ML20043C348
| ML20043C348 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/22/1990 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 9006050091 | |
| Download: ML20043C348 (2) | |
Text
V
.o MAY 2 21990 Docket'No. 50-289 GPU Nuclear Corporation ATTN: Mr. H. D. Hukill Vice President and Director of TMI-I P. O. Box 480 Middletown, Pennsylvania 17057 Gentlemen:
Subject:
INTERPRETATION OF BI0 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.ald 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 1\\
{nr an
\\ p
>v,
!=s.
Of hj OFFICIAL RECORD COPY MULTI LTRS - 0032.0.0 05/08/90
$O0 S$Obk boob. @9 P
l
.i GPU Nuclear Corporation 2
g47 2 2 1990 cc w/ attachment:
T. G. Broughton, Operations and Maintenance Director TMI-1 C. W. Smyth, Manager, TMI-1 Licensing R. J. McGoey, Manager, PWR Licensing E, L. Blake, Jr., Esquire TMI-Alert (TMIA)
Susquehanna Valley Alliance (SVA)
Public Document Room (PDR) local Public Document Room (LPDR)
NuclearSafetyInformationCenter(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 DRP Section Chief M. Conner, SALP Reports Only
'K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports J. Caldwell, NRR R. Hernan, PM, NRR L. J. Cunningham, NRR J. D. Buchanan, NRR i.
0FFICIAL RECORD COPY MULTI LTRS - 0033.0.0 05/08/90
co pP 8tICp M
'o UNITED STATES
[T se [,j NUCLE AR REGULATORY COMMISSION e a.
W ASHINoT ON, D. C. 20555
\\...../
March 14, 1990 NEh0RANDUM FOR:
Those on the Attached List FROM:
LeMuine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protectiun and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT NRC INFORMATION NOTICE, "lNTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKE" 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 NRC headquarters and regionel office comments on earlier drafts.
(Note:
The technicel 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
" 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 placing a copy of this memo-randum enclosure in the public document ruum. Therefore, you are free to trans-mit copies to licensees if you so desire.
eM e J. Cunningha, Chief f
Rad ation Protection Branch h63?;/ d ?'2 7
(-(g Division of Radiation Protection A
and Emergency Preparedness Office of Nuclear Reactor Regulation
Enclosure:
Subject Information Notice CONTACT: John D. Buchanan, NRR 492-1097
.f h e k.r. n e i
UtilitD STATts r
L NUCLEAR REGULATORY COW.15510N OFFICE OF NUCLEAR RIAC10R REGULATION k'ASHIN370N, D.C.
205!5 June xx, 1968 NRC INFORI'.ATION NDTICE ND. 8811:
INTERPRETATION OF t!OA55AY MEASUREMENT 5; A55E55 MENT Of INTAKES E
Addressees:
All nuclear power reactor facilities holding an operating license or a con.
struction pemit, research and test reactors, fuel facilities, and Friority 1 saterial licensees.
Sackcround and
Purpose:
This infortnation notice is intended to correct an NRC esition in Information Notice 62 28 (P.eference 1) that was in conflict with t e NR9 staff position s
published in several regulatory guides. The NRC position in Information Notice 8216 indicates that, for urposes of detereining comp 11ance with the 10 CFR Part 20 intake limits, on1 the methodo1ogy of the International Comission on Radiological Frotection (! RP) Publication 2 (Reference 2) can be used in assessing intakes of radioactive material using bionssay data. Another purpost-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 measurements. *laterpretation of Bionssay Easurements? TMIG/CR-4884).
It is expected that recipients will review the information in this information notice for applicability to their programs.
Nowever, suggestions contained in this information notice do not constitute NRC requirements; therefore, no specific action or written response is required.
Discussion:
The NRC staff position with respect to bicassay is presented in NRC Regulatory 8.22, and 8.26.
