ML20034C213
| ML20034C213 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 04/24/1990 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tucker H DUKE POWER CO. |
| References | |
| IEIN-82-18, NUDOCS 9005020177 | |
| Download: ML20034C213 (3) | |
Text
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'O&C/Q l APR 2 4l1990 l
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Docket Hos. 50-413, 50-414-License Nos, NPF-35, NPF-52 Duke Power Company ATTN:
Mr. H. B. Tucker, Vice President Nuclear Production Department 422 South Church Street i
Charlotte, NC 28242-1 Gentlemen:-
SUBJECT:
INFORMATION REGARDING INTERPRETATION OF B10 ASSAY MEASURF"ENTS
'4 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, 1
ORIGINAL SIGN 50 BY DOUGLAS M. COLUNS Douglas M. Collins, Chief Emergency Preparedness and.
Radiological Protection Branch Division of Radiation Safety and Safeguards
Enclosure:
Memorandum dated March 14, 1990 cc w/ encl:
T. B. Owen, Station Manager Catawba Nuclear Station P. O. Box 256 Clover, SC 29710 A. V. Carr, Esq.
Duke Power Company 422 South Church Street Charlotte, NC 28242 cc w/ encl:
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J. Michael McGarry, III, Esq.
Bishop, Cook, Purcell and Reynolds 1400 L Street, NW-Washington, D. C4 20005
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North Carolina MPA-1 3100-Smoketree Ct., Suite 600 P. O. Box 29513 Raleigh, NC 27626-0513 Heyward G. Shealy,-Chief Bureau of Radio'ogical Health South Carolina Department of Health and Environmental Control--
j 2600 Bull Street Columbia. SC 29201 Richard P. Wilson, Esq.
Assistant Attorney General-S. C. Attorney General's Office P. 0.-Box 11549 Columbia, SC 29211 l
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Federal Emergency Management Agency.
Michael Hirsch 500 C Street, SW, Rooa 840 i
H Washington, D. C.
20472 North. Carolina Electric
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Membership Corporation 3400 Sumner Boulevard P. O. Box 27306 Raleigh, NC 27611 Karen E.-Long Assistant Attorney General N. C. Department of Justice P. O. Box 629 p.
Raleigh, NC ~27602 L
Saluda River Electric a
Cooperative, Inc.
L P. O. Box 929 Laurens, SC-29360 S. S. Kilborn, Area Manager -
Mid-South Area ESSD Projects Westinghouse Electric Corporation MNC West Tower - Bay 239 P. O. Box 335 Pittsburg, PA 15230 l
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(Cont'd on page 3)
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~ Duke Power Company.
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J County Manager of York County l
York County Courthouse i
York, SC 29745 Piedmont Municipal Power Agency i
121 Village Drive l-Greer, SC 29651 State of South Carolina bec w/ enc 1:
K. N. Jabbour, NRR B. R. Bonser, RII M. B. Shymlock, RII Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 179-N York,'SC 29745 o
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March 14, 1990 i
l liEh0RANDUM FOR: Those on the Attached List FROM:.
LeMuine J. Cunningham, Chief l'
Radiation Protection. Branch Division of Radiation-Protectiun_
L and Emergency Preparedness Office of Nuclear Reactor Regulation l
SUBJECT:
DRAFT NRC INFORMATION NOTICE, " INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT:0F INTAKE" In a July 13,'1968 memorandum, I informed you that we had decided not to issue ~
the enclosed draft information-notice which had been prepared after resolution of NRC headquarters end regional office comments on earlier drafts.. (Note:
l The technical contacts have been-updated on the enclosed copy of-the draf t.)
l A primary reason for this decision was that a regulatory guide endorsing the use.
