ML20094P198

Implications of Proposed 10CFR20 Changes Upon Radiation Protection Dept at Clinton Power Station

ML20094P198
Person / Time
Site:	Clinton
Issue date:	06/09/1989
From:	WADMAN & ASSOCIATES
To:
Shared Package
ML19346A656	List: AECM-86-0118, Comment on Proposed Rules 10CFR2,19,20,30,31,32,34,35,39,40, 50,61 & 70 Re Stds for Protection Against Radiation ML20094P198 ML20095C041 ML20095C820 PLA-2640, Comment on Proposed Rules 10CFR2,19,20,30,31,32,34,35,39,40, 50,61 & 70 Re Stds for Protection Against Radiation
References
FRN-56FR23360, RULE-PR-19, RULE-PR-2, RULE-PR-20, RULE-PR-30, RULE-PR-31, RULE-PR-32, RULE-PR-34, RULE-PR-35, RULE-PR-39, RULE-PR-40, RULE-PR-50, RULE-PR-61, RULE-PR-70 AA38-2-0191, AA38-2-191, NUDOCS 9204070280
Download: ML20094P198 (51)

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{{#Wiki_filter:-.. -Y h- ] ppR 1 1-i + i. d i i THE IMPLICATIONS OF THE PROPOSED 10CFR20 CHANGES UPON THE RADIATION PROTECTION DEPARTMENT-1 at i 1 CLINTON POWER STATION 4 l l 1 i i June 9, 1989 i i i L i i Prepared By l Wm Wadman & Associates l Lake Oswego, Oregon Subcontracting to The Delphi Groupe l Austin, Texas l l-4 i 1 .e ( a I 9204070280 920225 PDR PR 2 56FR23360_ PDR j ._..--_..____..._....-.-.,-,.,-......,c_._.,

E~.2 N o THE IMPLICATIONS OF THE PROPOCED 10CFR20 CHANGES UPON THE RADIATION PROTECTION DEPARTMENT EXECUTIVE

SUMMARY

The Proposed Revision to Title 10, Code of Federal Regulations, Part 20 (10 CFR 20) has been five years in draft and comment. The announced date of issue is January 1, 1991. Prudent lincensees are assessing the impact to various programs. The impact evaluations permit reasonably accurate estimates of cost for both the implementation on changes to comply with the revised 10CFR20, and the added annual costs to maintain compliance. Detailed planning and scheduling should follow this assessment to provide the most effective approach to bring the Frogram into compliance. The broad revisions to the regulations will require a broad based effort both in the planning and in the effort during the time of implementation. The Proposed Revision to the regulations are extensive. The current version is 30 years old. They have had patchwork revisions that have not always been well placed nor integrated into the main body of rules. Many programs formerly addressed in Regulatory Guidance, NUREGs, or Branch Technical Position Papers, have been made integral to Part 20. The revisions have addressed International Radiation Protection Standards, to achieve a better level of uniformity with other nations. Scientific data of more recent research, has been inccrporated to provide more accurate dosimetric bases. Several new regulatory requirenents have been incorporuted to fill apparent voids in the current regulations. The major changes and additions are not without contrcversy. While some of the limits and requirements have been ede more restrictive, others have seemingly been relaxed. Major change and revision of regulations impacting an industry nation-wide, is not implemented without cost. While not originally part of this assessment, costs could not be ignored and have been estimated for Clinton Power St ' ion. A one year implementation schedule is an increase of 50' n manpower, while for a two year effort .s an increase of 2f .r more. Either time frame for implemer ation will be cost v. To implement a progran. for compliance with the Propos Revisions to 10CFR20 will be $1,865,000. The annual increase in costs to maintain compliance within the program will be $397,000 per year. Both values are expressed in 1989 dollara. The assessment describes the areas of the Proposed Revision and what parts need to be implemented. A few recommendations about. planning are included. The Department procedures are identified with those sections of the regalations that may need to be revised. Appendix D of this assessment report details the basis for the implementation costs for each major cost area of the Proposed Revisions, with the separate entries for the increased cost to maintain the program in compliance.

r-hY ffd'3:' z ~ THE IMPL1 CATIONS OF Tilt PROPODED 10CFR20 CIIANGED UPON T!!E RADIATION PROTECTION DEPART!!ENT INDEX EXECUTIVE

SUMMARY

i INDEX 11 INTRODUCTION 1 DISCUSSION 2 The Proposed Revision 2 Nomenclature 2 Brief Overview of Impact 3 The Scientific Bases 3 Methodology in Brief 3 MAJOR CHANGES ARISING FROM THE REVISION OF 10CFR20 4 Internal Doce Assessment 4 Summation of Internal and External Exposures 4 Occupational Dose Limits 5 Limiting Dose to the Public 6 I Record)eeping and Reporting Requirements 7 IMPACT FROM DOSE EVALUATION REQUIREMENTS 8 1 External Dose 8 Internal Dose 9 Bioassay Monitorina 10 Air Monitoring 10 Dose Evaluation Impact 11 Recordkeeping and Dose Evaluations 12 ii

+ 73 2 .2 IMPACT OF TIIE REVISED EXPOSURE LIMITS 13 Impact of occupational Dose Limits for Adults 13 Planned Special Exposures 14 Doso to the Embryo / Fetus 15 Dose LimJt for Individual Members of the Public 15 IMPACT OF OTi!ER CHANGES 16 Internal Exposure Controls 16 s Precautionary Procedures 16 x Waste Disposal 16 General Recordkeeping Requirements 17 Reporting Requirements 18 Summary of Other Changes 18 SECONDARY IMPACT EVALUATIONS 19 Training and Retraining 19 Procedure Revicions 19 USFULNESS OF CURRENT TECIINOIDGY AWD THE REVISIOli 20 CONCLUSIONS 21 APPENDICES INDEX 23 Appendix A Current and Proposed 10CFR20 Sections 24 \\ Appendix B Terms and Definitions for Dose 34 Appendix C Procedure Impact Matrix 36 Appendix D Estimates of Implementing and 'Mintenance Costs 48 111

I M3P-2 HIGNIFICANT IMPLICATIONS QF TiiE PROPOSED 10CFR20 CilANGES UPON Tile RADIATION PROTECTION DEFARTMEET 1. INTRODUCTION The International Commission on Radiation Protection (ICRP) set forth recommendations regarding radiation protection standards in the ICRP Publications 26, 30, and 32. These International Standards have been published for 8 to 12 years. Included are standards which, many in the profession of radiation protection feel, should be applied internationally, including in the United Staten. This contributed in part to the proposed changes to the Title 10, Code of Federal Regulations, Part 20 (10CFR20). The changes were envisioned as making the nearly thirty year old U.S. regulations more closely unified with standards accepted in the international community. Additionally it would provide the opportunity to clarify some of the current regulation's ambiguities. And some data used in the current regulations have more recent determinations that could be incorporated during the course of the revision to improve on accuracy. The revision cleaned up areas where requirements were stated in documents other than 10 CFR 20, such as A1 ARA in Regulatory Guides 8.8, 8.10, l and 8.19, and respiratory protection as described in the current Appendix A footnotes, Regulatory Guide 8.15 and NUREG 0041. The current proposed date of issue is January 1, 1991. To provide for better planning for the Proposed 10CFR20 changes an assessment was performed. The results would be used as a tool in the planning process for their implementation. Existing and proposed 10CFR20 regulations were compared. The aignificant differences were determined. The assessment was made of the impact upon the programmatics of the Radiation Protection Department. A thorough understanding and proper use of the data is necessary for effective planning and scheduling. An estimate was made of the additional resources necessary to meet that schedule. llaving developed a preliminary planning estimate, timely requests for the additional budgetary support can be submitted. The integration of the process will contribute to a smooth and orderly transition into compliance with the proposed changes as they are issued as the official version of the regulations. It appears that activities associated with-implementation of the revised regulations will, for the duration, significantly increase technical and administrative workloads. This will necessitate that additional resources are made available to achieve compliance. While the levels of continuing support 1

k-Q will not be as high as the implementation costs, increases in the annual operating costs of approximately 15%-25% of the implementation costs will be necessary to maintain compliance. The scope of the assessment was to identify Significant changes in the Radiation Protection Procedures and program changes caused by the implemenMtion of the proposed 10CFR20. The assessment was not designeu to be an exhaustive analysis for which detailed human resource allocations and dollar expenditures were to be determined. These will need further evaluation as the implementation date is firmly established. Part of the assessment necessarily reflected on resources from an overall perspective and established approximate values. DISCUSSION THE PROPOSED REVISION The U.S. intent to achieve international uniformity is commendable. The regulations have long needed serious revision to consolidate related information, correct errors and address better data from the scientific community. O.) this basis the revisions in those specific arees are welcome. The Proposed Revision introduces changen in methods of assessing

exposure, when to start that assessment, terminology, and changes limits of exposure for various organs with both increases and decreases.

With these changes comes the imposition of very costly system modifications which are an attempt to pr9 vent hypothetical over-exposures which could arise from not summing an individuals external and internal exposures. Thesc changes will handle data relevant for only about 1% of the workers. Such changes have not been justified in a clear manner to the power reactor licensees. NOMENCLATURE There have been major changes in the numbering of sections of 10CFR20. The present version is numbered from 20.1 to 20.8 in the General Provisions section as is the Revised version. The major changes are from 20.101 to the end. In the current 10CFR20, sections are numbered from 20.101 to 20.601, and four Appendices, one a reserve. The Proposed Revision is numbered from 20.101 to 20.1401, with six Appendices, one of which is a reserve. While an identical formatting system was used, no sections from 20.101 to the end, cover identicci subjects under identical numbering. The Current and Proposed Revision of 10CFR20 are annotated and outlined as parallel columns in Appendix A of this report. 2 \\

