Inspection Guidance on 10 CFR 50.72, "Immediate Notification Requirement for Operating Power Reactors"
See the memorandum from L. J. Cunningham to L. R. Greger dated November 15, 1983. This memo states that for reporting radioactive releases to unrestricted areas: (1) the annual average meteorological data should be used for determining offsite concentrations, and (2) the expanded definition of unrestricted area in NUREG-0133 should be used.
Clarification was requested on several aspects of the 10 CFR 50.72 notification requirements. These questions related to the requirement that licensees call in notification of radioactive releases that exceed the specified concentrations. Specifically, the questions were: (1) what meteorological data should be used in determining offsite concentrations e.g., annual average, real time or worst case), and (2) what location should be used (e.g., unrestricted area as defined by Part 20 or the expanded definition as specified in NUREG-0133).
In addition, it was noted that revised 10 CFR 50.72 was incorporated into 10 CFR by Supplement No. 12 issued on September 20, 1983, although the rule change was not effective until January 1, 1984. It was noted also that a currently effective version was not in 10 CFR.
Inspection guidance for operating nuclear power reactors concerning 10 CFR 50.72 are as follows:
Annual average meteorological data should be used for determining offsite airborne concentrations of radioactivity. This is to maintain consistency with the Technical Specifications.
The expanded definition of an unrestricted area as specified in NUREG-0133 should be used. This is to maintain consistency with the Technical Specifications.
The lack of a currently effective version of 50.72 in the 10 CFR loose-leaf version is an administrative problem only. Licensees and inspectors should keep the old pages for reference until January 1, 1984.
The old version is still the effective rule until January and deviation from those requirements in favor of the new requirements would be a technical violation. However, in such a case, notation in the inspection report without further enforcement action would be the appropriate approach.
Regulatory references: 10 CFR 50.72, NUREG-0133
Subject codes: 2.3, 4.4, 7.5