Information Notice 1997-04, Implementation of a New Constraint on Radioactive Air Effluents

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Implementation of a New Constraint on Radioactive Air Effluents
ML031050386
Person / Time
Site: Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Crane  Entergy icon.png
Issue date: 02/24/1997
From: Cool D
NRC/NMSS/IMNS
To:
References
-RFPFR IN-97-004, NUDOCS 9702130212
Download: ML031050386 (23)


i

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS

WASHINGTON, D.C. 20555

February 24, 1997

NRC INFORMATION NOTICE 97-04: IMPLEMENTATION OF A NEW CONSTRAINT

ON RADIOACTIVE AIR EFFLUENTS

Addressees

All materials, fuel cycle, and non-power reactor licensees.

purpose

The U.S. Nuclear Regulatory Commission (NRC) is issuing this information notice to alert

addressees to a recent change in the regulations contained in NRC's 10 CFR Part 20,

"Standards for Protection Against Radiation." This change affects all NRC licensees other than

nuclear power reactor licensees. It is expected that recipients will review the information for

applicability to their facilities and consider actions, as appropriate, to ensure compliance.

However, suggestions contained in this information notice are not NRC requirements; therefore, no specific action nor written response is required.

Description of Circumstances

The Environmental Protection Agency (EPA) promulgated, in 1989, a regulation that placed a

limit on the amount of radioactive material that may be released to the air in unrestricted areas

by NRC licensees, including Agreement State licensees. This regulation, which was contained

in EPA's 40 CFR Part 61, Subpart I, required licensees to limit their emissions of radioactive

materials to the air so that no member of the public would receive an effective dose equivalent

over 0.1 mSv (10 mrem) in a year. It also required licensees to submit an annual report to EPA

if the dose exceeded 0.01 mSv (1 mremlyr). The Subpart I limit was in addition to the already

existing limit on effluents in NRC's 10 CFR Part 20, which restricted the dose to any member of

the public to I mSv (100 mrem) in a year. It should be noted that EPA's limit applied only to air

emissions, whereas NRC's limit applies to all exposure pathways, both internal and. external.

To avoid regulation of the same activity, namely air emissions of radioactive materials, by both

NRC and EPA, an agreement was reached bptween the two agencies whereby NRC would

incorporate EPA's limit as a constraint on air emissions in its regulations and EPA would

rescind Subpart I. NRC published its proposed constraint rule in the Federal

egaiter on December 13, 1995 (60 FR 63984), and the final notice was published on

December 10, 1996 (61 FR 65120) (copy attached). The rule became effective January 9,

1997. EPA rescinded 40 CFR Part 61, Subpart I, on December 30, 1996 (61 FR 68971).

Summary Information on Subpart I, as well as the Federal Ragister rescission. notice, may be

accessed via the Internet at http:/Ivww.epa.gov/radiation/eshaps.

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IN 97-04

February 24, 1997

Page 2 of

Discussion

Effective January 9, 1997, the constraint rule was incorporated into 10 CFR 20.1101, "Radiation

Protection Programs," Section 20.1101(d):

To implement the ALARA requirements of § 20.1101(b), and notwithstanding the

requirements in § 20.1301 of this part, a constraint on air emissions of radioactive

material to the environment, excluding Radon-222 and Ks daughters, shall be

established by licensees other than those subject to § 50.34a, such that the individual

member of the public likely to receive the highest dose will not be expected to receive a

total dose equivalent in excess of 10 mrem (0.1 mSv) per year from these emissions. If

a licensee subject to this requirement exceeds this dose constraint, the licensee shall

report the excess as provided in § 20.2203 and promptly take appropriate action to

ensure against recurrence.

NRC licensees must still limit doses to members of the public to I mSv (100 mrem) in a year

from all sources of exposure, such as external radiation exposures as well as internal

exposures resulting from water and air effluents (10 CFR 20.1301). With implementation of the

constraint rule, the exposures resulting from air effluents are further constrained to a level not to

exceed 0.1 mSv (10 mrem) in a year. The difference between a constraint and a limit is that

exceeding a constraint level does not necessarily result in enforcement action, whereas

exceeding a limit always results in such action.

The constraint rule does not impose any reporting requirements on licensees, except in cases

where the constraint has been exceeded. In such cases, the licensee is required to notify NRC

that the constraint was exceeded, describe the corrective actions to be taken, and the schedule

for completion of such actions to ensure that the constraint will not again be exceeded.

Enforcement action may be taken if such reports are not filed as required by 10 CFR 20.2203, or if appropriate corrective action is not taken to prevent recurrence. Because Subpart I has

been rescinded, licensees are no longer required to file a report with EPA if the constraint is

exceeded, or if the dose from air emissions exceeds 0.01 mSv (1 mrem) in a year, as was

required before rescission.

Acceptable methods to estimate the dose from air emissions, and thereby show compliance, are described in Regulatory Guide 4.20, "Constraint on Releases of Airborne Radioactive

Materials to the Environment for Ucensees Other than Power Reactors," which was issued in

December 19961. These methods include those that have been in use to show compliance with

the effluent limits in 10 CFR 20.1301, as well as several screening methods that

Single copies of regulatory guides may be obtained free of charge by writing the Office of

Administration, Attention: Distribution and Services Section, U.S. Nuclear Regulatory

Commission, Washington DC 20555-0001; or by fax at (301)415-2260.

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IN 97-04 February 24, 1997 have been approved by EPA to show compliance with 40 CFR Part 61, Subpart I. Licensees

may also propose their own site-specific methods for showing compliance, subject to NRC

approval before use.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts listed

below or the appropriate regional office.

Donald A. Cool, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical contacts:

Cynthia Jones, NMSS

John Kinneman, RI

(301) 415-7853

(610)337-5252 E-mail: cgj@nrc.gov

E-mail: jkd@nrc.gov

John Potter, RII

Brenda Holt, RIII

(404) 331-5571

(630) 829-9836 E-mail: jpp@nrc.gov

E-mail: bjh@nrc.gov

Linda Howell, RIV

(817) 860-8213 E-mail: llh~nrc.gov

Attachments:

1. Federal Register Notice on the Constraint Rule

2. List of Recently Issued NMSS Information Notices

3. List of Recently Issued NRC Information Notices

rP;L4 act,

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Attachment 1

IN 97-04 February 24, 1997 (Federal Register: December 10,

1996 (Rules and Regulations]

[Page 65119-65127]

From the Federal Register Online via

(Volume 61, Number 238)]

GPO Access [wais.access.gpo.gov]

Page 65119

Part III

Nuclear Regulatory Commission

10 CFR Part 20

Clean Air Act: Radioactive Materials Airborne Effluents Dual Regulation

Resolution; Final Rule and Radiation Protection Programs Enforcement

Actions Policy and Procedure; Notice

[(Page 6512011

NUCLEAR REGCLATORY COWISB 0IN

10 CPR Part 20

RIN 3150-AP31 Resolution of Dual Regulation of Airborne Effluents of

Radioactive Materials; Clean Air Act

AGECWY: Nuclear Regulatory Co

ission.

ACTION: Final rule.

