ML20244D848
| ML20244D848 | |
| Person / Time | |
|---|---|
| Issue date: | 04/10/1989 |
| From: | Congel F Office of Nuclear Reactor Regulation |
| To: | Bernero R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 8904240149 | |
| Download: ML20244D848 (3) | |
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APR 101989 HEMORANDUM FOR: Robert it. Bernero, Director Office of Nuclear Material Safety and Safeguards FROM:
Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
QUESTIONS FROM COMMISSIONER CURTISS REGARDING PROPOSED CLEAN AIR ACT STANDARDS FOR RADIONUCLIDES The March 13, 1989 memorandum from Commissioner Curtiss to the Executive Director for Operations posed three questions regarding the subject proposed EPA Clean Air Standards. NRR consideration of Question 1 and the second part of Question 2 are presented below. We defer to OGC and OE, as appropriate, for consideration of the first part of Question 2 and Question 3, since they generally fall outside of our purview.
1.
How do each of the four options proposed by EPA differ from the regulatory limits already imposed by the NRC on its licensees?
KRC power reactor licensees presently must conform to dose limits imposed by 10 CFR 20 and 10 CFR 50, Appendix I, as well as the EPA limits of 40 CFR 190 imposed by 10 CFR 20.106(g). Effectively these dose limits for members of the public are as follows:
a) 10 CFR 20 limit:
Total dose: 500 mrem /yr b) 10 CFR 50, Appendix I: "Desian objectives" to meet ALARA:
Dose from gaseous effluents: 5 mrem /yr total body 15 mrem /yr any organ, including thyroid pfY h
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c) 40 CFR 190 limit:
Total dose: 25 mrem /yr whole body or any organ except thyroid 75 mrem /yr thyroid The term " design objective" is used in the context of 10 CFR 50, Appendix I because licensees are required to design nuclear power plants to meet the stated objectives. They are expected to meet the objectives during operation as well; however, if the objectives are exceeded, the occurrence would set in motion certain corrective actions, but would not be considered an overexposure per se.
Similar limit values for air doses proposed for the EPA air standards are:
Options A and B 10 mrem /yr Option C 3 mrem /yr Option D 0.03 iarem/yr Although there are minor differences in fine structure relative to the defined units attached to each cf the above numbers, intercomparisons can be made, number for number, with errors of only a few percent.
2.
".....Are the proposed limits technically enforceable?
Integrated radiation doses cannot be measured accurately, if at all, at the levels proposed for Options A, B, C, and D.
Enforcement would have to be based on calculations performed using specific models.
It should be
-noted however, that preliminary comparisons by NRR staff of dose results presented by EPA in background documents accompanying the proposal package with doses obtained with standard NRC modeling used for Appendix I compliance calculations, show differences as high as several hundred percent. We are continuing efforts to determine the precise reasons for these differences.
Otii;ird 4.. % ri ' C ' 01 Frank J. Congel, Director Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation Distribution: See Page 3
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