ML20132D009
| ML20132D009 | |
| Person / Time | |
|---|---|
| Issue date: | 12/31/1996 |
| From: | NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES) |
| To: | |
| References | |
| TASK-*****, TASK-DG-8016, TASK-RE REGGD-04.020, REGGD-4.020, NUDOCS 9612190099 | |
| Download: ML20132D009 (5) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION Dec:mber 1996 O g[ e a g)
REGULATORY GU DE A
OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 4.20 (Draft issued as DG-8016)
CONSTRAINT ON RELEASES OF AIRBORNE RADIOACTIVE MATERIALS TO THE ENVIRONMENT FOR LICENSEES OTHER THAN POWER REACTORS A. INTRODUCTION than those subject to 10 CFR 50.34a, such that the individual mernber of the public likely to receive the In 10 CFR Part 20, " Standards for Protection highest dose will not be expected to receive a total Against Radiation," 5 20.1302(b) requires that:
effective dose equivalent in excess of 10 mrem (0.1 A licensee shall show compliance with the annual mSv) per year from these emissions. If a licensee dose limit in i 20.1301 by (1) Demonstrating by subject to this requirement exceeds this dose con-measurement or calculation that the total effective straint, the licensee shall report the exceedance as dose equivalent to the individual likely to receive provided in 10 CFR 20.2203 and promptly take ap-J the highest dose from the licensed operation does propriate corrective action to ensure against not exceed the annual dose limit; or (2) Demonstrat-recurrence, ing that (i) The annual average concentrations of ra-dioactive material released in gaseous and liquid This regulatory guide provides guidance on meth-
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T effluents at the boundary of the unrestricted area do ods acceptable to the NRC staff for compliance with the V
not exceed the values specified in Table 2 of Appen-constraint on air emissions to the environment. If addi-dix B to Part 20; and (ii) If an individual were contin-tional significant comments are received in the first year uously present in an unrestricted area, the dose following its issuance, the staff will revise the guide as ap-from external sources would not exceed 0.002 rem propriate. Guidance on ALARA programs can be found (0.02 mSv) in an hour and 0.05 rem (0.5 mSv) in a in other regulatory guides. Although these guides deal year.
primarily with occupational exposure and may be specif-ic to one type of licensee, they contain programmatic in-In addition,10 CFR 20.1101(d) requires that:
a formation that may be useful to all licensees. These To implement the ALARA [as low as is reasonably guides are:
s achievable] requirements of 6 20.1101(b), and not-Regulatory Guide 8.10, " Operating Philosophy for withstanding the requirements in i 20.1301 of this e
part, a constraint on air emissions of radioactive ma-Maintaining Occupational Radiation Exposures As terial to the environment, excluding radon-222 and Low As Is Reasonably Achievable." This guide de-its daughters, shall be established by licensees other lineates the components of an ALARA program.
USNRC REGULATORY GUIDf.5 The gusoes are issued m the following ten stoad divisens Regv'atory Guides are issued to oescnbe and make avalable to the pubhc such miorma-ter, as memods acceptabee to the NRC staff for impeemannng specific parts of the Com-t Poww Reactors 6 Products ressen a regulabons, techmques used by the staff m evalvehng specific probtems or pos-2 Research and Test Reactors 7 Transportaten tulated acc, dents. ar'ri cata needed by the NRC staff in its review of apphcations for per.
3 Fuels and Matenais Fachtees 8 Occupanocal Health rmts and hcensen Reguietory guides are not subsetutes for regulehens. and compleance 4 Environments and Smng 9 Aretrust and Financial Aeview be sacep acte they proved asis for the11 ng r si th is T
d as aft darut of omments receved from the pubhc Com-Ad on trbuton and US N ogu at rnents and suggestions for improvements m theme guides are encouraged at aR times. and Comensseen, Washogton, DC20555-0001. or by fan at (30t1415-2260 guides ell be revised. as appropnate, to accommMare comments and 10 reflect new m-issued guidos may also be purchased from the Notenal Tecnnicannformahon sevee on
/N Wnttan comments may be submmed to the Rules Recow and Directives Brancn, DFIPS, a stanoin0 orde bases Deels on tru service may be obtened by wrmng NTIS. 5265 Port I
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ADM, U S Nucleer Regulatory Commpason, Wasnegtort DC 20555 -0001 Royal Road, Spnngriaid. VA 22161
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04,020 R PDR e"*'5
o Regulatory Guide 8.18, "Information Relevant to The NRC staff examines licensee programs to deter-Ensuring that Occupational Radiation Exposures at mine whether they are in compliance with the require-Medical institutions Will Be As Low As Reasonably ments of 10 CFR Part 20. This guide addresses only a Achievable."