In general, the position is t)at 8.9. 8.11, 8.20,l intake using bicassay data should be based on the best Guides assessment of individua data end 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 Publication 2 methodology in determining cospliance with 10 CFR 20 until the revision of 30 CFR 20 has been published as a final ruie."
DRAFT
l^
b1) p l IN 86.XX i
M M ao June ar, IgEB page 2 of 3 The NRC staff now reco;nizes that this position in Infora tion Notice $2 18 (1) is incorrect in ir. plying that only ICRP Publication 2 can be used for 4
assessin* bicassey data to detercine compliance with 10 CFR Part 20 and l
(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 et intake (based on long. tem, chronic exposures), it does not always pronice an acequate basis for essessins individual intake because it does not provide infomation on body content or escreta foHoming single I
(acute) intake or inforntion applicable to an individual differing from the
' standard un' defined in ICRP Publication 2. This inadequacy is recognized in ICRF Fub11 cations 10 and 10A (References 3 and 4), which are endorsed in Re;ulatory Guide 8.g and which are mentioned in Inforation 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 posihton in Information Notice 62-18 as a result of reviews and discussions during 'its draft stage) of a draf t report, ' Interpretation of Bionssay Nessurements (Reference 5),
e prepared by Brookhaven National Laboratory (BNL) under an NRC contract. This l
report (which was published in July 1987) is a comprehensive unual that, for the first time, provides information on how to consute intakes from both in vivo and in vitro bioassay sensurements and contains tables for the interpretation u bioaTiay results, in terms of intake, for several hundred nuclides. This a nual conforts to the positter.s in existing regulatory guides,. and the computed intake retention fractions in the report have been verified by conparison with results generated by other computer models using the same set of assumptions (REMEDY andDDSEDAY/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 draf t regulatory guide that would endorse the BNL report for use in assessing intakes of radioactive uterial from the results of bionssay measurements.
In the interim, use of this report for the interpretation of bicassay measurements is consistent with t.he regula-tory positions in existing regulatory guides on bioassay; therefore, the report my be used for this purpose. Of course, the limits on intake given in 30 CFR 20.103 and based on ICRP Publication 2 continue to apply untti 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 30 CFR Part 20.
l l
l l
l DRAIT
IN 38.XX
)
1988 June ax,f 3 Page 3 o No specific action or written res sense is required by this information notice.
If you have any questions about tifs Ntter please contact the rejienal adirinistrator of the appropriate regional office or this office.
1 Charles E. Rossi, Director Division of Operational Events Assessment Office of Nuclear Reactor Regulation 1
Jenn A Bucdastat?
Technical Contacts:-4meinestrash, NRR 8(tr&1rd 6 8roo/CS,R AS
?;r,.
(30/) +'92-2 73N (301) 492 3422 References (1) IE Inforation Notice 82-28,
- Assessment of Intakes of Radioactive Material by Workers.' June 11, 1982.
(2) ' Report of Comittee !! on fersissible Dose for Internal Radiation,"
l Recomendations of the International Comission on Radiological Protection, ICRP Pub 11 cation 2, 1959.
' Report of Comittee !Y en Evaluation of Radiation Doses in Body Tissues (3) from Internal Contamination due to Occupational Exposure " Recomendations of the International Cossission on Radiological Protection, ICRP Publication 10, 1968.
(4) "The Assessment of Internal Contamination Resulting from Recairrent or Prolonged Uptakes; A Report of ICRP Comittee 4.' Recomendations of the International Cosnission on Radiological Protection, ICAP Publication 10A, 1969.
(5) Edward T. Lessard, Xia Yihua, Kenneth W. Skrable et al.3), Interpretation of Bionssay Measurements," NUREG/CR-4884 (8NL-NUkEG 5206 July 1987.
Attachment:
List of Recently Issued NRC Infometion Notices G
..,w.
._..r_.,
.____.....,-,_...,,,,_.._,..._..__..m_.
., -,.. -. _. ~
-