ML20043B551
| ML20043B551 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/22/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| NUDOCS 9005300188 | |
| Download: ML20043B551 (2) | |
Text
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MAY 22 19m m,
Docket Nos, 50-352 50-353-
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-Philadelphia Electric Company r
ATTN: Mr. D. M. Smith s
' Executive Vice President -
Nuclear W
-Correspondence' Control Desk P. O. Box 195 1
.Nayne, PA-19087-0195 m
LGentlemen:
Subject:
. INTERPRETATION OF BIDASSAY MEASUREMENTS; ASSESSMENT OF INTAL.
- In'accor' dance.with the attached information, Region I Reactor licensees are advised that assessing, intakes of radioactive material;using bioassay cata should be' based on the best data.and models available for that purpose.
-Licensees;areLno longer restricted to the assessment methodology in ICRP:
w Publication'2 in. determining-compliance with 10 CFR 20 intake limits, i
' Licensees may use improved-and generally: accepted methodology such as provided in recent ICRP Public?tions and NUREG/CR-4884-Sincerely,
)
R ald R. Bellamy, Chief I
Facilities b diological Safety and Safegusrds Branch Division of1 Radiation Safety' ar.d Safeguards
Attachment:
LJCunningham Letter, " Draft NRC Information Notice,
' Interpretation of Bioassay Measurements; Assessment of Intake'". dausd March 14, 1990 c;,
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.9005300188 900522 PDR; ADOCK 05000352
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' MAY 2 21990 Philadelphia-Electric Company-2 cc w/ attachment:
R..J. Lees, Chairman, Nuclear Review Board G. M. Leitch, Vice President - Limerick Generating Station D. R. Halwig, Vice President of Nuclear Engineering and Services J. W. Durham, Sr., Vice President and General Council M. J. McCormick, Jr., Manager - Limerick Generating Station G. A. Hunger, Jr., Director - Licensing Section J. Doering, Project Manager - Limerick Ger? rating Station J. F. O'Rourke, Manager - Limerick Qualit;. Division T. B. Conner, Jr., Esquire G. J. Madsen, Regulatory Engineer - Limerick Generating Station Public Document-Room-(PDR)-
Local Public Document Room-(LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector -
Commonwealth of Pennsylvania bec w/ attachment:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o enc 1)
R. Bellamy, DRSS Section Chief, DRP M. Conner (SALP Reports Only)
PA0 (2) SALP Reports Only J. Dyer, EDO L. J. Cunningham, NRR J. D. Buchanan, NRR OFFICIAL RECORD COPY MULTI LTRS - 0019.0.0 05/08/90 9
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION i
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March 14, 1990 liEh0RAllDUM 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 U
SUBJECT:
DRAFT NRC INFORMATION NOTICE, "lNTERPRETATION OF B10 ASSAY MEASUREMENTS; A5SESSMENT OF IHTAKE" In a July 13, 1988 niemorandum, I informeo you that we had decided not to issue the enclosed draf t information notice which had been prepred after resolution of HRC headquarters and regional office co wents on earlier drafts.
(Note:
The technical contacts have been updated on the enclosed copy of the draft.)
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
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" 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 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 pkning a copy of this memo-randum enclosure in the public document room. Timretore, you are free to trans-mit copies to licensees if you so desire.
E eM e J. Cunningha, Chief Rad ation Protection Branch l--
and Emergency Preparedness Division of Radiation Protection Office of Nuclear Reactor Regulation
Enclosure:
Subaect Information Notice
' CONTACT: -John D. Buchanan, NRR 492-1097
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NUCLEAR-REGULATORY COW.1SS10P -
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WASHINGTON, D.C.
20555 June xx, 1988 1
L NRC'INTORMATION NOTICE NO. 88-XX:
INTERPRETATION 0F B10 ASSAY MEASUREMENTS; 1
ASSESSMENT OF INTAKES p
i Addressees:
L All nuclear. power reactor facilities holding an operating license or a con-struction permit, research and test reactors, fuel facilities and Priority 1 E
material licensees.
