ML20246J305
| ML20246J305 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 08/18/1989 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| IEIN-81-26, NUDOCS 8909050116 | |
| Download: ML20246J305 (5) | |
Text
_ - _
AUG!8 C9 Docket No.
50-336 Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations Group P. D. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
SUBJECT:
DEFINITION OF " EXTREMITY" FOR PURPOSES OF SETTING OCCUPATIONAL EXPOSURE LIMITS The purpose of this memorandum is to clarify the NPC's position regarding the definition of " extremity" for purposes of setting occupational exposure limits.
NRC inspections have shown that a number of licensees are using a definition of
" extremity" that is contrary to the provisions of 10 CFR Part 20.101, " Radiation Dose Standards for Individuals in Restricted Areas". This regulation specifies that " extremity" dose limits apply to the " hands and forearms; feet and ankler."
Information provided in NRC Information Notice No. 81-26. Part 3. Supplement No.1. his been misunderstood, and was not intended to change what is considered to be an extremity This Information Notice discusses placement of personnel dosimeters for determini.9g whole body doses.
Because of this apparent misunderstanding, we plan no enforcement action if your procedures have incorporated this misunderstanding. We have issued the enclosed morandum to provice clarification on the intent of Information Notice No. 81-26, and what is considered to be an extremity. We request that you ensure your procedures incorporate the applicable dose limits of 10 CFR Part 20.
Your cooperation with us in this matter is appreciated. Please contact me if you have any concerns or questions regarding this matter.
l Sincerely, 1
7.dg'nat signed Ef:
!xcaid R. Schery Ronald R. Bellamy, Chief Facilities Radiological Safety and l
Safeguards Branch l
Division of Radiation Safety and j
l Safeguards Enclosurer Memorandum from LeMoine J. Cunningham to ff-bl Ronald R. Bellamy, et. al., dated June 22, 1989 l
OfflCIAL RECORD COP'F 1
8907050116 090818 P #R 4 DOCK 05000336 FDC
2 A'.' : 1 i 1.;!"
cc w/enti:
W. D. Romberg, Vice President, Nuclear Operations S. E. Scace, Station Superintendent
.D. O. Nordquist, Director of Quality Services R. M. Kacich,' Manager, Generation Facilities Licensing D. B. Miller, $tation Superintendent, Haddam Neck Gerald Garfield,' Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC) 1.-
NRC Resident Inspector State of Connecticut bec w/ enc 1:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
DRP Section Chief J. Shediosky, SRI, Haddam Neck
)
W. Raymond, SRI, Millstone 3 1
D. Jaffe, LPM, NRR J. Dyer, EDD F. Congel, NRR/DREP l
L. Cunningham, NRR/PRPB M. Knapp, DRSS 1
l-M s
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7/8e/89 r/ //89 g.7f-f3 OfflCili RECORD COP'I u-----_--------
ENCLOSURE
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JUN 2 21989 L
MEMORANDUM FOR: Ronald R. Sellamy, Chief. EPRPB, DRSS, Region !
Couglas M. Collins, Chief. EPRPB, DRSS, Region 11 3~
L. Robert Greger, Chief, RFB, DRSS, Region IIT Blaine Murray, Chief, RPSB, DRSS, Region IV Gregory P Yuhas, Chief. EPRPB, DRSS, Region Y L
FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Divistor of Radiatien Protection and Emergency Preparedness Oiitce of Nuclear Reactor Regulation
SUBJECT:
CORRECTION OF MISUNDERSTANDING CONCERNING OCCUPATIONAL DOSE LIttITS FOR " EXTREMITIES" The prrpose of this memorandum is twofold:
(1) to document the correction of a misunderstanding concerning occupational dose limits for " extremities," and (2) to provide guidance concerning potential (niorcement action in cases in I
which licensees have incorporated this niisunderstar. ding into their procedures.
10 CFR Fart 20 provides different occupational dose limits for (1) the 'whole body; head and trunk; active blood-forming organs; lens of eyes; 9r gonads;"
(2) the " hands and foreams; feet and ankles"; and (3) the
- skin of the whole body. " As indicated in the instructions for NRC Form 5, " Current Occupational External Radiation Exposure,* the dose to the " hands anc forearms; feat and ankles" includes the dose to the skin of these body parts. The a;st to the skin is assessed at a depth of 7 mg/cm' in tissue. Thus, the limit for the l:
" skin of the whole body" and the limit for the "whole body..." apply to all parts of the body except the " hands and forearms,' feet and ankles."
I.
The term " extremities" has often been used to desiyste the " hands and fore-arms; feet and ankles," although this term is not used in 10 CFR Part 20. The term " extremities" is used in the pending major revision of 10 CFR Part 20 l
where it has the different meaning of " hand, elbow, are below the 4:1 bow, foot, knee, and leg below the knee." However, this revised definition should not be used until the effective date of the major revision.
I-l l
CONTACT:
John D. Buchanco, NRR j
492-1097 l
1 6 [' '
P
Multiple Addressees JUN 22 ggg IE Inforretion Notice No. 81-26, Fert 3, Supplement Wo.1.
