ML20236E230

Summary of 890222 Meeting W/Nuclear Industry Representatives in Rockville,Md Re Effects of Revs to 10CFR20 on Nuclear Fuel Fabrication Facilities

ML20236E230
Person / Time
Issue date:	02/22/1989
From:	NRC
To:	NRC
References
FRN-50FR51992, RULE-PR-19, RULE-PR-20, RULE-PR-30, RULE-PR-40, RULE-PR-50, RULE-PR-61, RULE-PR-70 NUDOCS 8903240027
Download: ML20236E230 (12)

Text

_

?*

L t. ., .

1 a, f ,

c, i

g- 1 H j MEETING MINUTES l

1

'Date: _ February 22, 1989 j Place: NRC Headquarters, One White Flint North Building. I LTime:~ 1:30-4:30 p.m i

Purpose:

Meeting of NRC staff with nuclear industry representatives to discuss- '!

' effects of revisions to 10 CFR Part 20 on nuclear fuel fabrication l facilities.

Attendees:- List attached. l Mr. Paul Stansbury of the General Electric Company's Wilmington, N.C. reactor ,

fuel fabrication facility described the 5-fold reduction in the allowable air l concentration limit for insoluble uranium. He noted that a large portion of I this change resulted mainly.from the assumptions inherent in the ICRP revised - -!

task group on lung dynamics model that was used to calculate concentration limits for-ICRP-30' and the revised Part 20 rather than the older ICRP-2 lung.

model. For an assumed 1-micron activity median aerodynamic diameter (AMAD) l j particle,-the five-fold reduction in allowable air concentrations would present  !

' ~ '

difficulties in demonstrating compliance with the revised 10 CFR Part 20 because fuel fabrication operations as currently implemented would result in air concentrations near the new limit.

l A number of measurements of the particle size of the airborne particulate at j the GE ' plant indicated that during normal operations the particle size was more I in the range of 3-4 microns AMAD rather than the 1-micron size assumed in  ;

calculatingthePart20derivedairconcentrations(DACs). A correction for I this difference in average particle size could be used to derive a DAC l different from that used in Part 20. Section 20.204(c) of the revised Part 20 rule permits altering the DAC with NRC approval based upon actual exposure conditions. Industry representatives indicated that they would examine the effect of using a more representative particle size on the magnitude of the DAC in order to see whether more realistic aerosol parameters would help alleviate potential problems. However, particle size adjustments would be of limited g32go27890222 19 50FR51992 PDR_

N Y( 0f

\

,d usefulness.for assigning comitted dose from air sampling results because of  !

the difficulty of. determining particle size during a frequent operational perturbations causing elevated airborne levels.' This limitation would'not be' .

]

significant'in using action levels for controlling the workplate' based on~ l committed dose methodology. l Mr. Stansbury also discussed various monitoring methods including bioassay, whole body or lung counting, and air sampling. For : insoluble uranium, fecal analyses' rather than urine analyses are required. _ Fecal samples are difficult to collect and analyze.and subject to considerable variation. Lung' counting lower lim'its of detection and associated statistical _ uncertainty will not permit this bioassay technique to be used to determine intakes frequently. It was Mr. Stansbury's conclusion that bioassay techniques are not suitable for the routine determination of intakes needed to demonstrate compliance with committed dose limits.

Mr. Stansbury pointed out that use of a committed dose approach would result in significantly increased error in dose determination from lung counts. This effect is due to the need to subtract successive lung counts to assess the intake in the intervening period. The NRC staff agreed that this subtraction.

was necessary for the committed dose approach as the assigned commitment had to reflect only the intake that occurred in the year of interest. Mr. Stansbury stated that~an annual dose approach would allow successive lung counts to be averaged which could reduce the overall error of measurement. '

Mr. Philip Rosenthal of Combustion Engineering described an extensive air sampling program initiated at Combustion Engineering using lapel air samplers  ;

to measure " breathing zone" air concentrations. The lapel air samplers draw 2 or 4 liters per minute and when combined with appropriate analytical techniques can detect 7.1E-13 uCi/cc (LLD for a 4-hour sample or 2.4E-13 uCi/cc (LLD for a 12-hoursample.) Experience with the samplers has shown a failure rate of about 10% which necessitates that more air samplers be available than the number of workers being monitored. Additional samplers were also required because of the time to recharge and calibrate the samplers which can exceed 2 days. Also, it was mentioned that the power packs and samplers were cumbersome and heavy. Extensive records of use were required for each sampler.

