ML20043C346
| ML20043C346 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/22/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| References | |
| RTR-NUREG-CR-4884 NUDOCS 9006050089 | |
| Download: ML20043C346 (2) | |
Text
.c MAY r 21990 Docket No. 50-320 GPU Nuclear Corporation ATTN: Mr. M. B. Roche Director of TMI-2 P. O. Box 480 Middletown, Pennsylvania 17057 Gentlemen:
Subject:
INTERPRE1ATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE In accordance with the attu hed information, Region I Feactor licensees are advised that assessing intakes of racioactivt 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 1
in recent ICRP Publications and NUREG/CR-4884 Sincerely.
\\
R nald 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 0FFICIAL RECORD COPY MULTI LTRS - 0034.0.0 9006050oep 9003 2 e m m osoog;ggo yg
a GPU Nuclear Corporation 2
VAY f 2 1993 cc w/ attachment:
T. F. Demmitt, Deputy Director, TMI-2 R. E. Rogan, Licensing and Nuclear Safety Director J. J. Byrne, Manager, TMI-2 Licensing W. J. Marschall, Manager, Plant Opt. rations S. Levin, Defueling Director J. B. Lieberman, Esquire E, L. Blake, Jr., Esquire G. A. Kuehn, TMI-2 Site Operations Director TMI-Atert(TMIA)
Susquehanna Valley Alliance (SVA)
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, DR$$
DRP Section Chief M. Conner, SALP Reports Only S. Lewis, OGC Michael Masnik, PM, TMI-2 K. Abraham, PA0 (20) SAlp Report and (2) All Inspection Reports J. Caldwell, NRR L. J. Cunningham, NRR J. D. Buchanan, NRR OFFICIAL RECORD COPY MULTI LTRS - 0035.0.0 05/08/90
/ p 08cg'c p
UNITED STATES E',3ej[,s NUCLE AR REGULATORY COMMISSION wF - t utmNG T ON. D. C. 20666
<s,.'.... e March 14, 1990 14Eh0RAliDUM FOR: Those on the Attached List FROM:
LeMuine J. Cunningham, Chief Radiation Protection branch Division of Radiation Protection and Emergency Prepanoness Office of Nuclear Reactor Regulation
SUBJECT:
MAFT NRC 1NFORMAT10N NOTICE, "lNTERPRETATION 0F bl0 ASSAY HEASUREMEliTS; ASSESSMENT OF INTAKE" in a July 13, 1968 memorandum, I informeo you thLt we had decideo not to issue the enclosed tref t information notice which had been prepared af ter resolution of NRC headquarters and regional office comments on earlier drafts.
(Note:
The technicci 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
" 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 50 primarily because the regulatory guide incorporating the information is still planned and because the importance of the information con.
tained in the encloseo 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-rendum enclosure in the public document room. Therefore, you are free to trans-mit copies to licensees if you so desire.
l eN e J. Cunningha, Chief Rad ation Protection Braach d A l k O [ d 6_
f Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097
/~a ch.rw e p1 WlTED STATES C -
h L.
NUCLEAR REGULATORY COMM15510N I
0FFICE OF NUCLEAR REACTOR REGULATION i
WASHINGTON, D.C.
20555 June ax 1988 NRC INTORMATION NOTICE NO. 68.XX:
INTERPRETATION OF 810 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKIS Addressees:
All nuclear power reactor facilities holding an operating license or a con-struction permit, research and test reactors, fuel facilities, and Priority I w terial lieer. sees.
Background and
Purpose:
This information notice is intended to correct an NRC aosition in Infomation Notice 8216 (Referente 1) that was in conflict with tie NRP staff position published in several regulatory guides. The NRC position in Infora tion Notice 8216 indtrates that, for p'urposes of deter'sining compliance with the 10 CFR Part 20 intale limits, only the mthodology of the International Comission on RadiologicalFrotection(ICRF) Publication 2(Reference 2)canbeusedin assessing intakes of radioactive material using bionssay 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 Sioassay KiaTuTiments? TRAIG/CR-4884).
