ML20045J193
| ML20045J193 | |
| Person / Time | |
|---|---|
| Issue date: | 04/26/1993 |
| From: | Klementowicz S Office of Nuclear Reactor Regulation |
| To: | Liza Cunningham Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9307230155 | |
| Download: ML20045J193 (3) | |
Text
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APR 2 61993 MEMORANDUM FOR:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Safety and Safeguards, NRR FROM:
Stephen P. Klementowicz, Health Physicist Radiation Protection Branch Division of Radiation Safety and Safeguards, NRR
SUBJECT:
MEETING REGARDING 10 CFR PART 20 On April 22, 1993, a public meeting was held with representatives of the Nuclear Management and Resources Council (NUMARC) to discuss their position on Appendix B to 10 CFR Part 20 as implemented in power reactor technical specifications (TS).
PARTICIPANTS:
NRC NUMARC BECHTEL F. Congel J. Schmitt T. Meisenheimer L. Cunningham R. Andersen R. Emch R. Bishop W. Reamer S. Klementowicz T. Tjader The meeting started with the representatives of NUMARC summarizing their position on the use of the Appendix B to 10 CFR Part 20 as implemented in reactor TS. A summary sheet listing their points was handed out (see Enclosure). NUMARC's position is that current reactor TS impose the concentrations in Appendix B to 10 CFR 20.1 - 20.602 as an instantaneous maximum for effluent concentrations. This TS is more restrictive than the requirements in the revised Part 20 and therefore, in accordance with 10 CFR 20.1008 must remain in force until there is a TS change through a license amendment. NUMARC maintains that power reactor licensees do not have to use Appendix B to 10 CFR 20.1001 - 20.2401 when they implement the new Part 20 since the TS is more restrictive than the new rule.
Power reactor TS should I
T(lt3 continue to use the old Appendix B concentrations as their release criteria.
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NUMARC maintains that this issue is not a public health and safety issue and 4
that requiring licensees to submit a TS amendment to use the new Appendix B values with a modifier, as some licensees have done, is a needless expenditure
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In reference to the forthcoming Generic Letter (GL) on TS for the new Part 20, the NRC discussed the intent of the GL. The intent is to provide licensees with standardized words, section number references, and revised bases that are in harmony with the new Part 20.
It is designed to maintain the same overall level of effluent control and operational flexibility that existed under the old Part 20 through the use of a modifier to the Appendix B values in the new Part 20.
NUMARC supports the continuing efforts of the NRC to issue the GL and does not view their position ca retention of the old Appendix B as being in conflict -
with the GL. NUMARC believes the guidance in the GL will benefit the industry and emphasized their support. However, they maintain that a TS amendment is-not required, when implementing the new Part 20, in order to keep the TS governed effluent release rates the same as under the old rule.
There was general agreement that regardless of which Appendix B is used, Lit is not a public health and safety issue. However, the NRC will need to further evaluate the issue from a technical perspective and then have it reviewed by the Office of General Council for compliance with the rule.
NUMARC was asked how long the old Part 20 should remain in effect in order for licensees to use the old Appendix B in their TS.
NUMARC responded that it should probably stay in effect until the regulations that use the "whole body" and " critical organ" dose methodology are changed to be consistent with the methodology used in the new Part 20.
NUMARC asked whether their position on Appendix B has merit and should be submitted to the NRC for formal review.
The NRC deferred judgement on the issue until it can evaluate the matter further.-
l The meeting closed with the understanding that the NRC would review the matter from a technical and regulatory compliance perspective and communicate their position to those in attendance.
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Stephen P. Klementowicz, Health Physicist Radiation Protection Branch Division of Radiation Safety and Safeguards, NRR
Enclosure:
as stated DISTRIBUTION:
Centralbfile. PE37e Met File, P137 PRPB R/F
.PDR, LL6 T. Murley,12D1 F. Miraglia, 12D7 F. Congel R. Emch W. Russell, 12E23 F. Gillespie, 12G18 J. Wigginton L. Cunningham D. Crutchfield, 11H21 S. KlementtNicz J. Partlow,-12G18 OFC PRPB:DRSS:NRJ)// PRPB:DRSS:SC PRPk:DESS/BC h
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NAME SKLEMENTOW REMCH DATE 04/2.3/93 04/1,3/93 04/h/93 OFFICIAL RECORD COPY
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ENCLOSURE
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p Part 50 License Radiological Emuent Technical Specifications
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and Revised 10 CFR Part 20 Implementation i
1.
The revised Part 20 ({ 20.1.008) requires that any technical specification that is more -
restrictive than a requirement in the revised Part 20 remains in force until there is a technical specification change through a license amendment.-
3 2.
The limit on radioactivity concentrations in effluents to unrestricted areas on an annual.
average basis, which is a requirement in the current Part 20 ({ 20.106), has been changed..
to an optional method of demonstrating compliance in the revised Part 20 ({ 20.1302) and is no longer a requirement after implementation of the revised Part 20.
3.
Part 50 license radiological effluent technical specifications require that:
(1) radioactivity in liquid effluents be limited to the maximum permissible.
l concentrations specified in the current Part 20 ( 20.106(e), Appendix B, Table II, Column 2) on an hourly average basis; (2) radioactivity in gaseous effluents be limited to the dose rate equivalent to the maximum permissible concentrations specified in the current Part 20 (Q 20.106(b),L y
Appendix B, Table II, Column 1) on an hourly average basis; and (3) radioactivity content in liquid holdup tanks be limited so that, in the event of i
an uncontrolled release of the tank's contents, the concentrations ~ f radioactivity o
at the nearest surface water supply in an unrestricted area (or nearest potable water supply in an unrestricted area) will not exceed the maximum permissible concentrations specified in the current'Part 20 (Appendix B, Table II, Column 2).
4.
The Part 50 license radiological effluent technical specifications, as referenced to Appendix B in the current Part 20, are more restrictive than the comparable requirements in the revised Part 20 because the applicable provision in the revised Part 20 (G 20.1302)
.j is not a requirement.
5.
In accordance with the implementation requirements of the revised Part 20 (Q 20.1008),.
the Part 50 license radiological effluent technical specifications, as referenced to-Appendix B in the current Part 20, remain in force until there is a change t'o the applicable l
technical specifications through a license amendment.
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