ML20034C235
| ML20034C235 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| 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 9005020200 | |
| Download: ML20034C235 (3) | |
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' APR'2 41990 Docket Nos. 50-369, 50-370 License Nos. NPF-9, NPF-17 Duke Power Company ATTN: Mr. H. B. Tucker,-Vice_ President:
Nuclear Production Department-422 South Church Street Charlotte, NC 28242 Gentlemen:
SUBJECT:
INFORMATION REGARDING INTERPRETATION OF B10 ASSAY MEASUREMENTS eThis 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 bicassay 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 giv'e me a call, j
Sincerely, MlOINAL SIGN 50 BY DOUGLAS M. Cou.tm Douglas.M.. Collins, Chief-Emergency Preparedness and Radiological Protection Branch i
Division of Radiation Safety and Safeguards
Enclosure:
Memorandum dated March 14, 1990 cc w/ enc 1:
i T. L. McConnell Station Manager McGuire Nuclear Station P. O. Box 488 Cornelius, NC 28031 s
(cc w/ enc 1 cont'd - see page 2)
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J. S. Warren Nuclear Production Department-i Duke Power Company l
-P. 0.-Box 33189 t
Charlotte,. NC 28242
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A.:V.-Carr, Esq..
l Duke Power Company 422 South ~ Church Street Charlotte,-NC 28242-
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J. Michael' McGarry. III, Esq.
-Bishop, Cook, Purcell and'Reynolds 1400 L Street, NW'-
_j Washington,'D._C. -20005.
Dayne H. Brown, Director.
'h Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P
0.' Box'27687 q
Raleigh, NC 27611-7687 t
County Manager of Mecklenburg County E
-720 East Fourth Street Charlotte, NC 28202
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S. _ S. Kilborn, Area Manager
'i Mid-South Area. ESSD~ Project Westinghouse Electric' Corporation MNC West Tower - Bay 239 P. O. Box.355 Pittsburgh, PA 15230 Dr. John M.-Barry-Department of Environmental Health Mecklenburg County j
1200 Blythe Boulevard j
Charlotte, NC ' 28203 -
Karen E. Long
' Assistant Attorney. General.
N. C. Department of Justice (P. 0.. Box 629 i
Raleigh, NC 27602 State of. North Carolina i
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',i NUCLEAR REGULATORY COMMISSION e
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March 14, 1990 r.
hEh0RAliDUM FOR: Thuse on the Attached List FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness 4
Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT NRC INFORMATION NOTICE, " INTERPRETATION
-i 0F B10 ASSAY MEASUREMENTS; ASSESSMENT OF. 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 coments' on ' earlier draf ts. - (Note:
The technical contacts have been updated on the. enclosed. copy of the draf t.)
a 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-
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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 ~.
i eH e J.-Cunn'ingha, Chief Rad ation Protection Branch Division of Radiation Protectiu and Emergency Preparedness --
j' Office of Nuclear Reactor Regulation ~
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 3
492-1097 DQQ[
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9-n UNITED STATES M. 1 NUCLEAR REGULATORY COMM15$10N s.
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OFFICE OF NUCLEAR REACTOR REGULATION
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20555 i
June xx, 1988
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I' NRC INFORMTION NOTJCE NO. 88-XX:
INTERPRETATION OF 810 ASSAY MEASUREMENTS; l
ASSESSMENT OF IhTAKES-t 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 licensees.
Background and
Purpose:
This information notice is intended to correct an NRC position in Information Notice 82-18 (Reference 1) that was in conflict with the NR9 staff position s
-published in several regulatory guides. The NRC position in Infomation Notice 82-18 indicates that, for p'urposes of determining compliance with.the 10 CFR a
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 in vivo and in vitro bioassay measuremehts, " Interpretation of Bioassay Easurements ' TERIG/CR-4884).
It is expected that recipients will review the -
4 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 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
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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 l
based on ICRP Publication 2 and concluded with the NRC position: 'The NRC will continue to use the ICRP Publication 2 methodology in detemining cospliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a. final rule.'
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1 MM 5 IN 88-XX gM June xx,1988 1
Page 2 of 3 The NRC staff now recognizes that.this position in Information Notice 82-18 L
(2) is incorrect in 1stplying that only ICRP Publication 2 can be used for bicassay data to determine compliance with 10 CFR Part 20 and-assessinIicts with the NRC staff position expressed in relevant regulatory a
r (2) conf l
guides.
Although ICRP Publication 2 provides the basis for current 20 CFR Part 20 limits on intake (based on long-tem, chronic exposures),because it it does not l
always provice an acequate basis for assessing individual intake does not provide information on body content or excreta following single (acute) intake or information applicable to an individual differing from the This inadecuacy is recognized in
' standard man" defined in ICRP Publication 2.
2CRF Publications 14 and 10A (References 3 and 4), which are endorsed in Regulatory Guide B.g and which are mentioned in Information Notice 82-18 as being used by the NRC to evaluate bionssay data to determine compliance with regulatory requirements.
l The NRC staff became aware of the problem with the NRC position in Inforsation J
Notice 82-18asaresultofreviewsanddiscussionsduring(itsdraftstage) of a draft 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 manuel that, for the first time, provides information on how to compute intakes from both in vivo and in vitro bioassay measurements and contains taales for the interpretation of This manual bioassay results, in terms of intake, for several hundred nuclides.
confonr.s to the positions in existing regulatory guides, and the computed intake i
retention fractions in the report have been verified by comparison with results generated by other computer sodels using the same set of assumptions (REMEDY andDOSEDAY/DOSEYR). The use of this report, with its straightforward method-ology, could help licensees avoid the difficulties associated with the use of the methodology in ICRF Publication 2.
The NRC -plans to issue, for comment, a draf t regulatory guide that would 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 bionssay; therefore, the report Of course, the limits on intake given in may be used for this purpose.
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 20 CFR Part 20.
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=IN 88 XX -
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1988 June xx,f.3-Pa9e 3 o l
No specific action or written res)onse is' required by this information notice.
If you have any questions about tifs matter please contact the regional administrator _oftheappropriateregionalofficeorthisoffice..
1 Charles E. Rossi. Ofrector Division of Operational Events Assessment Office of Nuclear Reactor Re9ulation Je/m a Buchanan Technical Contacts:-45messAssEipesh, NRR dardded 6. 8ep0ASj RAS (301) 492-M /d
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(301)492-3422 e-a References (1) IE Information Notice 82-18. " Assessment of Intakes of Radioactive Materia by Workers," June 11,;1982.
(2) ' Report of Comittee II on fermissible' Dose for Internal Radiation,"
Recomendations of the Intctnational Comission on Radiological Protection, JCRP Publication 2, 1959.
" Report of Comittee IV on Evalcation of Radiation Doses in Body Tissues (3) from' Internal Contamination due to Occupational Exposure," Recommendations of the International Cossnission on Radiological Protection, ICRP' Publication 10, 1968.
i
'The Assessment of Internal Contamination Resultin from ReaJrrent or -
f (4) Prolonged Uptakes; A Report of ICRP Comittee 4,*
ecournendations of the.
International Cossaission on Radiological Protection, ICRP. Publication 10A, 1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable, et al.,)* Interpretation i
of Bioassay Measurements," NUREG/CR-4884 (8NL-NUREG-52063, July 1987, Attachnent: List of Recently Issued NRC Information Notices G
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