ML20042E766
| ML20042E766 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/24/1990 |
| From: | Dan Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Eury L CAROLINA POWER & LIGHT CO. |
| References | |
| IEIN-82-18, NUDOCS 9005030056 | |
| Download: ML20042E766 (2) | |
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APR 2 4 99 Docket Nos. 50-325, 50-324 License Nos. DPR-71, DPR-62 Carolina Power and Light Company ATTN: Mr. Lynn W. Eury Executive Vice President Power Supply P. O. Box 1551 Raleigh, NC 27602 Gentlemen:
SUBJECT:
INf0kMAT10N REGARDING INTERPRETATION OF B10 ASSAY MEASUREMENTS This is to provide you information regarding the interpretation of bicassey 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.
.j If you have any questions on the above, please give me a call.
Sincerely, ORIGINAL $lGh:50 EY DOUGLAS M. COLLINS Douglas M. Collins, Chief Emergency Preparedness and Radiological Protection Branch Division of Radiation Safety-and Safeguards
Enclosure:
Memorandum dated March 14, 1990 cc w/ enc 1:
R. B. Starkey, Jr.
Vice President Brunswick Nuclear Project Box 10429 Southport, NC 28461 cc w/ enc 1:
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J. L. Harness Plant General Manager Brunswick Steam Electric Plant P. O. Box 10429 Southport, NC 28461 R. E. Jones, General Counsel Carolina Power & Light Company P. O. Box 1551 Raleigh, NC 27602 Ms. Frankie Rabon Board of Commissioners P. O. Box 249 Bolivia, NC 28422 Chrys Bagget State Clearinghouse Budget and Managenent 116 West Jones Street Raleigh, NC 27603 Dayne H. Brown, Director 0
Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. 0 Box 27687-Raleigh, NC 27611-7687 H. A. Cole Special Deputy Attorney General State of North Carolina P. O. Box 629 Raleigh, NC 27602 Robert P. Gruber Executive Director Public Staff - NCUC P. O. Box 29520 Raleigh, NC 27626-0520-bec w/ enc 1:
Document Control Desk NRC Resident inspector U.S. Nuclear Regulatory Commission Star Rte. 1, Box 208 Southport, NC 28461 11 - SS RI!
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t March 14, 1990 1
hEh0RANDUM FOR:
Those on the Attached List FROM:
LeMoine J. Cunningham. Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness i
Office of Nuclear Reactor Regulation
SUBJECT:
OPid: NRC INFORMATION NOTICE, " INTERPRETATION U U10 ASSAY MEASUREMENTS; ASSESSHENT OF INTAKE" l
t In a July 13, !?S8 memorandum, I informed you' that we had decided not to issue the enclosed draf t information notice which had been prepared af ter resolution of HRC 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 draf t information notice concerning the-incorrect
" position" in Information Notice No. 8218.
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 draf t notice; however,1we again have decided not to do so primarily because the regulatory guide incorporating the ir. formation 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.
eN ~ e J. Cunningha, Chief Rad ation Protection Branch Divicion of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097
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UNITED STATES i
N.
NUCLEAR REGULATORY COMMIS$10N 0FFICE OF NUCLEAR REACTOR REGULATION i
J WASHINGTON, D.C.
20555 l
June xx,1988 1
NRC INTORMATION NOTICE NO. 88 XX:
INTERPRETATION OF 810 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKES Addressees:
i 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 guider. The NRC position in Infomation Notice 82-18 indicates that, for-p'urposes of determining comp 1tance 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 using hioassay 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 measuremehts, " Interpretation of Bioassay Easurements? TEG/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:
i The NRC staff position with respect to bioassay is presented in NRC Regulatory and 8.26.
In general, the position is that 8.9, 8.11, 8.20, 8.22,ke using bionssay data should be based on the best Guides assessment of individual inta 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 coupliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final rule.'
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June xx, 1988 Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82-18 (1) is incorrect in ir. plying that only ICRP Publication 2 can be used for biocssay data to determine compliance with 10 CFR Part 20 and assessina (2) confIicts with the NRC staff position expressed in relevant regulatory guides. Although ICRP Publication 2 provides the basis for current 10 CFR Part 20 limits on inteke (based on long-term, chronic exposures), it does not always pronide an acequate basis for assessing individual intake because it does not provide information on body content or excreta rollowing single (acute) intake or infomation applicable to an individual differing from the This inadequacy is recognized in
' standard man' defined in ICRP Publication 2.
2CRT 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 82-18 as a result of reviews and discussions during {its-draft stage) of a draf t 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 manual that, for the first time, provides information on how to com>ute intakes from both in vivo and in vitro bioassay measurements and contains tasles for the interpretation c,f This manual bioassay results, in terms of intake, for several hundred nuclides.
conforts 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 computer models using the same set of assumptions (REME0Y i
and DOSEDAY/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 ICRP Publication 2.
The HRC plans to issue, for conenent, a draf t regulatory guide that would i
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 bicassay 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 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 30 CFR Part 20.
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IN 88.XX
'1 1988' June ax,f 3 Page 3 o a
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No specific action or written res sonse is required by this information notice.
If you have any questions about tiis matter please contact the regional administrator of the appropriate regional office or this office.
I Charles E.-Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation j
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References (1) IE Information Notice 82.18, " Assessment of Intakes of Radioactive Material by Workers,* June 11, 1982.
(2) " Report of Comittee II on permissible Cose for Internal Radiation,*
Recomendstions of the International Comission on Radiological Protection, JCRP Pub 11 cation 2, 1959.
f (3) " Report of Comittee !Y on Evaluation of Radiation Doses in Bo# Tissues from Internal Contamination due t: Occupational-Exposure " Recommendations of the International Commission on Radictogical Protectfon -ICRP Publication 10, 1968.
i i
(4) 'The Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptakes; A Report of.ICRP Committee 4,* Recomendations of the i
l International Comission on Radiological Protection,'ICRP Publication 10A,
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1969.
(5) Edward T. Lessard, Xia Y1hua. Kenneth W. Skrable, et al.,)' Interpretation i
of Stoassay Measurements " NUREG/CR-4884 (BNL-NUREG-52063, July 1987.
Attachment:
List of Recently Issued NRC Information Notices 4
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