[ M2 BRIEF OVERVIEW OF UiPACT Crrt-benefit analysis of the costs that will be borne by the licensees to comply, and the benefits that they or their workers will realize, does not support a valid basis for implementation of the proposed regulations. The regulations will impose extensive and costly changes in licensee programs: capital equipment, procedure revisions, training, additional staffing, software revisions (including the re-verification and re-valddation of electronic media legal records), and personnel exposure monitoring changes. Meanwhile, there is no evidence that it will produce an increase in safety or reduction in exposure (and may, in fact, work oppositely). Compliance with the proposed regulations will not be hchievable without the expenditure of significant initial economic and human resources by most nuclear utility licensees. Additionally, there will be a not increase in operating costs to maintain compliance after implementation is complete. 9 THE SCIENTIFIC BASES (or lack therec h The Proposed Revision to 10CFR20, and the limitations imposed for reducing exposure, is that data from U.S. Nuclear Power Plant facilities indicates that: The average exposure at those facilities is trending downwart. Highest exposures are trending downward. The number of internal depositions are trending downward. The number of exposures above one rem / year are trending downward. There is still no statistically significant difference from these workers and the surrounding populations regarding mortality or morbidity. There is no strong scientific evidence for the revision. METHODOLOGY IN BRIEF The assessment was conducted af ter the development of a matrix of the Existing and the Proposed 10CFR20 requirements. A mid-project test was performed. The initial metrix was used to identify the differences between the two versions of the regulations. Subsequently, Radiation Protection Department Procedures were matrixed against both versions of the 10CFR20 requirements. 3 )

M"{ The original intent of the matrices was to incorporato computer based search routinos. These would provide the contractor with the appropriate tools for a rapid, and fairly e accurate impact assessnent. Subsequently, the concept was expanded to consider providing that tool to the Radiation Protection Department for continued use. During a Mid-Project Test Demonstration, the interim results clearly showed that there are limitations. The major limitation occurs when the search routine is used with special case documentation, i.e.,

USAR, 10CFR20 (espacially comparing present with proposed versions),

Technical Specifications, Procedures. These regulations were written by different or multiple authors. Each author uses a slightly different style and language. Performing a text search requires an individual to have a very detailed knowledge of the subtle differences in phrasing of these documents. Common terminology used in those texts are not used as generic phrases. Therefore, many technical phrases of the same subject are not stated identically. This complicates a computer based search for phrases which, in print, may be identical in meaning without being identical in phras' between documents or in sections written by others. This requires an individual to make judgments regarding phrase structure for sc 4 'hos. Several searches may have to be made to cover a single- *3chnical meaning. 2. MAJOR CHANGES ARIBING FROM REVISION TO 10CFR20 2.1 INTERNAL DOSE ASSESSMENT The proposed 10CFR20, in addressing changes in the ICRP determination of relative risk, and as adopted by the USEPA, requires the summation of both external and internal exposures. It is now referred to as the total dose equivalent, inferring a measure of total health risk to individuals. The summation requirement might result in increased whole-body dose equivalents being recorded (compared to whole-body doses currently being recorded) even though the actual dose (risk) to the worker remains the same. Because this increase in recorded dose would be a result of changing terminology rather than an actual increase to risk, no impact regarding health effects is associated with this change. Additional records may be generated. 2.1.1 SUMMATION OF EXTERNAL AND INTERNAL EXPOSURES Proposed Revision 20.202 provides the details as to how a licensee considers intakes of radionuclides for the determination of total effective dose equivalent. 4

1 1 kk)fQ Proposed revision 20.204 defines acceptabic procedures for determining internal exposures based upon bioassay or air sampling measurements. The current 10CFR20 does not require summation, and uses dif ferent terminology for expression of exposure and dose from internal exposures. Regulatory Guidance is currently used for the description of acceptable models for calculating internal exposure and organ doses. 25% of Quarterly l'aits is the current monitoring limit, with concerns to daily and weekly thresholds for tracking HPCs, MPC-hrs. Proposed Revision 20.502 requires monitoring when it is likely that an individual will receitre in excess of 10% of the occupational limits. The section mandates that suitable measurements be performed, in accordance with 20.202, to allow summation of internal and external doses. Summation is required when internal doses exceed the applicable annual limits by 10%. MPC, MPC-hr have been replaced by ALI (Annual Limits on Intake) DAC and DAC-hr (Derived Air Concentration). This will be a major area of impact on Procedure revision, retraining of operational radiation protection technicians, counting room personnel (RP and/or Chemistry), and Supervisory staff responsible for the review, evaluation, and assessment of airborne conditions. 2.2 Occupational Dose Limits Proposed 20.201 addresses the Occupational Dose Limits for Adults. The definition of "whole-body" has been re-defined. There is no longer a specified nuarterly limit. The annual limits are: Total Effective Dose Equivalent of 5 Rem whole

body, and 50 Rem (the sum of deep and committed dose equivalents) for organs or tissues other than the lens of the eye, which is 15 Rom eye dose equivalent.

The Current version allows 1.25 Rem /qtr whole body and lens of the eye, or nead and trunk, or active blood forming organs, or gonads, 7.5 Rem /qtr to skin, and 18.75 Rem /qtr to each of the extremities. With a history on file, the worker could receive up to 3 Rem /qtr up to 5(Present age in years-18) Rem. The current 10CFR20 specifies limits of exposure to airborne radioactive material. The limit is based upon the current Appendix B. Continuous exposure to air concentrations stated for occupational MPC would produce the equivalent of 2.5 mrem /hr, or 5 Rem / year. The Proposed Revision does not specify limits, as such. The limit is the dif f erence of the Total Ef fecti" Dose Equivalent and the External Dose / Deep Dose Equivalent. The sum of which is limited to 5 Rem / year. Soluble Uranium intake is limited 5 _ _ _ - - _ _ _ _ _ _ _ _ = -

hE to 10 mg/wk for reasons of chemical toxicity. It should bc noted that for most utilities, tracking of exposures for external and internal has not been implemented with summation as a requirement. If for uhatever reason, a utility was inclined to operate near the upper ranges of the limits for both internal and external exposure, the system for tracking these exposures for each individual worker will be extensive and expensive. Utilities may set administrative limits to reduce the likelihood of overexposure. They may employ respiratory protection to take advantage of the protection factors. This action may prompt subtle regulatory pressure based on inadequate ALARA evaluations. The Proposed regulations state that respirators are only to be used when engir. - ing measures are not practical. If respirators are used,.aophisticated tracking system may be " required" or at t least "available for use" at each site not fully considering ALA9A practices. Planned Snecial Exposures are in Proposed section 20.206. This is a method for licensees to authorize adult workers to receives doses in excess of occupational dc,se limits, and the conditions which must be met prior t, these authorizations. Limitations are that the worker could receive double the annual limit for a maximum of 5 times during the worker's lifetime. The Planned Special Exposure is similar to the current regulations permitting the 5(N-18) rule exposures above 5 Rem / year. Dose to an Embryo / Fetus is new in Proposed 20.208. The new rule limits the Total Effective Dose Equivalent of a declared pregnant woman to 0.5 Rem during the pregnancy. Limiting exposure of pregnant women is not required by the current regulations and is considered voluntary. Guidance is found in Reg. Guide 8.13 (1987), and a Staff Position Paper. 2.3 Limitino Dose to the Public Present 10CFR20 implies public exposure limits of 0.5 Rem / year whole body. 10CFR50 Appendix I, recommends external whole body, beta and iodine limi.a. Proposed Revision specifies in 2 0. 3 01, limits of_the Total Effective Dose Equivalent to individual members of the public to 0.1 Rem / year from all operations by a licensee excluding disposal of radioactive material into sanitary sewerage. There is an allowance for applying to operate up to an annual Effective Dose Equivalent of 0.5 Rem / year for individual members of the public. 6 A

6//37-2 Proposed Revision section 20.302, requires licensees to make measurements, as required, to demonstrate compliance with the limits specified in section 20.301. 2.4 Recordkeepina and Reporting Recuirenents The current 10CFR20 recordkeeping and reporting requiremento addressed in 20.401-20.409, are relatively straight forward by present standards. Many recorded values are direct transcriptions from survey reports, dosimetry reports and incident reports filed in handwriting by operational RP staff. Terminology is relatively straight forward. This permits practical usage of clerical staff for hnnding the collection 5 of report data from files, and a reasonable chance for attentive clerks to catch errors in both records and reports. The Proposed Revision section on records is 20.1101-20.1110. There are increased numbers and types of required records. While many of these may have been retained in one form or another, the Proposed revision now requires the fo11oving records types: Radiation protection programs; surveys; determinations of prior occupational doue; planned special exposures; individual monitoring results (internal and external); dose to individual members of the public (formerly just in the REMP and Semi-annual effluent reports) ; waste disposal; testing of entry control devices for very high radiation areas. Proposed Revision section 20.1106, individual monitoring results, and supporting infocmation, are the subject of a major report by the Atomic Industrial Forum in NESP-030 (75 pages), Dosimetry and Recordkeeping Implications of the Proposed Revisions to 10 CFR 20. The quantity of records is 3xpected to increase with the Proposed Revisions, from 10% - 20%, after the initial period of implementation. The Battelle-Pacific Northwest Laboratories Report, PNL-6712, classify the changes as minor. This assessment of impact agrees more with the NESP-030 Report, that the impact is significant, especially in the dosimetry and recordkeeping requirements. Considerably more information is required to be accumulated and recorded to demonstrate compliance with the occupational dose limits and the prior exposure history. Records that are able to demonstrate coLpliance with the dose limits to members of the public are recently added to these regulations. Parts of these were found in the RG-1.21 keport and the REMP report. This is found in the Proposed Revision 20.1107. 7

M3n2 s a Proposed Revision section 20.1206 requires that annual individual monitoring reports be issue to every individual for whom monitoring is required. This is in addition to the 10CFR19 requirement for the Lanual statistical report. The current 10CFR20 requires that a report be issued to individuals upon request, or upon termination. Reports to the NRC are required for all Planned Specici Exposures. 3.0 IMPACT FROM DOSE EVALUATION REQUIREMENTS The Proposed Revision has somewhat redefined "whole-body" and revised the limits of exposure to everythirg else. There is no longer a quarterly exposure limit. The *.1se of 5(N-18) is no longer a choice for extending exposures beyond 5 Rom. Monitoring of internal or external exposure la proposed to be started at the 10% instead of 25% of MPE. Internal and external exposures are now to be added to describe total exposure. Internal exposure is no longer an evaluation with the simple calculations based upon MPC-hrs. Two limits were increased, eyes from 5 Rem / year to 15, and skin from 30 to 50 rem / year. There are major changes on the nomenclature for airbcrne from the carrent MPCs and MPC-hr units. Thr Proposed units are Annual Limits on Intake ( ALIs), and Deriv Air Concentrations (DACs) and Derived Air Concentration - 1. .trs (DAC-hrs). 3.1 External Dose The present 10CFR20 limits external whole body doses to 3 Rem / quarter, with a lifetime average of lese than 5 Rem / year after the age of 18. Doses to individual organs are not considered in the calculations for compliance with this limit. The Proposed Revision has a 5 Rem per year limit including the summation of external and internal doses when the internal exceed 10% of the annual effective dose equivalent limit. The proposed dose limits may impact personnel dosimeter physical configurations. The deep dose equivalent is measured 2 below 1000 mg/cm. The eye dose equivalent is measured 2 beneath 300 mg/cm. Skin dose is measured at a depth of 0.007 2 cm (7 mg/cm ). For the licensee to meet these requirements, the minimum deep dose sensitivity to meet the 10% MPE is 40 mrem / month. To accurately state a measure.nent to be 40 mrem, the sensitivity must be lower than that to provide statistically significant values after the background is subtracted. This means tnat the detection medium in the dosimeter must be sufficiently sized for the worst case under the filters to meet these limitations. E

