ML20034C201
| ML20034C201 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| 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 9005020162 | |
| Download: ML20034C201 (3) | |
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APR 2 41990 Docket'Nos. 50-321, 50-366 License Nos. DPR-57, NPF-5 Georgia Power Company ATTN: Mr. W. G. Hairston, III Senior Vice President -
Nuclear Operations-4 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 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, ONGNAL SIGNFO BY' I
DOUGLAS M. COLUNS Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety e
and Safeguards j!
Enclosure:
j Memorandum dated March 14, 1990 cc w/ enc 1:
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R. P. Mcdonald, Executive Vice President, Nuclear Operations Georgia Power Company P. O. Box 1295 i
Birmingham, AL 35201 J. T. Beckham Vice President, Plant Hatch Georgia Power Company P. O. Box'1295 Birmingham, AL 35201 H. C. Nix General Manager, Plant Hatch Route 1, Box 439 Baxley, GA 31513 S. J. Bethey Manager Licensing - Hatch Georgia Power Company P. O. Box 1295 Birmingham, AL 35201 Ernest L. Blake, Esquire Shaw, Pittman, Potts and Trowbridge 2300 N Street, NW Washington, D. C.
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l Charles H. Badger Office of Planning and Budget Room 610 270 Washington Street, SW Atlanta, GA 30334 J. Leonard Ledbetter, Director Environmental Protection Division Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513 State of Georgia bec w/ enc 1:
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L. P. Crocker, NRR A. R. Herdt, RII K. E Brockman, RII Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 1, Box 725 Baxley..GA 31513 Hugh S. Jordan, Executive Secretary Georgia Public Service Commission 244 Washington Street, SW-Atlanta, GA 30334 i
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March 14, 1990 hEh0RANDUM FOR: Those on the Attached' List FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Prepareoness Office of Nuclear Reactor Regulation l
SUBJECT:
DRAFT NRC INFORMATION NOTICE, "lNTERPRETATION OF B10 ASSAY' MEASUREMENTS; ASSESSMENT OF INTAKE" In a July 13, 1988 memorandum,1 informed 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 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.
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eH e J. Cunningha, Chief Rad ation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subaect Information Notice CONTACT: John D. Buchanan, NRR 492-1097
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58 M d.c NUCLEAR REGULATORY COW.lsS10N OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 June xx, 1988 NRC INFORMTION NOTICE NO. 88 XX:
INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESS >' INT OF INTAKES Addressees:
All nuclear power reactor facilities holding an operatir.g license or a con-struction permit, research and test reactors, fuel facilities, and Priority I material 11cer. sees.
Background and
Purpose:
This information notice is intended to correct an NRC position.in Information Notice 82-18 (Reference 3) 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 purposes of determining compliance with the 10 CFR Part 20 intake limits, only the sathodology 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 in vivo and in vitro bioassay measuremehts, " Interpretation of Sioassay Easurements TNURIG/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.
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 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.'
DRAff 3
M Bl IN 88-XX
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gMf June xx, 1988 Page 2 of 3 The NRC staff now recognises 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 20 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 rollowing 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 position in Information Notice 62-28 as a result of reviews and discussions during gits draf t 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 com>ute intakes froin both in vivo and in vitro bioassay measurements and contains ta)les for the interpretation cf bioassay 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 conparison with results generated by other cor.puter models using the same set of assusptions (REMEDY andD05EDAY/DOSEYR). The use of this report, with its straightfonrard method-clogy, could help licensees avoid the difficulties associated with the use of the methodology in ICRP Publication 2.
The NRC plans to issue, for consnent, a draft regulatory guide that would endorse the BNL report ter use in assessing intakes of radioactive material from the results of bicsssay measurements.
In the interim, use of this report for the interpretation of bicassay measurements is consistent with the regula-tory positions in existing regulatory guides on bionssay; therefore, the report may be used for this purpose. Of course, the limits en 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 eaterial for comparison with the intake limits of 10 CFR Part 20.
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l IN 88-XX June xx, 1988 Page 3 of-3
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' No' specific action or written res >onse is required by this information notice, L
If you have any questions _ about tiis matter please contact the regional f
administrator of the appropriate regional office or this office.
Charles E. Rossi. Director.
Division of Operational Events Assessment Office of Nuclear Reactor Regulation Je/m A BucAanart Technical Contacts: 6 NRR 8(tedded.6, 8eo0ASj RAS
[30/)Y92-37Sh y,-
(301) 492-3422 e
J References (1) IE Information Notice 82-18, ' Assessment of Intakes of Radioactive Material by Workers," June 11,1982.
(2) ' Report of Comittee II on Iersissible Dose for Internal Radiation,"
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Recomendations of the International Comission on Radiological Protection, l
ICRP Publication 2, 1959..
(3) ' Report of Comittet IV on Evaluation of Radiation Doses in Body Tissues l
from Internal Contamination due to Occupational Exposure," Reconnendations of the International Comission on Radiological Protection, ICRP i
Publication 10, 1968.
(4) 'The Assessment of Internal Cor,tamination Resulting from Rearrent or
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Prolonged Uptakes; A Report of ICRP Comittee 4,* Recomendations of the' International Comission on Radiological Protection, ICRP Publication IDA, 1
i 1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable, et al.,)" Interpretation L
of Bioassay Measurements,' NUREG/CR-4884 (8NL-NUREG-52063, July 1987.
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Attachment:
List of Recently Issued NRC Infomation Motices i*
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