Health Physics Questions and Answers - Question 69
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))