NUREG-0859, Responds to 820407 Questions Re NUREG-0859, Compliance Determination Procedures for Environ Radiation Protection Stds for U Recovery Facilities 40CFR190. W/O Encl Reg Guide 3.51
| ML20054H845 | |
| Person / Time | |
|---|---|
| Issue date: | 05/11/1982 |
| From: | Scarano R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Ferman J MINNESOTA, STATE OF |
| References | |
| REF-WM-5, RTR-NUREG-0859, RTR-NUREG-859 NUDOCS 8206250064 | |
| Download: ML20054H845 (3) | |
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WMUR w/f PG A WMUR s/f John W. Ferman WM r/f m
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Division of Air Quality JJLinehan.
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Minnesota Pollution Control Agency HJPettengill) 1935 West County Road B2 DEMartin
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Dear Mr. Ferman:
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MHaisfield eQ, As requested in your April 7,1982 letter, a copy of Regulatory Guide 3.51 is enclosed.
In your letter, you raised certain questions and concerns about NUREG-0859 (" Compliance Determination Procedures for Environmental Radiation Protection Standards For Uranium Recovery Facilities 40 CFR Part.190") for which we have provided responses as follows:
Question:
"At page A_2 you state that radon and daughters are excluded because EPA regulations do so: would it not be true that the Commissions own regulations require Pb-210, Bi-210, and Po-210 to be included in a licensing dose assessment?"
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Response
The NRC is charged with the responsibility of determining compliance with both EPA and NRC radiation protection standards,-and appropriate evaluations are made for both purposes.
Radon and its daughters, including Pb-210, Bi-210, and Po_210 are included in such evaluations except for determinations of compliance with EPA's 40 CFR Part 190 standards, which do not apply to radon and its daughters.
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MAY.11 1982 302.2/GNG/82/04/22/0
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Question:
"In the footnote to Table A 2(c) you state a 50 percent retention factor for both above ground and root vegetables: this seems grossly oversimplified in view of the very different botany and food preparation methods among vegetables."
Response
The 50% retention factor is for losses during food preparation and is based on available information, as summarized in " HERMES - A Digital Computer Code for Estimating Regional Radiological Effects From the Nuclear Power Industry," Hanford Engineering Development Laboratory, HEDL-TME-71-168, December 1971. Although this single
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value is a simplification of the many complexities actually involved, it is all that can be supported by the present limited state of knowledge as applied to our purposes. However, should information become available to allow for improvement of parameters, it would be considered.
Question:
"In the footnote to Table A-2(d) you allude to much higher resultant doses to younger people; but all the dose conversion factor tables apply to the adult age group. Based on RG 1.109 uptake rates and NUREG 0172 dose conversion factors it appears the resultant dose commitments are usually largest for the child, but sometimes for the teen, much less frequently for the infant, and almost never for the adult. Additional charts showing age group scaling factors for the adult would have been helpful."
O Resnonse:
Table A-2(d) addresses solely the milk ingestion pathway. Our experience to date has indicated that (1) there is no significant increase in doses to other age groups, above adult doses, unless the milk pathway is present, and (2) that the milk pathway is very rarely of concern in 40 CFR Part 190 compliance evaluations. The latter point is due to the semi-arid climate of existing U.S.
milling areas which does not readily support dairy cows.
Nevertheless, you should be able to generate age-specific dose tables for each age group based on the information in the enclosed copy of Regulatory Guide 3.51.
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AgW 11 1982 302.2/GNG/82/04/22/0 We trust t.'t this information will satisfactorily answer your questions.
However, *he:ld additional information be desired please call Mr. Gregory Eadie or
. Giorgio Gnugnoli of my staff at 301 427-4103.
Sincerely Original digned by J. J. Linehan C
Ross A. Scarano, Ch f Uranium Recovery Licensing Branch Division of Waste Management
Enclosure:
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