ML20009C459
| ML20009C459 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 06/29/1981 |
| From: | Crow W, Ketzlach N NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | |
| Shared Package | |
| ML20009C457 | List: |
| References | |
| NUDOCS 8107210091 | |
| Download: ML20009C459 (22) | |
Text
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DOCKET NO:
70-1100 WTCros
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IE HQ (2)
APPLICANT:
Combustion Engineering, Inc.
PErickson JRobertson
. FACILITY:
Windsor, Connecticut HWerner JRoth. R:I PRRosenthal,'
SUBJECT:
REVIEW 0F AMENDMENT APPLICATION DATED NOVEP3ER 10,1980 CE
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AND ITS REVISIONS DATED APRIL.10, AND MAY 1,1981 I.
Eackgraund Cc sustior. Engineering, Inc. (CE), by application dated November 10, 1980 its revisions dated April 10, and May 1,1981, requested authorization as.a to possess and repackage uranium and thorium wastes and contaminated soil located on its property.
The materials, consisting of residues from burning scrap metal containing alloys of zirconium, thorium and uranium (all enrichments), were generated as part of a fonner U.S. Navy program.
The material has been in place for at least 20 years.
There' are approximately 167, 55-gallon, drums containing this material and an estimated 1,100 cubic feet of loose material on the ground. There appears to be no uranium in the loose material on the ground. The drums containing the materials are in very poor condition.
Many of the drums have sections that have corroded away.
All the materials wil1 have to be repackaged.
.CE plans'to ship the material: to a commercial burial facility.
After the contaminated soil has been removed, CF will survey the grounds to determine whether criteria have been met te release the land for u,re-3 stricted use.
The land will remain as a restricted area until the flRC l
perfonns a confirmatory survey and authorizes the release of -he land.
i Aq i,in qpp/icsh~ sqwseded
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Discussion A.
Radiological Safety The materials involved in the repackaging operation are mainly alpha emitters, some being in a dispersible form.
The potential exposure to the worker during the operation would be from inhaling airborne particulate radioactivity generated during the repackaging opera tion.
To minimite the worker exposure, a hopper loading unit is provided fot transferring the waste into new drums which are H
placed under the downspout of the hopper.
The filled drums will a
be covered and transferred to a storage pad.
The airborne radio-activity concentration in the workino area will be continuourly
................ npni to red by a personnel sanpler and by ay?"specified in"10 CFR"20~.-
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air monitor with the
"'c 4 actior, level s et-at-25 percent"of-MPC"leve
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2 JUN 2 a 1991 Upon reactiing this limit, all work will be stopped, and a study made to determine the corrective action needed to prevent the air concentration from exceeding the MPC limit.
In addition to the foregoing, the operation will be conducted in accordance with written procedures.
The controls used to ensure radiation safety and adherence to ALARA principles in this operation are the same as those specified in the existing license. These controls will include the following essential elements:
1.
The area involved will be categorized a restricted area to allow access by essential personnel only.
2.
The storage area will be routinely surveyed to detect any potential surface contamination.
The clean up action levels used will be for a
" clean area."
3.
h ' kensee will provide personnel with protective clothing, shoe covers, and gloves to reduce the personal contamination. All personnel, prior to leaving the area, will be surveyed for radioactivity to control personal contamination.
Based on the above discussion and analysis, it is concluded.
that the radiation protection provided in the proposed operation is adequate.
8.
Environmental Effects The soil in the waste material staging area is contaminated with uranium and thorium.
It is recommended the licensee submit a detailed decontamination plan within 60 days of the date of the amendment for the decontamination ~ of the soil for unrestricted use in accordance with the attached criteria.
j C.
Nuclear Criticality Safety The 235U enrichments, based on analyses already made, vary from 1.0% to 82.7%.
Based on the licensee's conservative assumption l
for the density of the materials (1.5 g/cm ), the maximum content 3
of 23s0 in a drum would be 67.0 g.
For alinfinite array of drums (stacked two high) the mass / unit with a maximum of 67 g 23sU/ drum is 48.5 g 23sU/ square fee t.