SU4MMRY: The Nuclear Regulatory Commission 18 amending its

regulations

to establish a constraint of 10 mrem (0.1 mSv) per year total effective

dose equivalent (TIDE) for dose to members of the public from air

emissions of radionuclides from NRC licensed facilities other than

power reactors. This action is necessary to: Provide assurance to the

Environmental Protection Agency (EPA) that future emissions from NRC

licensees will not exceed dose levels that EPA has determined will

provide an ample margin of safety; and to provide EPA a basis upon

which to rescind its

Clean Air Act (CAA) regulations as defined in 40

CPR Part 61 for NRC licensed facilities (other than power reactors) and

Agreement State licensees, thereby relieving these licensees from

unnecessary dual regulations.

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Attachment 1

IN 97-04 EFFECTIVE DATE: This rule will become effective January 9, 1997.

February 24. 1997

FOR FURTHER INFORMATION

CONTACT

Alan K. Roecklein, Office of Nuclear Regulatory Research, U.S. Nuclear Regulatory Commission, Washington, DC

20S55-0001, telephone (301) 415-6223.

SUPPLEMENTARY INFORMATION:

Background

The EPA promulgated National Emission Standards for Hazardous Air

Pollutants (NBSHAPs)

for radionuclides on October 31, 1989. Under 40

CFR Part 61, Subpart I, emissions of radionuclides must be limited so

that no member of the public would receive an effective dose equivalent

greater than 10 mrem (0.1 mSv) per year.cSUP>l Subpart I of 40 CFR Part

61 was promulgated to implement the CAA and limit doses to members of

the public from air emissions of radionuclides (other than Radon-222)

from all NRC licensees other than licensees possessing only sealed

sources, high-level waste repositories, and uranium mill tailings piles

that have been disposed of in accordance with 40 CFR Part 192. Radon-

222 emissions from tailings were covered by 40 CFR Part 61, Subparts T

(addressing non-operational uranium mill tailings piles) and N

(addressing operating mill tailings piles). EPA rescinded Subpart T for

NRC licensees after Appendix A to 10 CFR Part 40 was amended by the

Com-ission to conform to changes EPA issued to 40 CPR Part 192. Subpart

W still applies to NRC licensees. Because Radon-222 is adequately

addressed in 10 CFR Part 40, Appeadix A, and other provisions of 10 CFR

Part 20, it is not covered in this final rulemaking.

____-______________________________________________

\\1\\ 1 Subpart I expresses dose in effective dose equivalent

(EDE).

NRC expresses dose in total effective dose equivalent (TEDE).

These terms are essentially equivalent.

___________________________________________________

In 1990, Congress enacted amendments to the CAA. Section 112(d)(9)

of these amendments to the CAA (the Simpson amendment) states:

No standard for radionuclide emissions from any category or

subcategory of facilities licensed by the Nuclear Regulatory

Comission (or an Agreement State) is required to be promulgated

under this section if the Administratot determines, by rule, and

after consultation with the Nuclear Regulatory Comnission, that the

regulatory program established by the Nuclear Regulatory Comission

pursuant to the Atomic Energy Act for such category or subcategory

provides an ample margin of safety to protect public health.

Upon issuance, the effectiveness of Subpart I for all NRC licensees

was imediately stayed by EPA pending further evaluation. During the

stay period, EPA conducted two studies of the air emissions from NRC

and Agreement State materials licensees. The first was a survey of 367 randomly selected nuclear materials licensees. EPA determined that the

highest estimated dose to a member of the public from air emissions

from these facilities was 8 mrem (0.08 mSv) per year, based on very

conservative modeling. In addition, 98 percent of the facilities

surveyed were found to have doses to members of the public resulting

from air emissions less than 1 mrem (0.01 mSv) per year. The second

study evaluated doses from air emissions at 4S additional facilities

that were selected because of their potential for air emissions

resulting in significant public exposures. EPA found that 7S percent of

these licensees had air emissions resulting in an estimated maximum

public dose less than 1 mrem (0.01 mSv) per year. For the licensees

evaluated, none exceeded 10 mrem (0.1 mSv) per year.

In its initial proposal to rescind Subpart I for NRC licensees

other than power reactors, EPA stated that:

Based on the results of the survey undertaken by EPA and the

commitments made by NRC in the MOU, EPA has made an initial

determination that the NRC prograw under the Atomic Energy Act

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Attachment 1

IN 97-04 provides an ample margin of safety to protect public health (57 FR

February 24. 1997

56880; December 1, 1992). However, EPA continued to express concern regarding the adequacy of

the measures to assure that future emissions from NRC licensees will

not exceed levels that will provide an ample margin of safety. The stay

on Subpart I expired on November 15, 1992, and Subpart I became

effective on November 16, 1992. Subsequently, in July of 1993, the EPA

Administrator determined that th-re was insufficient basis at that time

to rescind Subpart

I. Consequently, NRC and Agreement State licensed

facilities were subject to dual regulation of airborne effluents of

radionuclides under both the

AMM and the CAA, including regulatory

oversight by EPA (or authorized State) and NRC (or Agreement State).

NRC licensees subject to EPA's Subpart I are also subject to NRC

dose limits for members of the public contained in 10 CFR Part 20,

Subpart D, entitled "Radiation Dose Limits for Individual Members of

the Public"' (Subpart D). Under Subpart D, licensees shall ensure that

doses to members of the public are less than 100 mrem (1.0 mSv) per

year from all pathways (including airborne effluents) and all sources

associated with the licensee's operation. In addition, under Subpart B,

entitled "Radiation Protection Programs,

licensees must ensure that

doses to members of the public be kept as low as is reasonably

achievable (ALARA). Based on the studies conducted by EPA and licensee

reporting of doses to members of the public from airborne effluents to

EPA, it is evident that less than 10 mrem( 0.1 mSv) per year to the

maximally exposed member of the public from airborne radioactive

effluents to the environment is reasonably achievable.

NRC power reactor licensees subject to 10 CFR 50.34a must keep

doses to members of the public from airborne effluents consistent with

the numerical guidelines in Appendix I to 10 CFR Part 50. These

licensees have reported estimated doses to members of the public from

air emissions well below the Subpart I value for many years. Based on

the combination of a continuing regulatory basis for reduced air

emissions and documented proof of the effectiveness of the NRC program

for these licensees, EPA rescinded Subpart I for power reactors

licensed by NRC (60 FR 37196; September S, 1995).

Amendments

The amendments proposed on December 13, 1995 (60 FR 63984), and

[(Page 651211]

finalized in this rule establish a constraint of 10 mrem (0.1 mSv) per

year TEDS to members of the public from airborne radioactive effluents

to the environment from NRC-licensed facilities, other than power

reactors, as a part of its

program to maintain doses ALARA. These

amendments codify numerical values for NRC's application of ALAUM

guidelines for radioactive air emissions from its

licensees, other than

power reactors. For power reactors, ALARA guidelines have already been

established within 10 CPR Part So and existing facility licensing

conditions. These final amendments ensure that air emissions are

maintained at very low levels and, taking into consideration the

elimination of dual regulation, at some reduced cost to licensees. This

action brings consistency between the EPA's dose standard and the NRC's

ALARA application, and is expected to be the final step in providing

EPA with the basis to rescind Subpart I as it applies to NRC-licensed

facilities other than power reactors. NRC has been working

cooperatively with EPA to achieve rescission of EPA's standards in 40

CFR Part 61, Subpart I, under Section 112(d)(9) of the CAA. EPA

published a proposed rescission of 40 CFR Part 61, Subpart I, on

December 1, 1992 (57 FR 56877). On September 28, 1995. EPA published a

notice in the Federal Register reopening the comment period on

rescission of Subpart I (60 FR 50161). The objective of this effort is

to eliminate duplicative regulations that provide no incremental

benefit in terms of public and environmental protection.

