10CFR20 and ICRP 30

[LAHTIGP@ccmail.ceco.com]

     OK Radsafers, we all know that the ICRP-30 intake/dose 
     relationships have been incorporated in 10CFR20, Appendix B.  But 
     where does it explicitly say this in the regulation (or in the 
     Statements of Consideration)??
     
     The question was raised by the reviewer of a radiological 
     accident assessment that I made, in which I used the organ and 
     TEDE dose factors of Federal Guidance Report Nr. 11 (FGR-11).  
     The FGR-11 dose factors [Sv/Bq] were derived from information in 
     ICRP-30. [This connection is clearly stated.] My claim 
     [challenged by the reviewer] was that "the data of ICRP-30 [via 
     FGR-11] are accepted for assessments by the NRC. This data has 
     been accepted and is, for example,  the basis of the ALI and DACs 
     included in 10CFR20, Appendix B."  I could not find a clear 
     reference for the connection between 10CFR20 Appendix B and 
     ICRP-30.  Is there one???
     
     Indirectly one can show the ALIs and DACs of FGR-11 correspond to 
     those of 10CFR20, but this approach to connecting ICRP-30 to 
     10CFR20 is rather obtuse.
     
     Any leads??
     
     Jerry Lahti
     Radiological Safety Specialist
     ComEd
     lahtigp@ccmail.ceco.com