ML20034C160
| ML20034C160 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/24/1990 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Hairston W GEORGIA POWER CO. |
| References | |
| IEIN-82-18, NUDOCS 9005020123 | |
| Download: ML20034C160 (3) | |
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APR 2 j 1990 Docket Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81 Georgia Power Company ATTN: Mr. W. G; Hairston, III Senior Vice President -
Nuclear Operations P. O. Box 1295 Birmingham, AL' 35201 Gentlemen:
SUBJECT:
INFORMATION REGARDING INTERPRETATION OF BI0 ASSAY MEASUREMENTS This is to provide you information regarding the interpretation of bicassay 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.
i If you have any questions on the above, please give me a call.
1 Sincerely, c"r.'NAL SIONf*HY te:GLAG M, COLLINS Douglas M. Collins', Chief l
Emergency Preparedness and Radiological Protection Branch-Division of Radiation Safety and Safeguards
Enclosure:
Memorandum dated March 14, 1990 cc w/ enc 1:
(Seepage 2)
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R. P.-Mcdonald Executive Vice President-Nuclear Operations Georgia Power Company--
-P. O. Box 1295 Birmingham, AL 35201 C. K. McCoy-
.Vice President-Nuclear Georgia Power Company i
P. 0. 1295 Birmingham, AL 35201 l
G. Bockhold, Jr.
I General Mantger, Nuclear Operations-Georgia Power Company P. O. 1600' Waynesboro, GA 30830
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J. A. Bailey 1
Manager-Licensing Georgia Power Company
-P. O. Box 1295 Birmingham, AL 35201 Ernest L. Blake, Esquire
-i Shaw, Pittman, Potts and Trowbridge 2300 N Street, NW i
l-Washington, O. C.
20037 j
1 J. E. Joiner, Esquire-Troutman, Sanders, Lockerman, and Ashmore 1400 Candler Building 127 Peachtree Street, NE Atlanta, GA 30303
- 0. Kirkland, III, Counsel Office of the Consumer's Utility Council 1
Suite 225, 32 Peachtree Street, NE Atlanta, GA 30302
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Office'of Planning and Budget Room 615B 270 Washington Street, SW Atlanta, GA 30334
(_ c'c w/enci cont'd - see page 3) 7
x Georgia Power Company 3
(cc w/ enc 1 cont'd)
Office of the County Commissioner Burke County Commission Waynesboro, GA 30830 J. Leonard Ledbetter, Director Environmental Prote'ction Division Department.of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 State of Georgia bec w/ enc 1:
E. Reis 0GC J. Hopkins, NRR K. Brockman, R11 b
A. Herdt, R11 Document Control Desk NRC "sident Inspector U.S. huclear Regulatory Commission P. O. Box 572 Waynesboro, GA 30830 t
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March 14, 1990 I
hEh0RANDUM FOR: Those on the Attached List FROI4:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation l
SUBJECT:
ORAFT NRC IFFORMATION NOTICE, " INTERPRETATION-0F B10 ASSAY HEASUREMENTS; ASSESSMENT OF INTAKE" in a July 13, 1968 memorandum, I informeo you that we had decided not to issue 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 l
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 L
issued and, although the guide is still under development, we do not expect it to be issueo in the near future, j
Ne have reconsidered issuing the enclosed draft notice; however, we again have deciced 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 copits to licensees if you so desire.
l W
eh e J. Cunningha, Chief Rad ation Protection Branch Division of Radiation Protection and Emergency Preparednese Office of Nuclear Reactor Replation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097
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i UNITED STATES NUCLEAR REGULATORY COMMIS$10R 0FFICE OF NUCLEAR REACTOR REGULATION
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l WASHINGTON, D.C.
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June xx, 1988 j
NRC INT 0rJaiJON N072CE NO. 88 XX:
INTERPRETATION OF 810 ASSAY 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 licer. sees, f
Background and
Purpose:
l This information notice is intended to correct an NRC position in Information l
Notice 82-18 (Reference 1) that was in conflict with the NR9 staff position s
published in several regulatory guides. The NRC position in Information Notict 82-18 indicates that, for p'urposes of determining compliance with the 10 CFR l
i Part 20 intake limits, only the methodology of the International Comission on l
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 bionssay measurements 'Interpretetton of 8104ssay t
Easurements~' TRIG /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 bioassey is presented in NRC. Regulatory 8.22, and 8.26.