The regulatory framework that NRC is providing as a basis for

rescission of EPA's Subpart I consists of the requirement in 10 CFR

Part 20 to limit doses to members of the public to 100 mrem (1.0 MSv)

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Attachment 1

IN 97-04 February 24. 1997 per year, and the requirement to constrain doses to members of the

public from airborne effluents of radioactive materials to the

envir~.ment from a single licensed operation to 10 mrem '0.1 mSv) per

year.

Currently, under Sec. 20.1501 licensees are required to make or

cause to be made surveys that may be necessary to comply with the

regulations in 10 CFR Part 20. This data would be made available to

inspectors upon request. If the licensee estimates or measures a dose

to the nearest resident from air erissions greater than 10 mrem (0.1 mSv) per year, the licensee would be required to report the dose to NRC

in writing within 30 days, which would include the circumstances that

led to the greater than 10 mrem (0.1 mSv) per year dose, a description

of the corrective steps the licensee had taken or proposed to take to

ensure that the constraint is not again exceeded, a timetable for

implementing the corrective steps, and the expected results. Records of

the results of measurements and calculations needed to evaluate the

release of radioactive effluents to the environment will still be

required pursuant to 10 CPR 20.2103(b)(4).

Exceeding this constraint will not result in a Notice of Violation

(NOV) as would be the case if a limit needed for adequate protection of

public health and safety were exceeded. In the case of the constraint

rule, an NOV will be issued only if and when (1) a licensee fails to

report an actual or estimated dose from airborne effluent releases from

a facility that has exceeded the constraint value; or (2)

if a licensee

fails to institute agreed upon corrective measures intended to prevent

further airborne effluents in excess of those which would result in

doses exceeding the constraint level.

The rule applies to airborne effluents of radioactive materials to

the environment, other than Radon-222 and daughters, from all NRC

licensees except power reactors. Power reactors are exempt from this

rule because they are already required, under 10 CFR 50.34a, to

identify design objectives and the means to be employed for keeping

doses to members of the public from air effluents ALARA in their

license application. Appendix I to 10 CPR Part So contains the

numerical guidelines to meet this requirement.

Response to Comments

Fifty-seven individuals and organizations provided written comments

on the proposed rule and Draft Regulatory Guide DG-8016. Among the 57 coamienters, 24 were licensees, seven were professional organizations, five were States, 16 were members of the public, and five were

environmental organizations. Because many letters commenting on the

Draft Regulatory Guide DG-0016 also included comments on the rule, these comments were also considered in developing the final rule.

Issue 1--Proposed Rule Approach

CoAments: A total of thirty-one individuals and organizations

commented on the basis for the rule. Five commentere agreed with the

approach and need for the constraint. Four commented that the rule

should not be finalized and that EPA's Subpart I should remain in

effect. Twenty-two coamenters stated that existing NRC programs

provided an ample margin of safety and that the constraint was not

needed. However, of these, seven agreed that the constraint was

preferable to dual regulation or Subpart I alone.

Those coammenting that existing NRC program are adequate to protect

the public cited the two EPA studies on doses from air emissions. Two- thirds of these commenters were opposed to going forward with the

constraint because they believed it

was not needed and that licensee

and regulator costs could not be justified given the expectation that

risk to public health and safety would not be reduced. These commenters

encouraged NRC to continue working with EPA to provide sufficient basis

for rescission of Subpart I without the imposition of an equally

unnecessary regulation. A few commenters stated that the risk was

considerably less than estimated because excessively conservative

calculational methods were used by EPA. A few commenters compared the

10 mrem (0.1 mSv) per year constraint to variability in background or

doses from commercial air traffic as evidence that the dose and the

Attachment 1

IN 97-04 February 24. 1997 risk is

trivial. Seven commenters cited burden reduction and single- agency oversight as the reasons for agreeing that the constraint was

pre:zrable to dual regulation or EPA's Subpart I alone.

Coamenters opposed to the constraint as a less protective standard, stated that the constraint was based upon a voluntary program (ALARA)

and, as such, was not adequate to protect the public. one commenter

stated that NRC does not perform confirmatory measurements and

therefore, NRC jurisdiction was not adequate.

Response: NRC and EPA have been working to develop a basis upon

which dual regulation could be eliminated. EPA has stated that there

are two necessary components to any finding that NRC's program is

sufficient to protect the health and safety of the public. The first is

evidence that doses from air emissions are below 10 mrem (0.1 mSv) per

year to a member of the public. This has been demonstrated through the

two studies by EPA and by licensee reporting of actual air emissions.

The second component is a program to ensure that doses remain at this

level. In the absence of rulemaking requiring licensees to maintain

doses to levels of no more than 10 mrem (0.1 msv) per year, EPA would

not rescind Subpart I and dual regulation would continue.

The Federal Radiation Council (FRC) was formed in 1959, to provide

recommendations to the President for Federal policy regarding radiation

matters that affect health. In May 1960,

FRC set forth basic principles

for

((Page 6512211 protection of both workers and the public. The council was abolished in

1970 when its functions were transferred to the EPA Administrator. In

1981, EPA published proposed recommendations for new Federal guidance

for occupational exposure. In 1987, President Reagan approved

recommendations by the EPA Administrator for new "Radiation Protection

Guidance to Federal agencies for Occupational Exposure.'" EPA has not

yet issued recommendations on limits for the public. A working group

comprised of representatives from affected Federal agencies and experts

on radiological health matters has been developing these

reco1mendations for several years and expects to provide them during

the next year.

In 1977, the International Council on Radiological Protection

(ICRP) issued its

Report No. 26 "Recommendations of the International

Council on Radiological Protection" in 1977. These recommendations

concluded that the average doses to members of the public should not

exceed 100 mrem (1.0 mSv) per year with a limit of 500 mrem (5.0 mSv)

per year to any individual.

The National Council on Radiation Protection and Measurements

(NCRP)

is required by Congress to recommend limits for exposure to

ionizing radiation. In June 1987, NCRP issued its

Report No. 91,

"Recolmendations on Limits for Exposure to Ionizing Radiation." This

report contains recommendations on exposure limits for both

occupationally exposed individuals and individual members of the

public. The report recommended that doses to individual members of the

public be limited to 100 mrem (1.0 mSv) per year averaged over a

lifetime, not to exceed SOO mrem (5.0 mSv) in 1 year.

In 1991, NRC revised 10 CPR Part 20 Standards

for Protection

Against Radiation."

This revision included new limits for individual

members of the public. Though both the ICRP and the NCRP recommended

limits of 500 mrem (5.0 mSv) in any one year, the NRC established a

limit of 100 wrem (1.0 mSV) per year "-cause

it

was impractical to

control dose in terms of lifetime average without keeping track of

individual exposures. In addition, 10 CFR Part 20 requires that

licensees use procedures and engineering controls to maintain doses

Both the NRC and EPA regulatory programs are designed to achieve

protection of the public with an ample margin of safety. The approaches

of the two agencies differ. NRC limits TEDE, requires that doses are

maintained ALARA, and maintains an active inspection program. EPA

limits dose from individual pathways of exposure and individual

radionuclides to onsure that the total dose does not exceed recommended

levels. Both programs achieve similar levels of protection.

