ML17159A898
| ML17159A898 | |
| Person / Time | |
|---|---|
| Issue date: | 06/22/1989 |
| From: | Liza Cunningham Office of Nuclear Reactor Regulation |
| To: | Ronald Bellamy, Dan Collins, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| FRN-56FR23360 AA38-2, AA38-2-0197, AA38-2-197, IEIN-81-26, NUDOCS 8907170375 | |
| Download: ML17159A898 (6) | |
Text
C G
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ger UNITED STATES NUCLEAR REGULATORY COMMISSION
'WASHINGTON, D. C. 20555
'NCLOSURE JQN 22 589 MEMORANDUM FOR:
Ronald R. Bellamy, Chief,
- EPRPB, DRSS, Region I Douglas M. Collins, Chief,
- EPRPB, DRSS, Region II L. Robert Greger, Chief,
- RPB, DRSS, Region III Blaine Murray, Chief,
- RPSB, DRSS, Region IV Gregory P.
Yuhas, Chief,
- EPRPB, DRSS, Region V
FROM'.
SUBJECT:
LeMoine J.
Cunningham, Chief Radiation Protection Branch Divisioi of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation CORRECTION OF MISUNDERSTANDING CONCERNING OCCUPATIONAL DOSE LIMITS FOR "EXTREMITIES" The purpose of this memorandum is twofold:
(1) t'o document the correction of a misunderstanding concerning occupational dose limits for "extremities," and (2) to provide guidance concerning potential enforcement action in cases in which licensees have incorporated this misunderstanding into their procedures.
10 CFR Fart 20 provides different occupational dose limits for (1) t¹ "whole body; head and trunsk; active blood-forming organs; lens of eyes; or gonads;"
(2) the "hands and forearms; feet and ankles";
and (3) the "skin of the whole body."
As indicated in the instructions for NRC Form 5, "Current Occupational External Radiation Exposure,"
the dose to the "hands ana forearms; feet and ankles" includes the dose to the skin of these body parts.
The dose to the skin is assessed at a depth of 7 mg/cm2 in tissue.
Thus, the limit for the "skin of the whole body" and the limit for the "whole body..." apply to all parts of the body
~exce t the "hands and forearms, feet and ankles."
The term "extremities" has often been used to designate the "hands and fore-arms; feet and ankles," although this term is not used in 10 CFR Part 20.
The term "extremities" is used in the pending major revision of 10 CFR Part 20 where it has the different meaning of "hand, elbow, arm below the elbow, foot,
- knee, and leg below the knee."
However, this revised definition should not be used until the effective date of the major revision.
CONTACT:
John D. Buchanan, NRR 492-1097
Yultiple Addressees A3 A SUK 22 1S89 the licensee corrects the procedure(s).
Enforcement action should be consid-ered for any licensee who, after being given a copy of this memorandum, refuses to correct a procedure that incorporates the misunderstanding of the dose limits of 1G CFR Part FO; however, please contact me before you initiate any such action.
This memorandum has been coordinated with the Office of Enforcement.
Le ne J.
unningham, ief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Multiple Addressees IE Information Notice No. 81-26, Part 3, Supplement No. 1, "Clarification of Placement of Personnel Honitoring Devices for External Radiation,"
was issued July 19, 1982.
That information notice discusses placement of personnel dosimeters for determining whole bod doses in situations where the principal source of radiation is from un er oo That information notice indicates, and our position continues to be, that, in these situations, "a reasonable placement for a whole body dosimeter would be just above the knee."
That information. notice also notes that "extremity monitoring requirements may dictate the placement of additional dosimeters in the feet and ankle area."
Information notices cannot impose or change regulatory requirements and Infor-.
matioi Notice No. 81-26, Part 3, Supplement 1 did not change the requirements of 10 CFR Section 20.101.
Nevertheless, some licensees and, in at least one
- instance, regional personnel have maintained, incorrectly, that Information Notice No. 81-26, Part 3, Supplement 1 defined or redefined the terms "extremity", or "extremities" to include the knee and the lower leg between the knee and the ankle and thereby extended the applicability of the 18.75 rem dose limit for the "extremities" to the lower leg above the ankle and to the knee.
