ML20043C174
| ML20043C174 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/22/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Ellen Brown PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| References | |
| NUDOCS 9006040175 | |
| Download: ML20043C174 (2) | |
Text
,.
MAY g g 1999 l
Docket No. 50-443 Public Service Company of New Hampshire ATTN: Mr. Edward A. Brown, President and Chief Executive Officer New Hampshire Yankee Division Post Office Box 300 f
Seabrook, New Hampshire 03874 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 no 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 aid R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards
Attachment:
LJCunningham Letter, " Draft NRC Information Notice,
' Interpretation of Bioassay Measurements; Assessment of Intake'". dated March 14, 1990 OFFICIAL RECORO COPY MULTI LTRS - 0048.0.0
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h cc'w/ attachment:
J.'C. Duffett, President and Chief Executive Officer, PSNH U
T. C. Feigenbaum, Senior Vice President and Chief Operating Officer, NHY J. M. Peschel, Operational Programs Manager, NHY D. E. Moody, Station Manager,- NHY T. Harpster, Director of Licensing Services R. Hallisey, Director, Dept. of Public Health, Commonwealth of Massachusetts iB S. Woodhouse, legislative Assistant r
_ Public Document Room _(PDR)
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Local;Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Hampshire, SLO Commonwealth.of Massachusetts, SLO Designee Seabrook Hearing Service List bec w/ attachment:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
R. Bellamy, DRSS-E. McCabe, DRP J. Johnson, ORP SRI - Seabrook-(w/ concurrences) g L_
K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports J. Caldwell, NRR V. Nerses, NRR-P
.L.'J.-Cunningham, NRR J. D. Buchanan, NRR OFFICIAL RECORD COPY MULTI LTRS - 0049.0.0 05/08/90 bI '
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March 14, 1990 i
hEh0RANDUM FOR: Those on the Attached List FROH:
LeMuine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection ano Etnergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT NRC INFORMATION NOTICE, " INTERPRETATION OF bl0 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE" in a July 13, 1566 rnemorandum,1 informeo you that we had decided not to issue the enclosec: craft information notice which had been prepared after resolution of NRC ht:adquarters and regional office comments on earlier draf ts.
(Note:
The technicel 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 h0 REG /CR-4684, " 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 eApect 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 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.
i eM e J. Cunningha, Chief Rad ation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097 5
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NUCLEAR REGULATORY COMMIS$10N OFFICE OF NUCLEAR REACTOR REGULATION i
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June ax,1988 NRC JNTORP.ATION NOTICE NO. 88.XX:
INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKES l
Addres see_s:
All nuclear power reactor facilities holding an operating license or a con-struction pemit, research and test reactors, fuel facilities, and Friority I material licensees, j
Background and
Purpose:
This information notice is intended to correct en NRC position in Infometion
[
Notice $2-18 (Reference 1) that was in conflict with the NR(/ staff position published in several regulatory guides. The NRC position in Inforw tion Notice 82-161r.:icates that, for p'urposes of detervining compliance with the 10 CTR Part 20 intele limits, only the methodology of the International Comission on Radiological Frotection (ICRP) Publication 2 (Reference 2) can be used in assessing intakes of radioactive material using bionssay data. Another purpose of this 1985 information netice 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, "Interpretetion of Sioassey Neasurements? TutG/CR-4ss4).
It is expected that recipients will review the information in this information notice for applicability to their prograres, However, suggestions contained in this information notice do not constitute NRC t
requirerents; therefore, no specific action or written response is required.
i Discussion:
The NRC staff position with respect to bloessay is presented in NRC Regulatory i
8.22, and 8.26. In general, the position is that Guides 8 g, 8.11, 8.20,l intake using bicassay data should be based on the best assessment of individua data and models available for that purpose.
i.
- 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 poeition: 'The NRC will continue to use the ICRP Publication 2 methodology in determining cospliance with 10 CFR 20 until the revision of 30 CFR 20 has been published as a final rule.'
DRAli l
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M P "Y 2N 88 n yd5 June xx, 1sts Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82 28 (2) is inecrrect in fylying that only ICRP Publication 2 car. be used for assessin-bioessay data to determine compliance with 20 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 20 CFR Part 20 limits on intake (based on long term, chronte exposures), it does not always proitce an acequate basis for assessins individual intake because it dets not pro,'ide information on body content or excrete following single (acute) intake or information a splicable to an individual differing from the i
" standard man' defined in ICRP Publication 2.
This inadequacy is recognized in 2CRT Fublications 20 and 10A (References 3 and 4), which are endorsed in Regulatory Guide 6.g and which are mentioned in Infomation Notice 82-28 as being used by the NRC to evaluate bioassey data to determine compliance with regulatory requirenents.
The NRC staff became aware of the problem with the NRC posiyion in Information Notice 82 28 as a result of reviews and discussions during itsdraftstage) g of a draf t report, ' Interpretation of 810assey Nessurements ' (Reference 6),
prepared by Brookhaven National Laboratory (ENL) 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 bionssay measurements and contains tables for the interpretation of bionTsay 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 coeparison with results generated by other computer eodels using the same set of assusptions (REMIDY 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 coment, a draf t regulatory guide that would endorse the BNL report for use in assessing intakes of radioactive material from the results of bionssay measurements.
In the interim, use of this report for the interpretation of bioassay measurements is consistent with the regula.
tory positions in existing regulatory guides on bioassayIntake given in
- therefore, the report may be used for this purpose.
Of course, the limits on 30 CFR 20.103 and based on ICRP Publication 2 continue to apply until they are changed in a revision of 20 CFR Part 20.
Furthermore, to the extent it is applicable ICRP Publication 2 may continue to be used for assessing intakes of i
radioactive r.aterial for comparison with the intake limits of 30 CFR Part 20.
RAFT
IN 88 XX 1988 June ax,f 3
~J-Page 3 o No specific action or written res sense is required by this information notice, i
If you have aror questions about tiis utter please contact the regional j
adrinistrator of the appropriate regional office or this office.
Charles E. Rossi, Director j
Division of Operational Events Assessment Office of Nuclear Reactor Regulation J'chn D. Butdanar/
Technica1 Contaets:-4missenapesh, NRR 8cu-fard 6. ho AS, R Af
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(Sol) 9'92-2738 (301) 492-3422 J
Reference s (1) IE Inforation Notice 8218,
- Assessment of Intakes of Radioactive Material by Workers,' June 12,1982.
]
(2) ' Report of Comittee !! on fermissible Dose for Internal Radiation,'
Recomendatiens of the International Comission on Radiological Protection, ICRP Pub 1tcation 2, 1959.
(3)
- Report of Comittee IV on Evaluation of Radiation Doses in Body Tissues from Internal Contas;ination due to Occupational Exposure,' Reconnendations of the International Coscission on Radiological Protection, ICRP Publication 10,1968.
(4) 'The Assessment of Internal Contamination Resulting from Recurrent er A Report of ICRP Comittee 4,* Recomendations of the Prolonged Uptakes;ission on Radiological Protection, ICRP Publication 20A, International Comm i
1969.
(3) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable et al.3), Interpretation of Sloassay Measureser.ts,' NUREG/CR.4884 (8NL.NUkIG 5206 July 1987.
l Attachinent: List of Recently Issued NRC Information Notices 9
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