United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 97-34: Deficiencies in Licensee Submittals Regarding Terminology for Radiological Emergency Action Levels in Accordance with the New Part 20

                                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: lkc@nrc.gov

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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