L of NUREG/CR-4884, " Interpretation of Bioassay Heasurements," 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:issuea in the near future.
l 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 f ree to trans-mit copies to licensees if you so desire.
i eN 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 YO p --
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t M ck.r u e UNITED STATES I
NUCLEAR REGULATORY COMMISSION i
0FFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 June xx, 1988 i
NRC INFORMATION NOT]CE NO. 88-XX:
INTERPRETATION OF B10 ASSAY MEASUREMENTS; t
ASSESSMENT OF INTAKES 1
Addressees:
All nuclear power reactor facilities holding an operating license or a con-struction permit, research and test reactors, fuel facilities, and Priority 1 material licer. sees.
f
-Background and
Purpose:
This information notice is intended to correct an NRC position in Information i
Notice 82-18 (Reference 3) that was in conflict with the NRp staff position published in several regulatory guides. The NRC position in Infomation Notice 82-18 indicates that, for p'urposes of detemining cogliance with the 10 CFR 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 u;$ng bioassay data. Another purpose of this 1988 information notice is to call ictention to a comprehensive new manual prepared for the NRC that con be.used to compute intakes from both in vivo and in vitro bioassay measurements, ' Interpretation of Bioassay Easurements? TRIG /CR-4884).
It is expected that recipients will review the information in this information notice for appitcability 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 8.22, and <B.26.
In general, the position is that Guides B.9, 8.11, 8.20,l intake using bionssay data should be based on the best assessment of individua data and models available for that purpose, i
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 cogliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final rule."
i DRAff
MMM IN 88-XX
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g4 June xx,1988 4
Page 2 of 3 I
The NRC staff now recognizes that this position in Information Notice 82-18 l
(1) is incorrect in implying that only ICRP Publication 2 can be used for l
assessing bioassay data to determine compliance with 10 CFR Part 20 and (2) conflicts with the NRC staff position expressed in relevant regulatory puides. Although ICAP Publication 2 provides the basis for current 10 CFR
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Part 20 limits on intake (based on long term, chronic exposures), it does not always provide an adequate basis for assessing individua1' intake because it does not provide information on body content or excrete following single (acute) intake or infcrmation appitcable to an individual differing from the This inadequacy is recognized in
' standard man" defined in ICRP Publication 2.
ICRF Publications 10 and 10A (Refet ences 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 NOC staff became aware of the problem with the NRC position in Information NoticeE2-18asaresultofreviewsanddiscussionsduring[itsdraftstage) of a draft report, " Interpretation of Bioassay Neasurements (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 in vivo and in vitro bioassay measurements and contains tables for the interpretaBon of This manual bionEay 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 conparison with results i
generated by other computer endels using the same set of assumptions (REMEDY andDOSEDAY/DOSEYR). The use of this report, with its straightforward method-i ology, could help 1.censees avoid the difficulties associated with the use of the methodology in ICRP Publication 2.
The NRC plans to issue, for conment, a draf t regulatory guide that would endorse the BNL 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-tory positions in existing regulatory guides on bioassay; therefore, the report may be used for this purpose. Of course, the limits on 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 I
l radioactive material for comparison with the intake limits of 10 CFR Part 20.
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IN 88 XX--
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June ax,f 3-1988 o
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No specit'ic action or written response is required by this information notice.
If you have any questions about this matter please contact the regional-
-administrator.oftheappropriateregionalofficeorthisoffice.
Charles E.-Rossi, Director L
Division of Operational Events-Assessment--
Office of Nuclear.. Reactor Regulation l
I John A Buc/tanair -
I Technica1 Contacts: M, NRR harbara G. Brooks,R*S i
[30/)V92-37.Th (301) 492-3422 J
References i
(1) IE Information Notice 82-18.* Assessment of ' Intakes of Radioactive Material by Workers,' June 11, 1982.
(2) " Report of Comittee II on permissible Dose for Internal Radiation,"
Recomendations of the International-Comission on Radiological Protection, ICRP Publication 2, 1959.
I (3) " Report of Comittee IV on Evaluation of Radiation Doses in Body Tissues from Internal Contamination due to.0ccupational Exposure," Recommendations of the International Commission on' Radiological. Protection, ICRP '
Publication 10, 1968.
(4) "The Assessment of Internal Contamination Resulting from Recurrent or A Report of ICRP Committee 4," Recomendations of the Prolonged Uptakes;ission on Radiological: Protection. ICAP! Publication 10A, International Com l
1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable, et al.,)' Interpretation of Bioassay Measurements," NUREG/CR 4884 (8NL-NUREG-52063, July 1987.
Attachment:
. List of Recently Issued NRC Information Notices e
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