part of a licensee's overall radiation protection program.
l S ecifically, it addresses methods for demonstrating P
- Regulatory Guide 8.31, "Information Relevant to l
C mP iance with the constraint on releases of airborne Ensuring that Occupational Radiation Exposures at Uranium Mills Will Be As Low As Is Reasonably radioactive materials to the environment. In addition to Achievable."
controlling doses from the releases of airborne radioac-tive materials to the environment, licensees must imple-l Regulatory Guide 8.37, "ALARA Levels for Efflu-ment a radiation protection program that controls liquid I
ents from Materials Facilities."
effluents and dose rates in unrestricted areas.
Regulatory Guide 10.8, " Guide for the Preparation Many NRC licensees possess source, byproduct, or e
of Applications for Medical Use Programs." Sec-special nuclear material in a form that would not cause tion 1.3 and Appendix G deal specifically with doses to members of the puolic frcm releases of airborne ALARA programs for medical facilities.
radioactive material to the environment. These licens-In addition, further information can be found in Re.
ces include radiographers, well loggers, and other users f
vision 1 to NUREG-0267," Principles and Practices for of sealed sources. These licensees need not take any ac-
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Keeping Occupational Radiation Exposures As Low As tions to demonstrate compliance with the constraint on Reasonably Achievable"(October 1982).1 releases of airborne radioactive materials to the environment.
The information collections contained in this regu-latory guide are covered by the requirements of 10 CFR CONSTRAINTS Part 20, which were approved by the Office of Manage-ment and Budget, approval number 3150-0014. The A dose limit derived from a basic radiation protec-NRC may not conduct or sponsor, and a person is not re-tion standard is the upper acceptable bound of radiation quired to respond to, a collection ofinformation unless it dose and is needed to protect the health and safety ofin-displays a currently valid OMB control number.
dividuals; a limit is a value not to be exceeded. Such lim-B. DISCUSSION its should be set with the assumption that effluent re-leases associated with licensed activities would result in The dose limits in 10 CFR Part 20 are based on limit-doses to the public that are substantially below that val-I ing dose to an acceptably low level of risk to the exposed ue. Such limits are approached only under unusual cir-individual. However, any radiation exposure may carry some risk. Thus, the NRC requires licensees to take ac-cumstances, and only for a small fraction of the exposed population. A constraint is a dose value above which li-tions, to the extent practicable, utilizing procedures and censees are required to report to NRC and to take cor-engineering controls to further reduce risk below the lev-rective actions to lower the dose below the constraint val-els implicit in the dose limits in keeping with the princi-ue. Enforcement action would only occur if a licensee ple that exposures should be as low as is reasonably fails to report an exceedane: of the constraint or fails to achievable. This is the goal and purpose for radiation take appropriate and timely corrective actions.
protection programs. In order to achieve this goal,11-censees must control the way radioactive materialis han.
C. REGULATORY POSITION died from receipt through disposal.
1.
CONSTRAINT ON ENVIRONMENTAL AIR ALARA EMISSIONS Components of an effective radiation protection The following methods are acceptable to the NRC program, as required by 10 CFR 20.1101, include rads-staff for determining the dose to members of the public ation exposure control, written procedures and poh,cies, from exposure to airborne radioactive material that has contros of radioactive materials, radioactive contamma-been released to the environment by NRC licensees oth-tion control, radioactive waste management, training' er than power reactors. Licensees should choose a moni-program reviews, and audits.
toring period (e.g., a year, month, or quarter) to demon-strate compliance with the airborne emissions constraint in accordance with 10 CFR 20.1101(d). For most licens-ICopies are available for purchase from the U.S. Government Printmg ecs, the monitoring period will be one year.