/M%z Many of the values obtained from the personnel dosimeters in present systems do not ftlly support the data that will be required to define the three major parameters above. Where there is no in.ouse dosimetry system, the vendor based system chould meet the specification. Bid specifications for contracted services can have the service started on the appropriate date. Double mrvice for three to six months will provide crossover data between the two dosimeter types. A full ovaluation of the dosimetry computer database will be required in order to provide tracking of the two separate sets of dosimeter holders. This is a requirement for accumulating data between the two holder systems and the methods of interpretation of dose. Software that is written to select the appropriate data presentations according to the date of change-over between the two systems is necessary if raw data is also stored in the database. This is important to recognize and acknowledge in the bid specification as it pertains to the vendors storage of your raw dosimetry data during the crossover between dosimetry holder systems. Entry of data into the Station's computer database from ( written data input sheets or standard survey forms will require some degree of retraining. Additionally, the procedures from which these data sheets originate may require slight to major revision in order to have the dosimetric terminology stated correctly before input. These are considered to be areas in which there will be uignificant change in procedures,

forms, retraining and increased workload because of the Proposed Revision.

3.2 Internal Dose The currcnt 10CFR20 Section 101 (20.103) specifies the limits for exposure ;o concentrationt - f radioactive materials in air in restricted areas. Internal dose is a function of the concentration in air (MPC) and the duration of exposure (MPC-hr). The unit values of MPC woro established using empirically derives blokinetic models and the calculated dose to critical organs based upon inhalation. The critical organs were specific for each radionuclide. Compliance with the current regulations compares the present exposure with the time average concentration for 2 hours / day, 10 hours / week, or 520 hours / quarter. At a level of 25% of MPC-hr values for a comparable time period, monitoring of intake is required to be tracked. The Proposed Revision is based on an annualized average, and is referred to as the Annu 1 Limit on Intake (ALI). This is 9

Nf ' also based upon intake by inhalation of derived air concentration (DAC). Monitoring of intakes is required if an adult is likely to receive in one year, 10% of the applicable Annual Limit on Intake (0.1 X 2000 DAC-hr). The Proposed Revision indicates that compliance can be demonstrated in any of three ways. 1). Limit the sun of the quotients of the intakes divided by the ALIs to unity. 2). Limit the DAC-hrs of exposure to 2000. 3). Using data from successive bioassays, project the time for the annual limit to be reached based upon the committed effective dose equivalents to all organs and tissues for ongoing ambient exposures. There are several chenges in the DAC limits when compared to the current MPC limits. Some have been increased, and there are reductions in others. These may be either by radionuclide in all forms, or, as in the case of Cobalt-60, changes in only one of the forms (soluble / insoluble). Just as in the current regulations, bioassay with calculations ) of the committed effective dose equivalents, and measurements of airborne concentrations to establish exposure conditions are also acceptable exposure determining methodology. 3.2.1 Ricassav Monitorina The current 10CFR20 describes 25% MPC as the level to begin .N Titoring, usually referring to 520 MPC-hrs. Proposed Revision refers to monitoring being required at 105 of an ALI. Using the current and proposed exposure monitoring limits, and comparing them to the data of Draft ANSI Standard N13.30, I Performance Criteria for Radiobioassav, most of the required limits are measurable. This is valid u-ing a 30 day bica.;say frequency, and the appropriate "in titro" or "in vivo" bioassay techniques, which depend upon the isotope being monitored. This should be the subject of a detailed technical review. The determinations should establish the system sensitivity for "in vivo" and "in vitro" detection, fregoency of the bioassay that would improve sensitivity if required, and other methods for improving sensitivity if cost permits. Alternatives, such as improving the air monitor Tg methodology, should not be over looked. 3.2.2 Air Monitorina Air monitoring to collect and analyze work zone air samples, is a recognized method for assessing possible intakes by workers. Sampling flow rates provide a variable which can 10

Y$.2_ become the limiting factore for achieving acceptable MDAs. Both the current and the Proposed regulations require a thorough understanding of the dynamics of air sampling and analysis. From that, detailed and meaningful assessments of airborne radioactive mecerial can be calculated. The subsequent biokinetics of ingested radionuclides is then applicable for determining the committed dose equivalent. 3.3 Dose Evaluation Impact Changes in the dose evaluation requirements are not expected to af fect doses received by the public. Neither should it impact the frequency of accidents that impact occupational or public exposures, or cause property damage. There will be major program and procedural revisions to change over to the Proposed terminology, levels for required monitorina, external dosimetric measurements of deep and eye and skin exposure, and the elimination of the 3 Rem / Quarter and S(N-18) exposure limits. Revisions to the Airborno concentration levels will need retraining to prevent old habits from permitting overexposures. The computer database for all of the dosimetric information, methodology of performing dose calculations, especially for internal doso, and the new requirement for adding external and internal exposure, will require significant modification to existing systemc. Training in the new terminology of ALIs and DAC and DAC-hrs, the difference in monitoring, reporting, and dosimetric determinations for the subtle differences in the terms, will be essential prior to the implementation of the Proposed Revisions. There should bs a serious erfort by the Radiation Protection staff professionals to become familiar with the Proposed Revision when it is issued for rulemaking. This, with the mind toward practical administrative measures that are possible to implement to achieve the intent of the new regulations without having to expend major resources toward compliance aspects of the program that impoct only fractions of a tenth of a percent of the workers. (Booth, Bronson and Groth 1985, "Less than 0.03% of the individuals ted at nuclear power plants between 1978 and 1983 had mea d body burdens in excess of 10% of the relevant ALis".) NOTE: There is ardifference in the values stated in the assessments by the Atomic Industrial Forum (AIF) AIF/BNESP-030, Dosimetry and Recordkeepina Imolicatiorg_ 3f the Proposed Revisions to 10CFR20 and Battelle Pacific 2 Northwest Laboratory (B/ PNL) PL-6712, Rcoulatory Analysis for the Revision t' 10 CFR 11

Part 20 regarding the cost of implementing the in the area of exposure evaluations. This assessment is in much closer agreement with the AIF assessment values. Contrary to one of the stated purposes behind the Proposed Revisions being that of exposure reduction, no mechanism, nor new requirement was found that would produce those results for the nuclear power industry. In the end, the changes might produce increases in collective exposures. 3.4 Recordkeepina and Dose Evaluations The current 10CFR20 has cansiderable recordkeeping requirements. While the regulations state many of the retention times for various records, American Nuclear Insulers (ANI/MAELU) prefer longer retention times in the event that there is litigation to contend with. The Proposed Revision has comparable requirements as the current regulations. Additionally, with'the new requirement of adding the external and internal exposures, the calculations of internal exposure from internal ingestions and organ weighting factors, records retained for each exposed employee will be greater than with the current requirements. Records of the evaluative process and calculations for.the internal dosimetry programs will be necessary, including extensive modifications to the evaluative procedures. Records associated with NRC Form 5 will also increase. Information that is transmitted when supplying exposure history will increase. Extensive revisions in the dosimetry recordkeeping will be required. Procedures will require revision. Training in the new requirements will be necessary. These modifications must be extended into contracts with dosimetry services companies to assure compliance with the Proposed Revisions. The requirement for summation of external and internal exposures has the potential for major recordkeeping and handling workloads increases. A system for t;acking the exposures below the 10% monitoring or summation requirement is necessary, in the event that the worker exceeds the 10% limit prior to the end of the year. Hence the active records access is 100% for all workers who have the potential for exposures, external or internal or both, of 10% of the annual limits. Without the tracking, there may not be other evidence that compliance with the regulations was achieved. Cost for implementing these requirements has been estimated from 20-40% of the total cost of implementing the Proposed Revisions. For a single unit nuclear utility in 1989 dollars, 12 d

~Z the estimate is $900,000 for the dosimetry and recordkeeping of those program elenents. This value is somewhat higher than the AIF/NESP-030 Report, however, other cost items that were not identified by that report are included in this assessment. Cost for maintaining the required level of compliance is estimated to be $180,000.00. No attempt was made to quantify doses expended or dose saved by these requirements. There is disagreement regarding the costs and benefits in the reports of others and this work. 4.0 Impact of the Revised Excesure Limits Section 3.0 above described the changes from the current to the Proposed Revision of the revised exposure limits. In addition, the Proposed Revision now specifies limits for the embryo / fetus and for individual members of the public. 4.1 Impact of the Occuoational Dose Limits for Adults In both the current and the Proposed Revisions the annual limit is S Rem. The Proposed Revision refers to it as total effective dose equivalent. This is an administratively determined dose. One does not measure " Total Effective Dose Equivalency". It is the sum of calculations for Dose equivalent, deep dose equivalent and the effective dose equivalent. These are calculated from measurements of 2 personnel dosimeter values beneath 1000 mg/cm, evaluations of l that exposure to calculate the organ irradiation dose using the weighting factors, and data from the bioassay results which are evaluated against biokinetic models after exposure duration and recompartmentalization is accounted for. While the 16 new terms may have relevance to research radiobiologists, radiation litigation legal staff and radiodosimetry statisticians, these are not the terms that are practical for use in the field. Their need for use in the nuclear power industry will be infrequent. By deduction, data for the nuclear power industry has been showing a downward trend in levels of exposure over the last four years. And as mentioned, only 0.03%, or sixty workers por year will exceed 10% of an ALI that will require the summation of external and internal exposures. With such infrequent occasion to generate data that use the administrative dose terms, careful attention to detail will be necessary to minimize use of incorrect terms. [See Appendix B for the 16 dif ferent definitions of Jose used in the Proposed Revisions] l The eye dose equivalent was increased to 15 Rem / year as 2 measured beneath a 300 mg/cm absorber thickness. For this 13