NRC agrees that adoption of I'm constraint in Sec. 20.1101(d) is

Attachment 1

IN 97-04 preferable to dual regulation due to the reduction in burden on

February 24.

licensees as well as State and Federal agencies. Under the provisions of 40 CFR Part St, licensees with doses to members of the public

greater than 1 mrem (0.1 mSv) per year but less than 10 mrem (0.1 mSv)

per year must submit reports. However, under 10 CFR 20.1101(d), these

licensees will not have to file reports for doses below the constraint

level because doses can be evaluated during routine inspections. Under

the final rule, the burden of calculating doses should be reduced for

most licensees because the proposed guidance for demnsllmtrating

compliance with 10 CFR 20.1101(d) allows significantly more flexibility

and simpler methods for calculating doses than the model currently used

to demonstrate compliance with 40 CFR Part 61. These new methods for

calculating doses should result in fewer reporting and corrective

actions, as under EPA's Subpart Ir

Licensees are required under Sec. 20.2103 to maintain records of

surveys required to demonstrate compliance with the public dose limit.

Review of licensee records used to demonstrate compliance with the

public dose limit is part of the NRC inspection program. Confirmatory

measurements would generally not be useful since most licensees in this

category do not have routine ongoing effluent releases.

Finally, concerning those commenters that believe NRC's

requirements are less safe than Subpart I, Congress enacted legislation

comprehensively amending the Clean Air Act (CAA), which included a

section addressing the issue of regulatory duplication between EPA and

NRC in 1990. The 1990 CAA amendments permit the EPA Administrator to

rescind the CAA standards as they apply to radionuclides, at sites

licensed by NRC, and the Agreement States, if he or she finds that the

NRC regulatory program provides an ample margin of safety to protect

public health.

EPA's analysis of the NRC r gulutory program focused on two general

issues: (1) whether the implementation of the NRC regulatory program

results in sufficiently low doses to protect the health and safety of

the public with an ample margin of safety; and (2) whether the NRC

program is sufficiently comprehensive and thorough, and administered in

a manner that will continue to protect public health in the future. EPA

undertook studies to determine the level of protection provided by the

existing regulatory program nd found that doses were sufficiently low

to protect the health and safety of the public with an ample margin of

safety. The implementation of this rule will ensure that doses to

members of the public from air effluents will continue to remain below

10 mrem (0.1 mSv) per year and provide evidence to EPA that the current

level of protection will continue.

The purpose of this rulemaking is not to reduce doses, because it

has already been demonstrated that doses are sufficiently low. The

purpose is to ensure that doses are maintained at the low level

currently achieved by NRC licensees, eliminate unnecessary dual

regulation, and reduce costs associated with the current level of

protection, by providing a basis upon which EPA can find that doses

will not increase as a result of rescission of Subpart I.

Issue 2--Promulgation of the Constraint as MA

Comments: There were a number of commenters who objected to the

ALARA basis for the proposed constraint rule. Some coementers objected

on the ground that ALmRA is a matter of operating philosophy, good

radiation protection practice and licensee judgment, and cannot be

translated into an enforceable dose number. Other comenters objected

on the basis that ALARA is inherently site specific and cannot be

defined generically or that the proposed dose constraint cannot be

ALRA but must be a limit because the constraint contemplates some

enforcement actions for exceadance even if the licensee has foilowed

all good radiation protection practices. Some commenters argued that

the rule cannot be ALLRA because it adds costs with no safety benefit.

Other commenters stated that the constraint is inconsistent with a

prior NRC decision in 10 CFR Part 20 (56 FR 23360) on the use of

-'reference levels."

Response: The Colsaion has retained an ALt A basis for the rule

but recognizes that its use of the term in this rule may have led to

some confusion. The c a ission acknowledges that the ALMA concept in

1997

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Attachment 1

IN 97-04

February 24. 1997

10 CFR 20.1003 is an operating philosophy which requires good radiation protection practice and the exercise of expert licensee judgement. The

ALARA con-ept is site specific in that some of the factors to be

considered may vary from case to case, as the court so found in York

Committee for a Safe Environment v. NRC, 527 F. 2d 812

((Page 6512311 (D.C. Cir. 1975). The Cormidesin has presumed, without deciding, that

the ALARA concept in Sec. 20.1003 can be enforced in a particular case

so as to require a specific radiation protection practice, but it is

clear that the existing regulation does not translate readily into a

generic dose number, which, if

exceeded, will lead to enforcement

action.

The NRC intended the constraint rule to be a somewhat broader

concept found in the governing statute, the Atomic Energy Act of 1954, as amended (Act). The Act, as construed by both the ComuSiadon (e.g.,

10 CFR 50.109) and the courts (Union of Concerned Scientists v.

NRC,

924 F.2d 108 (D.C. Cir. 1987)), contemplates two distinct approaches to

radiological regulation. First, a level of "adequate protection must

be defined and enforced without regard to economic cost. Second, risk

may be reduced to a level below that associated with "adequate

protection' to "minimize danger to life or property" with economic

cost and other factors as permissible balancing considerations. See

"Revision of Backfitting Process for Power Reactors, (53 FR 20603;

June 6, 1988). It is

important to note that Section 161b of the Act

authorizes the Comission to adopt and enforce generic requirements

using either approach. Many recent NRC regulations (e.g., 10 CFR 50.63)

have been directed at incremental risk reduction under the second

approach based on a generic regulatory or backfit analysis which

considered and balanced economic and other costs and safety backfits.

These "minimize danger regulations provide "limits"' because they

establish generic requirements directly enforceable against licensees.

However, in a broad sense they are also ALARA regulations because cost, feasibility, and other relevant factors identified in 10 CFR 20.1003 are evaluated.

Viewed in its

larger statutory context, the use of ALARA in 10 CFR

20.1003 is one means to implement the second approach to radiological

regulation. However, other similar requirements can also be part of

this second approach. While the ALARA concept in 10 CFR 20.1003 may not

be consistent with a generic enforceable dose requirement, other

concepts of ALARA premised on generic considerations are appropriate.

This concept of ALKRA as a broadly applicable dose requirement based o..

a generic weighing and balancing of health and safety, feasibility, and

other factors is the basis for the longstanding limits on nuclear power

reactor emissions in 10 CPR Part so, Appendix I,

and is the basis for

the constraint rule. The ALARA rule imposes a limit in the sense that

exceedance will lead to corrective action, but it

is not a limit in the

sense that exceedance per se would constitute a violation of any

regulatory requirement. A violation occurs only when a licensee fails

to report an exceedance or fails to take appropriate corrective

actions. A limit would be appropriate if compliance were needed to

ensure adequate protection of public health and safety. In this case, the constraint is needed only to ensure that currently afforded levels

of protection are not reduced. This will provide the basis for

rescission of 40 CPR Part 61, Subpart I by EPA.

Thus, to say that the constraint rule cannot be based on ALARA

because it is in effect a limit.'" interchanges a narrow concept of

AULARM" with a broad concept of -limit.' If a broad definition is

used, the constraint rule withstands scrutiny as both ALARA and a

limit. In the statutory context of the Atomic Energy Act and general

principles of administrative law, the constraint rule is a limit based

on generic ALMA considerations. The constraint rule is not a limit

needed for adequate protection and the constraint rule is something

more than a narrow translation of the particular ALMA concept

contained in 10 CFR 20.1003. The term 'constraint'"

was used for the

rule to avoid confusion with the narrow concepts of ALARA and the limit

employed in radiation protection discussion.

