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NRC Regulatory Guide 1.109,
Calculation of Doses to Man From Routine Releases of Reactor Effluents For
the Purpose of Evaluating Compliance with 10 CFR 50, Appendix I, indicates
in the introduction that Regulatory Guide 1.109 contains methods that may be
used for demonstrating compliance with the provisions of 10 CFR 50, Appendix
I. Question: Are the methods contained in Regulatory
Guide 1.109 still in use by commercial nuclear power facilities for the purpose
of demonstrating compliance with 10 CFR 50, Appendix I? Comment: Regulatory Guide 1.109, Appendix E, item
(3.) indicates that the dose factors for the total body contained in Table E-6
are for the dose rate in air at 1 meter above the ground for a tissue depth of 5
cm. The 5 cm tissue depth may be
converted to a density thickness of 5000 mg per square cm, assuming a tissue
density of 1000 mg per cubic cm. 10
CFR 50.2, Definitions, contains the definitions of the committed dose
equivalent, committed effective dose equivalent, and the deep dose equivalent
(DDE) with the DDE defined at a tissue depth of 1000 mg per square cm. 10 CFR 20 references the same tissue
depth (1000 mg per square cm) in the definition of the
DDE. Question: How do the dose factors for the total
body contained in Regulatory Guide 1.109, Appendix E, Table E-6 demonstrate
compliance with the 10 CFR 50 Appendix I limits, and the dose limits for members
of the public contained in 10 CFR 20.1301, if the tissue depths differ by a
factor of 5 (i.e., 1000 mg per square cm compared to 5000 mg per square
cm)? Thanks for any
comments. |