Msn data the most reliable source of data vill be an appropriately fabricated dosincter. This increase is not supported by evidence for its increase. Work by the U.C. Berkeley Donner Laboratory found that for mixed radiations including possible charged particles, radiation cataract thresholds occurred at 235 Rad. In a literature search and report by Kephart, G., that for pure charged particles, lens opacity could occur from acute exposure in the tens of Rad, out to hundreds of Rem for gamma radiation. The new limit allows for a lifetime eye dose of 750 Rom. This may all be ratter academic, in that most power reactor employees that a;e s3rking where eye done may a factor, are instructed to wear eye protection. This reduces the exposure to beta radiation associated with the tasks. The elimination of the 3 Rem /Qtr was not accompanied by a requirement to distribute the 5 Rem /yr evenly over a year. There are alternatives for dealing with this in the licensee's program. Establish administrative limits ; weekly, monthly, etc.,) that maintain exposures such that there are no premature accumulations of external' and internal exposures that could add up to 5 Rom. Provide active ALARA job planning to distribute exposure to limit total exposures to each worker. If the licensee does not take active and positive

steps, employee organizations, bargaining units or labor unions will likely step forward and force the issue to keep i

people from being laid off due to exposure limits. Tracking these administrative limits and ALARA job planning will cause increases in staffing in those areas. Outage planning will likely hire 20 extra workers to use to distribute exposure. This will decrease the possibility of exceeding administrative limits. Unfortunately, it will also decrease the efficiency of the job by the increased turn-overs, and thereby increase the collective expor tre for the job. It should be noted that since 1986, collective exposures have reached an industry low, and no worker received greater than 5 Rom while working at one facility. Subsequent years data indicate that the trend is ongoing in the downward direction where it might reach a threshold in 1990 or 1991. This may see another downward trend as utilities incorporate more automated equipment and robotics for high exposure tasks. 4.2 Planned Sracial Exposures The planned special exposure is a measure that is to be used only when no other reasonable alternative exists. Cost I ef fectiveness is not in the wording of the Proposed Revisions, while unavailable or impractical are operative terms. The amount of paperwork, recordkeeping and approval process make this much more difficult to use than the former 5(N-18) provision from the current regulations. Complexities of the 14

MO use of the Planned Special Exposures provision, and the present trending of downward doses will make this a little used but necessary section. 4.3 Dose to the Embryo / Fetus There are no provisions in the current regulations for limit! q exposure to the unborn. The Proposed Revision is explic..tt within the regulations that the pregnant worker shall be limited to 0.5 Rem for the entire pregnancy, and that substantial variation above a uniform rate should be avoided. Most licensees have invoked the Reg Guide 8.13 guidance as administrative limits and will not find this to be a major impact. 4.4 Dose Limit For Individual Members of the Public The dose limit for individual members of the public is not explicit in the current 10CFR20. There are approximations of 2 mrem in any hour and 100 mrem in any 7 consecutive days based upon continuouc occupancy of an individual in an unrestricted area. There is an implied limit of 500 mrem per year. This is a matter addressed in 40CFR190, and to some er :ent, 10CFR50, Appendix I. The Proposed Revision explicitly states an annual dose limit of 0.1 Rem to individual members of the public from continuing operations by a licensee. Based upon present operations, this should be easily achievable. The only major complication would be a major gaseous or liquid release. The airborne activities would be dispersed and somewhat easier to recoNer from. A major release to the lake would impact the public using the waterway for recreation or sportfishing. There are no provisions for tracking members of the public that may frequently visit numerous nuclear facilities in one year. Visitor doses are already kept low, and therefore should not present increases in costs beyond dosimetry and recordkeeping. Administrative controls can easily restrict access to any radiologically controlled contaminated or airborne radiation area. In so doing, limiting exposures to visitors is not an impact different from current practices. l 15

&31. 5.0 Impact of Other Chances 5.1 Internal Exposure Controls occupational internal exposure control has changed in the Proposed Revision. The current regulations require licensees to maintain intakes of radioactive material as low as is reasonably achievable. This is without apparent regard for the external exposures. Therefore respiratory protection is often used to achieve this. The use of respirators may not be in the best interest for the reduction of external dose if the inefficiency from wearing them significantly increases the time for job performance. The Proposed Revision now includes the internal exposure as part of the total exposure. This may present opportunities to make ALARA exposure decisions to discontinue use of respirators to increase work efficiency. Data for either practice is sketchy and needs further evaluation prior to making any recommendations. The trade-offs of greater efficiency but having to do increased air monitoring and airborne activity determinations, along with the DAC-hr accounting, might reduce exposure but greatly increase support costs. 5.2 Enqcautionary Procedures Labelina reauirements have changed only slightly. Only 24 of the 581 listed radionuclides are more restrictive. The remainder are equal or greater than the current 10CFR20 requirements. Postina recuirements are essentially equal for the current and Proposed Revision _10 CFR 20. Eackace handlina reauirements have not been changed significantly from the current to the Proposed Revision of 10CFR20. 5.3 Waste Disposal The Proposed Revision explicitly permits on-site storage of radioactive material to allow for decay. The current 10CFR20 does not have this as a regulatory item. On site storage was permitted after 1981 when NRC issued a generic guidance letter for temporary radwaste storage at nuclear power plants. The Proposed Revision significantly reduces the concentrations that can be released to sewerage for disposal. This will not impact nuclear utilities that comply with 10CFR50 Appendix I. 16

N/ 5.4 General Recordkeepina Requiremep_t.fq Individual monitorina results, reauired by the Proposed Revision, are clearly a significant change over the currant 10CFR20 requirements. The increase in the amounts of materials will vary widely depending upon the characteristics of the exposure. All of the records have to be filcd for each exposed individual prior to the evaluation or calculation of that individual's exposure. The handling of the records must be timely and accurate-An assessment of the complexity of the records system will depend upon the design of the system, to what extent it can be computerized, and the number of workers that require more than just the basic exposure tracking to be performed. Records of Surveys required by the Proposed Revision state more detail as being required than the current 10CFR20. While the impact on recordkeeping may not increase significantly, the procedure revision to address the amount of detail, and the forms upon which the data is recorded, will require considerable revision. potermination of Prior occupational Dose has been modified in the Proposed Revision. The currer.t version permits up to 100 mrem / week occupational exposure until prior exposure histories are compiled, and the 5(N-18) rule can be used. The Proposed Revision requires that licensees must attempt to obtain lifetime records of dose before permitting individuals who require personnel monitoring devices to enter the controlled or restricted areas. In theory, this will increase the workload for any utility that does not now do NRC Form 4 histories on each worker issued a dosimeter. Awaiting the histories of contract workers, unless a system such as INDEX is used by all other utilities, where that data is immediately available for employees and transient

workers, will potentially incur much lost titue during the data accumulation.

One possible solution is to accept documentation issued by previous employers to the worker as they exit a job site. Another is for prime contractors to supply the appropriate information for making an exposure history inquiry for each worker that will be reporting on site. Planned Special Exposures will be so infrequently used that the recordkeeping requirements are expected to be insignificant. Dose to Individual Members of the Public is an area where nuclear power plants are already operating Radiological Environmental Monitoring Programs. Data from these efforts, as well as the programs which are operated to demonstrate compliance with Reg. Guide 1.21, should amply demonstrate the requirements of the Proposed Revision. 17

A8f1 Waste Disposal records should require only minor modifications to satisfy the proposed re pirements. Testino of Entry Control Devices for Very Hiah Radiation Areas is usually recorded in a legal type record for potential litigation situations. No significant impact is expected for this new requirement. 5.5 Reoortina Recuirements The current and Proposed Revisions to 10CFR20 have similar reporting requirements. The Proposed Revision has three significant changes. Planned Special Exposures must be reported to the NRC within thirty days after the exposure occurs. Separate reports for each individual for whom monitorina was reauired will be submitted to the NRC annually. This replaces the-current annual statistical (20.104)-report. Reports of doses received in the workolace to all individuals for whom monitoring was required. (A requirement found in the revised 10CFR19, but which impacts the reporting program significantly). 5.6 Summary of other Chances Units of Radiation Dose will not require that reports be submitted or filed using the International System of units (SI). Neutron Ouality Factor will not require such detailed spectral knowledge that the Proposed Revision chart will be used. Instead, the NRC has indicated that it will continue to accept neutron dose assessment using the default Quality Factor of 10. Radiation Protection Procrams are required to be developed and documented, and that it is commensurate with the scope and extent of the licensed activities. To the extent practicable, licensees procedures and controls will be adequate to maintain doses as low as is reasonably achievable. None of the above differ from the existing operations, and with minor revisions to upper tinr documents, are largely in place at this time. 18

6.0 Secondary Impact Evaluations 6.1 Trainina and Retraininc. Significant costs will be incurred in training most of the plant employees in the General Employee Training. Areas in which technically trained staff are required to know and understand the regulations, more extensive training / retraining will incur greater costs. There will be costs in the research and development of these training programs, including the training aids, scheduling and lost time from an already established routine for training departments in nature and stable operating plants. After the initial intensive training has been conducted for essential staff following the issuance of the Proposed Revision as final rule

making, the routine retrain!ng of less essential personnel can be normal cycle of their training.

The Pacific Northwest Laboratories value assessme.nt summary, indicated that no costs for training health physicist should be necessary. They felt that, as part of their job, they should already have an excellent understanding of such things as the Proposed Revisions of 10 CFR 20. Power plant health physicists are kept occupied with the routine, non-routine and immediate health physics duties. Therefore, training in the changes caused by revising 10CFR20, is and will continue to be a necessity for health physicists and radiation protection technicians in nuclear power plants that have less than 10% time devoted to training. (PNL does allow that others have determined that there will be significant training in all areas of the plant impacted by 10CFR20.) 6.2 Procedure Pevisions very significant costs will be incurred to incorporate the revised requirements into Policies, procedures, manuals and training documents. Where new requirements' have been issued, new program development will be necessary in that area, along with the implementing procedures. Extensive revisions were already mentioned for internal and external dosimetry. Appendix C Lists the Radiation Protection Procedures, and Proposed Revision section that impacts it. There are 214 procedures in the program area assesssed for impact. The following distributions of level of impact are: DEGREE OF CRANGE

1. of PROCS.

% of PROCS. No Change 69 32 1-2 paragraphs 60 28 1-2 Pages 30 14 5-25% of document 23 11 19

m 25-50% of document 5 2 100% of the document

• 6 3

5 50% now, major later* 21 10 New Procedures 15 N.A.

• = " Major" impact is usually associated with large scale revision of program performance or development of a new program element.