Three matters must be addressed:

t-

Attachment 1

IN 97-04 February 24.

(1) The comment that the rule cannot be based on ALARA because it will result in increased cost with no safety benefit;

(2) The problem of the licensee who cannot meet the dose constraint

despite using all good radiation protection practices; and

(3) The allegedly inconsistent Comission discussion of reference

levels in a recent revision to 10 CFR Part 20.

The

Commismion disagrees with the premise of the first comment.

There was no disagreement with the Commission's conclusion that all of

the licensees affected by the rule are achieving a level of control

such that doses are below the 10 mrem (0.1 mSv) per year level and so

there is no factual dispute over whether this level of radiation

protection is readily achievable. The final rule and EPA'S rescission

of its Clean Air Act emission limits and related requirements will

result in a significant net cost savings to licensees. The NRC

acknowledges that the positive direct health effects are likely to be

small and possibly nonexistent in the near future, given the current

level of controls. However, the rule can be said to offer a small, but

positive, net health and safety benefit in that it will

prevent a

decrease in the level of protection afforded the public if Subpart I

were rescinded in the absence of a rule like the constraint. Under the

ALARA concept, it is appropriate to base a requirement on a small

positive health and safety benefit when cost savings are also likely.

The NRC does not expect that any licensee subject to the rule will

be unable to demonstrate that doses to members of the public from

releases of airborne radioactive materials to the environment are less

than 10 mrem (0.1 mSv) per year. In the unlikely case that this dose is

exceeded or is projected to be exceeded, due to some temporary

circumstances or lapse in controls, the NRC expects the licensee to

take whatever corrective actions are necessary (if any) to protect

public health and safety, to report the dose, to recommend further

corrective actions if necessary, and take those corrective actions

agreed upon with NRC. NRC staff will review and approve corrective

actions to ensure that they are appropriate to reduce airborne

emissions sufficiently to comply with the constraint in the future. In

the unlikely case that a licensee is unable to take adequate corrective

actions, because of limits in technology or cost constraints, these

issues can be addressed in the future on a case-by-case basis.

The application of the ALARA principle used in this rule is not the

same as the concept of reference level which was rejected by the

Comission when 10 CFR Part 20 was recently revised. Commenters

on the

1991 revision to 10 CYR Part 20 objected to the use of reference levels

because they were implemented exactly tle same as adequate protection

limits. For that reason, the Comisia on did not adopt reference levels

in the 1991 revision. Implementation of the constraint is different

than such a limit because exceeding the constraint is not a violation, and only requires the licensee to report the dose and take corrective

actions to reduce future doses.

Issue 3--Whether the Constraint Is Actually a Limit

Comments: Nine comments were received on whether the constraint is

or should be a limit. Two commenters believed that the constraint was

no different than a limit. one commenter agreed with the term

constraint. Three coaaenters expressed concern that the constraint was

an inappropriate relaxation of requirements.

[(Page 6512411 Those commenting that the constraint was a de facto limit

interpreted the requirements to indicate that a second exceedance of

the constraint would result in enforcement action and therefore the

constraint is

a limit. Three commenters indicated that the rule should

be a strict

limit. They expressed concern that the constraint was less

protective than EPA requirements.

Response:

If a licensee exceeds a limit that is needed to protect

health and safety, the NRC may take immediate enforcement action. If

a

licensee exceeds a constraint, the licensee will be required to notify

NRC, take any actions that may

necessary to protect public health

and safety, and implement any fun.. er corrective actions that NRC staff

1997

Attachment 1

IN 97-04

February 24. 1997

agrees are adequate to prevent further doses in excess of the

constraint. However, if the licensee failed to report a measured or

calculated dose in excess of the constraint to KRC or failed to

implement appropriate corrective actions as agreed upon, enforcement

action would be expected. This is because, unlike an adequate

protection limit, the constraint is not needed to provide adequate

protection of public health and safety.

The NRC does not agree that the constraint is less protective than

current EPA requirements. Both EPA's Subpart I and the NRC constraint

require licensees to take actions to ensure that doses to members of

the public do not exceed 10 mrem (0.1 msv) per year from ambient air

emissions. NRC routinely inspects licensed facilities to ensure that

air effluents do not result in doses to members of the public that

exceed the requirements in 10 CFR Part 20. The inspection and

enforcement program will be amended as a result of this final rule to

review licensee records used to demonstrate compliance with the

constraint.

Issue 4--Citizen Suits

Comments: Three commenters opposed finalization of the constraint

on the basis that it forfeits citizen rights to sue a licensee who

exceeds the constraint.

Response: The Commissiones regulations in 10 CFR 2.206 provide the

public with the right to petition the NRC to take enforcement action

against a licensee for a violation of the ComisiLon's regulations.

This would include the final constraint rule.

Issue 5--Agreement State Compatibility

Comments: Four commenters addressed the proposal that the

constraint be a Division 2 matter of compatibility. Under Division 2, States could adopt similar or more stringent requirements. Three

commenters agreed that this rule should not be codified as a Division 2 requirement, but rather as a Division 1 matter of compatibility. Under

Division 1, the States would be required to adopt regulations that were

essentially identical. These commenters believed that if stricter

standards were permitted, reactor and non-reactor licensees would be

under different requirements and certain practices, such as nuclear

medicine, could be jeopardized. one commenter noted that because this

is really a limit, it should be under 10 CPR 20.1301 and would be a

Division 1 matter of crmpatibility. Another coamenter stated that NRC

should have provided a greater opportunity for State involvement in

this rulemaking, and that as a division 2 rule, Agreement States would

have to spend scarce resources to develop a compatible rule.

Response: Section 116 of the Clean Air Act specifies that nothing

precludes States from imposing air emission requirements that are more

stringent than those developed by EPA. Section 116(d)(9), which

contains the provisions related to EPA's margin of safety determination

for NRC or Agreement State licenses, specifies that: 'Nothing

in this

subsection shall preclude or deny the right of any State or political

subdivision thereof to adopt or enforce any standard or limitation

respecting emissions of radionuclides which is more stringent than the

standard or limitation in effect under Section 7411 of this title

or

this section. -

The Coamission believes that this provision clarifies

that EPA's determination regarding NRC and Agreement State licensees

has no effect on the existing authority of States to impose air

emission standards that are more stringent than those of EPA.

With regard to the comment concerning involvement of the Agreement

states in the development of this rule, NRC has routinely reported its

progress on providing an adequate basis upon which EPA could rescind

Subpart I to both the Organization of Agreement States (OAS)

and the

Conference of Radiation Control Program Directors (CRCPD) at each of

their annual meetings. The Agreement States were consulted extensively

on this issue over the last several years. There were extensive

discussions of the concept with the individual States and with the

Executive Board of the OAS.

Issue 6--Demographic Information Contained in Required Reports

Attachment i

IN 97-04

February 24. 1997

.... wents: Seven commenters addressed the application of Lhe requirement contained in

10 CFR 20.2203(b)(2) to the constraint. This

section requires reports to contain demographic information on the

exposed individual. These commenters expressed concern that a member of

the public would be under no obligation to provide demographic

information to licensees and that licensees would not always be able to

comply with the requirement.

