ML20213E807

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Responds to 840413 Memo on 10CFR50.72 Notifications Re Meaning of Unrestricted Areas.Understanding of Intent of 10CFR50.72(b)(2)(iv) Correct.No Need to Clarify Wording of 10CFR50.72 at Present Time
ML20213E807
Person / Time
Issue date: 05/14/1984
From: Liza Cunningham
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To: Tonus L
Office of Nuclear Reactor Regulation
Shared Package
ML20213E720 List:
References
FOIA-86-729, RTR-NUREG-0133, RTR-NUREG-133 NUDOCS 8405230135
Download: ML20213E807 (2)


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.s q May 14, 1984 HEMORANDUM FOR: L. H. Tonus, Systems Engineer Technical Support Secticn TMI Program Office FROM: LeMoine J. Cunningham, Chief Section 2, Operating Reactor Programs Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement

SUBJECT:

10 CFR 50.72 NOTIFICATIONS - HEANING OF " UNRESTRICTED AREAS" I am writing in response to your memorandum to me on "10 CFR 50.72 Notifi-cations," dated April 13, 1984.

Your understanding of the intent of 10 CFR 50.72(b)(2)(iv) is correct. The

" expanded definition" of " unrestricted area" as used in NUREG-0133 should be used in order to maintain consistency with the technical specifications.

That definition is as follows (NUREG-0133; page 6): .

"any area at or beyond the site boundary access to which is not con-trolled by the licensee for purposes of protection of individuals from exposure to radiation and radioactive materials, and any area within the site boundary used, for residential quarters or industrial, commercial, institutional and recreational facilities."

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This question has been raised earlier and addressed, together with related

. questions, in the enclosed memoranda and in NUREG-1022 Supplement No.1,

" Licensee Event Report System," page 16.

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Neither we, nor the Radiological Assessment Branch, believe that there it a need to clarify the wording of 10 CFR 50.72 at this time; however, we believe that the wording should be clarified when 10 CFR 50.72 is revised for other reasons.

3 , 'W 6Moine . Cunningham, Chief

  • Section 2, Operating Reactor Programs Branch Division of Quality Assurance, Safeguards, and Inspection Programs Office of Inspection and Enforcement

Enclosures:

I1 (1) " Inspection Guidance - 50.72," memorandum from L. J. Cunningham u for R. Greger, Nov. 15, 1983.

(2) " Notification and Reporting of Releases of Radioactive Materials,"

memorandum from C. A. Willis to D. R. Muller, Jan. 20, 1984.

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Distribution:

L. Barrett, TMI

P. G. Grant, TMI l' J. Bell, TMI l F. Young, TMI.

F. Congel, RAB/NRR '

C. Willis, NETB/NRR D. Allison, IE E. Weiss, IE F. Hebdon, AEOD -

R. R. Bellamy, RI .

D. M. Collins, RII C. J. Paperiello', RIII R. E. Hall, RIV F. A. Wenslawski, RV M. M. Shanbaky, RI W. J. Pasciak, RV G. R. Jenkins, RII -

D. M. Montgomery, RII L. R. Greger, RIII M. C. Schumacher, RIII B. Murray, RIV G. P. Yuhas, RV .

P. F. McKee, IE J. G. Partlow, IE '

J. N. Grace, IE

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- DCS 016 ORPB reading DQASIP reading JD Buchanan, IE SL Ramos, IE

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Record Note: F. Congel/RAB agreed there is no need to revise 50.72 now.

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M90RANDUM FOR: Robert Greger, Section Chief .

Emergency Preparedness & Radiological Safety Branch Region III FROM:

LeMoine J. Cunningham, Section Chief

  • Section 2, Operating Reactor Programs Branch Division of Quality Assurance, Safeguards, and Inspection Programs, IE

SUBJECT:

INSPECTION GUIDANCE - 50.72 .

On October 20, 1983, Paul Lovendale requested clarification of several aspects "~

of the new 50.72 notification requirements. The questions related to the requirement that licensees call in notification of radioactive releases that .

exceed the specified concentrations. Specifically, the questions were: 1)what reteorological data should be used in determining offsite concentrations? (e.g.,

annual average, real time or worse case?) and 2) what location should be used?

(e.g., unrestricted area as defined by Part 20 or the expanded definition as specified in NUREG-0133?).

In addition, you noted that the revised 50.72 was incorporated into the 10 CFR by Supplement No.12 issued September 20,, 1983, although the rule change is not effectivt until January 1, 1984. You note that a currently effective version is not in the 10 CFR.

inspection guidance for operating nuclear power reactors concerning 50.72 is

.as follows:

1. Annual average meteorological data should be used for determining offsite airborne concentrations of radioactivity. This is to maintain consistency with the tech specs.
2. The expanded definition of an unrestricted area as. specified in NUREG-0133 should be used. This is to maintain consistency with the tech specs.

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f' P,obert Greger .2~~- NOV 151983 i.

3. The lack of a currently effective version of 50.75'in the 10 CFR loose-leaf version is an administrative problem only. Licensees and inspectors should keep the old pages for reference until January 1,1984. The old version is still the' effective rule until January and deviation from those require-ments in favor of the new requirements would be a technical violation.

However, in such a case, notation in the inspection report without further en'orcement action would be the appropriate approach. .

J' Appropriate NRR, Admin, ELD and IE representatives were consulted during the for.xlation of this guidance.

LeMoine J. Cunningham, Section Chief Section 2, Operating Reactor Programs Branch Division of Quality Assurance, Safeguards, and Inspection Programs, IE cc: J. Partlow, IE -

E. Jordan, IE W. Fisher, IE E. Flack IE F. Congel, NRR

  • R. Bellamy, RI A. Gibson, RII C. Paperiello, R]II R. Hall, RIV -

. F.1.'enslawski, RV

~. P. F. McKee, IE rih:ticr 4 'iles / 1E reading / DQASIP reading /

. Cunningham, I / ORPB reading / J. Partlow, IE / Division Director Reading

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