Some licensees have chanoed their radiation protection procedures to <ncorpo-rate this misunderstanding and thereby to misrepresent the dose limits of 10 CFR Part PO.
This misunderstanding of the requirements of 10 CFR Part 20 has been identified primarily in relation to potential violations of the occupational dose limits resulting from radiation exposures from hot particles on or near the skin.
One example of this misunderstanding is the result of an informal survey taken by one licensee and reported to the NRC.
In that survey, ten nuclear power stations were contacted and asked, "If one of your personnel had been exposed to a hot particle in the region of the body between the middle of the knee and ankle, would you identify the dose as being to the skin of the whole body or to the extremity":"
Four stations responded, correctly, that they would record the dose as the skin of the whole body.
The other six statiors said they would record the dose as being to the "skin of the extremity", thus indicating their misunderstandings of both 10 CFR Part 20 and Information Notice No. 81-26, Par t 3, Supplement No.. 1.
In su+nary, for exposures of the knee and the lower leg above the ankle, the applicable occupational radiation dose limits of 10 CFR Section 20.101 are:
(1) the whole body dose limit of 1.25 rem per quarter or 3 rem per quarter, and (2) the skin of the whole body limit of 7.5 rem per quarter.
This memorandum is being placed in the NRC Public Document Room and I encourage you to make it available to licensees.
Licensees who have incorporated the misunderstanding concerning "extremity" doses into their procedures should be asked to correct those procedures;
- however, no enforcement action should be taken for such incorrect procedures if
5/18/89 - lp INDEX OPERATING REACTORS Licensee BWR Boston Edison Company GPU Nuclear Corporation Philadelphia Electric Company Power Authority of the State of New York Niagara Mohawk Power Corporation Northeast Nuclear Energy Company Vermont Yankee Nuclear Power Corporation Pennsylvania Power Light Company Philadelphia Electric Company
'I DN 50-293 Pilgrim 1
DN 50-219 Oyster Creek 1
DNs 50-277/50-278 Peach Bottom 2/3 DN 50-333 James A. FitzPatrick DNs 50-220/50-410 Nine Mile Point 1/2 DN 50-245 Millstone 1
DN 50-271 Vermont Yankee DN 50-387/50"388 Susquehanna 1/2 DN 50-352/50-353 Limerick 1/2
~P.
No.
7 20 21' s.
P No.
12 " 13 10 - 11 3-4 7-8 5" 6 14 -
15 38 " 39 40
Licensee PWR Ba 1.timore Gas and Electric Company Connecticut Yankee Atomic Power Co.
Consolidated Edi son Co. of New York Inc.
Power Authority of the State of New York Duquesne Light Company Maine Yankee Atomic Power Company General Public Utilities Nuclear Corporation General Public Utilities Nuclear Corporation Northeast Nuclear Energy Company Northeast Nuclear Energy Company Public Service Electric and Gas Company Rochester Gas 5 Electric Corporation Yankee Atomic Electric Company Long Island Lighting Co.
Public Service of
(
New Hampshire INDEX OPERATING REACTORS DNs 50"317/50-318 Calvert Cliffs 1/2 DN 50-213 Haddam Neck DN 50-247 Indian Point 2 DN 50-286 Indian Point 3
ONs 50-334/50-412 Beaver Valley 1/2 DN 50-309 Maine Yankee DN 50"289 TMI 1
DN 50"320 TMI 2 DN 50-336 Millstone 2 DN 50-423 Millstone 3 DN 50-272/50-311 Salem 1/2 ON 50-244 Ginna DN 50-29 Yankee Atomic DN 50"322 Shoreham DN 50-443 Seabrook 1
PcC.
No.
10 12 13 8
14 17 18 15 25 16 19 22 23 S s.
P
. No.
18 " 19 20 - 21 23 - 24 25 - 26 16 - 17 27 28 33 " 34 35 - 36 29 " 30 53 31 " 32 22 37 41 " 44 45 - 50
~Fact 1 <t BWR Hope Creek 1
INDEX CONSTRUCTION Docket 8 s
50-354 0
~Pa e
S s.
P No.
2 - 3