Based on an earlier b-
JUN 2 9 i391 studyl, an infinite array of crums stacked two high would be safe even if the 23s0 content / drum were three timas as great (200 g/ drum) independent of the degree of water moderation or reflection.
The licensee did not correct his method for estimating the cont'ertsf each drum, as requested. The licensee's contractor submitted the results of his analyses of samples taken from the wastes as ppm uranium.
The licensee assumed the concentration was expressed on a volume basis.
However, ppm was expressed on a mass bhsis.
Since the licensee stated the grams of 23sU/ drum will be made "using the method outlined in Attachment B-11," (on page 27 of the application),
a license condition should be added to require the calculated 2asU content of each drum to be based on the ppm U (determined by analysis) on a mass basis.
At the present time, the licensee is only authorized to possess uranium enriched to less than 20% 235U, excluding the small quantities of highly enriched uranium present as sealed neutron sources. Although c estimates the l
total uranium content of the fue'i to be approximately 2.1, kg of variable enrichments <93% 23sU, authcrization is requested for possession of 4.0 kg total uranium to l
include a possible error of approximately 100%.
There is no nuclear criticality safety related problem for granting the request.
The licensee is presently authorized to possess 10,500 kg of source material, which is more than adequate to include t?.e 10 kg thorium estimated to t,e in l
the waste.
l D.
General I
The amendment application was discussed with Mr. Jerome Roth, Region I (IE) Inspector of the CE facility,on June 15, 1981.
He foresaw no safety related problem with authorization to repackage tie uranium and thorium wastes und contaminated soil.
IR. L. Stevenson and R. H. Odegaarden, " Studies of Surface Density Spacirg Criteria Using KENO Calculations," Trans. Am. Nucl. Soc. 12, 891 (1969).
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4 JUN 2 91981 III. Conclusion The controls described in the revised license amendment application are adequate for the orotection of the health and safety of the operating personnel, the public a1d the environment.
Issuance of the license ameiAcit is recomended subject to the following conditions:
Condition 29. Notwithstanding the request to calculate the quantity of 2350 in each drum "using the method outlined in Attachment B-ll," the uranium content shall be calculated from its ppm content expressed on a total uranium F
mass basis.
Condition 30. Within 60 days of the issuance _of this amendment, the licensee shall submit a detailed plan for i
the decontamination of the soil in the waste f
material staging area identified in your revised i
application dated May 1,1981 in accordance I
with the attached criteria.
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Norman Ketzlach Uranium Process Licensing Section Uranium Fuel Licensing Branch l
Division of Fuel Cycle and i
Material Safety Approved by:
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W. T. Crow, Section Leader a
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APPENDIX INTERIM S0IL DEC0tiTAMINATION CP,ITERIA PROPOSED FOR LAND CLEAN-UP ACTION AT THE COMBUSTION ENGINEERING, INC. (CE)
SITE AT WINDSOR, CONNECTICUT o
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Interim Soil Decontamination Criteria for Land Clean-Up Action at the CE
. Windsor, Connecticut Site I.
Background
By letter dated tiovember 10, 1980, Combustion Engineering, Inc. (CE) requested authorization to possess and repackage uranium and thorium wastes and contaminated soil located on its property at Windsor, Connecticut.
The materials, consisting of residues from burning scrap metal containing alloys of. zirconium, thorium and uranium (all enrich-ments), were generated as part of a. former U.S. flavy program.
The material has been in place for at least 20 years.
There are about 167, 55-gallon drums of this material ord an estimated 1,100 cubic feet of loose material on the ground.
The drums containing 3
i the materials are in very poor condition.
Many of the drums have sections that have corroded away.
All the materials will have to be i
repackaged. Any land that had been contaminated will have to be cleaned up so that after decontamination to this acceptabic criteria, j-the land can be released for unrestricted use.
II.
Proposed Target Criteria for Soil Decontamination A.
Objectives and Rationale of the Proposed Criteria l
The objectives of the cleanup criteria are to return the land to i
unrestricted use for any purpose whatsoever without any restrictions, l
control.
