Information Notice 1997-34, Deficiencies in Licensee Submittals Regarding Terminology for Radiological Emergency Action Levels in Accordance with the New Part 20

Deficiencies in Licensee Submittals Regarding Terminology for Radiological Emergency Action Levels in Accordance with the New Part 20

ML031050574
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, Three Mile Island, 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
Issue date:	06/12/1997
From:	Slosson M Office of Nuclear Reactor Regulation
To:
References
IN-97-034, NUDOCS 9706090329
Download: ML031050574 (11)

UNITED STATES

NUCLEAR REGULATORY COMMISSION

OFFICE OF NUCLEAR REACTOR REGULATION

WASHINGTON, D.C. 20555-0001 June 12, 1997 NRC INFORMATION NOTICE 97-34: DEFICIENCIES IN LICENSEE SUBMITTALS

REGARDING TERMINOLOGY FOR

RADIOLOGICAL EMERGENCY ACTION LEVELS

IN ACCORDANCE WITH THE NEW PART 20

Addressees

All holders of operating licenses or construction permits for test and research reactors.

Puroose

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

addressees of the issuance of a revised Appendix I to NUREG-0849, "Standard Review Plan

for the Review and Evaluation of Emergency Plans for Research and Test Reactors." This

revised appendix provides guidance on incorporating the new 10 CFR Part 20 regulations

into the radiological emergency action levels (EALs). It is expected that recipients will review

the information for applicability to their facilities and consider actions, as appropriate.

However, suggestions contained in this information notice are not NRC requirements;

therefore, no specific action or written response is required.

Description of Circumstances

Part 20 was revised and the final rule was published in the FederalRegister on May 21,

1991 (56 FR 23360), with an original implementation date of January 1, 1993.

Subsequently, the implementation date was extended to January 1, 1994 (57 FR 38588). In

response to these regulations, many licensees of test and research reactors have submitted

to the NRC revised emergency plans that were intended to incorporate or reflect the

terminology introduced in the new regulations. Title 10 of the Code of Federal Regulations, Part 20 is referenced in the section of the emergency plan involving radiological EALs.

During its review of these submittals, the NRC staff noted that many licensees incorrectly

converted the wording of the EALs from the old terminology found in NUREG-0849. As an

example, (1) some licensees inappropriately converted "maximum permissible

concentrations" (MPCs) to "effluent concentrations" (ECs) and (2) some inaccurately used the

term "deep dose equivalent." Several licensees merely substituted the EC term for the MPC

term. Other licensees used various multipliers in an attempt to correct the differences

between the two values. Still other licensees replaced the MPC term with "derived air

concentration." These submittals indicate the need for additional guidance that could be

used to assist in updating EALs.

v52on ax? ,

IN 97-34 June 12, 1997 Discussion

If the errors in the revised EAL schemes are left uncorrected, they could potentially result in a

licensee taking some conservative actions that are unwarranted or in the licensee delaying

appropriate actions.

Guidance in the form of a revision to Appendix I to NUREG-0849 was issued in April 1997.

The revised appendix provides guidance on incorporating the current 10 CFR Part 20

regulations into the radiological EALs and, at the same time, corrects some omissions

in prior guidance and clarifies some other EALs for the implementation of the new

Part 20 regulations. Attachment 1 to this document is a copy of the revised Appendix I.

NUREG-0849, which was published in 1983, is available from the following sources:

• The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

20037 (202-634-3380). (Document may be copied for a fee, currently $0.08 per

page.)

• The Superintendent of Documents, U.S. Govemment Printing Office, P. 0. Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.

- The National Technical Information Service, Springfield, VA 22161-0002 (703-487-

4650), for a fee of $24.50 (paper) and $12.50 (microfiche), plus a $4.00 handling fee.

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

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

below or the appropriate regional office.

