ML20043B512
| ML20043B512 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 05/22/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Mroczka E CONNECTICUT YANKEE ATOMIC POWER CO. |
| References | |
| RTR-NUREG-CR-4884 NUDOCS 9005300130 | |
| Download: ML20043B512 (2) | |
Text
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.p MAY 2 21990 -
f Docket No; 50-213 g
Connecticut Yankee Atomic Power Company
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- ATTN:.Mr. E. J. Mroczka-Senior Vice President - Nuclear Engineering and Operations Group P.0, Box'270 e
-Hartford, Connecticut 06141 Gentlemen:
Subject:
INTERPRETATION OF B10 ASSAY MEl,SUREMENTS; ASSESSMENT OF INTAKE a
~In accordance with the attached information, Region I Reactor licensees are 4
advised that assessing intakes of radioactive material using bioassay data should.be based on-the best data and models avati.able for that purpose, Licensees are no langer restricted to the assessment methodology in ICRP.
Publication-2:in determining compliance with 10 CFR 20 intake limits.
Licenseas may u n improved and generally accepted methodology such as provided l
in recent ICRP Publications and NUREG/CR-4884.
Sincerely,
\\
R aid R. Bellamy, Chief Facilities Radiological Safety and Safeguards-Branch Division of Radiation Safety and Safeguards t
L;
Attachment:
LJCunningham Letter, " Draft NRC Information Notice,
' Interpretation of Bioassay Measurements; Assessment of l
Intake'". ' dated March 14,-1990 5
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, Connecticut Yankee Atomic Power Company 2
- EMY 2 2 1999 i>;
cc w/ attachment:
- W. D. Romberg, Vice President,. Nuclear Operations.
D. B. Miller, Station Superintendent D-D. 0.:Nordquist, Director.of Quality Services ti '
.R. M. Kacich, Manager, Generation Facilities Licensing.
S,'E.Scace,StationLSuperintendent, Millstone Gerald Garfield,-Esquire Fublic Document Room'(PDR)<
Local Public Document Room (LPDR)-
Nuclear Safety Information Center (NSIC) i NRC. Resident Inspector State of Connecticut bec w/ attachment:
' Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
R. Bellamy, DRSS DRP Section Chief M. Conner, SALP Reports Only J. Shediosky, SRI, Haddam Neck W. Raymond, SRI, Millstone 1&2
-K. Abraham, PA0'(20) SALP Report and-(2) All Inspection Reports J. Caldwell, NRR
'A.. Wang, LPM, NRR L. J. Cunningham, NRR x,
J.-D. Buchanan, NRR:
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1 0FFICIAL RECORD COPY MULll LTRS - 0023.0.0 05/08/90 1
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'o UNITED STATES Ig,
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NUCLEAR REGULATORY COMMISSION
- .,; j WASHINGTON, D. C. 20f 65 1, %,/
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March 14, 1990 HEh0RANDUM FOR: Those on the Atteched List i
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, " INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE" in.a July 13, 1988 memorandum, I informed,ou 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:
Thetechnicalcontactshavebeenupdatedontheenclosedcopyofthedraft.)
A' primary reasna for this decision was that a regulatory guide endorsing the use l
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 l
" 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 draft notice; however, we again have L
decided not to do so primarily because the regulatory guide incorporating the
-information is still planned and because the importance of the information con-ta ned in the enclosed draft is-below the current threshold of importance suf-ficient 1.0 warrant issuance of an NRC information notice. However, to make this information available to the public, we are placing a copy of this memo-s l
randum enclosure in the public document room. Therefore, vou are free to trans-y mit copies to licensees if you so desire.
i ll 1
L h
n eM ' e J. Cunningha, Chief Rad ation Protection Branch Division of Radiation Protection o
and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097 SGB5;1i002G
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DNITED STATES
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l NUCLEAR REGULATORY COMMIS$10N-I 0FFICE OF NUCLEAR REACTOR REGULATION-i.'
WASHINGTON, D.C.
20$55 June ax, 1988
' NRC'INFORMATION NOT]CE NO. 88 XX:
INTERPRETAT]DN 0F B10 ASSAY MEASUREMENTS; ASSESSMENT 0F 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 licensees.
