ML20205T315
| ML20205T315 | |
| Person / Time | |
|---|---|
| Issue date: | 02/10/1978 |
| From: | Cyr K NRC |
| To: | Higginbotham L NRC |
| Shared Package | |
| ML20205T301 | List: |
| References | |
| FOIA-88-203 NUDOCS 8811140211 | |
| Download: ML20205T315 (2) | |
Text
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- c. rosss COMM:S$10N 10 C issue Date: 11/1/78 k , , , , . ** .h '
FEB 2 0 1578 ,
MEMORANDUM FOR:
L. B. Higginbotham, Acting Director.
Division of FFNSI, IE FROM:
Karen Cyr, OELD i
SUBJECT:
GUICANCE ON REPORTING REQUIREMENTS O i t
.' F on reporting requirements of 10 CFR 20.403 foll with members of your staff. n Infoma tion was requested on:' l.
1) body deposition of licensed material is reportab under 10 CFR 20
- 2) whether paragrap.403; and ,
of release of radioactive material to restricted areas as !
well as unrestricted areas. '
As to the first question, results of in vivo data do not explicitly t fall within Section. any of the categories of reportable items listed in the Nor do any of the Sections of Part 20 which refer to the ,
use of a bicassay program of results under the requirements make any reference to reporting of those 20.403.
data is not reportable under 20.403 Consequently, in vive ' ,
520.405 to the extent that It would be reportable under together with other measurenents, it >
indicates that limits has occurred. an exposure,to corcentrations in excess of applicable ;
t 520.403(a)(2) and 20.403(b)(2) are applicable to rele ;
restricted and unrestricted areas. i that any release of the magnitude specified, whethei or unrestricted area, should be reported.
The concern was that a ,
a loss of control over the material. release of this magnitude, regard !
Sihce 120.403 ,
apply to releases in both areas.either restricted or unrestricted areas, r811140211 001017 L
F -203 PDR !
' .' =2-Enclosure to IE Manaul 10 CFR 20.403 ,
!ssue Date: 11/1/78 '
Confusion has arisen, however, because the section refers to releases-in excess of the limits in Table !!, Appendix B. Elsewhere in Part 20 Table II is used to detemine limits on radioactivity in releases of effluents to unrestricted areas. See reference 120.106(a). Table I, in contrast, is useo only in detemining limits on individual ex:osures ,
in restricted areas. See reference 20.103(a)(1) and (2). Therefore, !
it is reasonable to infer from the face of the regulation that Table II applies only to unrestricted areas and therefore, only releases to unrestricted areas are reportable under the requirenents of 20.403.
Consetuently, in our view, the interpretation of 120.a03(a)(2) and (b)(2) is ambiguous at best.. The regulation needs to be clarified -
to more accurately identify those releases which the Staff believes need to be reported and to put licensees on notice of what releases tr.ust be reported., . -
The proposed letter from one of the regional offices is not in accord with the past practice which is to be concerned with releases of a certain magnitude, apart from wnether an overexposure has occurred, because they represent a loss of control of material. The reportacility
, of releases to restricted areas should not be tied to an overexposure incident. In addition, overexposures to individuals in restricted areas are to be detemined only by the limits for airborne concentra-tion ir. 20.103 (Table I, Appendix B).
1'fw~.) u V2ren Cyr i Attorney
. Rulecaking and Enforcement Division l j
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