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Re: Questions on NRC Regulatory Guide 1.109





Claude,



This issue was raised when the NRC made the major revisions to 10 CFR 20

back in 1991 and was addressed in the Q&A's developed jointly by industry

and the NRC to address questions raised by the proposed revisions.

Specifically, see the following Q&A's:



"Question 21:  Is it time to update Regulatory Guide 1.109 and its

corresponding codes due to the updated dose conversion factors in the

revised Part 20?



Answer:   Perhaps, but such an update could only be a partial update at

this time.  The full updating could only occur if and when Appendix I is

recast as an effective dose equivalent.  The evaluation of whether Appendix

I should be changed is currently underway.  (Reference:  Regulatory Guides)



Question 384:  Nuclear power plant licensees are required to meet the

criteria in 10 CFR 50 Appendix I and 40 CFR 190 with regards to maintaining

doses to individual members of the public ALARA.  Related Regulatory Guides

(e.g., 1.21, 1.109, and 4.1) describe programs which are acceptable to the

NRC staff to demonstrate compliance with 10 CFR 50 Appendix I and 40 CFR

190 criteria. Specific requirements for monitoring, sampling, dose

calculation and reporting

are included in each plant's Technical Specifications and related Offsite

Dose Calculation Manual.  Does compliance with plant Technical

Specifications, applicable Regulatory Guides, and the radiation standards

in 40 CFR 190 fully meet the requirements of 20.1301?  The purpose in

asking this question is to obtain clarification that, although the revised

10 CFR 20 introduces new dose limits for individual members of the public

and new effluent concentration values in 10 CFR 20 Appendix B, the scope of

monitoring, sampling, dose calculation and reporting are not changed for

nuclear power plants by the revised 10 CFR 20 from the previously

applicable requirements and guidance.



Answer:   Not necessarily.  See the questions and answers in sections 10

CFR 20.1301 and 10 CFR 20.1302.  Generally, for nuclear power plants, no

major changes are needed in "the scope of monitoring, sampling, dose

calculation, and reporting" that has been adequate for compliance with

plant Technical Specifications and 40 CFR 190, and for conformance with

applicable regulatory guides.  However, some relatively minor changes may

be needed.  For example, at some plants, changes may be needed for

demonstrating compliance with the requirements of 10 CFR 20.1301 as they

apply in members of the public in controlled areas.  (See the answer to

Question 104.)  (References:  10 CFR 20.1301, 10 CFR 20.1302)."



To the best of my knowledge, neither Appendix I nor RG 1.109 have been

revised to address these issues.



Leon E. Brown, CHP

Staff Consultant

Big Rock Point Restoration Project

231-547-8419

lebrown@cmsenergy.com







                                                                                                                                            

                      "Claude Laney"                                                                                                        

                      <cflaney@BELLSOUTH.NET        To:       <radsafe@list.vanderbilt.edu>                                                 

                      >                             cc:                                                                                     

                      Sent by:                      Subject:  Questions on NRC Regulatory Guide 1.109                                       

                      owner-radsafe@list.van                                                                                                

                      derbilt.edu                                                                                                           

                                                                                                                                            

                                                                                                                                            

                      05/20/2003 08:56 AM                                                                                                   

                      Please respond to                                                                                                     

                      "Claude Laney"                                                                                                        

                                                                                                                                            

                                                                                                                                            









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.<?xml:namespace prefix = o ns

= "urn:schemas-microsoft-com:office:office" />





 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.

















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