Office. PO. Box 37082. Washington. DC 20013 - 7082, telephone (202) 512-2249; or from the National Technical !nformation Service by writmg NTIS at 5285 Port Royal Road. Sprmgfield. VA 22161. Co-1.1 Licensees who (1) operate a nuclear power reac-pies arc available for inspection or copying for a fee from the N RC Put,.
tor subject io 10 CFR 50.34a or (2) possess and use radio-hc Document Room at 2120 L Street NW.. Washington. DC; the PDR's nuclides only in the form of scaled sourn:s need not take mailing address is Mail stop LL-6. Washington, DC20555; telephone (202)634-3273; fax (202)634-3343.
any actions to demonstrate compliance with the constraint.
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l.2 Radioactive materials in sealed containers that C " fg remain unopened and have not leaked during the assess-p-
ment period need not be included in the calculations. Ex-O amples of sealed containers would include radiopharma-Where:
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ceuticals in unopened manufacturers packages and C
Average air concentration at the receptor
=
materials in undamaged shipping containers. Indepen.
3 dent spent fuel storage canisters that do not have vents to (Ci/m or pCi/ml) the atmosphere may also be considered sealed f
Fraction of the time the wind blows toward
=
containers, the receptor of interest (dimensionless) 1.3 Effluents from patients need not be included if (For a single " puff" release, the appropri-compliance with the constraint is demonstrated by using atualue is L)
Effluent release rate (Ci/s) an inventory approach. If compliance with the constraint Q
=
is demonstrated by using measured or calculated con-V Volumetric flow rate at the point of release
=
centrations of radioactive materials in the emironment, (m /s) 3 the contribution from patients is considered insignifi-cant and need not be considered.
The " sum of the fractions" technique should be used to assess compliance for effluents contammg multiple ra-1.4 Ifit can be determined that some detected mate-dionuclides. With this technique, if radionuclides "a,"
rials did not result from licensed activities of the licens-
"b," and "c" are present in concentrations Ca, C, and Cc, b
ee, only radioactive materials from the licensed activity and if the applicable effluent concentrations in Column 1 need be considered. Materials that are windblown from cf Table 2 in Appendix B to 10 CFR Part 20 are ECa, other facilities need not be considered.
EC, and ECc respectively, satisfying the following in-b 1.5 in determining the member of the publiclikely equality is sufficient to demonstrate compliance with the constraint.
to receive the highest dose from airborne radioactive material released from licensed operations to the envi-ronment, licensees need not consider nonresidents with-C, C.
ECa, _ CEC, < 0.2 i-in the facility boundary.
EC, 2.
CALCULATION OF DOSE TO THE MEMBER 2.3 Additional methods acceptable to the NRC staff Q
OF Tile PUBLIC LIKELY TO RECEIVE TIIE for demonstrating compliance with 10 CFR 20.1101(d)
HIGHEST DOSE FROM AIR EFFLUENTS can be found in the worksheets contained in either In demonstrating compliance with 10 CFR NCRP Commentary No. 3, " Screening Techniques for 20.1101(d), f usecs should determine whether there Determining Compliance with Environmental Stan-have been a-wility or design modifications, increases dards,"2 or EPA 520/1-89-002, "A Guide for Deter-in radionuc,
= ventories, or operational changes; li.
mining Compliance with the Clean Air Act Standards for censees should determine whether any of these factors Radionuclide Emissions from NRC Licensed and Non-resulted in variations to airborne emissions since the last DOE Federal Facilities" (Revision 2).3 monitoring period. If licensee operations have not 2.4 Another method that is acceptable to the NRC changed, the review of licensed operations and demon-staff for demonstrating compliance with 10 CFR stration of compliance with the constraint will be rela-20.1101(d)is the use of the computer code COMPLY.
tively straightforward.
