ML20246J437
| ML20246J437 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 08/18/1989 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Miltenberger S Public Service Enterprise Group |
| References | |
| IEIN-81-26, NUDOCS 8909050150 | |
| Download: ML20246J437 (5) | |
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AUG ! 81909 f
Docket No. 50-354 Publi: Service Electric & Gas Company ATTN-Mr. Steven E. Miltenberger Vice President and Chief Nuclear Officer Post Offica Box 236 Hancocks Bridge, New Jersey 08038 Gentlemen:
SUBJECT:
DEFINITION OF " EXTREMITY" FOR PURPOSES OF SETTING OCCUPATIONAL i
EXPOSURE LIMITS 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 inspctions have shown that a number of licensees are using a definition of "extrem' ty" that is contrary to the provisions of 10 CFR Part 20.101, " Radiation Dose St.ndards for Individuals in Restricted Areas". This regulation specifies that "ettramity" dose limits apply to the
- hands and foreams; feet and ankles."
Infomation provided in NRC Information Notice No. 81-26. Part 3, Supplement No. 1 has been misunderstood, and was not intended to change what is censidered to be an extremity. This Information Notice discusses placement of personnel dosimeters for determining whole body doses.
l Because of this apparent misunderstanding, we plan no enforcement action if yovr procedures have incorporated this misunderstanding. We have issued the enclosed memorandum to provide 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.
Sincerely, Onght! Eigned By:
g her.ald R. Seltsery Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards l
Enclosure:
l Memorandum from LeMoine J. Cunningham to g/
Ronald R. Bellamy, et. al., dated June 22, 1989 t
i nrriclAL RECORD COP'F 8909050150 890818 t
JF1R ADOCK 05000354 l
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S. LaBruna, Vice President-Nuclear E
Scott B. Ungerer, Manager, Joint Generation Projects Department, Atlantic Electric Company J. J. Hagen, General Manager - Hope Creek Operations
'L. A. Preston, General Manager - Licensing and Regulation R. Fryling, Jr., Esquire Licensing Project Manager, NRR Public Document Room (PDR)
Local Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey bec w/ encl.:
Region I Docket Room (with concurrences) i Management Assistant, DRMA (w/o enc 1)
DRP Section Chief B. Clayton, EDO F. Congel, NRR/DREP L.'Cunningham, NRR/PRPB M. Knapp, DRSS 1
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Sherbini Pasciak Bellamy 7/2/89 T/ / /89 j,T/v/89 OfflClli RECORD COP'!
ENCLOSURE
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l NEMORANDUM FOR: Ronald R. Bellamy, Chief. EPRPB, DRSS, Region I Douglas M. Collins, Chief. EPRPB, DRSS, Region II l
1 L. Robert Greger, Chief, RFB, DRSS, Region III J
Blaine Murray, Chief, RPSB, DRSS, Region IV Gregory P. Yubas, Chief. EPRPB, DRSS, Region V FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Divisior 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 misunderstanding concerning occupational dose limits for " extremities," and (2) to provide guidance concerning potential s.nforcement 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 foreams; feet and ankles"; and (3) the " skin of the whole As indicated in the instructions for NRC Form 5, " Current Occupational body. "
External Radiation Exposure," the dose to the " hands ano forearms; feet and ankles" includes the cose to the skin of these body parts. The dose to the skin is assessed at a. depth of 7 mg/cmr 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 forearms, feet and ankles.*
The term " extremities" has often been used to designate the " hands and fere-The ams; feet and ankles," although this term is not used in 10 CFR Part 20.
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.
1 CONTACT:
l John D. Buchanan, NRR 492-1097 D M N lh
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'su'ktiple Addrossees JUN 2 21989 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 trisunderstanding of the dose limits of 10 CFR Part 20; however, please contact me before you initiate any such action.
This memorandum has been coordinated with the Office of Enforcement.
Le ne J.
unningham, ief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Multiple Addressees JW 2 2 29 IE Inforrrntion Notice No. 81-26 Part 3 Supplement No.1, " Clarification of Placement of Fersonnel Monitoring Devices for External Radiation," was issued July 19,1982. That infortnation notice discusses placernent 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 1 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 ho. 81-26, Part 3, Supplement 1 defined or redefined the terms
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" 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 abme the ankle and to the knee.
Some licensees have changed their radiation protection procedures to incorpo-rate this inisunderstanding 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 violatiens of the occupational dose limits resulting from radiation exposures from hot particles on or near the skin. One example of this inisunderstanding is the result of an inferinal 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 extremit) P Four statiens 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 inisunderstandirigs of both 10 CFR Part 20 and Inforination Notice No. 81-26, Part 3, Supplement No. 1.
In sunnary, 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 l
(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 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 j
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INDEX OPERATING REACTORS Licensee BWR Pc. No.
Sys. Pg. No.
Boston Edison Company DN 50-293 6
12 - 13
-P11 grim 1 GPU Nuclear Corporation DN 50-219 4 '-
9 Oyster Creek 1 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. 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 l (
General Public Utilities DN 50-289 17 33 - 34 Nuclear Corporation TMI 1 l
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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 l
and Gas Company Salem 1/2 Rochester Gas & Electric DN 50-244 11 22 Corporation Ginna l
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--_________-____-________________
INDEX CONSTRUCTION v
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Facility Docket #(s)
Page Sys. Po. No.
BWR Hope Creek 1 50-354 1
2-3 c.
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