ML20034C152
| ML20034C152 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 04/24/1990 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Alto R FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| References | |
| IEIN-82-18, NUDOCS 9005020112 | |
| Download: ML20034C152 (1) | |
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i EPR 2 41930 Docket No. 70-1201 License No. SNM-1168 B&W Fuel Company Coninercial Nuclear Fuel Plant ATTN: Mr. R. A. Alto Plant Manager P. 0. Box 11646 Lynchburg, VA 24506-1646 Gentlemen:
SUBJECT:
INFORMATION REGARDING INTERPRETATION OF'BI0 ASSAY MEASUREMENTS-This is to provide you information regarding the interpretation of bioassay.-
1 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 _
l memorandum specifies that assessment of individual intakes.using bioassay data should be based on the best data and models available for that purpose rather j
than the models in place at the time the NRC.' regulations in 10 CFR Part 20-
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were implemented.
If you have any questions on the above, please give me a call.
NG dL SICNtO ]Y DOUGl.AS M. COLUNs -
Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety l
and Safeguards
Enclosure:
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l Memorandum dated March 14, 1990 l
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L U.S. Nuclear Regulatory Commission ATTN: NRC Resident Inspector Mail Code 42 i
P. O. Box 785 Lynchburg, VA 24505-0785 1
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March 14, 1990 hEh0RAliDUM FOR: Thuse on the Attached List FROM:
LeMuine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office.of Nuclear-Reactor Regulation
SUBJECT:
DRAFT NRC INFORMATION NOTICE, " INTERPRETATION 0F bl0 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE" In a July 13, 1988 memorandum, l informed you that we had decided not to issue-
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the enclosed draft information notice which had been prepared after resolution-of NRC headquarters and regional office comments on earlier. drafts.
(Note:
The technical contacts have been updated on the enclosed copy of the draf t.)
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 j
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 draf t notice; however, we again have j
decided not to do so primarily because the regulatory-guide incorporating the
- i 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 cocument room. ~ Therefore, you are free to trans-mit copies to licensees if you so desire.
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eN e'J. Cunningha, Chief-Rad ation Protection Branch Division of Radiation Protection 1
and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice 1
CONTACT: John D. Buchanan, NRR 492-1097 5{O SW
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NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION j'
WASHINGTON, D.C.- 20555-June xx, 1988 NRC INFORMTION NOTICE NO. 88-XX:~ INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKES Addressees:
All nuclear power reactor facilities holding an operating licente or a con-struction permit, research and test reactors, fuel facilities, and Priority I' material licensees.
Background and
Purpose:
I This information notice is-intended to correct'en NRC position in Infomation Notice 82-18 (Reference 1) that was in conflict with the NR9 staff position published in several regulatory guides. The NRC' position in Information Notice 82-18 indicates that, for p'urposes of determining compliance with the 10 CFR
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Part 20 intake limits, only the methodology of the International Comission 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
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in vivo and in vitro bioassay measuremehts, "Interpretetion of Bioassay Reasurements TWEG/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:
1 The NRC staff position with respect to bioassay is presented in NRC Regulatory 8.22, and 8.26. In general, the position 1s that 8.9, 8.11, 8.20,l intake using bioassay data should be based on the best Guides assessment of individua data and models available for that purpose.
IE 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
- The NRC will based on ICRP Publication 2 and concluded with the NRC position:
-continue to use the ICRP Publication 2 methodology in determining. cog 11ance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a:ffnal ruie.'
DRAFT
DD R" IN 88-XX y h,]T 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
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bicassay data to determine compliance with 10 CFR Part 20 and assessina (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 Tonowing single j
(acute) intake or information applicable to an individual differing from the This inadequacy is recognized in
' standard man" defined in ICRP Publication 2.
1CRF Publications 10 and 10A (References 3 and 4), which are endorsed in Regulatory Guide E.9 and which are mentioned in Information Notice 82-18 as being used by the NRC to evaluate bioassay data to determine compliance with
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regulatory requirements.
The NRC staff became aware of the problem with the NRC position in Information Notice 82-18 as a result of reviews and discussions during {its draft stage) of a draf t report, " Interpretation of Bioassay Measurements (Reference 5),
This prepared by Brookhaven National Laboratory (BNL) under an NRC-contract.
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 10 vivo and in vitro bionssay measurements and contains tables for the interpretcTion of This manual bioassay results, in terms of intake, for several hundred nuclides.
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 sodels using the same set of assumptions (REMEDY andD03EDAY/DOSEYR). The use of this report, with its straightforward method-ology, could help licensees avoid the dif ficulties associated with the use of -
the methodology in ICRP Publication.2.
The NRC plans to issue, for connent, s. draft regulatory guide that would l
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 anay be used for this purpose. Of course, the limits on intake given in 30 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.
O HAFT
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n IN 88 XX'-
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- June xx, 1988 Page 3 of 3
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No specific action or written response is required by this information notice.
1 If you have any questions'about this matter please contact the regional
- administrator of the appropriate regional:o fice or this office.-
1 l
Charles E. Rossi Director =
1
- Division of Operational Events Assessment i
Office of Nuclear Reactor Regulation 1
,fohn A BuCdanatt Technical Contaets:-4migiuguityssh, NRR Jctefard 6. BevoASjRAS (3ol) V92
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(301) 492-3422 e
J' References (1) IE Information Notice 82-18, " Assessment-of Intakes of Radioactive Material-by Workers," June II, 1982.
(2) ' Report of Comittee II on permissible Dose for Internal Radiation,'
Recomendations of the International Connission on Radiological Pmtection, ICRP Publication 2,1959.
(3) " Report of Comittee IV on Evaluation'of-Radiation Doses in Body Tissues from Internal Contamination due to Occupational Exposure " Reconnendations.
of the-International Consission on Radiological Protection ICRP Publication 10, 1968.
(4) 'The Assessment of Internal Contamination Resulting from Recurrent or A Report of ICRP Committee 4,* Aecomendations of the.
i Prolonged Uptakes;ission on Radiological Protection, ICRP Publication 20A,.
International Com 1969.
(5) Edward T. Lessard, Xia -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
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