NRC "constraint" rule

[glenn_sturchio@Merck.Com (Glenn Sturchio)]

Greetings RadSafe:

Since I haven't seen any traffic regarding Draft Reg. Guide DG-8016, 
"Constraints for air effluents for licensees other than power reactors," I 
thought I'd fire the first shot.  I just received the Guide and the comment 
period ends 3/12/96.

Basically, the proposal is to establish a "constraint" at 10 mrem/y TEDE 
from air emissions.  If you exceed the constraint:  the licensee shall 
report the exceedence and promptly take corrective action to ensure against 
recurrence.  They state that a limit (100 mrem/y) is an upper bound and a 
constraint is a level above which a specified action is required. 
 Additionally, enforcement action will only take place if a licensee fails 
to report an exceedence or fails to take appropriate and timely corrective 
action.

So far not so bad; however, their example exceedence report is for the 
exposure of a member of the public in a hallway outside of a lab using 
I-131!  When did this become an air emission scenario?  (my dictionary says: 
"emission ... (3) substances discharged into the air (as by a smokestack ... 
)")  I would poke a few holes in the calculation provided in the example; 
however, I'll leave some fun for the rest of you.

Would the same reporting be required if a member of the public received 10.1 
mrem TEDE in a year from the transmission of Co-60 photons through a shield 
wall?  Remember, the example calculation involved a "perceived" exposure.

Requests for copies can be made to: USNRC, Washington, DC, 20555, Attn: 
Office of Admin, Distribution and Mail Services Section.  I'm sure by the 
time you read this Sandy Perle will have posted the Reg. Guide on RadSafe!

glenn_sturchio@merck.com

Of course these comments are mine and should have no reflection on my fine 
employer.  And as Kent Lambert states:  if my comments are wrong, I hit send 
by accident.