In establishing the target criteria for the'immediate l
soil cleanup, the staff applies the following rationale and objectives:
(1) The radiation exposure to an individual using the l
land must be within current radiation exposure guidelines, including the requirement that these exposures be as low as reasonably achievable.
(2) These criteria must be consistent with criteria currently being applied or developed for similar j
type situations.
1.
B.
Proposed Target Criteria for Soil Decontamination Based on the results of the licensee's preliminary radiological surveillance and the nature of the contaminated soil, the staff set target crite'ria, as listed in Table 1, for the cleanup of the L
contaminated land.
Table 1 also lists other existing criteria or guidance for comparison.
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2 C. ' Demonstration of Compliance with the Proposed Target Criteria 1.
External Radiation The direct radiation dose rate can be measured with instruments after the decontamination operation to demonstrate compliance with-the external radiation criteria.
For convenience and recording purposes, the affected area should be divided into -
grids about 30' x 30'.
In order to meet the target criteria,
'the following conditions have to be met:
' External radiation (gamma dose rate in air one meter a?]ve ground level) not to exceed 10 pr/hr (not including background) for a diffuse source area (a contaminated area greater than 30' x 30').
and not to exceed 20 pr/hr -(not including back-ground) for a discrete area (a contaminated area smaller than 30' x 30').
Therefore, it is recommended that the licensee should evaluate the natural background radiation level for the site.
In addition, the licensee shoub work with the NRC Regional Inspector to obtain agreement on instrument calibration for di ect radiation measurement at an early stage since a close-out-surveillance will be conducted by NRC's Inspection and Enforce-ment Division prior to the release of the land for unrestricted use.
2.
Inhalation of Particulates The individual dose received from inhal6 tion of resuspended particulates from soil is dependent on the solubility of radionuclides in.soi~ and its particle sizes.
Tables 2-4 sumnarize the dose commitment resulting from inhalation of rescapended radionuclides from contaminated soil.
Tables 2-4 are based on an unit concentration, 1 pCi/g of each radionuclide in the soil.
The solubility of radionuclides is classified as Y, W and D compounds in accordance with the 'ICRP Task Group report on Lung Dynamics.1 Tables 5-7 t
I list the dose conversion factors (DCF) derived from the Task Group Model.1,2 The resuspended particles are assumed to have an-AMAD (activity median aerodynamic diameter) of 1 pm.
The dry density of soil is assumed to be 2.5 g/cm3 The resuspension factor is assumed to be 5 x 10-9 m
, in agreement with the approach taken by EPA in their proposed decontamination criteria for transuranium nuclidet in soil.3 i
i For compliance with the proposed criteria for the inhalation pathway, the licensee should determine the solubility class-ification of the identified nuclides in soil. After decon-tamination, representative surface soil samples shall. be callected and analyzed to determine the average concentration of radionuclides in the soil.
Isotopic analysis of the soil Y
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will lui required unless the licensee can demonstrate that other analysis, such as direct gamma or gross-alpha and j
' beta measurement can be.used to substitute isotopic analysis.
.The licensee is required to submit a detailed plan to, describe and demonstrate how to comply with the above criteria-The adequacy of the-plan will be reviewed by NRC.
During the close-out surveillance, split samples collected shall be provided -to NRC for confirmatory analysis.
3.
Ingestion of Radionuclides From the preliminary.results on water leach test submitted by. the licensee, one soil sample (out of seven samples tested) showed some leaching of alpha and beta radioactivity from soil.
Therefore, the staff has to consider potential i
ingestion pathways.
For the ingestion pathway, the staff conservatively assumes that all the food is grown or pro-L duced on the contaminated land.
Table 8 summarizes the dose _ comnitment from ingestion of beef, milk and vegetable crops contaminated via resuspension or by root uptake.
Figures are based on a unit concentration of 1 pCi/g of each radionuclide in the soil.
For compliance with the proposed criteria for the ingestion pathway, representative soil samples shall be collected and l
analyzed as described in Section C-2.
I 2
III.
Conclusion Preliminary results from the licensee's soil analysis indicate the' presence of thorium and its daughters and enriched uranium.
