ML20034C994
| ML20034C994 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 05/22/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| NUDOCS 9006050086 | |
| Download: ML20034C994 (2) | |
Text
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2 2 1990 Docket No.
50-336 Northeast Nuclear Energy Company ATTN: Mr. E. J.- Mroczka Senior Vice President - Nuclear Engineering and Operations Group P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
Subject:
INTERPRETATION OF BI0 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE In accordance with the attached information, Region I Reactor licensees are advised that assessing intakes of radioactive material using bioassay data should be based on the best= data and models available for that purpose.
Licensees are no longer restricted to the assessment methodology'in ICRP L
Publication 2 in determining compliance with 10 CFR 20 intake limits, licensees may use improved and generally accepted methodology such as provided in recent ICRP Publications and NUREG/CR-4884.
Sincerely, i
&~
R@ald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards i
Attachment:
LJCunningham Letter, " Draft NRC Information Notice,
' Interpretation of Bioassay Measurements; Assessment of i
Intake'". dated March 14, 1990 l
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OFFICIAL RECORD COPY MULTI LTRS - 0036.0.0 9006050086 900522 05/08/90
- PDR ADOCK 05000336 P
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Northeast Nuclear Energy Company 2
F MM/ 2 21990 cc w/ attachment:
W. D. Romberg, Vice President, Nuclear Operations S. E. Scace, Station Superintendent f.
O. Nordquist, Director of Quality Services
?.- M. Kacich, Manager, Generation Facilities Licensing D. B. Miller,. Station Superintendent, Haddam Neck Gerald Garfield, Esquire Public Document Room (PDR) j Local Public Document.qoom (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector i
State of Connecticut bec w/ attachment:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
R. Bellamy, DRSS DRP Section Chief M. Conner, SALP Reports Only
- J. Shedlosky, SRI. Haddam Neck W. Raymond, SRI, N111 stone 3 K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports J. Caldwell, NRR O Ja f fe, LPM,. NRR L. J. Cunningham, NRR J. D. Buchanan, NRR-0FFICIAL RECORD COPY MULTI LTRS - 0037.0.0 05/08/90
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UNITED ST ATES
. E'x#j[,g NUCLEAR REGULATORY COMMISSION
- .j WASHINGTON, D. C. 20555
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March 14, 1990 liEh0RANDUM FOR:
Those on the Attached List FROM:
LeMoine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT NRC INFORMATION NOTICE, "lNTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF IHTAKE" 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 HRC headquarters and regional office comments on earlier drafts.
(Note:
The technical contacts have been upcated on the enclosed copy of the draft.)
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 issued in the near future.
We have reconsidered issuing the enclosed draf t 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.
1
/
eM e J. Cunningha, Chief a-7 W IMO 6 CNf fM Division of Radiation Protection Rad ation Protection Branch i
C and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR l
492-1097
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n si A e4.rwe UNITED STATES A" t "hL.
NUCLEAR REGULATORY COMMISSION 0FTICE OF NUCLEAR REACTOR REGULATION f
WASHINGTON, D.C.
20555 June xx,1988 NRC INFORtKTION NOTICE 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.
-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 Information Notice l
82-18 indicates that, for purposes of deteretning compliance with the 10 CFR Part 20 intake limits, only the methodology of the International Comission on i
Radiological Protection-(ICRP) Publication 2 (Reference 2) can be used in L
assessing intakes of radioactive material using bicassay data. Another purpose of this 1988 information notice is to call attention to a_ comprehensive new l
manual prepared for the NRC that can be.used to compute intakes from both E
in vivo and in vitro bioassay measuremehts, " Interpretation of Bioassay l'
Ea surements'"' '(MG/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 l
requirements; therefore, no specific action or written response is required.
Discussion:
The NRC staf f positior, 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 L
based on ICRP Publication 2 and concluded with the NRC position:
'The NRC will continue to use the ICRP Publication 2 methodology in determining cospliance l
with 10 CFR 20 until the revision of 20 CFR 20 has been published as a final L
rule.'
t e
DRAIT
Mf7 IN 88 XX-y Vau g June xx, 1988
)
Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82-18 l
(1) is incorrect in isplying that only ICRP Publication 2 can be used for i
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 30 CFR Part 20 limits on intake (based on long tem, chronic exposures) it does not always proiide an acequate basis for assessing individual intake because it does not provide information on body content or excreta following single (acute) intake or information applicable to an individual differing from the
' standard men
- defined in ICRP Publication 2.
This inadequacy is recognized in l
3CRF Publications 20 and 10A (References 3 and 4), which are endersed in Regulatory Guide 6.9 and which are mentioned in Information Notice 82-18 as L
being used by the NRC to evaluate bioassay data to determine compliance with l
regulatory requirements.
The NRC staff became aware of the problem with the NRC position in Information i:otice 82-18 as a result of reviews and discussions during {its draft stage) of a draf t report, " Interpretation of Bioassay Neasurements (Reference 5),
e 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 compute intakes from both in vivo and in vitro bionssay measurements and contains tables for the interpretaUon of bioaEay results, in terms of intake, for several hundred nuclides. This manual confore.s to the positions in existing reguletory guides,, and the computed intake l
retention fractions in the report have been verified by comparison with results l
generated by other computer endels using the same set of assumptions (REMEDY and D05EDAY/DOSEYR).
The use of this report, with its straightforward method.
ology, could help licensees avoid the difficulties associated with the use of I
the methodology in ICRP Publication 2.
The NRC plans t issue, for comment, a draft regulatory guide that would endorse the BNL MP0rt for use in assessing intakes of rad material gogssay measures nts.
in the interim, use of this report vla-
,ymentsisC0" sis *[hreore,thereport for t e interpr
.]grj a a1ntak b
tory Positio s n x sting gu tory gu g n g en in r his purpose. Of
'Tcu n'.m anj y$'VioTrMa t th f";t"Z"M9 t e extent it is u
cation 2 continue to a
{ the, are 1*/g,,i'$'[cy,,P
,,n r
i; th the intake limits o;sgsg n'a y 1 a" "
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IN 88 XX June xx,1988
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Page 3 of 3 i
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 adrinistrator of the appropriate regional office or this office.
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Charles E. Rossi Director i
Division of Operational Events Assessment Office of Nuclear Reactor Regulation
,Je/m D. Buchattatt i;
Technical Contacts:-4Engiisisitpssh, NRR 8ardded 6. 8 rooks, RAS
[g.,.
(30/) 992-3738 (302)492-342 J
Reference s (1) IE Information Notice 82-18,
- Assessment of Intakes of Radioactive Material by Workers," June 12, 1982.
(2) ' Report of Comittee II on Permissible Dose for Internal Radiation,'
Recomendations of the International Comission on Radiological Protection, ICRP Publication 2, 1959.
(3) ' Report of Comittee IV on Evaluation of Radiation Doses in Bedy Tissues l
from Internal Contamination due to Occupational Exposure,' Recomendations of the International Comission on Radiological Protection. ICRP l
Publication 10, 1968.
(4) "The Assessment of Internal Contamination Resulting from Recurrent or l:
Prolonged Uptakes; A Report of ICRP Comittee 4,* Recomendations of the International Comission on Radiological Protection, ICRP Publication IDA, 1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable, et al.,)' Interpretation of Bioassay Measurements,' NUREG/CR-4884 (BNL-NUREG-52063, July 1987.
l Attachnent: List of Recently Issued NRC Info 3ation Notices I
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