ML18087A167
| ML18087A167 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2018 |
| From: | Office of Nuclear Regulatory Research |
| To: | |
| Karagiannis H | |
| Shared Package | |
| ML18087A159 | List: |
| References | |
| DG-4019 RG-4.013, Rev. 2 | |
| Download: ML18087A167 (2) | |
Text
1 REGULATORY ANALYSIS DRAFT REGULATORY GUIDE (DG-4019)
ENVIRONMENTAL DOSIMETRYPERFORMANCE SPECIFICATIONS, TESTING, AND DATA ANALYSIS (Proposed Revision 2 of Regulatory Guide 4.13, dated July 1977)
- 1.
Statement of the Problem The U.S. Nuclear Regulatory Commission (NRC) is considering a Revision 2 to Regulatory Guide (RG) 4.13, Performance, Testing, and Procedural Specifications For Thermoluminescence Dosimetry: Environmental Applications.
Revision 1 to RG 4.13 (1977) endorses American National Standards Institute (ANSI)
N545-1975, Performance, Testing, and Procedural Specifications for Thermoluminescence Dosimetry (Environmental Applications). ANSI standard N545-1975 has been replaced by American National Standards Institute/Health Physics Society (ANSI/HPS) N13.37-2014, Environmental DosimetryCriteria for System Design and Implementation, which provides improved environmental dosimetry system design criteria and dosimeter laboratory test protocols, as well as methods of data analysis suitable to assess potential facility-related radiation doses.
The staff is considering changing the title of the guide to more clearly indicate the content of standard ANSI/HPS N13.37-2014, which includes data analysis, and to broaden its scope by including different types of dosimetry. The title of Revision 1 was limited to thermoluminescence dosimetry.
- 2.
Objective The objective of this regulatory action is to revise the RG to endorse ANSI/HPS N13.37-2014, which provides environmental dosimeter performance specifications, testing criteria and data analysis methods for passive environmental dosimetry systems, such as thermoluminescence Dosimeters (TLD). The data analysis methods described in the standard may be used for determining the facility-related dose (FRD) from direct radiation to individual members of the public present in both the unrestricted area and the controlled area of a licensed facility.
- 3.
Alternative Approaches The NRC staff considered the following alternative approaches:
- 1.
Do not revise RG 4.13 Revision 1;
- 2.
Withdraw RG 4.13 Revision 1; and
- 3.
Revise RG 4.13 Revision 1.
Alternative 1: Do not Revise Regulatory Guide 4.13 Under this alternative, the NRC would not revise RG 4.13. If the NRC does not take action to revise RG 4.13, licensees would use the guidance in Revision 1. Operating experience
2 has shown that the dosimetry performance specifications in Revision 1 are difficult to meet and unnecessarily burdensome.
Alternative 2: Withdraw Regulatory Guide 4.13 Under this alternative, the NRC would withdraw RG 4.13. This alternative would eliminate the staffs guidance regarding monitoring and data analysis, which would leave licensees without guidance. The NRC staff then would review licensee applications on a case-by-case basis, which would take additional time for the staff and licensees reviewing and approving other methodologies in order to comply with the regulations.
Alternative 3: Revise Regulatory Guide 4.13 Under this alternative, the NRC staff will issue a new revision, Revision 2 to RG 4.13.
Revision 2 would endorse (without exception) ANSI/HPS N13.37-2014 as an acceptable method for conducting an environmental dosimetry program. This alternative provides the most up-to-date staff positions for applicants and licensees.
- 4.
Conclusion Based on this regulatory analysis, the NRC staff concludes that a revision of RG 4.13 (Alternative 3) is warranted. The proposed action will provide the latest staff positions to licensees regarding monitoring of direct radiation from licensed facilities into both the unrestricted area and the controlled area of a licensed facility.