It is expected that recipients will review the information ir, 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 bioassay is presented in NRC Regulatory 8.22 and 8.26.
In general, the position is that 8.9. 8.11, 8.20,l intake using bloessay data should be based on the best Guides assessment of individua data and models available for that purpose.
1E Information Notice 8218, ' 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 Pchlication 2 methodology in determining cospliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final ruit.'
DRMT 4
l DD p IN 88.XX d
- ylh 3 June xx,f 3 IgEB Page 2 o J
The hRC staff now recognizes that this position in Inforn tion Notice 82 18 (2) is incorrect in isiplying that only ICRP Publication 2 can be used for i
assessin bicassay data to determine compliance with 10 CFR Part 20 and (2) conflicts with the NRC staff position expressed in relevant regulatory guides. Although ICRT Publication 2 provides the basis for current 10 CFR Part 2011mits on intake (based on long tem, chronic exposures), it does not always prmee an acequate basis for assessin; individus1 intake because it does not provide infomation on body content or escreta following single (acute) intake or information applicable to an individual differing from the
- standard un' defined in ICRP Publication 2.
This inadequacy is recognized in 1CRT Fublications 20 and 10A (References 3 and 4), which are endorsed in Regulatory Guide 8.9 and which are mentioned in InforMtion Notice 8218 as i
being used by the NRC to evaluate bloassey data to determine compliance with regulatcry requirerients.
The NRC staff became aware of the problem with the NRC postyion in Inforation Notice 62 28 as a result of reviews and tiscossions during
,itsdrAftstage) of a draf t rtport, ' interpretation of Bioassay Nessurements' (Reference 6),
s 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 infomation on how to compute intakes from both in vivo and in vitro bionssay measurements and contains taales for the interpretation of bioalsey results, in terms of intake, for several hundred nuclices. This u nual conforts to the positions in existing regulatory guides, and the computed inteke retention fractions in the report have been verified by' conparison with results generated by other corputer models 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.
l for consnent, a draf t regulatory guide that would The NP.C plans to issue,for use in assessing intakes of radioactive Nterial endorse the BNL report 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 bioassays therefore, the report imay 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 say continue to be used for assessing intakes of radioactive raterial for comparison with the intake Ifmits of 20 CFR Part 20.
O MAT
t IN 88.XX Junt an 1968 Page 3 of 3 No specific action or written res >onse is required by this information notice.
If you have any questions about tiis setter please contact the regional administrator of the appropriate regional office or this office.
Charles E. Rossi, Director 4
Division of Operational Events Assessment Office of Nuclear Reactor Regulation i
J'enn D. Buc// Mat?
Technical Contacts:-4!a9uesepush, NRR 80edard 6 8eo0 AS, R AS l
[$hr, Croi) 492-1738 (301) 492 3422 j
e i
Refe rence,s,,
(1) IE Infor! nation Notice $2-18, 'Assesssent of Intakes of Radioactive Material by Workers ' June !!, 1982, (2) ' Report of Comittee !! on permissible Dose for Internal Radiation,'
Recomendations of the International Comission on Radiological Protection, 3CRP Publication 2, 1959.
(3) ' Report of Comittee 3Y en Evaluation of Radiation Doses in Body Tissues from Internal Contamination due to Occupational Exposure,' Recospendations of the International Coscission on Radiological Protection, ICRP Pubitcation 10, 1968.
(4) 'The Assessment of Internal Contamination Resulting from Recurrent or Prolonged Uptakes; A Report of ICRP Comittee 4,* Recomendations of the International Comission on Radiological Protection, 3CRP Publication 20A, 1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable, et al.,)' Interpretation of Bioassay Measuresents,' NUREG/CR.4884 (BNL NUREG 52063, July 1987.
Attachnt: List of Recently Issued NRC Infomation Notices
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