Background and Pgrpose:
This information notice is intended to correct en NRC position in N unation Notice 82-18 (Reference 3) that was in conflict with the NR9 staff p sition s
published in several regulatory guides. The NRC position in Inforn.e ion Notice 82-18 indicates that, for p'urposes of detersining compliarice 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 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 MasiiEments? TRURG/CR-4884). -It is expected that recipients will review the s
information in this-hformation notice for applicability to their programs.
However. suggestions 4.ontained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Discussien:
.The NRC staff position with respect to bioassry is presented in NRC Regulatory
. Guides 8.9, 8.11, 8.20, 8.22, and 8.26. In guaral, the position is that assessment of individual intake using bicassay data should be based on the best data and models available for that purpose.
1E 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 Publicatior 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 ru1e.*:
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DRAIT t
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hh,k En$ ass 8 Page 2 of 3 The NRC staff now recognizes that this position in Inforsation Notice 82-28 (2) is inecrrect in itiplying that only ICRP Publication 2 can be used for assessing bicassey data to determine compliance with 10 CFR Part 20 and (2) conflicts with the NRC staff position expressed in relevant regulatorv guides. Although ICRP Publication 2 provides the basis for current 20 CFH Part 20 limits on intake (based on long term, chronic exposures), it does not
.always pronide an acequate basis for assessing individual inta e because it k
does not provide information on body content or excrete following single (acute) intake or information applicable to an individual differing from the j
- standard man' defined in ICRP Publication 2.
This inadequacy is recognized in f
ICRT Publications 10 and 10A (Referencet 3 and 4), which are endorsed in Regulatory Guide 8.9 and which are mentbned in Information Notice 82-18 as beir.g used by the NRC to evaluate bioassay data to determine compliance with
)
regulatcry requirements.
The NRC staff became aware of the problem with the NRC position in Information Notice 82-28 as a result of review and discussions during [its draft stage) of a draf t report, " Interpretation of Bioassay Measurements (Reference 5),
e prepared by Brookhaven National taboratory (BNL) under en 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 bioassay measurements and contains tables for the interpretation of
- bioassay results, in terms of intake, for several-hundred nuclidus. 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 computer endels using the same set of assumptions (RiMIDY andD05EDAY/DOSTYR). The use of this report, with its straightforward method-clogy, could help licensees avoid the difficulties associated with the use of the methodology in ICRP Publication 2.
l The NRC plans to issue, for comment, a draft regulatory guide that would I.
endorse the SNL report for use in assessing intakes of radioactive material l
from the results of bionssay 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 rnay. be used for this purpose. Of course, the limits on intake given in 20 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 cf radioactive material'for comparison with the intake limits of 10 CFR Part 20.
DRAFT
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IN 88 XX 4
?L June xx 1988 7%
Page 3 of 3 No specific action or written response is required by this information notice.
If you have any questions about this satter please contact the regional
- administrator of the appropriate regional office or this office.
i Charles E. Rossi, Director Division of Operational Events Assesssent Office of Nuclear Reactor Regulation J'enn A Buchanart Technical Contacts:-4sia0iumiE4pssh, NRR 8tu-62r4 6. BrooAg,Raf e
7e fer-(U*l) V'fI~.IlStI!l'
. =-:=, NRSS
. - _ _(301) 492-3422 J
References j
.(1) IE Information Notice 82-18, "Assesse:nt of Inu#s of Radioactive Material by Workers,' June 12, 1982.
j (2) ' Report of Comittee !! on fermissible Dese for rtenal Radiation,"
Recomendations of the International Comission on Radiological Protection, ICRP Publication 2, 1959.
1 (3)
- Report of Comittee IV on Evaluation of Radiation Doses in Body Tissues 4
from Internal Contamination due to Occupational Exposure,' Recommendations of the International Comission on Radiological Protection, ICRP l
-Publication 10, 1968.
(4) "The Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptakes; A Report of ICRP Committee 4,* Recomendations of the International Comission on Radiological Protection. ICRP Publication 20A, i
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 Inforwtion Notices e
I 1
h a
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