ML19259B118
| ML19259B118 | |
| Person / Time | |
|---|---|
| Issue date: | 01/09/1979 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Chernick C CHICAGO, UNIV. OF, CHICAGO, IL |
| References | |
| NUDOCS 7901160293 | |
| Download: ML19259B118 (5) | |
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The University of Chicago License No. 12-00509-03 ATTh:
Dr. Cedric L. Chernick Vice President for Sponsored Programs 5801 Ellis Avenue Chicago, IL 60637 Gentlemen:
This refers to your letter of November 6, 1978, in response to our letter of October 16, 1978, and to the telephone con-versation between Edward Mason of your staff and Messrs. Carl Paperiello, Ron Paul, and Don Sreniawski of our staff on December 7,1978, and to the subsequent letter of December 6, 1976 from Mr. Edward Mason.
We have reviewed the information submitted in these letters and the information supplied by Mr. Fbson during the tele-phone conversation and conclude that the item of noncompliance identified in the Notice of Violation is valid. We vill ex-amine your corrective action described in Mr. tbson's letter of December 8, 1978, during a future inspection.
If you dis-agree with our position please let this office know by letter within ten (10) days of receipt of this letter.
In the telephone conversation Mr. Mason expressed a concern with respect to the imposition of civil penalties. In this case we do not intend to recommend imposition of a civil penalty. When we issue a civil penalty we include such a notice with the Notice of Violation.
The issues raised in your letter of October 16, 1978, are addressed in the enclosure to this letter.
79011609293
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The University of,-
Chicago If you have any other questions on this matter do not hesitate to call Dr. Carl J. Paperiello (312-858-2660, ext 291).
Sincerely, ws. b h ~ff-gJames G. Keppler Director
Enclosure:
Discussion of Issues cc w/ encl:
Central Files Reproduction Unit NRC 20b PDR NSIC
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ENCLOSURL Discussion of Issues Your letter of November 6,1978, was discussed at length in the tele-phone conversation of December 7,1973.
With respect to the hood in Room N-101, our intent in our letter was to bring to your attention a factor which may have contributed to the thyroid radioiodine uptakes in this area.
It is our understanding from the telephone conversation of December 7, 1978, that your personnel in this room did not understand the inspector's questions at the time of the inspection. A check by your personnel showed that this hood is in prope. working order. At the time of the inspection it was in bypass mode and this was not brought to the inspector's attention due to a misunderstanding.
We apologize for the numerical errors in our letter of October 16, 1978.
As discussed with Mr. Mason in the telephone conversation, the dates on which the thyroid of the individual performing routine iodinations was counted were hay 31, 1978 and June 7,1978 and not June 19, 1978 as stated in the October 16th letter.
In addition we note that the wrong license number was included on the Notice of Violation. With respect to the names of exposed individuals who worked with iodine without being monitored, Mr. Mason was told that it was our policy to avoid including names of exposed individuals in correspondence that would be placed in the public document room as this would violate their right to privacy.
We gave the names of these individuals to Mr. Fbson during the telephone conversation. We believe that this information had been provided during the exit interview at the conclusion of the inspection.
With respect to the unit FTC hours, this is a short hand way of express-ing the exposure of an individual to airborne material and is the product of the length of the exposure in hours and the concentration of material in air divided by the maximum permissible concentration from Table 1, Appendix B of 10 CFR 20.
As an example if an individual _gere exposed to a uniform airborne concentration of ic _ine-125 of 5 x 10 uCi/ml for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />, we would call _ghis a 40 MPC hour exposure because the MPC for iodine-125 is 5 x 10 uCi/ml and the individual was exposed to this for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br />. Ontheotherhandifan_gndividualwereexposedtoanairborne iodine-125 concentration of 2 x 10 uCi/mlfor10 hours,wewouldcalg this also a 40 MPC hour egposure since the product of 10 times 2 x 10 uCi/mldgvidedby5x10 uCi/ml ig the same as the product of 40 times 5 x 10 uCi/ml divided bj ' x 10 uCi/ml, which is MPC for iodine-125.
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Enclosure ~
10 CFR 20.103(b) states in part that certain actions will be taken to maintain intake of radioactive material by any individual within any period of seven consecutive days as far below that intake of radioactive material which would result from inhalation of such material for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> at the uniform concentration specified in Appendix B. Table 1, Column 1 as is reasonably achievable. Whenever the intake of radio-active material by any individual exceeds this 40 hour4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> control measure, the licensee shall make such evaluations and take such actions as are necessary to assure against recurrence. The licensee shall maintain records of such occurrences, evaluations, and actions taken in a clear and readily identifiable form suitable for summary review and evaluation.
The exposure described above at which an evaluation is required is frequently called 40 MPC hours.
In our letter of October 16, 1978 when we indicated that an individual had thyroid readings which showed expo-sures of 35 MPC hours and 46 MPC hours respectively we mean that this individualwasinthelattercaseexposedtoaconcentrationofairborne iodine which was either '4 times FTC for iodine-125 (2.g x 10 uCi/ml) for a period of one hou.
an exposure of MPC (5 x 10 uCi/ml) for a period of 46 hours5.324074e-4 days <br />0.0128 hours <br />7.60582e-5 weeks <br />1.7503e-5 months <br /> or any oduct of time and concentration which would be cqual to the above.
Footnote 3 to 10 CFR 20.103(a) states that the volume of air inhaled in g
13 weeks for 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week is 6.3 x 10 ml.
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volume inhaled in 7
40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> is 4.85 x 10 ml.
Therefore, theintakeofiodine-125permittep by10CFR20.103fb)asstatedaboveisequaltotheproductof4.85x10 ml times 5 x 10 uC1/ml or 0.243 microcuries.
ICRP Publication states that 23% of the material inhaled goes to the thyroid (specified through footnote 5 to 10 CFR 20.103(a)). This gives a thyroid uptake of 0.056 microcuries. The individual noted above had a thyroid burden of 0.066 microcuries on June 6, 1978, 0.066/0.056 times 40 MPC hours is about 46 MPC hours.
If this quantity were taken up in seven consecutive days, the action point in 20.103(b), which requires a formal written evaluation, would have been reached. In your case your surveillance program was inadequate to determine if such a limit were exceeded. You were cited for failing to perform the survey adequately enough to ensure compliance and not for exceeding any limit or action point in 20.103(a) or 20.103(b).
It should also be noted that 10 CFR 20.401(b) and (c)(2) require you to keep records of surveys required to determine compliance with 20.103(a) in the units used in 10 CFR 20.
Thie means that records of measurements should be kept in units of concentration and length of exposure.
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Enclosure ~
10 CFR 20.103(a)(3) states in part that for purposes of determining con-pliance with the requirements of this section the licensee shall use suitable measurements of concentrations of radioactive material in air for detecting and evaluating airborne radioactivity in restricted areas and in addition, as appropriate, use bioassay. Regulatory Guide 8.20 provides an acceptable bioassay program for cases where a license appli-cant or license renewal applicant is required to prescribe a bioassay program for iodine-125 or iodine-131 as part of his application. The program in Regulatory Guide 8.20 in itself may not in all cases provide sufficient surveillance to ensure compliance with 10 CFR 20.103(a) and (b).
This may require air monitoring and/or additional bioassay measurements.