RE: public dose

["Brewer, Ronald K.(RBREWER)" <RBREWER@apsc.com>]

If your operations involve the Uranium fuel cycle, don't forget the 
requirements of 40CFR190, which the NRC will enforce since it is required by 
Title 10, Part 20, 20.1301(d), which specifies 25 mrem WB, 75 mrem THY, and 
25 mrem any other organ, from planned discharges of licensed materials and 
direct radiation, from ALL "normal" Uranium fuel cycle operations. 
 40CFR190.10(b) goes on to specify some specific release levels on a per 
"gigawatt year" basis.

I agree with Les.  Direct measurement of releases and direct dose, and 
calculation for comparison to the 100mrem/yr requirement is the best 
approach.
 ----------
From: Les Slaback, Health Physics
To: Multiple recipients of list
Subject: public dose
Date: Friday, October 6, 1995 9:27

I tried to send this directly to S. Marsh at his stated address.
It was not accepted.
Since it is of possible interest to this list I am resending via this route.
********

Public dose:

While 10CFR20 provides a method of demonstrating compliance by
assuming the external and internal components are split 50:50,
and using the Appendix B values to demonstrate compliance for the
internal dose component (and using a 50 mrem limit for the
external component), this method has several
disadvantages/complications.

1. The exposures are rarely split evenly, so this method adds up
to a factor of two additional conservatism.

2. Despite the statement in 20.1302 and in the preface to App. B
that App. B represents a public dose of 50 mrem, the values in
Appendix B are clearly based on 100 mrem (based on the stated
method of calculation).  This adds some uncertainty as to just
what the dose to the public is for your release.

************************************
So (IMHO) the best approach is the direct
calculation/determination of the total public dose for
comparision against the 100 mrem public dose limit.
************************************

Also, do not forget the need to meet the EPA 40CFR61 limit for
airborne releases.

SLABACK@MICF.NIST.GOV
   ...a little risk, like a bit of spice, adds flavor to life