Response: NRC agrees that members of the public may choose to

withhold the demographic information from. licensees. Such information

is only needed for occupationally exposed individuals to ensure that

lifetime exposure records are accurate. Section 20.2203 has been

changed to only require such information on occupationally exposed

individuals.

Issue 7--Effective Date

Comment: One commenter requested that an effective date be added to

the final rule to coincide with EPA's rescission of Subpart I.

Response: The NRC and EPA will, to the extent possible, publish both

final rules so that they become effective concurrently.

Issue 8--Enforcement

Comments: Five commenters stated that NRC should establish a limit

rather than a constraint. They believed that if the limit has been

exceeded, a notice of violation aid civil penalties should always

result. One commenter expressed concern that "self-reporting

and

confession" is not adequate. Another stated that because ALARA is only

guidance, it is not enforceable.

Response: ALARA is not guidance. As stated previously, the 1991 revision to 10 CFR Part 20 codified ALARA as a required part of the

licensee's radiation protection program. A limit often implies that

doses must be controlled below that level in order to provide adequate

protection of health and safety of the public and workers. To meet

ALARA requirements licensees are currently controlling effluents to

levels below that which would be required under the constraint. If a

licensee exceeds the constraint, the rule requires that this be

reported and that corrective actions be promptly taken. If a licensee

does not comply with the obligation to report and take corrective

actions, enforcement action will result. In NRC's judgment, as a matter

of enforcement policy, it

is not necessary to issue a notice of

violation or civil penalties upon exceedence of the constraint level;

it

is sufficient that this be reported and that prompt corrective

action is taken.

H[Page 6512S]5 Issue 9--Exemptions

Comments: Five commenters stated that the rule should only apply to

members of the public ofosite. They cited the EPA's Subpart I

requirement to calculate dose to the nearest resident or offeite

individual likely to receive the highest dose. Under Subpart I,

licensees would not calculate doses from air emissions to visitors in

hospitals, workers that are not radiation workers within the facility, or other members of the public within the facility.

Response: The language in the rule has been changed to reflect that

it

is intended to apply to radioactive airborne effluents to the

environment. The Draft Regulatory Guide DG-B016 will be revised to

indicate that the dose limit is to be calculated or measured at the

nearest resident or individual offaite likely to receive the highest

dose. The final regulatory guide will be available when the rule

becomes effective.

Comments: Two commenters stated that air emissions from adjacent

nearby exempt uranium wills should not be included in the calculation

of dose. One commenter stated that materials from unlicensed portions

of the facility such as ore stockpiles should not be considered in the

calculation of dose.

K>

I

Attachment 1

IN 97-04 February 24, 1997 Response: Subpart

I

does not apply to disposal at facilities

regulated under 40 CFR Part 191, Subpart B, or to any uranium mill

tailings pile after it has been disposed of under 46

CFR Part 192. The

constraint applies to airborne effluents of only licensed materials to

the environment. Draft Regulatory Guide DG-S016 will be changed to

clarify that windblown particulates from other licensed facilities or

unlicensed materials do not need to be considered in the calculation of

doses used to demonstrate compliance with the constraint.

Comments: Four commenters stated that air emissions from patients

should be exempted from this rule.

Response: The regulatory impact analysis (NUREG-1492) for a recent

NRC rulemaking analyzed potential doses from exposure to patients who

were released after administration of radiopharmaceuticals. This

analysis concluded that internal doses from inhalation of radioactive

materials in the exhaled air of a released patient are trivial. For

licensees using an inventory approach to demonstrating compliance with

the rule, such as the

COMPLY computer code, there is no need to account

specifically for the materials that might be released to the air

through respiration or transpiration by patients. The Regulatory Guide

will make it clear that dose from air emissions from patients do not

need to be specifically addressed in the calculation of dose used to

demonstrate compliance with the constraint.

Comments: Four commenters stated that in addition to Rn-222, all

daughters produced after release should also be excluded.

Response: EPA's Subpart I exempts both Rn-222 and any daughters

produced after release of Rn-222 because these types of releases are

normally not attributable to licensed activities. The proposed rule was

not intended to be more stringent than Subpart

I. The rule language has

been changed to reflect this exemption.

Comments: Two comaienters recommended that in addition to Rn-222, Rn-220 and its

daughters should also be exempted. One commenter stated

that it was an EPA oversight that led to this erroneous omission from

the final Subpart I.

Response: Rn-220 is normally attributable to licensed activities.

EPA does not exempt Rn-220 or its daughters from consideration in the

dose calculations in support of demonstrating compliance with Subpart

I. The commenter's suggestion that an oversight led to the erroneous

omission of this exemption from Subpart I is incorrect, and Rn-220

should not be excluded from the calculations that are used to

demonstrate compliance with the constraint.

Comments: Six commenters requested that in addition to sealed

sources, sealed containers should also be excluded from the rule.

Response: Paragraph 2(a) of Appendix D to 40 CFR Part 61 states:

Radioactive materials in sealed packages that remain unopened, and have

not leaked during the assessment period should not be included in the

calculations. " Subpart I exempts sealed packages, because any package

that has remained sealed cannot contribute to airborne effluents. When

a total inventory of licensed materials possessed during the year is

used to model potential doses, it is unnecessary to include materials

that could not have contributed to airborne effluents. The Regulatory

Guide will provide further guidance on this issue.

Issue 10--Measurability of 10 urem (0.1 mSv) Per Year

Comments: Three commenters stated that 10 urem (0.1 mSv) per year

was not measurable. one commenter stated that although 10 mrem (0.1 BSv)

per year might be easily achievable, it is not easily measurable.

Another stated that the exposure rate corresponds to 1 microR (0.01 micro-Sv) per hour and cannot be measured accurately.

Response: Draft Regulatory Guide DG-8016 provides several methods

for demonstrating compliance with the constraint, and only one of the

methods described would require direct measurement at the receptor

location. If this method is not practical due to the emission

characteristics of the radionuclide releases, there are other options

cited in Draft Regulatory Guide DQ-8016 that do not require a direct

measurement to demonstrate compliance with the constraint.

Issue 11--Scope of the Rule

K-.)

Attachment 1

IN 97-04

February 24. 1997

Comments: One commenter stated that if there must be a constraint, Page 12 of

15 it should apply to all licensees, including power reactor licensees.

9 Rz:ponse: Although this rule only applies to licensees other than

power reactor licensees, the Commission's existing regulations in 10 CFR Part 50, Appendix I, already establish a similar regulatory

framework for power reactors. Appendix I includes separate requirements

to develop design objectives and operational levels sufficient to

demonstrate compliance with EPA's Subpart I.

In addition, reactor

licensees must annually report quantities of radioactive materials

released into the environment, as well as the resulting doses.

Issue 12--ocation of Constraint in NRC Regulations

The Com iasion requested specific comment on the question of

whether the 10 mrem (0.1 mSv) per year constraint should be established

in 10 CFR Part 20 as proposed or whether it should be established

separately in each appropriate part of Title 10 instead.

Comments: Two comments were received in response to this issue. One

commenter stated that the constraint should be in 10 CFR Part 20. The

other commenter stated that the constraint should be in each

appropriate part. Two other comnenters stated that it

should be in

Sec. 20.1301 with the dose limits.