7.0 Usefulness of Current Technoloov After the Revision The hardware presently in use for radiation protection surveys, spectroscopy, and analysis, will perform the intended function after 10CFR20 Revision is issued. q All sof tware presently in use that performs evaluations of concentrations, depositions, internal dose estimates, organ burden estimates, external dose evaluations, will require extensive revision. With the current instrument compliment without software revision, compliance is not possible. With sof tware rewritten to incorporate the changes in values, terms, and dosimetric formulae, compliance will be achieved in these areas. At present, Radiation Protection Professional Staff is (on the average) marginally knowledgeable of the current regulations. Continuous effort is required to maintain compliance under the current regulations. Individual effort is extreme for new entrants in the groups or the Department. Experienced staf f are much Itore knowledgeable, and ef ficient at regulatory application. There will be considerable effort to take the existing technology into compliance with the Proposed Revisions of 10 CFR 20. It will require extensive training, program redesign for existing programs, program development and implementation for newly required programs, major revisions to about 15% of the procedures, significant revision to about 50% of the procedures, major redevelopment throughout those programs with impact on dosimetry or input for dose evaluations for external and internal dose. Records will need considerable revision for the dosimetric parts of the radiation protection program. Major rewrite (programming) to the software of the department will be required to adapt to the new requirements. Tables for all values of concentrations for

exposure, as well as concentrations that can be released, and those which requite 20 j

h.S. labelling, must be installed in place of the current tables in the software. The level of effort to provide upgrades, training, software rewrites, and those activities to achieve compliance with the Proposed Revision can be graded. High levels of efficient and effective effort can shorten the period of transition to compliance.

However, the NRC is apparently prepared to provide an implementation period that will be one to two years.

Effectively planned, contract support can be used to perform the current dutier under the curront regulations permitting the permanent staff to revise or write procedures, develop or redesign programs to meet the new requirements, rewrite

software, and acquire training in the revised regulations.

This utilization of permanent staff to provide the majority of the effort to make the changes to comply with revised 10CFR20 makes practical sense. Enen contractors provide such services, their departure creates a void in the knowledge of how, and what, and much of the history and bases for why one solution was chosen over another. When the new programmatics are in-place, and field

tested, personnel trained in all the aspects of the operations, shift to the new 10CFR20 regulations, with appropriate notification to the NRC.

When the operations are under control, release the supporting contractors.

8.0 CONCLUSION

S The few studies that have been performed presume that permanent staff have adequate " free" time to be able to implement the necessary changes to comply with the Proposed Revisions given two or more years before compliance is required by the NRC. The presumption is that there is an adequate level of professional expertise and experience with all of the program elements that there is no need to hire contractors to support the effort. The major areas of impact by the Proposed Revision have been evaluated using industry average labor costs including benefits, and making an attempt to include costs not always recognized by the two major groups that published the earlier assessments. For instance, no previous work addresses the need for and cost of revising the various computer software that supports many of these programs. Nor have the procedure revisions previously addressed the costs from the effort that is required in the approval cycle, printing and distribution costs. This assessment has profitted from the groundwork laid by others and has refined the costs of these. Additionally, the PNL costs have subtracted dollars per man-rem saved. This may be in an attempt to justify the very high costs that have very little benefit for the implementation of the Proposed Revision. 21 ~

n193' f-2 The summary estimates of cost for this utility to implement the Proposed Revisions to 10CFR20 are in Appendix D. The Total for the implementation costs in 1989 dollars is $1,865,000. The Total for the annual increase in operational expenditures for the program to maintain compliance with the Proposed Itevision is estimated to be an additional $397,000. Neither value includes any amount for contractor support. Recommendations for ef fective use of contract 7r support is discussed ir mtion 7.0. The single greatest impact in dollars will the new and complex requirement for the summation of inn nal and external dose. This feature should not be developed until the Proposed Revision is issued, and no other changes in the regulations will be made. Then, if NRC can be persuaded to accept alternatives, programs can be designed that are more efficient, and are not invoked unless the 10% of the limits are met. Currently, all discussions have presummed that all utilities will procede towards full, verbatim, compliance. 22

I APPENDICES A. Current and Proposed 10CFR20 Versions, Major Sections Are Annotated. B. Terms Used

• o Characterize Dose or Exposure, with Definitions C.

Procedure Matrix with Current and Proposed 10CFR2D D. Cost Estimates For Implementing Proposed Revision

10CFR20, and Estimated Additional Cost to Maintain compliance With Proposed 10CFR20 23

f-{ APPENDIX A NEW 10CFR20 REQUIREMENTS OLD 10CFR20 REQUIREMENTS SUBPART Is - GENERAL PROVISIONS GENERAL PROVISIONS (Subparts not in old Part 20) n20.1 PURPOSE o20.1 PURPOSE n20.2 SCOPE o20.2 SCOPE n20.3 DEFINITIONS o20.3 DEFINITIONS n20.4 UNITS OF RADIATION DOSE o20.4 UNITS OF RADIATION DOSE n20.5 UNITS OF RADIOACTIVITY o20.5 UNITS OF RADIOACTIVITY n20.6 INTERPRETATIONS o20.6 INTERPRETATIONS n20.7 COMMUNICATIONS o20.7 COMMUNICATIONS g n20.8 REPORTING, RECORDING, AND 020.8 INFORMATION COLLECTION APPLICATION REQUIREMENTS? REQUIREMENTS:OMB APPROVAL OMB APPROVAL nSUBPART B - RADIATION PROTECTION PERMISSIBLE

DOSES, LEVELS AND PROGRAMS CONCENTRATIONS (New Subpart)

(Subparts not in old Part 20) n20.101 RADIATION PROTECTION 020.101 RADIATION DOSE STANDARDS FOR PROGRAMS (New subject INDIVIDUALS IN RESTRICTED AREAS matter for new Part 20. (Now in n20. 201, n20.202, n20.101 is only section in n20.203, n20.204, n20.206, Subpart B) n20.207, n20.208) n20.102 (Does not exist in New Part o20.102 DETERMINATION OF PRIOR DOSE 20) (Now in n20.1104) n20.103 (Does not exist in new Part o20.103 EXPOSURE OF INDIVIDUA.E TO 20) CONCENTRATIONS OF RADIOACTIVE MATERI ALS IN AIR IN RESTRICTED AREAS (Now in n20.204, n20.701, n20.702, n20.703, n20.704) n20.104 (Does not exist in new Part o20.104 EXPOSURE TO MINORS 20) (Now in n20,207) 24

Ad'38-t l n20.105 (Does not exist in neu Part o20.105 PERMISSIBLE LEVELS OF 20) PADIATION IN UNRESTRICTED AREAS (Now in n20.301, n20.302) n20.106 (Does not exist in new Part o20.106 RADIOACTIVITY IN EFFLUENTS 20) IN UNRESTRICTED AREAS (Now in n20.301, n20.302) n20.107 (Does not axist in new Part o20.107 MEDIO.L DIAGNOSIS AND 20) THERAPY (Not a specific section in the new Part 20) i j n20.108 (Does not exist in new Part o20.108 ORDERS REQUIRING FURNISHIMG 20) OF BIO-ASSAY SERVICES (Now in n20.204, n20.502) SUBPART C - OCCUPATIONAL DOSE PRECAUTIONARY PROCEDURES LIMITS (Subparts are new to Part 20.) n20.201 OCCUPATIONAL DOSE LIMITS o20.201 SURVEYS FOR ADULTS (Now in n20.501, n20.502, (Was in o20.101, o20.103) n20.1103) n20.202 COMPLIANCE WITH o20.202 PERSONNEL MONITORING REQUIREMENTS FOR SUMMATION (Now in n20.502) OF EXTERNAL AND INTERNAL DOSES (New requirement) n20.203 DETERMINATION OF EXTERNAL 020.203 CAUTION SIGNS, LABELS, DOSE FROM AIRBORNE SIGNALS AND CONTROLS. RADIOACTIVE MATERIAL (Now in n20.901-904) (Was in o20.103, o20.106) n20.204 DETERMINATION OF INTERNAL o20.204 EXCEPTIONS TO o20,203 EXPOSURE (Now in n20.905) (Was in o20.103, o20.106, o20.108) n20.205 RESERVED o20.205 PROCEDURES FOR PICKING UP, RECEIVING AND OPENING PACKAGES (Now in n20.906) 25

n20.206 PLANNED SPECIAL EXPOSURFS o20.206 INSThUCTION OF cERSONNEL (Not a specific section in (Now not a specific section old Part 20) in the n2w Part 20) n20.207 OCCUPATIONAL DOSE LIMITS o20.207 STOP. AGE AND CONTROL OF FOR MINORS LICENSED MATERIALS IN (Was in c20.104) UNRESTRICTED AREAS (Now in n20.802) n20.208 DOSE TO EMBRYO / FETUS o20.208 (Does not exist in old Part (New section and subject 20) matter for Part 20. Previously covered only in Reg. Guide 8.13) RADIATION DOSE LIMITS WASTE DISPOSAL COBPART D FOR INDIVIDUAL MEMBERS OF (Subparts are new to Part 20) THE PUBLIC n20.301 DOSE LIMITS FOR INDIVIDUAL o2a.301 GENERAL REQUIREMENT MEMBERS OF THE PUBLIC (Now in n20.1001) (Was generally found in o20.105, o20.106, 10CFR50 Appendix I) n20.302 COMPLIANCE WITH DOSE LIMITS o20.302 METHOD FOR OBTAINING FOR INDIVIDUAL MEMB'ERS OF APPROVAL OF PROPOSED THE PUBLIC DISPOSAL PROCEDURES (Was generally found in (Now n20.1002) o20.105, o20.106, 10CFR50 Appendix I) n20.303 (Does not exist in new Part o20.303 DISPOSAL BY RELEASE INTO 20) SANITARY SEWERAGE SYSTEMS (Now in n20.1003) n20.304 (Does not exist in new Part o20.304 DISPOSAL BY BURIAL IN SOIL 20) (Removed from old Part 20, not reinstated in new Part 20) n20.305 (Does not exist in new Part o20.305 TREATMENT OR DISPOSAL BY 20) INCINERATION (Now in n20.1004) n20.306 (Does not-exist in new Part o20.306 DISPOSAL OF SPECIFIC WASTES s 20) (Now in n20.1005) n20. 307 >(Does not exist in new Part o20.307 (Deleted) 20) 26 3 e a

-^ 'f n20.308 > O20.308 (Deleted) n20.309 > o20.309 (Deleted) n20.310 > o20 310 (Deleted) n20.J11 > o20.311 TRANSFER FOR DISPOSAL AND MANIFESTS (Now in n20.1006) SUBPART E - RESERVED RECORD, REPORTS AND NO'"IrICATIONS n20.401 (Does not exist in new Part o20.401 RECORDS OF