The licensee's water leach test on soil samples collected showed some i-degree of leaching; however, most of radioactive materials are expected to be in insoluble form.
If this is the case, the direct 1
i radiation and inhalation pathways are the critical pathway for dose to man.
Confirmatory analysis by NRC should provide verification 4
of the licensee's soil analysis.
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Table 1
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Proposed Criteria for Soil Dacontamination at the CE Site
~
Exposure Target Other Existing Pathway Criteria Criteria or Guidance External Radiation 10 pr/hr 20 pr/hr indoor (b) EPA (whole body)
(35 mrem /yr)(a) interim cleanup standard for Inactive Uranium Processing Site, 500 mrem /yr-10 CFR 20, 170 mrem /yr-FRC Guidance, 400-900 mrem /yr-Surgeon General's Guidance, 25 mrem /yr-40 CFR 190 Inhalation of Particulates 1 mrad /yr or 1500 mrem /yr-10 CFR 20 (lung, bone) 10 mrem /yrld) 25 mrem /yr-40 CFR 190 1 mrad /y -
Guidance {cjPATransuranic Food Ingestion 3 mrad /yr 9r 3000 mrem /yr-10 CFR 20 (bone) 30 mrem /yrid) 25 mrem /yr-40 CFR 190 3 mrad /yr-EPA Transuranic Guidance (c) l l
(a) This value does nat includt background; the 35 mrem /yr includes shielding factor of 0.5 for general population anc residence time 80 percent.
(b) 40 CFR Part 192 - Federal R2gister, Vol 45, fio. 79, April 22,1980 (c) Proposed criteria (d) Based on a quality factor of 10 for alpha particles
- - - _ - _ _ ~ _ - _ _ _ _ - - _ _. - - _ _ _. - _ - _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -.. - -. _ _ _ -
Table 2 Dose Conmitments Resulting from Inhalation of Resuspended Radionuclides from Contaminated Soil.
Figures Based on a Unit Concentration of 1 pCi/g of Each f uclide in the Soil (Clearance Rate Class Y, Particle Size (AMAD) = 1 pm)
Radionuclide Dose (millirem per year)
Lung Bone U-238 2.8E-l*
2.6E-3 U-235 3.lE-1 2.8E-3 U-234 3.2E-1 2.9E-3 Th-232 3.8E-1 6.8E-1 Ra-228 8.lE-1 5.9E-2 Th-228 9.6E-1 6.5E-2
- 2.8E-1 = 2.8 x 10-l 1
I Note:
It is assumed that the first centimeter of surface soil is subject to resuspension.3 i
Erample:
0-238 (Y compound) 1 pCi (soil conc) x 10-6 pCi x 2.5_g (soil density) x 1 cm (surface soil) x 104 2
cm pCi cm3 1 m4 x 5 x 10-9 1/m (resuspension factor) x 7300 m3/yr (breathing rate) x 80% (percent of occupancy) x 390 x 103 mrem /pCi = 0.28 mrem /yr h-
.. =
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~ Table 3 Dose Comitments Resulting from Inhalation of Resuspended-Radionuclides from Contaminated Soil. -Figures Based on a-U it Concentration of 1 pCi/g of Each Nuclide in the Soil (Clearance Rate Class W, Particle Size (AMAD) = 1 pm)
Radionuclide Dose (millirem per year)
Lung Bone U-238 2.9E-2 6.7E-3 U-235~
3.lE-2 7.0E-3 U-234 3.3E-2
-7.3E-3 i
Th-232 2.8E-2 1.8E-0 I
Ra-228 1.5E-2 8.lE-2 Th-228 1.4E-1 4.0E-1 I
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Table 4 Dose Commitments Resulting from Inhalation or Resuspended Radionuclides from Contaminated Soil.
