ML20043B516
| ML20043B516 | |
| 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 9005300141 | |
| Download: ML20043B516 (2) | |
Text
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1 MAY 2 21990 I
-I Docket No.
50-423 Northeast Nuclear Energy Company o
ATTN: Mr. E. J. Mroczke Senior Vice President - Nuclear I
Engineering and Operations Group l
P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
Subject:
INTERPRETATION OF BIOASSAY 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 nc longer restricted to the assessment methodology in ICRP 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.
\\
r R aid R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards
Attachment:
LJCunningham Letter, "Draf t NRC Information Notice,
' Interpretation of Bioassay Measurements; Assessment of Intake'". dated March 14, 1990
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OFFICIAL RECORD COPY MULTI LTRS - 0038.0.0 05/08/90 9005300141 900522 PDR ADoCK 05000423 P
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- Northeast Nuclear Energy Company 2
MAY 2 219n3 i
cc w/ attachment W. D. Romberg, Vice President Nuclear Operations D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing S. E. Scace, Station Superintendent D. B. Miller, Station Superintendent, Haddam Neck Public Document Room (PDR)
L Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Senior Resident ' Inspector State of Connecticut r
bec w/ attachment:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
R. Bellamy, DRSS DRP Section Chief 1
M. Conner, SALP Reports Only S. Pindale, RI, Beaver Valley l
W. Raymond, SRI, Millstone 1&2 i
K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports J. Caldwell, NRR D. Jaffe, LPM, NRR L. J. Cunningham, NRR J. D. Buchanan, NRR
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11 0FFICIAL RECORD COPY MULTI LTRS - 0039.0.0 05/08/90
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UNITED STATES j
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1 NUCLEAR REGULATORY COMMISSION t'
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WASHINGTON, D. C. 206$5 e
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.e March 14, 1990 s
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, " INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF lHTAKE" in a July 13, 1986 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 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 huREG/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 a 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, i
We have reconsidered issuing the enclosed draf t notice; however, we again have i
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 cocument room.
Therefore, you are free to trans-mit copies to licensees if you so desire.
l L
eM e J. Cunningha, Chief Rad ation Protection Branch l
Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097 h0U 0 h{}
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UNITED STATES M.
NUCLEAR REGULATORY COMM15$10N OFFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555 June xx, 1988 NRC INTORMATION NOT]CE NO. 88 XX:
INTERPRETATION OF B10 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 1 material licensees.
Background and
Purpose:
This information notice is intended to correct en NRC position in Infometion Notice 82 18 (Reference 1) that was in conflict with the NRQ staff position s
published in several regulatory guides. The NRC position in Infomation Notice 82-16 incicates that, for purposes of detemining compliance with the 10 CFR Part 20 inta'ke limits, only tbe methodology of the International Commission 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 bioassey measuremehts " Interpretation of Bioassay Reasurements TR'JRIG/CR-assa).
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:
The NRC staf f position with respect to bioassey is presented in NRC Rejulatory Guides 8.9, 8.11, 8.20, 8.22, and 8.26.
In general, the position is t)at assessment of individual intake using bioassay 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 Publication 2 and concluded with the NRC position: 'The NRC will continue to use the ICRP Pubitcation 2 methodology in determining compliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final rule.'
DRAFT
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- j' M3P IN 88oXX l-y 'Q"'
June xx,1988 Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82 18 (3) is incorrect in is: plying that only ICRP Publication 2 can be used for assessing bionssay data to determine compliance with 10 CFR Part 20 and (2) conflicts with the NRC staff position expressed in relevant regulatory guides. Although JCRP Publication 2 provides the basis for current 20 CFR Fart 20 limits on intake (based on long term, chronic exposures), it does not
.always provide an actuate basis for assessing individual intake because it does not provide information on body content or escreta following single (acute) intake or information applicable to an individual differing from the
- standard man" defined in ICRP Publication 2.
This inadequacy is recognized in 3CRT Putlication: 10 and 10A (References 3 and 4), which are endorsed in Regulatory Guide 8.9 and which are mentioned in Inferretion Notice 82-18 as being used by the NRC to evaluate bionssay data to determine compliance with regulatcry requirements.
~ The NRC staff became aware of the problem with the NRC poslyton in Information Notice 82-28 as a result of reviews and discussions during itsdraftstage) g of a draf t report, " Interpretation of Bionssay Neasurements ' (Reference 5),
i 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 interpretaIIon of biosisay results, in terms of intake, for several hundred nuclides. This manual conforms to the positions in existing Mgulatory guides and the computed intake l
retention fractions in the report have been verified by,,coniparison with results generated by other computer models using the same set of assumptions (REMEDY andDOSEDAY/DOSEYR). The use of this report, with its straightforward method-clogy, could help Jicensees avoid the difficulties associated with the use of the methodology in_ICRP Publication 2.
i The NRC plans to issue, for comment, a draf t regulatory guide that would endorse the BKL report for use in assessing intakes of radioactive material l
from the results of bicassay 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 20 CFR 20.203 and based on ICRP Publication 2 continue to apply until they are changed in a revision of 10 CFR Fart 20.. Furthermore, to the extent it is e
' applicable. ICRP Publication 2 may continue to be used for assessing intakes of t
L radioactive material for comparison with the intake limits of 10 CFR Part 20.
O DRAFI
IN 88-XX 1988 June ax,f 3 Page 3 o No specific action or written response is require 1 by tha information notice.
If you have any questions about this atter plea u cuntu.? the regional
-administrator of the appropriate regional office or tMs Wice.
Charles E. Rossi, Director Division of Operational Events Assessrent Office of Nuclear Reactor Regulation Jobn A Buc/tanar?
- Technical contacts: -4lingisisiistigualib, NRR Boedard 6. 8tvoA5j RAS (301) 492-3087- /d $P7, g,
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(301) 492-3422 e
i 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 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 Body Tissues from Internal Contamination due to Occupational Exposure," Recournendations of the International Consnission on Radiological Protection, ICRP '
Publication 10,1968.
(4) 'The Assessment of Internal Contamination Resulting free Restrent or Prolonged Uptakes; A Report of ICRP Committee 4,' Recomendations of the International Cosseission on Radiological Protection. ICRP Publication 10A, 1969.
(5): Edward T. Lessard, Xia Yihua. Kenneth W. Skrable, et al.,)' Interpretation of Bioassay Measurements,' NUREG/CR-4884 (BNL-NUREG-52063, July-1987. -
Attachment:
List of Recently Issued NRC Information Notices 9
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