Information Notice No. 97-34: Deficiencies in Licensee Submittals Regarding Terminology for Radiological Emergency Action Levels in Accordance with the New Part 20
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF NUCLEAR REACTOR REGULATION
WASHINGTON, D.C. 20555-0001
June 12, 1997
NRC INFORMATION NOTICE 97-34: DEFICIENCIES IN LICENSEE SUBMITTALS REGARDING
TERMINOLOGY FOR RADIOLOGICAL EMERGENCY ACTION
LEVELS IN ACCORDANCE WITH THE NEW PART 20
Addressees
All holders of operating licenses or construction permits for test and
research reactors.
Purpose
The U.S. Nuclear Regulatory Commission (NRC) is issuing this information
notice to inform addressees of the issuance of a revised Appendix I to NUREG-
0849, "Standard Review Plan for the Review and Evaluation of Emergency Plans
for Research and Test Reactors." This revised appendix provides guidance on
incorporating the new 10 CFR Part 20 regulations into the radiological
emergency action levels (EALs). It is expected that recipients will review
the information for applicability to their facilities and consider actions, as
appropriate. However, suggestions contained in this information notice are
not NRC requirements; therefore, no specific action or written response is
required.
Description of Circumstances
Part 20 was revised and the final rule was published in the Federal Register
on May 21, 1991 (56 FR 23360), with an original implementation date of
January 1, 1993. Subsequently, the implementation date was extended to
January 1, 1994 (57 FR 38588). In response to these regulations, many
licensees of test and research reactors have submitted to the NRC revised
emergency plans that were intended to incorporate or reflect the terminology
introduced in the new regulations. Title 10 of the Code of Federal
Regulations, Part 20 is referenced in the section of the emergency plan
involving radiological EALs.
During its review of these submittals, the NRC staff noted that many licensees
incorrectly converted the wording of the EALs from the old terminology found
in NUREG-0849. As an example, (1) some licensees inappropriately converted
"maximum permissible concentrations" (MPCs) to "effluent concentrations" (ECs)
and (2) some inaccurately used the term "deep dose equivalent." Several
licensees merely substituted the EC term for the MPC term. Other licensees
used various multipliers in an attempt to correct the differences between the
two values. Still other licensees replaced the MPC term with "derived air
concentration." These submittals indicate the need for additional guidance
that could be used to assist in updating EALs.
9706090329.
IN 97-34
June 12, 1997
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Discussion
If the errors in the revised EAL schemes are left uncorrected, they could
potentially result in a licensee taking some conservative actions that are
unwarranted or in the licensee delaying appropriate actions.
Guidance in the form of a revision to Appendix I to NUREG-0849 was issued in
April 1997. The revised appendix provides guidance on incorporating the
current 10 CFR Part 20 regulations into the radiological EALs and, at the same
time, corrects some omissions in prior guidance and clarifies some other EALs
for the implementation of the new Part 20 regulations. Attachment 1 to this
document is a copy of the revised Appendix I. NUREG-0849, which was published
in 1983, is available from the following sources:
� The NRC Public Document Room, 2120 L Street, NW., Lower Level,
Washington, DC 20037 (202-634-3380). (Document may be copied for a fee,
currently $0.08 per page.)
� The Superintendent of Documents, U.S. Government Printing Office, P. O.
Box 37082, Washington, DC 20402-9328 (202-512-1800), for a fee of $3.75.
� The National Technical Information Service, Springfield, VA 22161-0002
(703-487-4650), for a fee of $24.50 (paper) and $12.50 (microfiche),
plus a $4.00 handling fee.
This information notice requires no specific action or written response. If
you have any questions about the information in this notice, please contact
the technical contact listed below or the appropriate regional office.
signed by S.H. Weiss for
Marylee M. Slosson, Acting Director
Division of Reactor Program Management
Office of Nuclear Reactor Regulation
Technical contact: Lawrence K. Cohen
301-415-2923
E-mail: lkc@nrc.gov
Attachments:
1. Revised Appendix I of NUREG-0849.
APPENDIX 1 Attachment 1
EMERGENCY CLASSES IN 97-34
June 12, 1997
Page 1 of 3
_________________________________________________________________________
ACTION LEVEL*_________________________________PURPOSE____________________
Notification of Unusual Events (NOUE)
Actual or projected radiological � Ensure that the first step in
effluent� at the site boundary which any response later found to be
is calculated (or measured) to result necessary has been carried out.
in either of the following conditions,
both of which are based on an exposure � Bring the operating staff to a
of 24 hours or less: state of readiness.
(1) A deep dose equivalent of 0.15 � Provide systematic handling of
milliSievert (mSv) [15 mrem] unusual events information and
OR decisionmaking.