Figures Based on a Unit Concentration of 1 pCi/g of Each Nuclide in the Soil (Clearance Rate Class D, Particle Size ( AMAD) = 1 pm)
Radionuclide Dose (millirem per year)
Lung Bone U-238 5.1E-4 2.6E-2 U-235 5.lE-4 2.6E-2 U-234 5.1E-4 2.8E-2 l
to
Table 5 L'
Dose Conversion Factors from Inhalation of Radionuclides (Clearance Rate Class Y, Particle Size AMAD = 1 um Radionuclides Dose Conversion Factors (Rem /uCi-Inhaled).
I Lung Bone
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(1-238 3.9E+2 3.6E-0 U-235 4.2E+2 3.8E-0 U-234 4.5E+2 3.9E-0 Th-232 5.2E+2 9.3E+2 Ra-228 1.lE+3 8.lE+1 Th-228 1.3E+3 8.9E+1 1
The dose converslon factors are derived based on the.ICRP Task Group Lung Dynamics and computer code "DACRIN" developed by Battelle Pacific Northwest Laboratories.2 i
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Table 6 Dose Conversion Factors from Inhalation of Radionuclides (Clearance Rate W, Particle Size AMAD = 1 pm)
Radionuclides Dose Conversion Factors (Rem /uCi Inhaled)
Lung Bone U-230 4.0E+1 9.2E-0 c
d-235 4.2E+1 9.6E-0 '
U-234 4.ci+1 1.0E+1 Th-232 t+-
2.5E+3 Ra-228
- 2. ' t-1.lE+2 Th-228
- 1. 9E r2 5.5E+2 9
Table 7 Dose Conversion Fac'. ors from Inhalation of Radionuclides (Clearance Rate D, Particle Size AMAD = 1 um)
Radionuclides Dose Conversion Facto's (Rem /uCi Inhaled) r Lung Bone U-238 0.7 35 U-235 0.7 36 U-234 0.7 38 Th-232 (a)
(a)
Ra-228 (a)
(a)
Th-228 (a)
(a)
(a)
ICRP-30 classifies thorium compounds as Y and W types.4
)
1
Table 8 Dose Commitment Resulting from Ingestion (Vegetation, Beef, Milk) of Radionuclide from Contaminated Soil.
Figures Based on a Unit Concen-tration of 1 pCi/g of Each fluclide in the Soil (the First 15 cm of Soil)
Id)
Radionuclides Bone Dose (mrem /yr)
U-238 1.9E-0 U-235 1.9E-0 U-234 2.2E-0 Th-232 2.lE-0 Ra-228 4.5E-0 Tn-228 4.0E-1 (a) The following sections provide detailed irgestion dose calculations.
w
r Dose Calculations for Ingestion Patn'way 1.
Ingestion dose frora vegetable intake -
l Root uptake 1 x 10-6 pCi/g (conc. in soil) x Cf (see Table 9) x 1.94 x 10 g/y. (veg. intake) 5 x dose conversion factor (rem /pci; see Table 10) x 1 x 103 millirem / rem
= 50 yr. dose commitment (millirem).
Resuspension 1 x 10-6 pCi/g x 2.50 x 10 g of soil /m 4
2 x 5 x 10-9
-l (rosuspension m
factor) x 10-2 m/sec (deposition factor) x 3.15 x 107 sec/yr x pCi/ day Ci/m4-day p
(Tele 11) x Jose conversion factor (rem /pCi) x 1 x 103 (millirem / rem)
= dose 2.
Ingestion dose from meat intake -
Root uptake 1 x 10-6 pCi/g x C (pasture grass; Table 9) x 1 x 10 g/ day (grass eaten) 4 (F ; Table 12) x 94 kg/ year (meat intake) x dCF (rem /pCi) x 1 X 103 x d/k3 f
(mil.lirem/ rem) = dose Resuspension 1 x 10-6 Ci/g x 2.50 x 10 g of soil /m 4
2 x 5 x 10-9
-l (resuspension m
factor) x 10-2 m/sec (deposition factor) x 3.15 x 107 sec/yr x uCi/ day x dCF (rem /pCi) x 103 (millirem /ren) = dose
~
3.