Background and
Purpose:
)
This information notice is intended to correct an NRC position in Information Notice 82-18l(Reference 3) that was in conflict with the NR9 staff position.
L published in several regulatory guides. The NRC position in Information Notice 82-18 indicates that, for p'ur oses of detersinin compliance with the 10 CFR Part 20 intake limits, only t e methodology of t e International Commission on
-Radiological Protection (ICRP) Publication 2 (Reference 2) can be used in o
~ assessing intakes of radioactive material using bioassay data. Another purpose E
of this 1988 information notice is to call attention to a comprehensive new
'sanual prepared for the NRC that can be.used to compute intakes from both' V
in vivo and in vitro bionssay measure ** hts, "Interpretetion of Bioassay Easurements? TRIG /CR-4884).
It is expected that recipients will review the information.irrthis 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 bioassay is presented in NRC Regulatory
- Suides 8.9, -8.11, 8.20, 8.22, and 8.26. In general, the position is that 4 -
Lassessment of individun intake using bioassay data should be based on the best data and models available for that purpose.
- 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 wiil continue to use the ICRP Pubitcation 2 methodology in determining conpliance with 10 CFR 20 until the revisfor of 20 CFR 20 has been published as a final ru le. * -~
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Mf IN 880XX yM June xx, ISEB
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Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82-18 (2) is incorrect in implying that only ICRP Publication 2 can be used for assessin-bicassey data to determine compliance with 10 CFR Part 20 and (2) conf $icts with the NRC staff position expres ed in relevant regulatory guides. Although ICRP oublication 2 provides the basis for current 10 CFR Part 20 limits on intake (based on long-term, chronic exposures),because it it does not always preside an adequate bests for assessing individual intake does not provide information on bu@ content er excreta followflig single (acute) intake or information applicable to an individual differing from the
' standard man' defined in ICRP Publication 2.
This inadequacy is recognized in ICRFPublications10and10A(References 3and4),whichareendorsedin 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 posi$1on in Information Notice 82-18 as a result of reviews and discussions during itsdraftstage) of a draft 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 interpretation of bioaTiay results, in terms of intake, for several hundred nuclides. This manual 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 sedels using the same set of assumptions (REMEDY andD05EDAY/DOSEYR). 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.
The NRC plans to issue, for comment, a draft regulatory guide that would endorse the BNL report for use in assessing intakes of racioactive 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 1
may be used for this purpose. Of course, the limits on intake given in 10 CFR 20.103 and based on ICRP Pub" cation 2 continue to apply until they are changed in a revision of 30 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 10 CFR Part 20.
O DRAFI
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-!N 88 XX E
1988 June xx,f 3 f
I' Pa9e 3 o I g No specific action or written response is required by this information nottee.
lf you have any qeestions about tiis matter please contact the regional
. edininistrator of the appropriate regional office'er this office.
Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation J'c/pr A Buc4Ma*7 Technical contacts: AsiEmi8sangert, NRR 8ar42rd 6. 8 coo /t5 / R AS
[30/) YP2-3738 (301) 492-3422 References
-(I) IE Information Notice 82-18, ' Assessment of Intakes of Radioactive Material by Workers," June ll,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 Dccupational Exposure,*.Reconnendations of the International Comission on Radiclo91 cal Protection, ICRP Publication 10,1968.
(4) 'The Assessment of-Internal Contamination Resulting from Recurrent or Prolon9ed Uptakes; A Report of ICRP Committee 4,' Recomendations of the International Comission on Radiological Protection, ICRP Publication 10A, 1969.
(5) Edward T..Lessard, Kia Yihua, Kenneth W. Skrable, et al.,)' Interpretation
- of Bioassay Measurements," NUREG/CR-4884 (3NL-NUREG-52063, July 1987.
Attachment:
List of Recently Issued NRC Information Notices S
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