In general, the position is that 8.9, 8.12, 8.20,l intake using bionssay 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 based on ICRP Publication 2 and concluded with the NRC position:
'The NRC will centinue to use the ICRP Publication 2 methodology in detemining compliance i
with 10 CFR 20 until the revision of 10 CFR 20 has been pubitshed as a final rule.*
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MMP IN 88.XX
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The NRC staff now recognizes that this position in Information Notice 82-18 i
(1) is incorrect in iniplying that only ICRP Publication 2 car be used for assessin bioassay data to determine compliance with 10 CFR Part 20 and i
(2) conflicts with the NRC staff position expressed in relevant regulatory guides. Although ICRP Publication 2 provides the basis for cutrent 20 CFR Part 20 limits on intake (based on long-term, chronic exposures),because it it does not i
always provide an adequate basis for assessing individual intake does not provide information on bo@ content or escreta following single (acute) intake or information applicable to an individuel differing from the i
4 This inacequacy is recognized in
- standard man' defined in ICRP Publication 2.
3CRT Publications 10 and 10A (References 3 and 4), which are endorsed in
)
Regulatory Guide 8.g and which are mentioned in Information Notice 82-18 as being used by the NRC to evaluate bicassay data to determine compliance with j
regulatory requirements.
Tu MRC staff became aware of the problem with the NRC position in Information Notice 82-28 as a result of reviews and discussions during [f ts draft stage) 4 of a draf t report, " Interpretation of 81oassay Measurements (Reference 5),
This prepared by Brookhaven National Laboratory (8NL) 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 in vivo and in vitro bloassay measurements and contains tables for the interpretaTio'n of This manual bioaiiay results, in terns 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 corrputer models using the same set of assumptions (REMEDY and D03EDAY/D03EYR). The use of this report, with its straightforward method-i l
ology, could help licensees avoid the dif ficulties associated with the use of j
the methodology in ICRP Publication 2.
i The NRC plans to issue, for comment, a draft regulatory guide that would endorse the 8NL report for use in assessing intakes of radioactive material from the results of bicassay measurements.
In the interim, use of this report for the interpretation of bioassay measurements is consistent with the regula-I tory positions in existing regulatory guides on bioassay; therefore, the report r
Of course, the limits on intake given in mily be used for this purpose.
I 10 CFR 20.103 and based on ICRP Publict.tlon 2 continue to apply until they are changed in a revision of 10 CFR Part 20.
Furthermore, to the extent it is l
applicable, ICRP Publication 2 may continue to be used for assessing intakes of j
radioactive raterial for comparison with the intake Ifmits of 10 CFR Part 20.
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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 Reg 61ation Je/m A Buchattan Technical Contacts:-4lBElseemipesh, NRR 8(v$ded 6. 8eco/ S, 8 AS (301) 492-M d (y,
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(301) 492-3422 e
References (1) IE Information Notice 82-18, " Assessment of latakes of Radioactive Material by Workers," June 11,1982.
I (2)
- Report of Counittee 11 on Iermissible Dose for Internal Radiation,"
Recomendations of the International Commission on Radiological Protection, ICRP Pubitcation 2, 1959.
' Report of Comittee TV on Evaluation of Radiation Doses in Bo@ Tissues (3) from Internal Contamination due to Occupational Exposure,' Recomendations of the International Commission on Radiological Protection, ICRP Publication 10, 1968.
(4) "The Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptakes; A Report of ICRP Cosaittee 4 ' Aecoirendations of the International Commission on Radiological Protection, ICRP Publication 10A, 1969.
(5) Edward T. Lessard, Ria Yihua Kenneth W. Strable et al.$), Interpretation of Bioassay Haaaurements," MUREG/CR-4884 (8NL-MUkEG 5206July 1987.
Attachment:
List of Recently Issven RRC Information Notices 4
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