Re: Q: dose calc. for testing compliance with 40CFR61 Sub I and40CFR190

[Judd Sills <sillsj@GAT.COM>]

At 09:03 AM 8/16/97 -0500, you wrote:
>Dear radsafers; 
>
>As I know, NRC licensees in U.S. should calculate doses to any member of
the public
> for testing  that effluents from NPPs are in  compliance with the dose
limits 
>established in 40CFR61 Subpart I and 40CFR190. 
>
>Could anybody help me in getting the details about
>doses to any member of the public ?
>  - In the definition of "any member of the public" described in 40 CFR 61
>    Subpart I and 40 CFR 190, are all age groups such
>     as infant, child, teenager, and adult included ?  
>  - Which age groups should considered for testing compliance with 
>    those regulations above(i.e., whether only doses to the reference man
are needed or not )?
>
>
>If Anybody have information related, please mail to me.
>
>With Regards,
>
>Si-Young Jang
>
>Rad. Safety Dept.
>KINS
>Korea, the Republic of 
>
>email : k244jsy@pinpoint.kins.re.kr
>
>
>
>
40CFR61, subpart I does not apply to NPP.  The NPP
are limited by their Facility Technical Specifications
(Operating License) and limitations in 10CFR50 and 20.  

40CFR190 definition of the general public is as follows:
"(k) Member of the public means any individual
that can receive a radiation dose in the general environment,
whether he may or may not also be exposed
to radiation in an occupation associated with
a nuclear fuel cycle. However, an individual is not
considered a member of the public during any period
in which he is engaged in carrying out any
operation which is part of a nuclear fuel cycle."

There are no age specific limitations imposed.  Be aware,
however, that the method chosen to demonstrate compliance
with any emission standard could indirectly introduce age
specificity by application of dose conversion factors (DCF) that
are different for different age groups.  40CFR61, which as
I said earlier, doesn't apply to NPP, does use an EPA computer
code COMPLY as an acceptable means to demonstrate compliance
with the NESHAPS emission standards.  I do not know, myself,
whether this has age specific DCFs or not, but perhaps someone
else can answer that aspect of the question.  In any event,
if you had age specific DCFs, then compliance with a standard
would be based upon the critical, or most limiting, age group.
Use of any compliance model or method, should be reflective of
the population's dietary habits and the critical exposure pathways
that is reflective of that population.

I don't know if this is helpful to you or not...in summary,
the rules that do exist are not by themselves age specific, but
the computer models that are used to demonstrate compliance may
introduce age specific DCFs that do result in a critical age group.

My opinions only...not my employer's.

Best regards to all