Re: 40CFR190 Compliance

[William V Lipton <liptonw@DTEENERGY.COM>]

Compliance with 40 CFR 190 should be part of a nuclear power plant's "Offsite

Dose Calculation Manual."  I can try to provide a summary of the major

concerns.  Please contact me directly for additional guidance.



1.  The limits of 40 CFR 190 apply to "members of the public," as defined in

that regulation.  This would be a real person, not a fence sitter.



2.  I'm not sure what you mean by an "occupancy factor."  Our effluent

calculations make some allowance for the amount of food of local origin

consumed.  For example, in MI an individual would not consume food from a

local garden during the winter.  I don't see anything in the regulations that

would prohibit using some defensible factor, e.g., if you know that a

residence receiving a higher dose rate than any other is only occupied

seasonally.  Generally, the doses are well below a level at which you have to

be concerned about that.



3.  The limits of 40 CFR 190 apply to the entire "nuclear fuel cycle," as

defined in that regulation.  Thus, the limits apply to both units of IP.



4.  For doses due to effluents, we assure compliance with 40 CFR 190 through

our surveillance program that assures compliance with the limits of 10 CFR 50,

Appendix I .



5.  The EPA may grant a waiver to these limits.  In the unlikely event that a

monthly projection indicates that we may exceed a 40 CFR 190 limit, then we

would request a waiver.



6.  In practice, this is unlikely to ever limit our operations.  The only

plant event that could cause this would be operation with significant fuel

failure.  For many reasons, we would shut down to fix the problem well before

we reached 40 CFR 190 limits.



The opinions expressed are strictly mine.

It's not about dose, it's about trust.

Curies forever.



Bill Lipton

liptonw@dteenergy.com



"Glander, Lori" wrote:



> Can anyone provide guidance on the use and/or non-use of occupancy factors

> when determining 40CFR190 compliance?  Is the 25 mrem/yr to a real

> individual in a realistic location or a theoretical post sitter?

>

> Lori Glander

> Indian Point Radiation Protection

> lglande@entergy.com

>

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