ML20211B674
| ML20211B674 | |
| Person / Time | |
|---|---|
| Issue date: | 09/14/1978 |
| From: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Davis A, James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20211B681 | List: |
| References | |
| NUDOCS 8610200186 | |
| Download: ML20211B674 (1) | |
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UNITED STATES y
NUCLEAR REGULATORY COMMISSION
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MEMORANDUM FOR:
J. G. Keppler, Director, Region III A. B. Davis, Chief FFMSB, Region III FROM:
L. B. Higginbotham, Acting Director FFMSI, HQ
SUBJECT:
APPLICABILITY OF FOOTNOTE (1) 0F 10 CFR 20.103(a)(1)
Enclosed is a response written by OHSB, Office of Standards Development, concerning the subject applicabilty of Footnote (1), which, according to the guidance provided, applies to any applicable subsection of 10 CFR 20.103. A verbal explanation was provided to Bert Davis on September 12, 1978.
What may not be entirely clear 'is the. fact that the airborne concentration limit in Appendix B for tritium is one-half of the actual limit for inhalation because one half of the tritium environment to which a person is exposed is absorbed through the skin.
Hence, a bioassay sample would represent both inhalation and absorption and the limit would be twice the limit for inhalation in Part 20 or about 484 microcuries. Therefore, in the case presented to HQ for clarification, the licensee is correct in his assertion.
During the discussion with Bert Davis on 9/12/78 it was agreed that OELD concurrences or opinions should not be sought because guidance is the only issue in this matter.
We consider Action Item No. F30414H3 closed.
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LeoB.Higg@xothan, Acting Director Division of Tuel Facilities and Materials Safety Inspection Office of Inspection and Enforcement
Enclosure:
As stated cc: w/ enclosure H. E. Book, RV M own, RIld J. Sutherland, RII H. Crocker, RI CONTACT:
J. R. Metzger 49-28188 8610200186 780914 PDR 18(E PDR MISC
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