ML20246J334

Clarifies NRC Position Re Definition of Extremity for Purpose of Setting Occupational Exposure Limits.Regulation Specifies That Extremity Dose Limits Apply to Hands & Forearms,Feet & Ankles,Per Info Notice 81-26,Part 3

ML20246J334
Person / Time
Site:	Shoreham File:Long Island Lighting Company icon.png
Issue date:	08/18/1989
From:	Bellamy R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Leonard J LONG ISLAND LIGHTING CO.
References
IEIN-81-26, NUDOCS 8909050123
Download: ML20246J334 (5)

Text

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4 Docket No. 50-322 MJ8 I 8.1M9 Long Island Lighting Company ATTN: Mr. John D. Leonard, Jr.

Vice President - Nuclear P. O. Box 618 Shoreham Nuclear Power Station Wading River, New York 11792 Gentlemen:

SUBJECT:

DEFINITION EXPOSURE LIMITSOF " EXTREMITY" FOR PURPOSES.0F SETTING OCCUP The purpose of this memorandum is to clarify the NRC'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 foreams; feet and ankles."

Information provided in NRC Infomation Notice No. 81-26, Part 3, Supplement No.1 to be has been misunderstood, and was not intended to change what is considered an extremity.  ;

dosimeters for detemining whole body doses.This Infomation Notice discusse

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Because of this apparent misunderstanding, we plan no enforcement action if your procedures have incorporated this misunderstanding. We have issued the enclosed memorandum to provide clarification on the intent of Information c

Notice No. 81-26, and what is considered to be an extremity. We request that you ensure your procedures incorporate the appifcable 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.

Sincerely, Odginal Signed By:

kcnald R. Ballassy Ronald R. Be11any, Chief Facilities Radiological Safety and Safeguards Branch i Division of Radiation Safety and Safeguards

Enclosure:

Memorandum from LeMoine J. Cunningham to R)nald R. Bellamy, et. al., dated June 22, 1989 s . * *n . o,g-Y y *9e w m esp 1"T N;, g0 !.. 4.. .is bekt, 8909050123 890818 2 PDR ADOCK 0500 a ___

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C. Daverio,-Manager, Nuclear Operations Support' E. Youngling, Manager, Nuclear Engineering J. Futter, General Counsel J. Notaro, Manager, QA Department Director, Power Division State of New York, Department of Law Shoreham Hearing ~ Service List Public Document Room (PDR)-

Local Public Document Room (LPDR)-

Nuclear Safety'Information Center (NSIC)

'NRC Resident Inspector State of New York bec w/ encl:

Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

M. Knapp, DRSS T. Martin, DRS E. McCabe, DRP P.'Kauffman, DRP M.. Young, OGC PA0 (14) SALP Reports and All Inspection Reports S. Barr, DRP S. Brown, NRR J. Dyer, ED0 F. Congel, NRR/DREP L. Cunningham, NRR/PRPB M. Knapp, DRSS R SS f -

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MEMORANDUM FOR: Ront.1d R.' Bellamy, Chief. EPRPB, DRSS, Region 1

Douglas M. Collins, Chief,- EPRPB, DRSS, Region 11 L. Robert Greger, Chief, RPB, DRSS, Region Ill Blaine Murray, Chief, RPSB, DRSS, Region IV Gregory P. Yuhas, Chief. EPRPB, DRSS, Region Y FROM: LeMoine J. Cunningham, Chief Radiation Protection Branch Divis1or of Radiatien Protection and Emergency Preparedness Office of Nuclear Reactor Regulation

SUBJECT:

CORRECTION OF MISUNDERSTANDING CONCERNING OCCUPATIONAL DOSE LIMITS FOR " EXTREMITIES" The purpose of this memorandum is twofold: (1) to document the correction of a

.misunderstt.nding concerning occupational dose limits for " extremities," and (2) to provide guidance concerning potential Enforcement action in cases in which licensees have incorporated this misunderstanding into their procedures.

10 CFR Part 20 provides different occupational dose limits for (1) the "whole body; head and trunk; active blood-forming organs; lens of eyes; or gonads;"

(2) the " hands and forearms; 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 ano forearms; feet and ankles" includes the dose to the skin of these body parts. The dose to the skin is assessed at a depth of 7 ag/cm r in tissue. Thus, the limit for the

" skin of the whole body" and the limit for the "whole body..." apply to all parts of the body except the " hands and forearns, feet and ankles."

The term " extremities" has often been used to designate the " hands and fore-ams; 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 where it has the different meaning of " hand, elbow, are below the elbow, foot, knee, and leg below the knee." However, this revised definition should not be used until the effective date of the major revision.

CONTACT:

John D. Buchanan, NRR  ;

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.. - Multiple ~ Addressees # 22 389 lE Inforntion. Notice No. 81-25, Fart 3, Supplement No.1. " Clarification of Placement of Personnel 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 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-additional dosimeters in the feet and ankle area."

Information notices cannot impose or change regulatory requirements and Infor-mation 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 Infor:c.ation 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 P0.

This misunderstanding of the requirements of 10 CFR Part 20 has been identified primarily in relation to potential violations of the occupational dose limits resulting from radiation exposures from hot particles on or near the skin. One example of this misunderstanding is the result of an informal survey taken by '

one licensee and reported to the NRC. In that survey, ten nuclear. power stations were contacted and asked, "If one of your personnel had 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 extremityP 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, Svpplement No. 1.

In sumary, 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.

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 concerr.ing " extremity" doses into their procedures should be asked to correct those procedures; however, no enforcement action should be taken for such incorrect procedures if

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the licensee corrects-the procedure (s). Enforcement action should be consid-ered for any licensee-who,- after being given a copy of this memorandum, refuses 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, l'

This memorandum has been coordinated with the Office of Enforcement.

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L ne J. unningham, ief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation

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INDEX OPERATING-REACTORS.

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Licensee nr. EwR Pg. No. Sys. Po. No.

Soston Edison Company DN 50-293 6 12 - 13 Pilgrim 1 GPU Nuclear Corporation DN 50-219 4 9 Oyster Creek 1

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Philadelphia Electric DNs 50-277/50-278 5 10 - 11 Company Peach Bottom 2/3' Power Authority of the DN 50-333 1 3-4 State of New York James A. FitzPatrick Niagara Mohawk Power DNs 50-220/50-410 3 7-8 Corporation Nine Mile Point 1/2 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 & DN 50-387/50-388 20 38 - 39 Light Company Susquehanna 1/2 Philadelphia Electric .DN 50-352/50-353 21 40 Company Limerick 1/2

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INDEX OPERATING REACTORS Licensee PWR Pg. No. Sys. Pa. 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 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 50-29 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 l

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