Marylee M. Slosson, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Lawrence K. Cohen

301-415-2923 E-mail: lkc@nrc.gov

Attachments:

1. Revised Appendix I of NUREG-0849

2. List of Recently Issued NRC information Notices

44AaJ p U

Attachment 1 IN 97-34 June 12, 1997 APPENDIX I

EMERGENCY CLASSES

ACTION LEVEL*

PURPOSE

Notification of Unusual Events INOUE)

Actual or projected radiological effluentt at the site * Ensure that the first step in any response later

boundary which is calculated (or measured) to result found to be necessary has been carried out.

In either of the following conditions, both of which

are based on an exposure of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less: * Bring the operating staff to a state of readiness.

(1) A deep dose equivalent of 0.15 milliSievert

(mSv) 115 mrem) * Provide systematic handling of unusual events

OR Information and decisionmaking.

(2) A committed effective dose equivalent of 0.15 mSv [15 mrem] based on the following

considerations:

• 100 EC x 24 hr* = 2.4 x 103 EC-hr m 0.15 mSv (15 mrem) (for radionuclides other

than noble gases)

3

• 50 EC x 24 hr = 1.2 x 10 EC-hr m 0.15 mSv [15 mrem](for noble gases)t

Report or observation of a severe natural

phenomenon affecting the reactor site

Receipt of bomb threat affecting the reactor facility

Fire within the reactor facility not extinguished within

15 minutes

Alert

Actual or projected radiological effluentt at the site * Ensure that emergency personnel are readily

boundary which Is calculated (or measured) to result available to respond If the situation becomes

in either of the following conditions, both of which more serious or to perform confirmatory

are based on an exposure of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less: radiation monitoring If required.

(1) A deep dose equivalent of 0.75 mSv [5mrem] * Provide current offsite authorities with status

OR information.

(2) A committed effective dose equivalent of 0.75 mSv 15 mrem) based on the following

considerations:

• 500 EC x 24 hr = 1.2 x 104 EC-hr - 0.75 mSv [75 mrem] (for radionuclides other

than noble gases)

• 250 EC x 24 hr"= 6 x 1 3 EC-hr m 0.75 mSv (75 mrem] (for noble gases)tt

Actual or projected radiation levelst at the site

boundary of 0.2 mSv/hr deep dose equivalent [20

mremlhr] for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or 1.0 mSv 1100 mrem] to the

thyroid (committed dose equivalent)

Attachment I

IN 97-34 June 12. 1997 APPENDIX I (cont'd)

-. - W%1 At;I 1IUN LtVtL- Irumrvo

Site Area Emernencv

Actual or projected radiological effluentt at the site * Ensure that response centers are manned.

boundary which is calculated (or measured) to result

in either of the following conditions both of which * Ensure that monitoring teams are dispatched.

are based on an exposure of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less:

• Ensure that personnel required for evacuation of

(1) A deep dose equivalent of 3.75 mSv [375 onsite areas are at duty stations.

mrem]

OR * Provide consultation with offsite authorities.

(2) A committed effective dose equivalent of 3.75 mSv [375 mrem] based on the following * Provide Information for the public through offske

considerations: authorities.

• 2500 EC x 24 hr = 6 x IV0 EC-hr m3.75 mSv 1375 mrem] (for radionuclides other

than noble gases)

• 1250 EC x 24 hr* = 3 x I10 EC-hr m 3.75 mSv 1375 mrem](for noble gases)"

Actual or projected radiation levelst at the site

boundary of 1.0 mSv/hr [100 mremlhr] deep dose

equivalent for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or 5.0 mSv [500 mrem] to the

thyroid (committed dose equivalent)

General Emergency

Sustained actual or projected radiation levelst at the * Initiate predetermined protective actions for the

site boundary of 5.0 mSv/hr [500 mremlhr] deep public.

dose equivalent

• Provide continuous assessment of Information

Actual or projected doset at the site boundary in the from licensee and offsite organization

plume exposure pathway of 10 mSv 11 rem] (total measurements.

effective dose equivalent) or 50 mSv 15 rem] to the

thyroid (committed dose equivalent) * Initiate additional measures as Indicated by

actual or potential releases.

• Provide consultation with offsite authorities.

