Guidance on Reporting Doses to Members of the Public from Normal Operations

HPPOS-140 PDR-9111210378

See the memorandum from D. R. Muller to T. M. Novak and G. C. Lainas dated March 10, 1983.

The memo summarizes dose design objectives of 10 CFR 50, Appendix I, and requirements of 40 CFR 190 regarding off-site doses from normal operations. The memo also provides guidance on the content of required annual reports.

To meet the dose design objectives of 10 CFR 50, Appendix I, the following conditions must be satisfied.

1. The dose or dose commitment to a member of the public from radioactive materials in liquid effluent from each reactor does not exceed:
   1. during any calendar quarter, 1.5 mrem to the total body or 5 mrem to any organ, or
   2. during any calendar year, 3 mrem to the total body or 10 mrem to any organ.
2. The dose from noble gases in gaseous effluents from each reactor does not exceed:
   1. during any calendar quarter, 5 mrad from gamma radiation or 10 mrad from beta radiation, or
   2. during any calendar year, 10 mrad from gamma radiation or 20 mrad from beta radiation.
3. The dose to a member of the public from radioiodines and particulates in gaseous effluents from each reactor does not exceed:
   1. during any calendar quarter, 7.5 mrem to any organ, or
   2. during any calendar year, 15 mrem to any organ.

The requirements of 40 CFR 190 are met if the dose or dose commitment to any member of the public from uranium fuel cycle source in a calendar years does not exceed: 1.75 mrem to the thyroid, or 2.25 mrem to any other organ or to the total body.

The 40 CFR 190 requirements differ in significant ways from the Appendix I criteria. Specifically, for 40 CFR 190 purposes, consideration must include the following (as well as doses from effluents):

1. Direct radiation doses, and
2. Doses from fuel cycle facilities, including other reactors.

The term "members of the general public" includes all persons who are not occupationally associated with the plant. The term does not include employees of the utility, its contractors, or vendors. Also excluded are people who enter the site to inspect, service equipment, or make deliveries. The term includes people who use portions of the site for recreational, occupational, or other purposes not associated with the nuclear plant. "Direct radiation" is radiation which reaches unrestricted areas even though its source is retained within the plant. Examples are gamma rays from the decay of nitrogen-16 in BWR turbine buildings and gamma rays from low level wastes stored on site.

The purpose of an annual report is to summarize the calculations performed during the year to show compliance with Appendix I and with 49 CFR 190 Technical Specifications. The information should be presented as indicated in Table 1 of the enclosure to this memo. Where doses exceed the Appendix I criteria, an explanation should be provided. Compliance with the 40 CFR 190 dose limits must be addressed explicitly. If the dose is below the 40 CFR 190 limits, all that needs to be added are statements addressing doses from other fuel cycle facilities (uranium mills, conversion plants, enrichment plants, fabrication plants, power reactors, reprocessing plants, and waste disposal sites). In most cases, the limits of 40 CFR 190 are satisfied by statements that there are no other fuel cycle facilities within 8 km.

Regulatory references: 10 CFR 50, 40 CFR 190, Technical Specifications

Subject codes: 2.2, 7.3, 12.8

Applicability: Reactors