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HPPOS-052 PDR-9111210224

Effluent Reporting Requirement Per 10 CFR 20.405 (a), “Reports of Overexposures and Excessive Levels and Concentrations”

See the letter from T. F. Dorian to A. Mattox (Brandeis University) dated December 21, 1979. It is an OELD opinion that 10 CFR 20.405 (a) requires a report on effluent release only if the releases exceed 10 times the limit in 10 CFR 20.106 or in the license when averaged over one year. Limits in Technical Specifications were not addressed in this OELD opinion. The health physics position was written in the context of 10 CFR 20.106, 20.201, and 20.405, but it also applies to the “new” 10 CFR Part 20, Sections 20.1302, 20.1501, and 20.2203.

10 CFR Part 20 was promulgated to establish precautionary requirements for personnel monitoring, posting of areas and containers where radiation or radioactive materials exist, radiation surveying, record keeping, storage of radioactive materials, instruction of personnel, and reporting of radiation overexposure, accidents, and loss or theft of licensed material. The regulation does not specify detailed procedures to be followed in meeting safety standards in most cases, but individual licenses may, and usually do, contain special safety requirements and conditions necessitated by the particular situation. Radiation exposure of personnel is controlled through the licensee’s ability to control access to its facility and to direct the actions of individuals within the facility and by protective equipment, devices, and procedures. Exposures to the public are controlled by limiting the quantity and concentration of radioactive material that may be released to areas not controlled by the licensee.

The sections and appendixes incorporating limits on radiation levels and concentrations of radioactive material are designed to assure that individuals in “unrestricted areas” do not receive exposure in excess of 10% of the limits established for persons exposed in restricted areas. For this purpose, these regulations limit levels of radiation and concentrations of radioactive material that may be created in unrestricted areas by licensees, without special authorization from NRC, to extremely low levels. These levels are believed to be sufficiently low to assure that there is no reasonable probability to individuals in unrestricted areas receiving exposures in excess of 10% of the permissible levels for restricted areas under any circumstance. Moreover, as a precautionary procedure, 10 CFR 20.201 [or 10 CFR 20.1501] requires licensees to make (or have made for them) such surveys (and with such frequency) as may be necessary to comply with the regulations in Part 20.

Within this scheme, section 10 CFR 20.405 (a) [or 10 CFR 20.2203 (a)] requires written reports within 30 days of levels of radiation or concentrations of radioactive material in an unrestricted area in excess of ten times any applicable limit set forth in Part 20 or in the license. The applicable limits in Part 20 are listed in Table II of Appendix B to 10 CFR 20 ••20.1-20.601) [and Table 2 of Appendix B to 10 CFR 20 (••20.1001-20.2401)] and are modified to the extent that 10 CFR 20.106 [and 10 CFR 20.1302 (b)] allows a licensee to average concentrations over a period not greater than one year. Thus, 10 CFR 20.106 and 20.405 [or 10 CFR 20.1302 (b) and 20.2203 (a), respectively] are complementary; averaging is, in fact, permitted; and a licensee is not normally required to report in writing releases of single milliliters of air or water that exceed by a factor greater than ten the concentrations specified in Table II of Appendix B to ••20.1-20.601 [or, at present, Table 2 of Appendix B to ••20.1001-20.2401].

Each report under 10 CFR 20.405 [or 10 CFR 20.2203] requires the licensee to “describe the extent of exposure of individuals to radiation or radioactive material, including estimates of each individual’s exposure…; levels of radiation and concentrations of radioactive material involved; the cause of the exposure, levels or concentrations of radioactive materials involved; and corrective steps taken or planned to assure against a recurrence.” [Note: 10 CFR 20.2203 requests additional information such as an individual’s dose.] Clearly, the regulations attempt to ensure that NRC knows about abnormal conditions at licensees’ facilities; that licensees control their activities, including procedures, equipment and people, to protect against radiation hazards; and that every reasonable effort is made to maintain radiation exposures, and releases of radioactive materials in effluents to unrestricted areas, as low as is reasonably achievable.

Regulatory references: 10 CFR 20.106, 10 CFR 20.405, 10 CFR 20.1302, 10 CFR 20.2203

Subject codes: 2.2, 7.3

Applicability: All