  Could somebody point me 
to a basis for leaving doses from alpha emitting nuclides out of the 
calculations of offsite doses.

thnx in advance  - -jmr

John Rich
312-269-3768
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