COMPLY was developed by the EPA to assess doses by Any of the following methods are acceptable for using site-specific information in the determination of demonstrating compliance with 10 CFR 20.1101(d).
dose. COMPLY has four screening levels. In Level 1, the simplest level, only the quantity of radioactive material 2.1 The simplest screening technique is to assume possessed during the monitoring period is entered. The that the air concentration at the receptor is equal to the calculations are based on generic parameters. Level 4 air concentration measured at the point of release. This produces a more representative dose estimate by prosid-is analogous to using Appendix B to 10 CFR Part 20 to ing for more complete treatment of air dispersion by re-demonstrate compliance with the dose limits in Part 20-quiring site-specific information. It is expected that all 2.2 To demonstrate compliance with the constraint 2NCRP Commentary No. 3 was published in January 1989 and the ad-on air emissions, the licensee should demonstrate, by dendum was published in October 1989. Copies may be purchased measurement or calculation, that the annual average from the Nauonal Council on Rodiation Protection and Measure.
p concentration of airborne radioactive material released
$3I NCRP Publications,7910 Woodmont Avenue, Bethesda, MD
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to the environment does not exceed 20% of the values in 3Copies may be obtained from the U.S. Environmental Protection Column 1 of Table 2 in Appendix B to 10 CFR Part 20.
Agency, Office of Radiation and indoor Air,401 M Street SW., Wash-The following formula demonstrates this technique.
ington, DC 20460.
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NRC licensees will be able to demonstrate compliance at learning of the dose in excess of the constraint, and 10 one of the four levels. The basis for the compliance mea-CFR 20.2203(b)(1) requires licensees to describe the ex-sures in COMPLY are contained in " Background Infor-tent of exposure. The report should include the follow-mation Document: Procedures Approved for Demon-ing information.
strating Compliance with 40 CFR Part 61, Subpart I" e An estimate of the dose l
(EPA 520/1-89-001, October 1989).4 e The concentrations of the radioactive material If a computer code other than those listed above is rele sed used to demonstrate compliance with the constraint, the licensee should be prepared to demonstrate that the e The cause of the elevated concentrations in code has undergone verification and validation (V & V).
effluents For more information on software quality assurance in-cluding V & V, licensees may refer to NUREG/
The corrective steps taken or planned to ensure e
gainst a recurrence BR-0167, " Software Quality Assurance Program and Guidelines." This document can be purchased from the A schedule for completing the corrective steps. The e
U.S. Government Printing Office, P.O. Box 37082, Wash-report should contain enough information to allow ington, DC 20402-9328.
the NRC staff to verify the calculations.
3.
REPORTS TO NRC IF CONSTRAINT llAS The report should be sent to the U.S. Nuclear Regu-BEEN EXCEEDED latory Commission, Document Control Desk, Washing-If the constraint of 10 mrem (0.1 mSv) per year to with a copy to the appropriate ton, DC 20555-0001, the member of the Public likely to receive the highest NRC Regional Office listed m, Appendix D to 10 CFR Part 20*
dose has been exceeded as determined by measurement or calculation,10 CFR 20.2203(a)(2)(vi) requires licens-D. IMPLEMENTATION ecs to send a report to the NRC within 30 days after i
The purpose of this section is to provide m. forma-Copiesof the EPA Background information Document and the COM.
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PLY compute r code with its Use rs Guide may be obtained by writing to staff,s plans for using this guide.
the Center for Rderal Guidance and Air Standards (66021), Office of Radiation and Indoor Air, Erwironmental Protection Agency, Wash.
Except in those cases in which an applicant proposes ington, DC 20460. It can also be downloaded from the Technology an acceptable alternative method for complying with Transfer Network (TTN) Electronic Bulletin Board under the Office of Radiation and Indoor Air technicalinformation area. The number sEUcified Portions of the NRC's seEulations, the meth-for the TTN is (919)S41-5742. In addition, EPA has pages on the Jds described in this guide will be used in the evaluation World Wide We b as anothe r mechanism to provide computer codes to of applications for new licenses, license renewals, or li-hnEr'tpnc epa go cense amendments and for evaluating compliance with 2
" P NPnc.cpa.gm and 10 CFR Part 20.
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REGULATORY ANALYSIS A separate regulatory analysis was not prepared for this regulatory guide. The regulatory analysis prepared for the amendments to 10 CFR Part 20," Standards for Protection Against Radiation," provides the regulatory basis for this guide. A copy of this regulatory analysis is available, as an enclosure to SECY-95-133, for inspection or copying for a fee at the NRC Public Document Room,2120 L Street NW., Washington, DC.
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