- Clarification of 01ecepent of Fersonnel Monitoring Devices for External Radiation " was issued July 19,1982. That information notice discusses placement of personnel dosimeters for determining whole body doses in situations where the principal source of radiation is from underfoot. That information notice indicates, and our position continues to be, that, in these situations, "a reasonable I
placement for a whole body dosimeter would be just above the knee." That information notice also notes that " extremity monitoring requirements may dictate the placement of edditional dosimeters in the feet and ankle area.*
Information notices cannot impose or change reguletory requirements and Infor-ration Notice No. 81-26, Part 3, Supplement I did not change the requirements of 10 CFR Section 20.101. Nevertheless, some licensees and, in at least one instance, regional personnel have maintained, incorrectly, that Information Notice No. 81-26, Part 3 Supplement I defined or redefined the terms
" extremity", or " extremities" to include the knee and the lower leg between the knee and the ankle and thereby extended the applicability of the 18.75 rem dose limit for the " extremities" to the lower leg above the ankle and to the knee.
Some licensees have changed their radiation protection procedures to incorpo-rate this misunderstanding and thereby to misrepresent the dose limits of 10 CFR Part 20.
This misunderstanding of the requirements of 10 CFR Part 20 has been identified primarily in relation to potential violaticos of the occupational dose limits resulting from radiation cxposures from hot particles on or near the skin. One example of this misunderstanding is the result of an inferral survey taken by one licensee and reported to the NRC.
In that survey, ten nuclear power stations were contacteo and asked, "If one of your personnel b:d been exposed to a hot particle in the region of the body between the middle of the knee and ankle, would you identify the dose as being to the skin of the whole body or to the extremity?"
Four stations responded, correctly, that they would record the dose as the skin of the whole body. The other six stations said they would record the dose as being to the
- skin of the extremity *, thus indicating their misunderstandings of both 10 CFR Part 20 and Information Notice No. 81-26 Part 3, Supplenent Ho.1.
In summary, for exposures of the knee and the lower leg above the ankle, the applicable occupational radiation dose limits of 10 CFR Section 20.101 are:
(1) the whole body dose limit of 1.25 rem per quarter or 3 rem per quarter, and (2) the skin of the whole body limit of 7.5 rem per quarter.
l This memorandum is being placed in the NRC Public Document Room and I encourage you to make it available to licensees.
Licensees who have incorporated the misunderstanding concerning " extremity' doses into their procedures should be asked to correct those procedures; however, no enforcement action should be taken for such incorrect procedures if 3
I I
F;ultiple Adcre5 sees J W g g'1ggg the licensee corrects the procedure (s). Enforcement action should be consid-i ered for any licensee who, after being given a copy of-this memorandum, refcses to correct a procedure that incorporates the misunderstanding of the dose limits of 10 CFR Part 20; however, please contact me before you initiate any such action.
This memorancum has been coordinated with the Office of Enforcement.
f i
s y
L ne J.
unningham, ief Radiation Protection Branch i
Division of Radiation Protection I
ar.d Emergency Preparedness l
Office of Nuclear Reactor Regulation l
3 l
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1*b/18/89-Ip-T
- yp I;l,I fNJ INDEX L.4 OPERATING' REACTORS h
,Liceewe-uj :
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~
Pg. No.
Sys.'Pg. No.
[
.BostonEdisonCon4ah DN 50-293 6
12 - 13 0
Pilgrim 1 GPU Nuclear Corporation DN 50-219 4
9 L
Oyster Creek 1 Philadelphia Electric
.DNs 50-277/50-278 5
10 - Il Company Peach Bottom 2/3 Powei Authority of the.
DN 50-333 1
3-4
. State of New. York-James A. FitzPatrick i
L Niagara Mohawk Power-DNs 50-220/50-410 3
7-8 Corporation Nine Mile Point 1/2 u.-*
~ Northeast Nuclear DN 50-245-2 5-6 Energy Company Millstone 1 Vermont Yankee Nuclear DN 50-271 7
14 - 15 Power Corporation Vermont Yankee Pennsylvania Power L DN 50-387/50-388 20
'38 - 39 Light Compary Susquehanna 1/2 Philadelphia Electric DN 50-352/50-353 21 40 Company Limerick 1/2
e
/*
E INDEX DPERATING REACTORS Licensee PWR Pg. No.
Sys. Pg. No.
Baltimore Gas and DNs 50-317/50-318 9
18 - 19 Electric Company Calvert Cliffs 1/2 Connecticut Yankee DN 50-213 10 20 - 21 Atomic Power Co.
Haddam Neck Consolidated Edison DN 50-247 12 23 - 24 Co. of New York Inc.
Indian Point 2 Power Authority of the DN 50-286 13 25 - 26 State of New York Indian Point 3 Duquesne Light Company DNs 50-334/50-412 8
16 - 17 Beaver Valley 1/2 Maine Yankee Atomic DN 50-309 14 27 - 28 Power Company Maine Yankee
(-
General Public Utilities DN 50-289 17 33 - 34 Nuclear Corporation TMI 1 s.
General Public Utilities DN 50-320 18 35 - 36 Nuclear Corporation TMI 2 Northeast Nuclear DN 50-336 15 29 - 30 Energy Company Millstone 2 Northeast Nuclear DN 50-423 25 53 Energy Company Millstone 3 Public Service Electric DN 50-272/50-311 16 31 - 32 and Gas Company Salem 1/2 Rochester Gas & Electric DN 50-244 11 22 Corporation Ginna Yankee Atomic Electric DN 50-?9 19 37 Company Yankee Atomic Long Island Lighting Co.
DN 50-322 22 41 - 44 Shoreham Public Service of DN 50-443 23 45 - 50 New Hampshire Seabrook 1
INDEX
, CONSTRUCTION Facility Docket #(s)
Page Sys. Pg. No.
BWR Hope Creek 1 50-354 1
2-2
.i
-g l
L-..
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