ML20043D300
| ML20043D300 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| 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 9006070348 | |
| Download: ML20043D300 (2) | |
Text
_____ _
MAY t 21990 Docket Nos.
50-277 50-278 Philadelphia Electric Company ATTN: Mr. O, M. Smith Executive Vice President-Nuclear Correspondence Control Desk P. O. Box 7520 Philadelphia, Pennsylvania 19101 Gentlemen:
Subject:
INTERPRETATION OF BIDASSAY MEASUREMENTS; ASSESSMENT OF INTAKE In accordance with the attached information, Region I Reactor licensees are advised that assessing intakes of radioactive material using bionssay 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, Y'
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 Ik 0FFICIAL RECORD COPY MULTI LTRS - 0006.0.0 hb 9006070348 900522 8
PDR ADOCK 05000277 P
Philadelphia Electric Company 2
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cc w/ attachment:
D. R. Helwig, Vice President of Nuclear Engineering and Services E. C. Kistner, Chairman, Nuclear Review Board J. Urban, General Manager, Fuels Department, Delmarva Power & Light Co.
J. F. Franz, Plant Manager, Peach Bottom Atomic Power Station T. E. Cribbe, Regulatory Engineer, Peach Bottom Atomic Power Station J. P. Wilson, Acting Project Manager, Peach Bottom Atomic Power Station D. B. Miller, Vice President for Peach Bottom T. B. Conner, Jr., Esquire W. H. Hirst. Director, Joint Generation Projects Department.
Atlantic Electric B. W. Gorman, Manager, External Affairs E. J. Cullen, Esquire, Assistant General Counsel (Without Report)
R. L. Hovis, Esquire T. Magette, Power Plant Siting, Nuclear Evaluations G. Hunger, Director, Licensing Section D. Poulsen, Secretary of Harford County Council R. J. Lees, Chairman, Nuclear Review Board J. H. Walter, Chief Engineer, Public Service Commission of Maryland Padlic 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 DRP Section Chief M. Conner, SALP Reports Only K. Abraham, PA0 (20) SALP Report and (2) All Inspection Reports J. Caldwell, NRR G. Suh, NRR L. J. Cunningham, NRR J. D. Buchanan, NRR i
0FFICIAL RECORD COPY MULTI LTRS - 0007.0.0 05/08/90
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UNITED STATES l'
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I NUCLEAR REGULATORY COMMISSION W A5HINGTON. D. C. 20666 k....*
March 14, 1990 i
hEh0RANDUM FOR: Those on the Attached List FROH:
LeMuine J. Cunningham, Chief Radiation Protection Branch Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation
SUBJECT:
DRAFT NRC INFORMATION NOTICE, " INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSHENT OF INTAKE" s
in a July 13, 1968 memorandum I informeo you that we had decided not to issue of NRC he6dquarters and regional office comments on earlie 3
The technical contacts have been updated on the enclosed copy of the draft.)
(Note:
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 bee 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 to be issued in the near future. issued and, although the guide is still unde We have reconsidered issuing the enclosed draft notice; however, we again have decided not to do so primarily because the regulatory gu ficient to warrant-issuance of an NRC information notice.tained this information available to the public, we are placing a copy of this memo-However, to make randum enclosure in the public document room.
rait copies to licensees if you so desire.
Therefore, you are free to trans-eH 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 f5<T Nf W
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'M ".
LINITED STATES t
L NUCLEAR REGULATORY COMMISSION OFFICE OT NUCLEAR REACTOR REGULATION J
WASHINGTON. D.C.
20555 June xx,1988 i
NRC INFORM 710N NOTICE NO. 88 XX:
INTERPRETATION OF B10 ASSAY MEASUREMENTS; ASSESSMENT OF INTAKES Addressees:
All nuclear pwer reactor facilities holding an operating license or a con-struction permit, research and test reactors, fuel facilities, and Priority 1 material licensees.