(2) A committed effective dose equi-
valent of 0.15 mSv [15 mrem] based
on the following considerations:
� 100 EC � 24 hr** = 2.4 � 103 EC-hr
� 0.15 mSv [15 mrem] (for radio-
nuclides other than noble gases)
� 50 EC � 24 hr** = 1.2 � 103 EC-hr
� 0.15 mSv [15 mrem](for noble gases)�
Report or observation of a severe natural
phenomenon affecting the reactor site
Receipt of bomb threat affecting the
reactor facility
Fire within the reactor facility not
extinguished within 15 minutes
Alert
Actual or projected radiological � Ensure that emergency personnel
effluent� at the site boundary which are readily available to respond
is calculated (or measured) to result if the situation becomes more
in either of the following conditions, serious or to perform confirmatory radiation
both of which are based on an exposure monitoring if required.
of 24 hours or less:
(1) A deep dose equivalent of 0.75 � Provide current offsite
mSv [75mrem] authorities with status
OR information.
(2) A committed effective dose equiva-
lent of 0.75 mSv [75 mrem] based on
the following considerations:
� 500 EC � 24 hr** = 1.2 � 104 EC-hr
� 0.75 mSv [75 mrem] (for radio-
nuclides other than noble gases)
� 250 EC � 24 hr** = 6 � 103 EC-hr
� 0.75 mSv [75 mrem]
(for noble gases)��
Actual or projected radiation levels�
at the site boundary of 0.2 mSv/hr
deep dose equivalent [20 mrem/hr]
for 1 hour or 1.0 mSv [100 mrem] to
the thyroid (committed dose equivalent). Attachment 1
IN 97-34
June 12, 1997
Page 2 of 3
APPENDIX I (cont�d)
___________________________________________________________________________
ACTION LEVEL*__________________________________PURPOSE_____________________
Site Area Emergency
Actual or projected radiological � Ensure that response centers are
effluent� at the site boundary manned.
which is calculated (or measured)
to result in either of the follow- � Ensure that monitoring teams are
ing conditions, both of which are dispatched.
based on an exposure of 24 hours
or less: � Ensure that personnel required for
evacuation of onsite areas are at
(1) A deep dose equivalent of duty stations
3.75 mSv [375 mrem]
OR � Provide consultation with offsite
(2) A committed effective dose authorities.
equivalent of 3.75 mSv
[375 mrem] based on the � Provide information for the public
following considerations: through offsite authorities.
� 2500 EC � 24 hr** = 6 � 104 EC-hr
� 3.75 mSv [375 mrem] (for radio-
nuclides other than noble gases)
� 1250 EC � 24 hr** = 3 � 104 EC-hr
� 3.75 mSv [375 mrem](for noble
gases)��
Actual or projected radiation levels�
at the site boundary of 1.0 mSv/hr
[100 mrem/hr] deep dose equivalent
for 1 hour or 5.0 mSv [500 mrem] to
the thyroid (committed dose equivalent)
General Emergency
Sustained actual or projected radiation � Initiate predetermined protec-
levels� at the site boundary of 5.0 mSv/hr tive actions for the public.
[500 mrem/hr] deep dose equivalent
� Provide continuous assessment of
Actual or projected dose� at the site information from licensee and
boundary in the plume exposure pathway offsite organization measurements.
of 10 mSv [1 rem] (total effective dose
equivalent) or 50 mSv [5 rem] to the � Initiate additional measures as
thyroid (committed dose equivalent) indicated by actual or potential
releases.
� Provide consultation with offsite
authorities.
� Provide updates for the public
through offsite authorities.
* The situation that may lead to an emergency class described in the
subsections of Section 4.0 may be referenced as emergency action levels
appropriate to the emergency class.
� It is expected that licensees will determine the relationship of the EAL
dose levels at the site boundary to instrumentation readings and/or safety
analyses accident conditions for their specific facilities..
Attachment 1
IN 97-34
June 12, 1997
Page 3 of 3
** Effluent concentration (EC) as listed in Title 10 of the Code of Federal
Regulations, Part 20 (10 CFR Part 20),
� Standards for the Protection Against Radiation,� Appendix B, Table 2. If
the exposure time is less than 24 hours, the EC multiplier can be increased
portionately, provided that the values of 2.4 � 103 and 1.2 � 103 EC-hr are
used to declare a NOUE; the proportional increase for an alert is 5 and for
a site area emergency it is 25.
�� Table 2 of Appendix B to 10 CFR Part 20 lists the concentration values that
are equivalent to the radionuclide concentrations which, if inhaled or
ingested continuously over the course of a year, would produce a total
effective dose equivalent of 0.5 mSv [50 mrem]. However, for noble gases
where the submersion (external dose) is limiting, the concentration values
would produce a total effective dose equivalent of 1 mSv [100 mrem].
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