Response: While the constraint could just as easily be included

under other parts of the regulations, including it

in

10 CFR Part 20

provides uniformity. Because 10 CFR Part 20 is the designated area for

radiation protection standards and related requirements, it is the

appropriate location for the constraint. The rule will be codified

under Sec. 20.1101 to make it clear that although the constraint is not

the same as a limit, licensees are expected to develop radiation

programs to ensure that doses from air emissions are below 10 mrem (0.1 msx) per year.

((Page 6512611

Agreement State Compatibility

The Coriasson believes that the Division 2 compatibility

designation for the rule is consistent with state authority in this

area as described in the Clean Air Act. The Division 2 designation

means that Agreement States must address these rules in their

regulations but may adopt requirements more restrictive than those of

IRC. Accordingly, the authority of the Agreement States to impose air

emissions standards under their Atomic energy Act authority after the

effective date of this rule will be consistent with their existing

authority. Under Section 274 of the Atomic Energy Act the Cami--

don

reviews Agreement State programs to ensure that adequacy and

compatibility of the State Program is maintained. The Comission has

also approved procedures to suspend or terminate programs that are not

adequate or compatible.

Summary of Changes in the Final Rule

Based on the responses to comments, a few changes were made in the

final rule. Otherwise, the provisions of the final rule are the same as

those presented in the proposed amendments. Specific changes to the

final rule are summarized as follows:

(1) Section 20.2203(b)(2) has been changed to require the name, social security number, and date of birth only for occupationally

overexposed individuals and not for members of the public who have

received doses in excess of the public limits, including the

constraint.

(2) The language of the rule has been changed to indicate that Rn-

222 and all

daughters produced after the release of the radon are

categorically excluded from this rule.

(3) The language of the rule has been changed to indicate that the

constraint applies only to release of airborne radioactive effluents to

the environment and, thus, dose to the nearest resident, offaite

business or school, is

to be constrained.

In addition, the following cl-nqes will be made to Draft Regulatory

i

-

tAttachment 1 IN 97-04

February 24. 1997

Guide DG-8016: (1) An inventory of radioactive materials used to model a potential

dost. to a member of the public need not include radioactive mcterials

in sealed containers that have remained sealed throughout the

compliance period.

(2) Airborne emissions of radioactive materials from patients does

not need to be considered if the materials have already been included

in the site inventory.

TLe Regulatory Guide was issued in draft for public comment

concurrent with the proposed rule. The final regulatory guide will be

available by the effective date of this rule.

Conforming Amendments To NRC's Enforcement Policy

By separate notice in the Federal Register, the Commission is

modifying its

"General Statement of Policy and Procedures for NRC

Enforcement Actions" (Enforcement Policy), to address the new

regulation, and to provide an example Severity Level Iv violation of

the constraint. This change will also be reflected when the Enforcement

Policy is reprinted in its

entirety in the next revision of NUREG-1600.

Small Business Regulatory Enforcement Fairness Act

In accordance with the Small Business Regulatory Enforcement

Fairness Act of 1996, the NRC has determined that this action is not a

major rule'

and has verified this determination with the Office of

Information and Regulatory Affairs, Office of Management and Budget.

Finding of No Significant Environmental Impact

The Comission has determined under the National Environmental

Policy Act of 1969, as amended, and the NRC's regulations in Subpart A

of 10 CPR Part 51, that this rule, if adopted, would not be a major

Federal action significantly affecting the quality of the human

environment and therefore, an environmental impact statement is not

required. This action is not expected to have any significant

environmental impact because the programs will provide equivalent

protection. Also, airborne effluents of radioactive materials to the

environment are not expected to increase. The changes to the final rule

are to the procedural methods for demonstrating compliance as well as

licensing and inspection procedures. The environmental assessment and

finding of no significant impact on which this determination is based

are available for inspection and photocopying for a fee at the NRC

Public Document Room, 2120 L Street NW.

(Lower Level), Washington, DC.

Paperwork Reduction Act Statement

This final rule amends information collection requirements that are

subject to the Paperwork Reduction Act of 1995 (44 U.S.C. 3501 et.

seq.). These requirements were approved by the Office of Management and

Budget, approval number 3150-0014.

Theipublic reporting burden for this collection of information is

estimated to average 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> per response, including the time for

reviewing instructions, searching existing data sources, gathering and

maintaining the data needed, and completing and reviewing the

collection of information. Send comments on any aspect of this

collection of information, including suggestions for further reducing

this burden, to the Information and Records Management Branch (T-6 P33), U.S. Nuclear Regulatory Conission, Washington, DC 20555-0001, or

by Internet electronic mail to bsjllnrc.gov; and to the Desk Officer, office of Information and Regulatory Affairs, NEOB-10202,

(3150-0014),

Office of Management and Budget, Washington, DC 20503.

Public Protection Notification

The NRC may not conduct or sponsor, and a person is not required to

respond to, a collection of information unless it displays a currently

valid OMB control number.

X-

KAttachwent

1 IN 97-04

February 24. 1997

Regulatory Analysis The NRC ha- prepared a regulatory analysis for this final rule. The

analysis examines the costs and benefits of the alternatives considered

by the NRC. In the response to comments, the NRC concluded that only

some minor changes to the draft regulatory analysis were necessary, corresponding to some minor procedural changes in the final rule. The

regulatory analysis is available for inspection in the NRC Public

Document Room, 2120 L Street, NW. (Lower level), Washington, DC 20555-

0001. Single copies of the analysis may be obtained from Alan K.

Roecklein, Office of Nuclear Regulatory Research, U.S. Nuclear

Regulatory Ciiassion, Washington, DC 20555-0001, telephone (301) 415-

6223.

Regulatory Flexibility Certification

In accordance with the Regulatory Flexibility Act of 1980,

(5 U.S.C. 605(b)), the Cominision certifies that this rule will not have a

significant economic impact on a substantial number of small entities.

This final rule only impacts NRC licensees with emissions of

significant quantities of radioactive material who would be required to

report the exceedance to the NRC. It will relieve licensees from the

unnecessary burden of dual regulation. The level of air emissions from

NRC-licensed facilities has historically been well below the NRC dose

limit and except for a few unusual cases, readily met the EPA standard.

([Page 6512711

Backfit Analysis

The NRC has determined that the backfit rule, 10 CFR SO.109, does

not apply to this final rule because it does not apply to power reactor

licensees, and therefore, a backfit analysis is not required for this

final rule because these amendments do not involve any provisions which

would impose backfits as defined in 10 CFR 50.109(a)(1).

List of Subjects In 10 CFR Part 20

Byproduct material, Criminal penalties, Licensed material, Nuclear

materials, Nuclear power plants and reactors, Occupational safety and

health, Packaging and containers, Radiation protection, Reporting and

recordkeeping requirements, Source material, Special nuclear material, Waste treatment and disposal.

For the reasons set out in the preamble and under the authority of

the Atomic Energy Act of 1954, as amended, the Energy Reorganization

Act of 1974, as amended, and 5 U.S.C. 553, the NRC is adopting the

following amendments to 10 CFR Part 20.

PART 20--STAIDARDS FOR PROTECTION AGAINST RADIATION

1. The authority citation for Part 20 continues to read as follows:

Authority: Secs. 53, 63, 65, 81, 103, 104, 161, 182, 186, 68 stat. 930,

933, 935, 936, 937, 949, 9S3, 955, as amended, sec. 1701,

106 Stat. 2951, 2952, 2953 (42 U.S.C. 2073, 2093, 2095, 2111, 2133,

2134, 2201, 2232, 2236, 2297f) secs. 201, as amended, 202, 206, 98 stat. 1242, as amended, 1244, 1246 (42 U.S.C. 5841, 5842, 5846).