SURVEYS, 20)

RADIATION MONITORING AND

i DISPOSAL (Now in n20.1103, n20.1106, n20.1108) n20.402 (Does not exist in new Part o20.402 REPORTS OF THEFT OR LOSS OF 20)

LICENSED MATERIAL (Now in n20.1201) n20.403 (Does not exist in new Part 020.403 NOTIFICATIONS OF INCIDENTS 20) (Now in n20.1202) n20.404 (Does not exist in new Part o20.404 (Reserved) 20) n20.405 (Does not exist in new Part o20.405 REPORTS OF OVEREXPOSURES 20) AND EXCESSIVE LEVELS AND CONCENTRATIONS (1:ow in n20.1203) n20.406 (Does not exist in new Part o20.406 (Reserved) 20) n20.407 (Does not exist in new Part o20.407 PERSONNEL MONITORING 10) REPORTS (Now in n20.1206) n20.A08 (Does not exist in new Part o20.408 REPORTS OF PERSONNEL 20) MONITORING ON TERMINATION OF EMPLOYMENT OR WORK (Not a specific section in the new Part 20) n20.409 (Does not exist in the new o20.409 NOTIFICATIONS AND REPORTS Part 20) TO INDIVIDUALS (Now in n20.1205) t 27 a

M L h SUBPART F - SURVEYS AND MONITORING EXCEPTIONS AND ADDITIONAL REQUIREMENTS I d.501 GENERAL o20.501 APPLICATIONS FOR EXEMPTIONS { (Was in o20.201) (Now in n20.1301) n20.502 CONDI'llONS REQUIRING THE o20.502 ADDITIONAL REQUIREMENTS INDIVIDUAL MONITORING OF (Now in n20.1302) EXTERNAL AND INTERNAL OCCUPATIONAL DOSE (was generally covered in o20.101, o13.103, o20.104) SUBPART G - CONTROL OF EXPOSURE FROM ENFOP. CEMENT EXTERNAL SOURCES IN

• ^w in Subpart O)

= RESTRICTED PREAS E n20.601 CONTROL OF ACCESS TO.HIGH o20.601 VIOLATIONS RADIATION AREAS (Now in n20.1401) (Was generally covered in 020.203) p r n20.602 CONTROL OF ACCESS TO VERY o20.602 (Does not exist in old HIGH RADIATION AREAS 10CFR20) (Was generally covered in o20.203) ~ n20.603 CONTROL OF ACCESS TO VERY o20.603 (Does not exist in old ~ HIGH RADIATION AREAS 10CFR20) I IRRADIATORS (Was very generally covered ,p in o20.203) SUBPART H - RESPIRATORY PROTECTION (There are no more : ext sections to AND CONTROLS TO RESTRICT the old Part 20. The next INTERNAL EXPOSURE IN information i-found in the RESTRICTED AREAS Appendices) g n20.701 USE OF PROCESS OR OTHER ENGINEERING CONTROLS (Was found in NUREG 0041) w L' n20.702 USE OF OTHER CONTROLS (Was in NUREG 0041) E 28 p =_ E B ^ ^

r h2 n20.703 USE OF INDIVIDUAL RESPIRATORY PROTECTIVE EQUIPMENT (was in NUREG 0041) n20.704 FURTHER RESTRICTIONS ON THE USE OF RESPIRATORY PROTECTIVE EQUIPMENT (Was in NUR"G 0041) SUBPART I - STORAGE AND CONTROL OF LICENSED MATERIAL n20.801 SECURITY OF STORED MATERIAL (Was in o20.203, o20.207) n20,802 CONTROL OF MATERIAL NOT IN STORAGE (Was in o20.207) SUBPART J - PRECAUTIONARY PROCEDURES n20.901 CAUTION SIGNS (Was in o20,203) n20.902 POSTING REQUIREMENTS (Was in o20.203) n20.903 EXCEPTIONS TO POSTING REQUIREMENTS (Was in o20.204) n20.904 LABELING CONTAINERS (Was in o20.203) n20.905 EXCEPTIONS TO LABELING CONTAINERS (Was in o20,204) n20.906 PROCEDURES FOR RECEIVING AND OPENING PACKAGES (Was in o20,205) SUBPART K - WASTE DISPOSAL n20.1001 GENERAL REQUIREMENTS (Was in o20.301) 29 l I _J

~ n20.1002 METHOD FOR OBTAINING APPROVAL OF PROPCSED DISPOSAL PROCEDURES (Was in o20.302) n20.1003 DISPOSAL BY RELEASE INTO SANITARY SEWERAGE (Was in o20.303) n20.1004 TREATMENT OR DISPOSAL BY INCINERATION (Was in o20.305) n20.1005 DISPOSAL OF SPECIFIC WASTES (Was in o20.306) n20.1006 TRANSFER FOR DISPOSAL AND MANIFESTS (Was in o20.311) n20.1007 COMPLIANCE WITH ENVIRONMENTAL AND HEALTH PROTECTION REGULATIONS (Not a specific section in old Part 20) SUBPART L - RECORDS n20.1101 GENERAL PROVISIONS (Not a specific section in old Part 20) n20,1102 RECORDS OF RADIATION PROTECTION PROGRAMS (Not a specific section in old Part 20) n20.1103 REC.ORDS OF SURVEYS (Was in o20.401) n20.1104 DETERMINATION OF PRIOR OCCUPATIONAL DOSE (Was in c20.102) n20.1105 RECORDS OF PLANNED SPECIAL EXPOSURES (Not a specific section in old Part 20) n20.1106 RECORDS OF INDIVIDUAL MONITORING RESULTS 30

fj (Was in o20.407) n20.1107 RECORDS OF DOSE TO INDIVIDUAL MEMBERS OF THE PUBLIC (Was in o20.106, 10CFR50 Appendix I,

ODCM, Semi-Annut 1 Radioactive Ef fluent Report) n20.1108 RECORDS OF WASTE DISPOSAL (Was in o20.401) n20.1109 RECORDS OF TESTING ENTRY CONTROL DEVICES FOR VERY HIGH RADIATION AREAS (Not a specific section in old Par':. 20.

Covered as a surveillance at CPS) n20.1110 FORM OF RECORDS (Not a specific section in old Part 20) SUBPART M - REPORTS n20.1201 REPORTS OF THEFT OR LOSS OF LICENSED MATERIAL (Was in o20.402) n20.1202 NOTIFICATION OF INCIDENTS (Was in o20.403) n20.1203 REPORTS OF EXPOSURES, RADIATION

LEVELS, AND CONCENTRATIONS OF RADIOACTIVE MATERIAL EXCEEDING THE LIMITS (Was in o20.405) n20.1204 REPORTS OF PLANNED SPECIAL EXPOSURES (Does not exist in old Part 20) 31

[- n20.1205 [ RESERVED) n20.1206 REPORTS OF INDI'/IDUAL MONITORING (Was in o20.407) EXEMPTIONS AND SUBPART N ADDITIONAL REQUIREMENTS n20.1301 APPLICATIONS FOR EXEMPTIONS (Was in o20.501) n20.1302 ADDITIONAL REQUIREMENTS (Was in o20.502) SUBPART O - ENFORCEMENT n20.1401 VIOLATIONS (Was in o20.601) APPENDICES nAPPENDIX A oAPPENDIX A PROTECTION FACTORS FOR 9ROTECTION FACTORS FOR RESPIRATOPS RESPIRATORS 'Now in nAPPENDIX A) (Was in oAPPENDIX A) nAPPENDIX B oAPPENDIX B ANNUAL LIMITS ON INTAKE (ALIs) CONCENTRATIONS IN AIR AND WATER AND DERIVED AIR CONCENTRATIONS ABOVE NATURAL BACKGROUND (DACs) OF RADIONUCLIDES FOR (Now in nAPPENDIX B with new bases) OCCUPATIONAL EXPOSURE; 10NCENTRATLNS IN AIR AND WATER ~ EFFLUENTS, CONCENTRATIONS FOR RELEASE TO SEWERAGE (Was in oAPPENDIX B) nAPPENDIX C oAPPENDIX C QUANTITIES OF LICENSED MATERIAL '(Does not exist in-old Part 20) REQUIRING LABELING (Does not exist in old Part 20) 32 A

~~ ) nAPPENDIX D oAPPENDIX D j UNITED STATES NUCLEAR REGULATORY (UNITED STATES NUCLEAR REG'LATORY COMMISSION REGIONAL OFFICES COMMISSION REGIONAL OFFICES, (Was in JAPPENDIX D) nAPPENDIX E oAPPENDIX E [ RESERVED] (Does not exist in old Part 20) nAPPENDIX F oAPPENDIX F REQUIREMENTS FOR LOW LEVEL WASTE (Does not exist in old Part 20. TRANSFER FOR DISPOSAL AT LAND Content does exist in c20.311 for DISPOSAL FACILITIES AND transfer for disposal and MANIFESTS manifests.) d i 33

$) APPENDIX B Terms Used to Characterize Dose or Exposure 1. Absorbed Dose-The energy imparted by Jonizing radiation per unit mass of irradiated material. 2. Collective Dose-The sum of the individual doses received in a given period of time by a specified population fron exposure to a specified radiation source. 3. Committed Dose Equivalent- (HT 50), The dose eclivalent to organs or tissues of refere,nce (T) that will be received from the intake of radioactive material by an individual during the 50 yNr period tollowing the intake. 4. Committed Effective Dose Equivalent- (H,3n=7 vHIAo), the sum of g 7 the products of the weighting factors applicable to each of tne body crgans or tissues which ere irradiated and the committed dose equivalent to the organs or tissues. S. Deep Dose Equival ent- (H ), which applies to external whole-d body exposure, is the dcsc equivalent at a tissue depth 2 of 1 cm (1000 mg/cm ), 6. Dose (Radiation Dose)- A generic term which can mean absorbed

doso, dose equivalent, effective dose equivalent, committed dose equivalent, committed effective dose equivalent, or total effective dose equivalent, as defined in other paragraphs in this section.