Backcround and Purpose.:
This information notice is intended to correct an NRC position in Infomation Notice 82-18 (Reference 1) that was in conflict with the NR9 staff position published in several regulatory guides. The NRC position in Infomation Notice 82-18 indicates that, for p'urposes of determining compliance with the 10 CFR Part 20 intake limits, only the methodology of the International Comission on Radiological Protection (ICRP) Publication 2 (Reference 2) can be used in assessing intakes of radioactive material using bioassay 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 bioassay measuremeAts, ' Interpretation of Stoassay
)
Reasurements? TEIG/CR-4884).
It is expected that recipients will review the information in 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 bloessay is presented in NRC Regulatory 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.
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 j
i based on ICRP Publication 2 and concluded with the NRC position: 'The NRC will continue to use the ICRP Pubitcation 2 methodology in detemining cospliance with 10 CFR 20 until the revision of 10 CFR 20 has been published as a final rule.'
DRAR
g@[Qf IN 88 XX June xx,1988 l
Page 2 of 3 The NRC staff now recognizes that this position in Information Notice 82-28 I
(2) is incorrect in implying that only ICRP Publication 2 can be used for bicassay data to determine compliance with 10 CFR Part 20 and assessinlicts with the NRC staff position expressed in relevant regulatory (2) conf guides. Although ICRP Publication 2 provides the basis for current 30 CFR l
Part 20 limits on intake (based on long term, chronic exposures), it does not always provide an adequate basis for assessing individual intake because it l
does not provide information P hody content or escreta following single (acute) intake or information @!1 cable to an individual differing from the l
1
' standard man' defined in ICRF hlication 2.
This inadequacy is recognized in ICRF Publications 20 and 10A (References 3 and 4), which are endorsed in i
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 l
regulatory requirements.
The NRC staff became aware of the problem with the NRC posiyion in Information Notice 82-18 as a result of reviews and discussions during itsdraftstage) g of a draf t report, " Interpretation of Bioassey Neasurements ' (Reference 5),
e prepared by Brookhaven National Laboratory (8NL) under an NRC contract. This i
report (which was published in July 1987) is a comprehensive manual that, for t
the first time, provides information on how to compute intakes fism both in vivo I
and in vitro bicassay measurements and contains tables for the interpretaTioTTf I
bioasisy results, in terms of intake, for several hundred nuclides. This manual i
conforms to the positions in existing regulatory guides, and the computed intake l
retention fractions in the report have been verifled by cosparison with results generated by other computer models using the same set of assumptions (REMEDY andDOSEDAY/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 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 bioassay; therefore, the report may 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 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.
O HAFT
t Y
IN 88 XX June xx 1988 l
Page 3 of 3 No specific action or written res sense is required by this information notice.
If you have any questions about tifs matter please contact the regional edininistrator of the appropriate regional office or this office.
l Charles E. Rossi, Director l
Division of Operational Events Assessment Office of Nuclear Reactor Regulation Joba D. Buchastart Technical Contacts:-4pesauspush, NRR 8ttedded 6, 8twoASj KAS 1
(301) 492-38P-/dP7, (y,
g.,, pg g
i (301) 492-3422 e
J References (1) IE Information Notice 82-18, " Assessment of Intakes of Radioactive Material by Workers," June 12, 1982.
(2) ' Report of Comittee II on fermissible Dose for Internal Radiation,"
Recomendations of the International Connission on Radiological Protection, ICRP Publication 2,1959.
(3) " Report of Cosnittu 3v er m1ustion of Radiation Doses in Body Tissues from Internal Contami:o (.na in to Occupational Exposure," Reconnendations of the International 7 an;ip,fon r Radiological Protection, ICRP
(
Publication 10, 1962, (4) "The Assessment of InP'ot t 4rtwhation Resulting from Recurrent or Prolonged Uptakes; / isput M KkP Committee 4,* Recomendations of the International Comisat.n to hciiP.gical Protection,-ICRP Publication 20A, 1969.
(5) Edward T. Lessard, Xia Yihua. Kenneth W. Skrable, et al.,)" Interpretation of Bioassay Measurements," NUREG/CR-4884 (BNL-NUREG-52063, July 1987.
I t
Attachment:
List of Recently Issued NRC Information Notices l
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