• Provide updates for the public through offsite

authorities.

• The situation that may lead to an emergency class described in the subsections of Section 4.0 may be

referenced as emergency action levels appropriate to the emergency class.

t It is expected that licensees will determine the relationship of the EAL dose levels at the site boundary to

instrumentation readings andlor safety analyses accident conditions for their specific facilities.

Attachment I

IN 97-34 June 12, 1997 Effluent concentration (EC) as fisted In Title 10 of the Code of Federal Regulations, Part 20 (10 CFR Part 20),

Standards for the Protection Against Radiation,* Appendix B. Table 2. If the exposure time Is less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the EC multiplier can be increased proportionately, provided that the values of 2.4 x 103 and 1.2 x 10 3 EC-hr are

used to declare a NOUE; the proportional Increase for an alert is 5 and for a site area emergency it Is 25.

" Table 2 of Appendix B to 10 CFR Part 20 lists the concentration values that are equivalent to the radionuclide

concentrations which, if Inhaled or Ingested continuously over the course of a year, would produce a total effective

dose equivalent of 0.5 mSv [50 mrem]. However, for noble gases where the submersion (external dose) Is

limiting, the concentration values would produce a total effective dose equivalent of I mSv [100 mremJ.

Ki1_

Attachment 2 IN 97-34 June 12, 1997 LIST OF RECENTLY ISSUED

NRC INFORMATION NOTICES

Information Date of

Notice No. Subject Issuance Issued to

97-33 Unanticipated Effect 06/11/97 All holders of OLs or CPs

of Ventilation System for nuclear power reactors

on Tank Level Indica- tions and Engineering

Safety Features Actua- tion System Setpoint

95-36, Potential Problems 06/10/97 All holders of OLs or CPs

Supp. 1 with Post-Fire Emer- for nuclear power reactors

gency Lighting

97-32 Defective Worm Shaft 06/10/97 All holders of OLs or CPs

Clutch Gears in for nuclear power reactors

Limitorque Motor- Operated Valve

Actuators'

97-31 Failures of Reactor 06/03/97 All holders of OLs or CPs

Coolant Pump Thermal for pressurized-water

Barriers and Check reactor plants

Valves in Foreign

Plants

97-30 Control of Licensed 06/03/97 All material and fuel

Material During Reorgan- cycle licensees

izations, Employee- Management Disagreements, and Financial Crises

97-29 Containment Inspection 05/30/97 All holders of OLs or CPs

Rule for nuclear power reactors

OL = Operating License

CP = Construction Permit

IN 97-34

' June 12, 1997 Discussion

If the errors in the revised EAL schemes are left uncorrected, they could potentially result in a

licensee taking some conservative actions that are unwarranted or in the licensee delaying

appropriate actions.

Guidance in the form of a revision to Appendix I to NUREG-0849 was Issued in April 1997.

The revised appendix provides guidance on incorporating the current 10 CFR Part 20

regulations into the radiological EALs and, at the same time, corrects some omissions

in prior guidance and clarifies some other EALs for the implementation of the new

Part 20 regulations. Attachment 1 to this document is a copy of the revised Appendix I.

NUREG-0849, which was published in 1983, is available from the following sources:

• The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

20037 (202-634-3380). (Document may be copied for a fee, currently $0.08 per page.)

• The Superintendent of Documents, U.S. Government Printing Office, P. 0. Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.

• The National Technical Information Service, Springfield, VA 22161-0002 (703-487-4650),

for a fee of $24.50 (paper) and $12.50 (microfiche), plus a $4.00 handling fee.

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

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

below or the appropriate regional office.

original signed by S.H. Weiss for

Marylee M. Slosson, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Lawrence K. Cohen

(301) 415-2923 E-mail: Ikcenrc.gov

Attachments:

1. Revised Appendix I of NUREG-0849

2. List of Recently Issued NRC information Notices

DOCUMENT NAME: S:\DRPM SEC\RAD51 IN *SEE PREVIOUS CONCURRENCE

To receive a copy of ths document, hIdicate hI the box: C' - Copy wlo

attachmenVenclosure E - Copy w/attachment/enclosure AN- - No copy

OFFICE TECH CONI C:PERB:DRPM C:PECB:DRPM D: DRPM 6W

NAME LKCohen* CLMiller* AEChaffee* MMSlosscn I

DATE 05/20/97 05/22/97 05/30/97 0 //O/97 OFFICIAL RECORD COPY.

