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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 Page 2 of 2 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: firstname.lastname@example.org 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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