United States Nuclear Regulatory Commission - Protecting People and the Environment

U.S. Nuclear Regulatory Commission

Question 69: This question concerns radioactive effluent

concentrations. 10 CFR 20.1302 (b) (2) addresses the

annual average concentrations, and limits on these

concentrations, as they apply to members of the public. The

changes published as conforming amendments to Part 2

uniformly address violations to these effluent limits as

instantaneous values. While it is clear that significant

instantaneous concentrations of these limits constitute a

concern to public safety, the description that any release

in concentrations above the limits of Appendix B, Table 2

constitutes a Severity Level IV Violation and an

instantaneous release exceeding twice the limit of this

table constituting a Severity Level III Violation are not

consistent with the intent of the rule. It is requested

that the descriptions of violations be clarified with

respect to the clear intent of the rule that the limits of

Appendix B, Table 2 apply to annual average limits.



Answer: The examples in the enforcement policy concerning

release of radioactive materials to an unrestricted area at

concentrations in excess of the limits for members of the

public should be understood to refer to the annual average

concentrations and not the instantaneous concentrations.

There is no requirement in 10 CFR Part 20 based on the

instantaneous concentrations (although technical

specifications for power reactors do contain such

requirements); thus there can be no violation of a Part 20

requirement involving instantaneous concentrations and,

therefore, the question of the severity level of the

violation, and the examples used for these severity levels,

are not relevant. Nevertheless, the subject examples will

be clarified in a future revision of the enforcement policy

to make it clear that the subject examples refer to the

statement concerning annual average concentrations in 10

CFR 20.1302 (b) (2) (i). (Reference: 10 CFR 20.1302 (b))

Page Last Reviewed/Updated Thursday, March 29, 2012