I,

IN 97- May , 1997 Discussion

If the errors in the revised EAL schemes are left uncorrected, they could potentially result in a

licensee taking some conservative actions that are unwarranted or in the licensee delaying

appropriate actions..

Guidance in the form of a revision to Appendix I to NUREG-0849 was issued in April 1997.

The revised appendix provides guidance on incorporating the current 10 CFR Part 20

regulations into the radiological EALs and, at the same time, corrects some omissions

in prior guidance and clarifies some other EALs for the implementation of the new

Part 20 regulations. Attachment 1 to this document is a copy of the revised Appendix I.

NUREG-0849, which was published in 1983, is available from the following sources:

• The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

20037 (202-634-3380). (Document may be copied for a fee, currently $0.08 per page.)

• The Superintendent of Documents, U.S. Govemment Printing Office, P. 0. Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.

• The National Technical Information Service, Springfield, VA 22161-0002 (703-487-4650),

for a fee of $24.50 (paper) and $12.50 (microfiche), plus a $4.00 handling fee.

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

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

below or the appropriate regional office.

Marylee M. Slosson, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Lawrence K. Cohen

(301) 415-2923 E-mail: lkc@nrc.gov

Attachments:

1. Revised Appendix I of NUREG-0849

2. List of Recently Issued NRC information Notices

DOCUMENT NAME: S:\DRPM SEC\RAD51 IN *SEE PREVIOUS CONCURRENCE

To receive a copy of this document. indcite inthe box: 'C- - Copy w/o

attachmentlenclosure E' - Copy w/attachmentlenclosure 'N' - No copy

OFFICE TECH CONT C:PERB:DRPM C:PECB:DRPM D:DRPM I

NAME LKCohen* CLMiller* AEChaffee blo, MlMS'lossonl

DATE 05/20/97 05/22/97 05/so/97 )5/ /97

0!

OFFICIAL RECORD COPY ,41brJ i41M I

IN 97- May , 1997 Discussion

If the errors in the revised EAL schemes are left uncorrected, they could potentially result in a

licensee taking some conservative actions that are unwarranted or in the licensee delaying

appropriate actions.

Guidance in the form of a revision to Appendix I to NUREG-0849 was issued on April 1997.

This revised appendix provides guidance on incorporating the current 10 CFR Part 20

regulations into the radiological EALs and, at the same time, corrects some omissions

in prior guidance and clarifies some other EALs for the implementation of the new

Part 20 regulations. Attachment I to this document is a copy of the revised Appendix I.

NUREG-0849, which was published in 1983, is available from the following sources:

• The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

20037 (202-634-3380). (Document may be copied for a fee, currently $0.08 per page.)

• The Superintendent of Documents, U.S. Govemment Printing Office, P. 0. Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.

• The National Technical Information Service, Springfield, VA 22161-0002 (703-487-4650),

for a fee of $24.50 (paper) and $12.50 (microfiche), plus a $4.00 handling fee.

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

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

below or the appropriate regional office.

Marylee M. Slosson, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Lawrence K. Cohen

(301) 415-2923 E-mail: lkc@nrc.gov

Attachments:

1. Revised Appendix I of NUREG-0849

2. List of Recently Issued NRC information Notices

DOCUMENT NAME: S:\DRPM SEC\RAD51 IN *SEE PREVIOUS CONCURRENCE

To receive a copy of this document. kidicate inthe box: * - Copy w/o

attachment/enclosure 'E' - Copy wlattachment/enclosure *N0 - No copy

OFFICE TECH CONT

NAMELKC ohen*

C:PERB:DRPM

ICLMiller*

C:PECB:DRPM

AEChaffee

D:DRPM

MMSosson

H

DATE

.FFICALREOR /20/97 COYe

05/22/97 05/ /97 05/ /97

IN 97- May, 1997 Discussion

If the errors in the revised EAL schemes are left uncorrected, they could potentially result in a

licensee taking some conservative actions that are unwarranted or in the licensee delaying

appropriate actions.