2. In Sec. 20.1003, the definition of Constraint is added to read

as follows:

Sec. 20.1003 Definitions.

Constraint (dose constraint) means a value above which specified

licensee actions are required.

Attachment 1

IN 97-04

February 24. 1991

3.

In Sec. 20.1101, paragraph (d) is added to read as follows: Sec. 20.1101 Radiation Protection Programs.

(d) To implement the ALARA requirements of Sec. 20.1101 (b),

and

notwithstanding the requirements in Sec. 20.1301 of this part, a

constraint on air emissions of radioactive material to the environment, excluding Radon-222 and its

daughters, shall be established by

licensees other than those subject to Sec. 50.34a, such that the

individual member of the public likely to receive the highest dose will

not be expected to receive a total effective dose equivalent in excess

of 10 mrem (0.1 mSv) per year from these emissions. If

a licensee

subject to this requirement exceeds this dose constraint, the licensee

shall report the exceedance as provided in Sec. 20.2203 and promptly

take appropriate corrective action to ensure against recurrence.

4.

In Sec. 20.2203 the section heading is revised, a new paragraph

(a)(2)(vi) is added, and paragraphs (b)(1)(iv) and (b)(2) are revised

to read as follows:

Sec. 20.2203 Reports of exposures, radiation levels, and

concentrations of radioactive material exceeding the constraints or

limits.

(a) * * *

(2) * *

(vi) The ALARA constraints for air emissions established under

Sec. 20.1101(d); or

(b) * * *

(1) * *

{iv) Corrective steps taken or planned to ensure against a

recurrence, including the schedule for achieving conformance with

applicable limits, ALARA constraints, generally applicable

environmental standards, and associated license conditions.

(2) Each report filed pursuant to paragraph (a) of this section

must include for each occupationally overexposed \\7\\ individual: the

name, Social Security account number, and date of birth. The report

must be prepared so that this information is stated in a separate and

detachable part of the report.

__________________________________________________________________________

\\7\\ With respect to the limit for the embryo-fetus

(Sec. 20.1208),

the identifiers should be those of the declared

pregnant woman.

Dated at Rockville, Maryland, this 3rd day of December, 1996.

For the Nuclear Regulatory Comission.

John C. Boyle, Secretary of the Oondisidon.

(FR Doc. 96-31221 Filed 12-9-965 8:45 am]

BILLING CODE 7590-01-P

-

y

i-

Attachment 2

IN 97-04

February 24, 1997 LIST OF RECENTLY ISSUED

NMSS INFORMATION NOTICES

I

nformation

Date of

Notice No.

Subject

Issuance

Issued to

97-03

96-72

96-70

96-66

96-63

96-57

96-54

Defacing of Labels to Comply

with 10 CFR 20.1904(b)

Undetected Failures that May

Occur During Patient Treat- ments with Teletherapy

Devices

Year 2000 Effect on Computer

System Software

Recent Misadministrations

Caused by Incorrect Cali- brations of Strontium-90

Eye Applicators

Potential Safety Issue

Regarding the Shipment

of Fissile Material

Incident-Reporting Require- ments Involving Intakes, During a 24-Hour Period

that May Cause a Total

Effective Dose Equivalent

in Excess of 0.05 Sv (5 rem)

Vulnerability of Stainless

Steel to Corrosion When

Sensitized

02/20197

12/24/96

12/24196

12/13/96

12/05/96

10/30/96

10117/96

All material licensees

involved with disposal of

medical waste

All teletherapy licensees

All U.S. Nuclear Regulatory

Commission licensees, certi- ficate holders, and regis- trants

All U.S. Nuclear Regulatory

Commission Medical Use

Licensees authorized to use

strontium-90 eye applicators

All U.S. Nuclear Regulatory

Commission licensees

authorized to possess special

nuclear material in unsealed

quantities greater than a

critical mass

All U.S. Nuclear Regulatory

Commission licensees

All material licensees

K>-y

Attachment 3

IN 97-04

February 24, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information

Date of

Notice No.

Subject

Issuance

Issued to

97-03

97-02

97-01

96-72

96-71

Defacing of Labels to

Comply with 10 CFR

20.1904(b)

Cracks Found in Jet Pump

Riser Assembly Elbows at

Boiling Water Reactors

Improper Electrical Ground- ing Results in Simultaneous

Fires in the Control Room

and the Safe-Shutdown Equip- ment Room

Undetected Failure that

May Occur During Patient

Treatments with Teletherapy

Devices

Licensee Response to Indi- cations of Tampering, Van- dalism, or Malicious Mis- chief

02/20/97

02/06/97

01/08/97

12/24/96

12/27/96

All material licensees

involved with disposal

of medical waste

All holders of OLs

or CPs for boiling

water nuclear power

reactors models 3,

4, 5 and 6, except

those licenses that

have been amended to

possession-only

status

All holders of OLs

or CPs for nuclear

power reactors

All teletherapy

licensees

All holders of OLs

or CPs for nuclear

power reactors

OL = Operating License

CP = Construction Permit

IN 97-04 February 24, 1997 have been approved by EPA to show compliance with 40 CFR Part 61, Subpart I. Licensees

may also propose their own site-specific methods for showing compliance, subject to NRC

approval before use.

This information notice requires no specific action or written response. If you have any

questions about the information in this notice, please contact one of the technical contacts listed

below or the appropriate regional office.

Donald A. Cool, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical contacts:

Cynthia Jones, NMSS

(301) 415-7853 E-mail: cgj@nrc.gov

John Kinneman, RI

(610)337-5252 E-mail: jkd@nrc.gov

John Potter, Ril

(404) 331-5571 E-mail: jpp@nrc.gov

Brenda Holt, R1iI

(630) 829-9836 E-mail: bjh@nrc.gov

Linda Howell, RIV

(817) 860-8213 E-mail: llhenrc.gov

Attachments:

1. Federal Register Notice on the Constraint Rule

2. List of Recently Issued NMSS Information Notices

3. List of Recently Issued NRC Information Notices

Coordinated with: C. Jones

P. SobeVB. Nelson,DWM

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1122/97

1/23/97

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2/6/97

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OFFICIAL RECORD COPY

IN 97-XX

January XX, 1997 Coordinated with: C. Jones

P. Sobel/B. Nelson,DWMI

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IN 97-XX

January XX, 1997 have been approved by EPA to show

pliance with 40 CFR Part 61, Subpart I. Licensees

may also propose their own site- ific methods for showing compliance, subject to NRC

approval before use.

Donald A. Cool, Director

Division of Industrial and

Medical Nuclear Safety

Office of Nuclear Material Safety

and Safeguards

Technical Contacts:

Headquarters: Cynthia Jones

(301) 415-7853, cgjeJnrc.gov

Region I:

John Kinneman

(610) 337-5252, jkdinrc.gov

Region II:

John Potter

(404) 331-5571, jpp~nrc.gov

Region III:

Brenda Holt

(630) 829-9836, bjhenrc.gov

Region IV:

Linda Howell

(817) 860-8213, llhenrc.gov

Attachment:

Federal Register Notice on the Constraint Rule

Coordinated with: C. Jones

P. Sobel/B. Nelson,DWM

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