ML17160A007
| ML17160A007 | |
| Person / Time | |
|---|---|
| Issue date: | 03/14/1990 |
| From: | Liza Cunningham Office of Nuclear Reactor Regulation |
| To: | Ronald Bellamy, Dan Collins, Joyner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RTR-NUREG-CR-4884 IEIN-82-18, NUDOCS 9003210225 | |
| Download: ML17160A007 (4) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 14<
1990 tiEtiORAHDUH FOR:
Those on the Attached List FROID:
SUBJECT:
Lel1oine J.
Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation DRAFT NRC IHFORNATION NOTICE, "INTERPRETATION OF BIOASSAY NEASUREHEHTS; ASSESSMENT OF INTAKE" in a July 13, 1988 memorandum, I informed you that we had decided not to issue the enclosed draft information notice which had been prepared after resolution of HRC headquarters and 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 issued in the near future.
Re 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 issuanc'e 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.
Enclosure:
Subject Information Notice CONTACT:
John D. Buchanan, NRR 492-1097 eN J.
Cunningha
, Chief Rad ation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
UNITED STATES NUCLEAR REGULATORY COYibilSSION OFFICE OF NUCLEAR REACTOR REGULATION NSHINGTON, D.C.
20555 June xx, 1988 NRC INFORHATION NOTICE NO. 88-XX; INTERPRETATION OF BIOASSAY MEASUREMENTS; ASSESSYZNT 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.
Back round and Pur ose:
This information notice is intended to correct an NRC position in Informatfon Notice 82-18 (Reference )) that was in conflict with the NRp staff position publfshed in 'several regulatory gufdes.
The NRC position fn Informatfon Notice 82-18 indicates, that, for p'urposes of determining compliance with the 10 CFR Part, 20 intake limits, only the methodology of the International Coamissfon on Radiological Protection (ICRP) Publication 2 (Reference
- 2) can be used in assessing intakes of radioactive material using bfoassay data.
Another pvrpose of this 19BB information notice fs to call attention to a comprehensive nevi manual prepared for the NRC that can be used to compvte intakes from both in vivo and in vitro bioassay measurements,
'Interpretation of Bioassay measurements, PKJKG/CR-4884).
It is expected that recipients will review the information in this information notice for applicability to their programs.
However, suggestions contained fn this information notfce do not constitute NRC requirements; therefore, no specific action or written response is required.
Discussion:
The NRC staff position with respect to bioassay fs presented fn NRC Regulatory Guides 8.9, 8.)l, 8.20, 8.22, and 8.26.
In general, the position is that assessment of individual intake using bfoassay data should be based on the best data and aodels available for that purpose.
IE Information Notice 82-18, Assessment of Intakes of Radioactive Rater fal by Morkers," issued in 1982, pointed out that the present NRC limits on intake are based on ICRP Publication 2 and concluded wfth the NRC position:
The NRC will contfnue to use the ICRP Publication 2 methodology in determining conplfance with 10 CFR 20 until the revision of 10 CFR 20 has been publfshed as a final rule.'
DRI,"FT IN 88-XX June xx, 1SBB Page 2 of 3 The NRC staff now recognizes that this position fn Information Notice 82-18 (1) is incorrect fn implying that only ICRP Publicatfon 2 cari be used for assessing bioassay 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 2G limits on fntake (based on long-tern, chronic exposures), ft does not y p~qt b
i f t
5'dlld ittvl It does not provide information on bog con en or excre a
o owing single (acute) intake or information applicable to an individual differing from the standard man" defined in ICRP Publication 2.
This inadequacy fs recognized in ICRF Publications 10 and 10A (References 3 and 4), which are endorsed in Regulatory Guide Sag and which are mentioned fn 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 posf fon fn Information Notice 82-18 as a result of reviews and discussions during fts draft stage) of.a draft report, "Interpretation of Bioassay Heasurements (Reference 5),
prepared by Brookhaven National Laboratory (BNL) under an NRC contract.
This report (which was published in July 1987) fs a comprehensfve manual that, for the first tfme, provides information on how to compute intakes from both in vfvo nnd in vitro bioassay measurements and contains tables for ehe interpretatvon oi hioassay resuIts
~ in terms of intake, for several hundred nuclides.
This emnua I conforms to the positions in exfstfng regulatory guides, and the computed intake retention fractions in the report have been veriffed by comparison with results generated by other computer audels using the same set of assumptfons (REMEDY and DGSEDAY/DDSEYR).
The use of this report, with fts straightforward method-ology, could help licensees avoid the difficulties associated with the use of the methodology fn ICRP Publication 2.
The NRC plans to issue, for coneent, a draft regulatory guide that would endorse the BNL report for use in assessing fntakes of radioactive Iaterfal from the results of bioassay measurements.
In the interim, use of this report for the interpretation of bioassay ieasurements fs consistent with the regula-tory positions fn existing regulatory guides on bioassay; therefore, the report IMy be used for this purpose.
Of course, the limits on intake given fn 10 CFR 20.1D3 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 ft fs applicable, ICRP Publication 2 lay continue to be used for assessing fntakes of radioactive material for comparison wfth the intake limits of 10 CFR Part 20."
DRAFT
IH 88-XX June xx, 1988 Page 3 of 3 No specific action or written response fs required by this information'otice.
If you have any questions about this Nitter, please contact the tegfonal administrator of the appropriate regional office or this office.
Charles E. Rossf, Dfrector Division of Operatfonal Events Assessment Office of Nuclear Reactor Regulation 2ohn 4'ut'dtv)4u7 T
I 1
C t t
~~
IIRR (3Ol) 492-See-qyPP 4'hery) 3 7'H)er
~,
KGE (301) 492-3422 References Btb-hard 5. CF~ck$, R~S Cans) We~- Zr"ZP (I) IE Information Notfce 82-18, Assessment of Intakes of Radioactive Material by Morkers, June 11, 1982.
(2) 'Report of Coamfttee II on Perafssible Dose for Internal Radiation, Recoamendatfons of the International Coaeissfon on Radiological Protection, ICRP Publication 2, 1959.
(3) "Report of Coamittee IV on Evaluation of Radiation Doses in Body Tissues from Internal Contamination due to Occupational Exposure,'ecoamendatfons of the International Coamfssion on Radiological Protection, ICRP Publication 10, 1968.
(4)
The Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptakes; A Report of ICRP Conmittee 4,'econrnendatfons of the International Coakssion on Radiological Protection, ICRP Publication lOA, 1969.
(5) Edward T. Lessard, Xfa Yfhua, Kenneth M. Skrable, et al., 'Interpretation of Sioassay Measurements,'REG/CR-4884 (BNL-NUREG-52063)
July 1987.
Attachment:
Lfst of Recently Issued NRC Inforaatfon Notfces