Guidance in the form of a revision to Appendix I to NUREG-0849 was issued on April 1997.

This revised appendix provides guidance on incorporating the current 10 CFR Part 20

regulations into the radiological EALs and, at the same time, corrects some omissions

in prior guidance and clarifies some other EALs for the implementation of the new

Part 20 regulations. Attachment 1 to this document is a copy of the revised Appendix I.

NUREG-0849, which was published in 1983, is available from the following sources:

• The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

20037 (202-634-3380). (Document may be copied for a fee, currently $0.08 per page.)

• The Superintendent of Documents, U.S. Government Printing Office, P. 0. Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.

• The National Technical Information Service, Springfield, VA 22161-0002 (703-487-4650),

for a fee of $24.50 (paper) and $12.50 (microfiche), plus a $4.00 handling fee.

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

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

below or the appropriate regional office.

Marylee M. Slosson, Acting Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Lawrence K. Cohen

(301) 415-2923 E-mail: lkcenrc.gov

Attachments:

1. Revised Appendix I of NUREG-0849

2. List of Recently Issued NRC information Notices

DOCUMENT NAME: S:\DRPM SEC\RAD51 IN

To receive

• copy Of this document. hndIcite In the box: C*'- Copy w/o

attachment/enclosure 'E' - Copy wlattachmentlenclosure 'N' - No copy

OFFICE TECH CONT C:PERB:DRPM C:PECB:DRPM D:DRPM

INAME LKCohens..t CLMiller (Lb, 1AEChaffee I MMS1osson I I

DATE 0/24/97 9&zV97 /97 97 OFFICIAL RECORD COPY S. -, A

' ' FIN 97- May , 1997 Discussion

If the errors in the revised EAL schemes are left uncorrected, they could potentially result in a

licensee taking some conservative actions that are unwarranted or in the licensee delaying

appropriate actions.

Guidance in the form of a revision to Appendix I to NUREG-0849 was issued on April 1997.

This revised appendix provides guidance on incorporating the current 10 CFR Part 20

regulations into the radiological EALs and, at the same time, corrects some omissions

in prior guidance and clarifies some other EALs for the implementation of the new

Part 20 regulations. Attachment 1 to this document is a copy of the revised Appendix I.

NUREG-0849, which was published in 1983, is available from the following sources:

• The NRC Public Document Room, 2120 L Street, NW., Lower Level, Washington, DC

20037 (202-634-3380). (Document may be copied for a fee, currently $0.08 per page.)

• The Superintendent of Documents, U.S. Govemment Printing Office, P. 0. Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.

• The National Technical Information Service, Springfield, VA 22161-0002 (703-487-4650),

for a fee of $24.50 (paper) and $12.50 (microfiche), plus a $4.00 handling fee.

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

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

below or the appropriate regional office.

Marylee M. Slosson, Director

Division of Reactor Program Management

Office of Nuclear Reactor Regulation

Technical contact: Lawrence K. Cohen

(301) 415-2923 E-mail: lkc@nrc.gov

Attachments:

1. Revised Appendix I of NUREG-0849

2. List of Recently Issued NRC information Notices

DOCUMENT NAME: S:\DRPM SEC\RAD51 IN

To receive a copy of this document. hIdfice hI the box: ACT - Copy w/o

attachmentlenclosure 'E' - Copy w/attachmentlenclosure 'N - No copy

OFFICE TECH CONT C:PERB:DRPM C:PECB:DRPM D:DRPM

NAME LKCohen %4V CLMiller AEChaffee MMSlosson

DATE 06711/97 04/ /97 04/ /97 04/ /97 OFFICIAL RECORD COPY