ML14188B694
| ML14188B694 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 04/24/1990 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eury L CAROLINA POWER & LIGHT CO. |
| References | |
| IEIN-82-18, NUDOCS 9005030122 | |
| Download: ML14188B694 (7) | |
Text
APR 2 4 Docket No. 50-261 License No. DPR-23 Carolina Power and Light Company ATTN: Mr. Lynn W. Eury Executive Vice President Power Supply P. 0. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
INFORMATION REGARDING INTERPRETATION OF BIOASSAY MEASUREMENTS This is to provide you information regarding the interpretation of bioassay measurements to assess intakes of radioactive material.
Enclosed is an NRC memorandum which updates a position taken in Information Notice 82-18, "Interpretation of Bioassay Measurements; Assessment of Intakes."
This NRC memorandum specifies that assessment of individual intakes using bioassay data should be based on the best data and models available for that purpose rather than the models in place at the time the NRC regulations in 10 CFR Part 20 were implemented.
If you have any questions on the above, please give me a call.
Sincerely, ORIGINA~eL SIGN)
.8y DOUGLAS M4. CL Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety and Safeguards
Enclosure:
Memorandum dated March 14, 1990 cc w/encl:
C. R. Dietz, Manager Robinson Nuclear Project Department H. B. Robinson Steam Electric Plant P. 0. Box 790 HarDtsville, SC 29550 (cc w/encl cont'd -
see page 2)e 90050o30122 90-4_24D FEIR A.D'CJ:;i< 0500 0-261 QF'EIC-
Carolina Power and Light Company 2
(cc w/encl cont'd)
R. E. Morgan, Plant General Manager H. B. Robinson Steam Electric Plant P. 0. Box 790 Hartsville, SC 29550 Heyward G. Shealy, Chief Bureau of Radiological Health Dept. of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 McCuen Morrell, Chairman Darlington County Board of Supervisors County Courthouse Darlington, SC 29535 Richard E. Jones, General Counsel Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 H. A. Cole Special Deputy Attorney General State of North Carolina P. 0. Box 629 Raleigh, NC 27602 Avery Upchurch, Chairman Triangle J Council of Governments 100 Park Drive P. 0. Box 12276 Research Triangle Park, NC 27709 Robert Gruber Executive Director Public Staff -
NCUC P. 0. Box 29520 Raleigh, NC 27626-0520 bcc w/encl:
(See page 3)
Carolina Power and Light Company 3
bcc w/encl:
Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 5, Box 413 Hartsville, SC 29550 RI SS RII:DRP 41, D J ter HDanqeD r~ /90 031 /90
0 4UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 14, 1990 INEMORANDUM FOR:
Those on the Attached List FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation SUbJECT:
DRAFT NRC INFORMATION NOTICE, "INTERPRETATION OF BIOASSAY MEASUREMENTS; ASSESSMENT OF INTAKE" In a July 13, 1988 memorandum, I informed you that we had decided not to issue the enclosed draft inforiation notice which had been prepared after resolution of NRC headquarters adr regional office comments on earlier drafts. (Note:
The technical contacts have been updated on the enclosed copy of the draft.)
A primary reason for this decision was that a regulatory guide endorsing the use of NUREG/CR-4884, "Interpretation of Bioassay Measurements," was to have been issued within a few months and we intended to have that guide incorporate the message in the enclosed draft information notice concerning the incorrect "position" in Information Notice No. 82-18. That regulatory guide has not been issued and, although the guide is still under development, we do not expect it to be issueo in the near future.
We have reconsidered issuing the enclosed draft notice; however, we again have decided not to do so primarily because the regulatory guide incorporating the information is still planned and because the importance of the information con tained in the enclosed draft is below the current threshold of importance suf ficient to warrant issuance of an NRC information notice. However, to make this information available to the public, we are placing a copy of this memo randum enclosure in the public document room. Therefore, you are free to trans mit copies to licensees if you so desire.
eM I ieJ.
Cunningha, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT:
John D. Buchanan, NRR 492-1097
UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C. 20555 June xx, 1988 NRC INFORMATION NOTICE NO. 88-XX:
INTERPRETATION OF 8IOASSAY MEASUREMENTS; ASSESSMENT OF INTAKES Addressees:
All nuclear power reactor facilities holding an operating license or a con struction permit, research and test reactors, fuel facilities, and Priority I material licensees.
