Question 18: For power reactors, the Technical
Specification instantaneous release rate limits are based
on old Part 20 doses and concentrations (relative to an
implied 500 mrem/yr limit). Will changes in the Technical
Specifications and ODCMs be required as a result of the
explicit 100-mrem/yr limit in the revised Part 20?
Answer: The instantaneous release rate limits for
airborne releases will not be changed because they are
imposed on licensees as a control to ensure that licensees
meet Appendix I requirements. However, the instantaneous
release rates for liquid effluents, to the extent that they
directly reference Appendix B concentration values, will
need to be changed. The corresponding bases and certain
alarm set-points will have to be changed by license
amendment. (Reference: Reactor Technical Specifications)