7. Dose Equivalent- (H ), the product of the absorbed dose in 7 tissue, quality factor, and all other necessary modifying factors at the location of interest, expressed in Rem or Sievert. 8. Effective Dose Equivalent- (H ), the sum of the products of g the dose equivalent to the organ or tissue (H ) and the 7 weighting factors (w ) applicable to each of the body y organs or tissues which are irradiated, (H =TVH). T 7 g 9. External Dose-That portion of the dose equivalent received fron radiation sources outside of ths body 10. Eye Dose Equivalent-The external exposure of the lens of the eye and is taken as the dose equivalent at a tissue depth of 2 0.3 cm (300 mg/cm), 11. Internal Doce-That portion of the dose equivalent received from radioactive raterial.taken into the body. 34 1

fQ I 12. Occupational Dose-The dose received by an individual in a restricted area or in the course of employment in which the individual's assigned duties involve exposure to radiation and to radioactive materials from licensed and unlicensed sources of radiation, whether in the possession of the licensee or other person. Occupational Dose does not include dose received from natural background, as a patient from medical practices, from voluntary participation in medical research programs, or as a member of the general public. 13. Planned Special Exposure-A planned, infrequent exposure, separate from and in addition to the annual dose limits. 14. Public Dose-The dose received by a member of the public from exposure to radiation and to radioactive material relensed by a licensee, or to another source of radiation either within the licensee's controlled area or in unrestricted areas, but not to include occupational dose, or natural background

doses, doses from medical practices, or from voluntary participation in medical 1

research programs. 15. Shallow Dose Equivalent- (H,), The external exposure of the skin or an extremity, is taken as the dose equivalent at 2 a tissue depth of 0.007 cm (7mg/cm ) 16. To'ca. Effective Dose Equivalent-The sum of the deep dose .quivalent (for external exposures) and the committed effective dose equivalent (for internal exposures). 35

\\.' ~L I l l APPENDIX C PROCEDURE MATRIX WITH EXISTING AND PROPOSED 10 CFR 20 PROCEDURE RADIATION PROTECTION PROCEDURE TITLE d QCFR20 IMPACT NUMBER OLD NEW 1001.01

• CPS Organization, Responsibilities and ANSI 3.1 n20.101 Minimum Qualifications ANSI N546 RG 1.8, 8.8 1002.01
• Indoctrination and Training o20.206 n20.101 1003.01
• Design Control and Modification RG 6.8, 8.10 1005.01

^ Preparation, Review, Approval, and o20.205 n20.101 Implementation of and Adherence to o20.101 to n20.906 Station Procedures and Documents 1005.02

• Organization of the Station Operating n20.101 Manual 1017.01
• Plant Records Preparation, Transmittal o20.401 n20.1101 and Retention 1017.02
• Training Records o20.206 n20.1101 1019.04
• Tool and Material Control for the o20.101 n20.801 Refuel Floor and Fuel Handling Floor n20.101 During Refueling Outages 1019.05
• Dry Radioactive Waste and Laundry o20.207 n20.1001 Handling Program c20.306 n20.101
• = Not Radiation Protection Department Procedures, but are either a major impact on the RP Program, or are programs required specifically by the 10CFR20 Regulations.

I 1023.10 Containment Purge Operational Data o20.105 n20.301 1 Gathering Program and Containment Access Management Program 1024.10 Radiological Controls Training Program o20,206 n20.101 36

/M3F2. PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT NUMBER OLD NEW 1024.15 Exposure Control and Routine Exposure o20.101 n20,201 Report o20.103 (c) ( 2 ) n2 0. 601 n20.701 1024.16 Radiation Health Advisory Board NR NR i 1024.20 Radiological Work Control n20.101 1024.25 Radiological Access Control n20.101 1024.30 Radioactive Material Control o20 207 n20,208 1024.35 Control of Radioactive Effluents o20.106 n20.301 1024.40 Contamination Control o20.101 n20.101 1024.45 Management of Radiation Protection XX n20.101 Department Computer System 1024.50 Radiolog!. cal Environmental Monitoring o20.106 n20.1007 Program 1024.60 Respiratory Protection Program o20.103 n20.703 1024.65 ALARA Program R.G.8.8 n20.101 1024.80 Employee Compensation Reepest NR NR 1931.10 Radiation Protection Department NR n20.101 Organization and Functions 1902.10 Radiological Controls Training o20.206 n20.101 Requirements ANSI 3.1 ANSI 3.1 1903.11 Dose Extensions o20.101 n20.201 o20.103 n20.206 1903.20 External Exposure Monitoring o20.202 n20.502 1903.21 Noble Gas and Beta Dose Equivalent o20.103 n20.203 Calculations 1903.25 Visitor Dosimetry o20.202 n20.301 0 1903.30 External Exposure Investigations c20.405 n20.1203 1904.10 Internal Exposure Bioassay o20.108 n20.204 1905.10 Radiation Work Permit (RWP) n20.101 37 l

PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT OLD NEW NUMBER 1905.20 Radiological Area Posting o20.302 n20.902 1905.21 High Radiation Area Key Control o20.203 n20.601 n20.602 1905.30 Control of Radiography Operations o20.103 n20.602 o20.203 n20.603 1905.31 Control of Diving Operations o20.103 n20.206 1905.32 Initial Dryvell Entries o20.201 n20.501,2 o20.203 n20.601 1906.10 Access Control - Radiation Prottation o20.201 n20.101 n20.501 1906.20 Containment Access Management Program o20.201 n20.101 n20.501 (CAMP) 1907.10 Receipt of Radioactive Material o20.205 n20.906 1907.20 Radioactive Source Control, Leak o20.207 n20.801,2 Testing, and Accountability 1907.30 Control of Radioactive Material o20,207 n20.801,2 1908.10 Liquid Radioactive Effluent Release o20.105,6 n20.1007 n20.301,2 1908.20 Gaseous Radioactive Effluent Release o20.105,6 n20.301,2 1909.20 Radiological Reporting o20.401-9 n20.1201-6 1909.21 Radiological Improvement Reports n20.101 1910.01 Radiation Protection Computer System n20.101 Management 1910.10 Management of the ND1066 n20.101 1910.20 Management of the ND6685 Computers n20.101 1910.30 Management of the Whole Body Counter. o20.103,8 n20.202,4 1910.50 Computerized Dose Record Repair o20.407 n20.1106 1910.60 Radioactive Release Report Generating o20.405 n20.1203 System Database Maintenance 1910.70 AR/PR System Management o20.106 n20.302 1911.10 Radiological Control Instrumentation n20.101 Calibration and Control 38 J

m I 1 ~ PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20.. IMPACT NUMBER OLD NEW 1912.10 Use cf Respiratory Protection Equipment NUREG0041 n20,703 1913.02 Radioactive Waste Storage and Inventory o20.302,3,n20.1001,2 o20.306 n20.1005,6 1913.04 Solid Radioactive Waste Radiological o20.401 n29.1108 Reporting 1914.15 Control of Temporary Shielding n20.101 3920.00 RadWaste Operating Philosophy ? ? 4979.01 High Airborne Radioactivity o20.103 n20,204 n20.703,1203 4979.04 Abnormal Airborne Radioactive Release o20.405 n20.1203 4979.05 Abnormal Release of Radioactive Liquids o20.103,6 n20.1203 4979.06 Radioactive Spill o20.103,6 n20.1203 4979.07 Dropped Fuel Bundle in the Fuel o20.101 n20.101, Building 601,2,3 4979.08 Dropped Fuel Bundle in the Containment o20.103,6 n20.101, Building n20.601,2 4979.09 Response to Fuel Handling Building Area ? ? Radiation Monitor (ARM) Alarm 4979.10 Containment Building Exhaust Process T.O. T.S. Radiation Monitor (PRM)(Address:201-- 204) Problem 4979.11 Containment Building Fuel Transfer Pool T.S. T.S. Vent Plenum PRM (Address: 205-208) Problem 4979.12 Fuel Building Ventilation Exhaust PRM T.S. T.S. (Address: 209-212) Problem 4979.13 Main Control Room Air Intake PRM T.S. T.S. (Address:213-216) Problem 4979.14 Station HV7' Exhaust PRM (Address: 125-T.S. T.S. 126) Probli.a 4979.15 Standby Gas Treatment System Exhaust T.S. T.S. PRM (Address: 127, 128) Problem 39 4

~ r PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT NUMBER OLD NEW 4979.16 Containment Continuous Purge Exhaust T.S. T.S. PRM (Address: 217-220) Problem 4979.17 Pretreatment Off-Gas PRM (Address: 131) T.S. T.S. Problem 4979.18 Post-Treatment Off-Gas PRM (Address: T.S. T.S. 132, 133) Problem 4979.19 Radwaste Erfluent PRM (address: 140) T.S. T.S. Problem 4979.20 Plant Service Water PRM (Address: 134) T.S. T.S. Problem 4979.21 Component Cooling Water PRM (Address: T.S. T.S. 135) Problem 4979.22 Residual Heat Removal PRM (Address: T.S. T.S. 136, 137) Problem 4979.23 Fuel Pool Heat Exchanger PRM (Address: T.S. T.S. 138, 139) Problem 4979.24 Main Control Room (MCR) Direct T.S. T.S. ( Radiation Area Radiation Monitor (Address: 030) Problem 4979.25 Fixed or Portable Digital Area T.S. T.S. Radiation Monitor Problem 4979.27 Continuous Air Monitors (Address: 102-T.S. T.S. 123) Problem 497E.28 Meteorological Tower Digital T.S. T.S. Acquisition Module (DAM) (Address: 150) Problem 4979.29 HVAC/SGTS Stack Flow DAM (Address: 151) T.S. T.S. Problem 4979.30 Liquid Flow DAM (Address: 152) Problem T.S. T.S. 4979.31 SGTS Exhaust High Range Monitor-T.S. T.S. Accident Monitor (AXM) (Address: 221) Problem 40 _ _ _ _ _ _ _ _ - _ _ - - - - - _ _ - _ - _ _ _ _ _ = -