Ingestion dose from milk intate -
Root uptake 4
1 x 10-6 ud/g x Cf (Table 9) x 1.0 x 10 g/ day (grass intake) x d/1 (F ; Table 12) x 0.31 1/d of milk x 365 x dCF (rem /pCi; Table 10) g x 103 (millirem / rem) = dose Resuspc.nsio_n_
4 2
-9
-l (resuspension 1 x 10-6 pCi/g x 2.50 x 10 g of soil /m x 5 x 10 m
7 factor) x 10-2 m/sec (deposition factor) x 3.15 x 10 sec/yr x pCi/ gay x dCF (rcm/pCi) x 103 (millirem / rem) = dose e
W e.
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Table 9 The plant / soil bioacc,umulation f, actors (B 1
$V3 er concentration factor (C ) soil plant f
Radionuclide Concentration factor (C l Concentration factor (C,)D Pasture grass (Bjy)]"f Edible Produce (Bj y l' g
U-234 8.5E-3 2.9E-4 U-235 8.5E-3 2.9E-4 0-238 8.5E-3 2.9E-4 Th-232 2.7E-3 3.5E-4 1
l Ra-228 9.7E-2 3.lE-4 Th-228 2.7E-3 3.5E-4 Ref. - AIRD0% - EPA 520/1 0097 bRef. - C taken from f4RC Regulatory Guide 1.1096 f
Table 10 Dose conversion factors (rem /uCi)a Radionuclide Bone U-234
- 2. 0E+1 U-235
- 1. 8E+1 U-238
- 1. 8E+1 Th-232 1.8E+1 Ra-228
Table 11.
Radionuclide intake rates [uCi/ day )
(pCi/ day-m' s
Radionuclide Above Surface Milk Beef food U-234 1.20 0.08 0.023 U-235 1.20 0.08 0.023 U-238,
1.20 0.08 0.023 Th-232 1.20 0.002 0.030 Ra-228 1.20 2.370 2.440 Th-228 1.10
<10-3 0.01 0 Ref. - ORiiL-4992, Table 2-8e i
Table 12 a
Estimates of transfer coefficients for milk and meat
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I I
Radionuclide (day /liteh)
Milk (F Meat (F )
f
)
day /kg U-234.
5.0E-4 3.4E-4 U-235 5.0E-4 3.4E-4 U-238 5.0E-4 3.4E-4 Th-232 5.0E-6 2.0E-4 Ra-2?8 5.9E-4 5.lE-4 Th-228 5.0E-6 2.0E-4 i
aRef. - NRC Regulatory Guide 1.109 and NRC Task RH 802-49 o
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References 1.
Task Group of Committee 2, ICRP, Task Group on Lung Dynamics for Committee II of the_ICRP, Health Physics, Vol. 12, 1966.
2.
J. R. Houston,.D. L. Strengh, and E. C. Watson, DACRIN - A Computer Program j
for Calculating. Organ Dose from Acute or Chronic-Radionuclides Inhalation, BNWL-B-389, Battelle Pacific Northwest Laboratories, Richland,- Washington c
1975.
3.
Persons Exposed.to Transuranic Elements in the Environment - Federal Radiation Protection Guidance on Dose Limits - Federal Register, Vol. 42, No. 230, Wednesday, hovember 30, 1977.
4.
International Comission on Radiological Protection Publication 30 -
Pergamon Press, July 1978.
5.
AIRDOS-EPA: A Computerized Methodology for Estimating Environmental Concentrations and Dose to Man for Airborne Releases of radionuclides, EPA 520/~e-79-009, December 1979.
6.
NRC Regulatory Guide 1.109 - Casculations of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I, March 1976.
7.
NUREG/CR-0150, Vol. I and II, Estimates of Internal Dose Equivalent to 22 Target Organs for Radionuclides Occurring in Routine Releases from Nuclear Fuel Cycle Facilities,1979.
8.
A Methodology for Calculating Radiation Dose from Radioactivity Released to the Environment, ORNL-4992, March 1976.
I 9.
NRC Task RH 802 Calculational Models for Estimating Radiation Doses to Man from Air borne Radioactive Materiais Resulting from Uranium Milling Opera'tions.
i 4
9 C'
.