ML20043C345
| ML20043C345 | |
| 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 9006050088 | |
| Download: ML20043C345 (2) | |
Text
.
MAY 2 21990 Docket No. 50-245 Northeast Nuclear Energy Company ATTN: Mr. E. J. Mroczka Senior Vice President - Nuclear Engineering and Operations P. O. Box 270 Hartford, Connecticut 06141-0270 Gentlemen:
Subject:
INTERPRETATION OF B10 ASSAY 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 ar n
0FFICIAL RECORD COPY MULTI LTRS - 0012.0.0 yl*
L'gi ;d d 05/08/90 A
9006050088 900522 PDR ADOCK 03000245 p
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Northeast Nuclear Energy Company 2
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cc w/ attachment:
W. D. Romberg, Vice Prer,ident, Nuclear Operations S. E. Scace, Station Superintendent D. O. Nordquist, Director of Quality Services R. M. Kacich, Manager, Generation Facilities Licensing D. B. Miller, Station Superintendent, Haddam Neck Gerald Garfield, Esquire Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of Connecticut bec w/ attachment:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
R. Bellamy, DRSS DRP Section Chief.
W. Raymond, SRI, Millstone M. Conner, SALP Reports Only J. Shediosky, SRI, Haddam Neck K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports
'J. Caldwell, NRR M. Boyle, LPM, NRR L. J. Cunningham, NRR J. D. Buchanan, NRR 0FFICIAL RECORD COPY MULTI LTRS - 0013.0.0 05/08/90
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/o UNITED STATES
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March 14, 1990 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, "lNTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE" s
in a July 13, 1968 memorandum, I informed you that we had decided not to issue the enclosed draft information notice which had been prepared after resolution of HRC headquarters and regional office comments 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 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
" 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-7 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-rendum enclosure in the public document room. Therefore, you are free to trans-mit copies to licensees if you so desire.
ons7,,
eH e J. Cunningha, Chief
- - 4, C/g2 Rad ation Protection Branch
( ~' -oi Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097
q MI D:ck.wre t
UNITED STATES Mh 6
NUCLEAR REGULATORY COW.1SS!ON 0FFICE OF NUCLEAR REACTOR REGULATION WASHINGTON, D.C.
20555' June xx, 1988 NRC INFORMATION NOTICE NO. 88-XX:
INTERPRETATION 0F 810 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKES l
Addressees:
j All nuclear power reactor facilities holding an operating license or a con-struction pemit, research and test reactors, fuel facilities, and Priority I material licer. sees.
Background and
Purpose:
This information notice is intended to correct an NRC osition in Information Notice 82-18 (Reference 1) that was in conflict with t e NR9 staff position s
published in several regulatory guides. The NRC position in Information Notice 82-28 indicates that, for p'urposes of determining compliance with the 10 CFR l'
Part 20 inta'ke limits, only the methodology of the International Comission on J
Radiological Protection (ICRP) Publication 2 (Reference 2) can be used in assessing intakes of radioactive material using bicassay 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, 'Interpretetion of Bioassay l
Keasurements? TTJRIG/CR-4884).
It is expected that recipients will review the s
i information in this information notice for applicability to their programs.
t 1
However, suggestions contained in this information notice do not constitute NRC l
requirements; tiierefore, no specific action or written response is required.
l L
Discussion:
)
The NRC staf f ptrsition with respect to bioassay is presented in NRC Regulatory
- 1 Guides 8.9, 8.11, 8.20, 8.22, and 8.26. In general, the position is that assessment of individual intake using bloassay data should be based on the best data and models available for that purpose.
IE Information Motice 82-38, " 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 coupliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final rule."
i
'w-
MfU IN 88 XX ydg June xx, 3pBB Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82-18 (1) is incorrect in is: plying that only ICRP Publication 2 can be used for assessin-bicassey data to determine compliance with 10 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 10 CFR Part 20 limits on intake (based on long tem, chronic exposures), it does not always provide an acequate basis for assessing individual intake because it does not provide information on body content or excreta 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 ICRT Fub11 cations 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 pos1% ion in Information Notice 82-18 as a result of reviews and discussions during [its draft stage) of a draft report, " Interpretation of 81oassay Neasurements (Reference 5),
a 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 bioassey measurements and contains taales for the interpretation of bioasiay results, in terms of intake, for several hundred nuclities. This manual conforts to the positions in existing regulatory guides,, and the computed intake retention fractions in the report have been verified by comparison with results generated by other computer sedels using the same set of assus:ptions (REMEDY andDOSEDAY/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 NRC plans to issue, for comment, a draft regulatory guide that would 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 bloassay; therefore, the report say be used for this purpose. Of course, the limits on intake given in 10 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 10 CFR Part 20.
IN 88 XX 1988 L---
June xx,f 3 Page 3 o No specific action or written res sense 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.
Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation J'eba D. Buc/tanart Technica1 Contaets:-4ilisiliisiliigpush, NRR 8(ted2rd 6. 8epo AS, R AS (30/) 992-3738 g.,.
(301) 492-3422 J
References (1) IE Information Notice 82-18, ' Assessment of Intakes of Radioactive Material by Workers ' June 22, 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," Recomendations of the International Commission on Radiological Protection, ICRP Publication 10, 1968.
(4) 'The Assessment of Internal Contamination Resulting from Recurrent or A Report of ICRP Comittee 4,* Recomendations of the Prolonged Uptakes;ission on Radiological Protection. ICRP Publication 10A, International Com l
1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable, et al.,)" Interpretation
. of Bioassay Measurements " NUREG/CR-4884 (BNL-NUREG-52063, July 1987.
l
Attachment:
List of Recently Issued NRC Infomation Notices s
O e
e m