/hf35-2_. PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT NUMBER OLD NEW 4979.32 HVAC Vent High Range Monitor Accident T.S. T.S. Monitor (AXM) Address: 222) Problem 4979.33 Dropped Fuel. Bundle Warning System T.S. T.S. Alarm 5140.01 AR/PR Alarn Panel 5140 Annunciators T.S. T.S. 7001.01 Radiation Protection Indoctrination o20.206 n20.101 7001.02 Radiation Protection Key Control o20,203 n20.601,2 n20.801 7001.03 Radiation Protection Shift Logging and n20.101 Turnover 7001.04 Radiation Protection Follow-up Report n20.101 7002.01 MPC-Hr (Maximum Per asible o20.103 n20.204 Concentration-Hour) Accountability o20.401 n20.502 n20.704 7002.02 Cleaning, Repair and Certification of NUREG0041 n20.704 Respiratory Protection Equipment NUREG0041 7002.03 Respirator Fitting Using the Dynatech NUREG0041 n20.703 Frontier Corporation Model 260B 7002.04 Preventative Maintenance on Dynatech n20.101 Frontier Respirator Fit Test Booth 7002.05 Operating the Bauer Unus 5 Air n20.101 Compressor 7003.01 Personnel Decontamination o20.405 n20.101 7003.02 Skin Dose Calculation o20.103 n20.502 7003.20 Maintaining Exposure History Records o20.401 n20.1106 7013.10 Shipping Radioactive Material o20.311, n20.1006 020.401 n20.1108 7013.11 RADMAN, RAMSHIP and TRASHP Database n20.101 Maintenance 7013.20 Packaging Radioactive Material o20.203 n20.904 7013.40 10CFR61 Compliance Program 10CFR61 10CFR61 7013.41 Classification of Radioactive Waste o20.301 n20.1001 41 1

bfO c. s PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT NUMBER OLD NEW 7017.01 Radiation Protection Records o20.401 n20.1102 7092.01 Operatica of the Gastech Model 1562 o20.206 n20.101 Protechtor and Industrial Scientific Model MX 241 7092.02 Operation of the Drager Multi-Gas o20.206 n20.101 Detector 7092.03 Operation of the Gastech Model 1220 Gas o20.206 n20.101 Alarm System 7092.04 Operation of *be Alnor Alarming o20.206 n20.101 Dosimeters 7100.00 Clinton Power Station Radiation Survey o20.201 n20.501 Sheets F001-F240 7105.01 Radiological Surveys o20.201 n20.501 7105.02 Air Sample Assay o20.103 n20.502 7105.03 New Fuel Receipt Surveys o20,201 n20.501 7105.10 Hot Particle Contamination Control o20.201 n20.501 3 7105.11 Conduct of Transfer Evolutions 7105.12 Conduct of Refuel Activities 7179.01 Radiological Environmental Reports o20.405 n20.302, n20.1203 7179.10 Radiological Environmental Sample Storage and Shipment 7179.11 Radiological Environmental Soil and o20.105 n20.302 Snow 55u.pling 7179.16 Radiological Environmental Grass o20.105 n20.302 Sampling 7179.17 Radiological Analysis Laboratory Safety Check wording, refs Manual (DRAFT) 7179.20 Radiological Environmental Sample o20.105 n20.302 Analysis Scheduling and Preparation 42

PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT OLD NEW NUMBER t 7179.30 Quality Program of the Radiological Ck wording, refs Environmental Monitoring Program's j Analysis Laboratory (DRAFT) 7179.31 Chemical Inventory Record (DRAFT) 7179.32 Reagent Preparation (DRAFT) { 7179.33 Calibration and Operation of Electronic Analytical Balance (DRAFT) l l 7180.01 Stack Effluent Sampling and Analysis o20.105 n20.302 3 7180.10 Drywell Leak Detection Continuous Air o20.105 n20.302 5 Monitor Sampling and Analysis 7211.01 Operation of the Gamma Calibrator o20.206 ni)-Jf' ( f 7211.02 Operation of the Model 142-10 Dosimeter o20.206 p ' '. 2 01 Irradiator ex. / 0 3 7211.03 Operation of the Model 149 Neutron o20.;! < Source 7211.04 Operation of the Victoreen Model 570 o20.206 n20.101 Condenser R-Meter 7211.05 Radiation Protection Department Survey o20.206 n20.101 Instrument Response Checks 7211.07 Operation of the Victoreen High Range o20.206 n20.101 Field Calibrator Model 878-10 7211.10 Operation of the PRS-1 o20.206 n20.101 7211.11 Operation of the PRS-2P/NRD o20.206 n20.101 7211.31 Operation of TASC-12 Alpha / Beta o20.206 n20.101 Counting Systems 7410.30 Operation of the Whole Body Counter o20.206 n20.101 7410.31 Operation of the ND6685 - HPGe Gamma o20.206 n20.101 Spectroscopy System 7410.32 Operation of the Gamma-10 Portal c20,206 n20.101 Monitor 43

d PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT NUME.ER OLD NEW 7410.33 Operation of the PCM-1A/B o20,206 n20.101 7410 35 H: 3h Activity Sample Gamma Analysis o20.206 n20.101 7416,i2 Effluent Management Reports o20.105,6 n26.301 j n20.1203 p 7410.64 Emergency Offsite Dose Calculation o20.106 n20.301 ( Using the SR Computer System y 7410.65 Operation of the Polaroid Video Printer o20.206 n20.101 and Processor 7i >>.71 Operation of the AR/PR Control o20.206 n20.101 Terminals T; 7410.72 Operation of the AR/PR CRT o20.206 n20.101

y I

t-} 7410.73 Operation of the Emergency Operations o20,206 n20.101 Facility Continuous Air Monitor 7410.75 Operation of the Digital AR/PR Monitors o20.206 n20.101 7410.76 Operation of the Analog Area Radiation c20.206 n20.101 Monitors 741^.77 Operation of the Eberline Accident o20,206 n20.101 Range Monitors 7410.78 Operation of the Dropped Fuel Bundle c20.206 n20.101 Warning System 7410.80 AR/PR Setpoint Modification o20.106 h20.301,2 7410.84 Monthly Non-Technical Specification ARM o20.206 n20.101 Channel Checks 7910.30 Calibration of the Whole Body Counter o20.103,6 n20.20t. o20.108 n20.1102 7910.31 Efficiency and Energy Calibration of o20.101,3 n20.502 the HPGe Detector o20.401 n20.1102 7910.40 Calibration of the Beta Aerosol Beacon o20.103,6 n20.204 o20.108 n20.1102 7910.73 PING-1A Calibration Data Sheet o20.401 n20.1102 7910.74 Analog ARM Channel Functional Test Data o20.401 n20.1102 Sheet 44 ] m-

/ ~1 PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT OLD NEW NUMBER 7910.75 Monthly Digital ARM Source Checks o20.101 n20.201 7910.76 Monthly Exhaust Duct PRM Source Checks o20.106 n20.301 7910.84 Monthly Non-Technical Specification ARM o20.101 n20.201 Channel Checks 7911.01 Calibration of the Gamma Calibrator o20.101 n20.201 o20.401 n20.1102 7911.02 Calibration of the Model 142-10 Dosimeter Irradiator 7911.03 Calibration of the Model 149 Neutron Source 7911.04 Calibration of in Air Gamma-Sources 7911.05 Statistical Check of Scalers and Counters 7911.10 Calibration of the PRS-1 7911.11 Calibration of the PRS-2P 7911.12 Calibration of the MS2-/MS3 7911.13 Calibration of the RC-2/RO-2A 7911.14 Calibration of the RO-7 7911.16 Calibration of the E-120 7911.17 Calibration of th' E-520 7911.18 Calibration of the Teletector (6112B) 7911.20 Calibration of the PAC-lSAGA 7911.21 Calibration of the RM-20 and the RM-14 7911.22 Calibration of the E-530N 7911.23 Calibration of Pocket Dosimeters 7911.24 Calibration of the RADECO H-809C, H-809V and H-809B2 45

-2 4 PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFke0 IMPACT NUMBER OLD NEW 7911.25 Calibration of the Eberline RAS-1 7911.26 Calibration of the E-130A 7911.27 Calibration of the BC-4 7911.28 Calibration of the PRM-6 with a AC-3-7 Probe 7911.30 Calibration of the PNR-4 7911.31 Calibration and Performance Verification of the TASC-12 Alpha and Beta Counter 7911.32 Calibration of the AMS-2 7911.33 Operation and Calibration of the Water Compositer Sampler 7911.34 Calibration of the Lapel Air Sampler 7911.35 Calibration of the ALNOR Alarming Dosimetars 7911.36 Calibration of the FAG FH40 F5 and so (DRAFT) 7911.37 Calibration of the FAG FH40 FT Telescope (DRAFT) 9911.11 Liquid PRM Surveillance Monthly Source Check 9911.16 Gaseous PRM Surveillance Monthly Source Checks 9911.17 AXM Surveillance Monthly Channel Checks 9911.24 AR/PR Shiftly/ Daily Surveillances 9911.50 Liquid Discharge Surveillance 9911.51 Liquid Radioactive Effluent Surveillance Monthly 9911.59 Gaseous Radioactive Effluent Surveillance-Monthly 46 j

PROCEDURE RADIATION PROTECTION PROCEDURE TITLE 10CFR20 IMPACT NUMBER OLD NEW 9911.60 Gaseous Radioactive Effluent Surveillance 9911.61 Vent Exhaust Treatment System Surveillance - Trigger 9911.70 Radiological Environmental Monitoring o20.105,6 n20.302 Program /REMP) Surveillance For o20.401 n20.1102 Airborne adiciodine and Particulates - Monthly 9911.71 REMP Milk Monitoring Surveillance 9911.72 REMP Direct Radiation Monitoring Surveillance 3911.73 REMP Aquatic Pathway Sampling Surveillance 9911.75 REMP Surveillance Annual Land Use Census 9911.78 REMP Surface Water Monitoring Surveillance 9911.79 REMP Ground Water Monitoring Surveillance 9911.80 REMP Vegetation Monitoring Surveillance 9974.01 Sealed Source Contamination Leak Test 9974.02 Start-up Source Contamination Leak Test 47 s \\

/ Man APPENDIX D COST ESTIMATES FOR IMPLEMENTING PROPOSED REVISION 10CFR2O PIogram Activity Est. 1989 $ Occupational Dose Limits 180,000 Summation Internal + External Dose 960,000 Embryo / Fetus Exposure Limits 50,000 Individual Monitoring 20,000 Records-Individual Monitoring 240,000 Records of Doses to Public 25,000 Reports of Personnel Monitoring 90,000 Personnel Training 175,000 Procedure Revisions 125,000 TOTAL (Does NOT include contractor services) 1,865,000 ESTIMATED ADDITIONAL COST TO MAINTAIN COMPLIANCE WITH NEW 10CFR20 Procram Activity Annual Est. Added Cost In 1989 Dollars ($1 Occupational Dose Limits 60,000 Summation Internal + External Dose 190,000 j Embryo / Fetus Exposure Limits 40,000 Individual Monitoring 75,000 Records-Individual Monitoring 2.,500 Records of Doses to Public 15,000 Reports of Personnel Monitoring 15,000 Personnel Training --0-- Procedure Revisions --0-- TOTAL (Does NOT include contractor services) $397,000 48 I )}}