Background and
Purpose:
This information notice is intended to correct an NRC position in Information Notice 82-18 (Reference 1) that was in conflict with the NR staff position published in several regulatory guides. The NRC position in Information Notice 82-18 indicates that, for purposes of determining compliance with the 10 CFR Part 20 intake limits, only the methodology of the International Commission on Radiological Protection (ICRP) Publication 2 (Reference 2) can be used in assessing intakes of radioactive material using bioassay data. Another purpose of this 1988 information notice is to call attention to a comprehensive new manual prepared for the NRC that can be used to compute intakes from both in vivo and in vitro bioassay measurements, "Interpretation of Bioassay Feal'Iments7' TMURIG/CR-4884). It is expected that recipients will review the information in this information notice for applicability to their programs.
However, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Discussion:
The NRC staff position with respect to bioassay is presented in NRC Regulatory Guides 8.9, 8.11, 8.20, 8.22, and 8.26. In general, the position is that assessment of individual intake using bioassay data should be based on the best data and models available for that purpose.
TE Information Notice 82-18, "Assessment of Intakes of Radioactive Material by Workers," issued in 1982, pointed out that the present NRC limits on intake are based on ICRP Publication 2 and concluded with the NRC position: 'The NRC will continue to use the ICRP Publication 2 methodology in determining compliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final rule.R 01RAllT
IN 88-XX June xx, 1988 Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82-18 (1) is incorrect in implying that only ICRP Publication 2 can be used for assessing bicassay data to determine compliance with 10 CFR Part 20 and (2) conflicts with the NRC staff position expressed in relevant regulatory guides. Although ICRP Publication 2 provides the basis for current 10 CFR Part 20 limits on intake (based on long-term, chronic exposures), it does not always provide an adequate basis for assessing individual intake because it does not provide information on body content or excreta tollowing single (acute) intake or information applicable to an individual differing from the
- standard man' defined in ICRP Publication 2. This inadequacy is recognized in ICRF Publications 10 and 10A (References 3 and 4), which are endorsed in Regulatory Guide 8.9 and which are mentioned in Information Notice 82-18 as being used by the NRC to evaluate bioassay data to determine compliance with regulatory requirements.
The NRC staff became aware of the problem with the NRC posi ion in Information Notice 82-18 as a result of reviews and discussions during its draft stage) of a draft report, *Interpretation of Bioassay Measurements (Reference 5,
prepared by Brookhaven National Laboratory (BNL) under an NRC contract.
This report (which was published in July 1987) is a comprehensive manual that, for the first time, provides information on how to compute intakes from both in vivo and in vitro bioassay measurements and contains tables for the interpretatio1IT biossay results, in terms of intake, for several hundred nuclides.
This manual conforms to the positions in existing regulatory guides, and the computed intake retention fractions in the report have been verified by comparison with results generated by other computer models using the same set of assumptions (REMEDY and DOSEDAY/DOSEYR). The use of this report, with its straightforward method ology, could help licensees avoid the difficulties associated with the use of the methodology in ICRP Publication 2.
The NRC plans to issue, for comment, a draft regulatory guide that would endorse the BNL report for use in assessing intakes of radioactive material from the results of bioassay measurements. In the interim, use of this report for the interpretation of bioassay measurements is consistent with the regula tory positions in existing regulatory guides on bioassay; therefore, the report may be used for this purpose. Of course, the limits on intake given in 10 CFR 20.103 and based on ICRP Publication 2 continue to apply until they are changed in a revision of 10 CFR Part 20. Furthermore, to the extent it is applicable, ICRP Publication 2 may continue to be used for assessing intakes of radioactive material for comparison with the intake limits of 10 CFR Part 20.
DRAFF
IN 88-XX June xx, 1988 Page 3 of 3 No specific action or written response is required by this information notice.
If you have any questions about this matter, please contact the regional administrator of the appropriate regional office or this office.
Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation Technical Contacts:-4ag/o/
psh RR6a ra c2.
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I (301) 492-ee op (3ro)
IdP2-Y737 (301) 492-3422 J
References (1) IE Information Notice 82-18, gAssessment of Intakes of Radioactive Material by Workers," June 12, 1982.
(2)
'Report of Committee II on Oermissible Dose for Internal Radiation,*
Recommendations of the International Commission on Radiological Protection, ICRP Publication 2, 1959.
(3)
PReport of Committee IV on Evaluation of Radiation Doses in Body Tissues from Internal Contamination due to Occupational Exposure, Recommendations of the International Commission on Radiological Protection, ICRP Publication 10, 1968.
(4) gThe Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptakes; A Report of ICRP Committee 4," Recommendations of the International Commission on Radiological Protection, ICRP Publication 1OA, 1969.
(5)
Edward T. Lessard, lia Yihua, Kenneth W. Skrable, et al., 'Interpretation of Bioassay Measurements. NUREG/CR-4884 (BNL-NUREG-52063), July 1987.
Attachment:
List of Recently Issued NRC Information Notices