2 P

-________m__.____.________._e______m.____-_____._____._.._.__._ _ _ . _ _ . . . _ _ _ _ _ . _ - . _ . . _. . _ _ _ _ _ _ _ . . . . . _ _ _ _ _ . _

,1 .:

h j-Mr. Richard Cunningham of the NRC mentioned that the fact.that the ICRP. lung model did not accurately'. describe the behavior in 1 or 2 cases does'not .

invalidate the model. The lui nodel was developed from a wide variety of-experimental data'and paramett. appropriate to these actual exposure conditions may not have been used. Mr. Cunningham noted that the lower DAC limit required measurements that were at the limits of existing technology.- He also noted that the limits were not ALARA values but basic health protection. i limits and.that feasibility of showing compliance with the limits should not be  !

a major consideration in setting these limits. He also noted the NRC staff's concerns regarding the future employability of ex-fuel' plant workers and about the burden on future employers of these workers for monitoring pre-existing body burdens of long-lived radionuclides.

Mr. Richard Burklin of the Westinghouse Electric Company, presented a proposal for an alternative to the sole use of committed dose equivalent in the revised Part 20 and to the original $20.205 in the proposed Part 20 rule. The proposal made by Mr. Burkland was that each licensee shculd be given the option of controlling exposures either on: (a) the basis of the comitted dose equivalent or (b) a shared annual dose equivalent and a residual 50-year comitted dose equivalent. Alternative (a) is that currently in the revised 10 CFR Part 20. Alternative (b) would involve the following:

1. The external and internal annual dose, with the appropriate weighting factors, shall be sumed. The annual dose equivalent resulting from exposure to radioactive material at the licensee's facility plus the comitted dose equivalent resulting from exposure to radiation at any other licensee's facility shall not exceed 5 rem.

I

2. Within 90 days of the end of each calendar year (or employment period),

the ' residual' 50 year comitted dose equivalent shall be estimated.

3. The grand total of the annual dose equivalents and the last residual 50 year comitted dose equivalent from exposure to radiation at the licensee's facility plus the 50 year comitted dose equivalent received at other licensee's facilities shall not exceed SN, where N is the integer 3

~

number of calendar years the worker was exposed to radioactive material at the facility.

l An example calculation using hypothetical data was presented showing how this concept would work. However, NRC staff noted that the residual comitted dose corresponding to an initial I rem annual dose was 0.8 rem, whereas for

! uranium-238 approximately 20% of the 50-year comitted dose is delivered in the l first year so the actual residual comitment for 1-rem annual dose would be closer to 4 rem.

It was agreed that:

1. NUMARC would provide to NRC within 12 weeks an estimate of the time it would take to evaluate their proposal using data based upon the retention models for insoluble uranium of ICRP-30.

2. The fuel manufacturers would examine and report to NRC through NUMARC the impact Of using more realistic particle size distributions together with the provisions of $20.204(c) to request modified DACs specific to each plant or process areas, and

3. The NRC staff would evaluate the new industry proposal and provide the results of this evaluation to the Comission and NUMARC.

4. NUMARC would provide an assessment of how the proposal would affect (a) worker employability and (b) new employers who would have to account for dose monitoring of workers with body burdens from previous amployment.

4

1 ATTENDEES AT 02/22/89 MEETING ON INTERNAL DOSES.

NAME AFFILIATION Lynne 'Fairobent NUMARC John F.'Schmitt NUMARC Philip R. Rosenthal Combustion Enginering C. W. Malody Advanced Nuclear Fuel-Richard Burklin Westinghouse Paul Stansbury General Electric Altheia Wyche SERCH Licensing /Bechtel J. R. Clark Nuclear Fuel Services Rob Woolley General Atomics Judith D. Foulke DOE Dianne D'Arrigo Nuclear Information Research Services Bill M. Morris NRC/RES 4 Zoltan Rosztoczy NRC/RES Stephen McGuire NRC/RES Barbara Brooks HRC/RES Harold T. Peterson, Jr. NRC/RES Walter Cool NRC/ Consultant Richard Cunningham NRC/NMSS Leland C. Rouse NRC/NMSS Donald A. Cool NRC/NMSS John D. Buchanan NRC/NRR Joanna Becker NRC/0GC Sher Bahadur NRC/0CM/LZ Janice Dun Lee NRC/0CM/LZ Gail Marcus NRC/0CM/KR Margaret Federline NRC/0CM/KC 1

4

[ . ,, .,

• ~

l.

I' NOTE TO: Document Con!rol Raam4Mr 4180 #4#8d.

FR6rt:

Please place the attached document in the PDR using the following file and file. points:

PDR File Related Documents (SelectOne) (Enterifappropriate).'

fo /"N 6^/f92 ProposedRule(PR) 8,7Cl&d eM ACRS Minutes No.

Reg. Guide Proposed Rule (PR)- -

Draft Reg. Guide Draft Reg. Guide Reg. Guide PetitionRule Effective' (PRM) (RM) Petition (PRM) i Effective Rule (RM)

Federal Register Notice 5~V F# 6Sf[

. SD Task No.

' 'W* ' s NUREG. Report-Contract'No.

Subject:

/S CM [ArrT/'ld

/).emrad- 2/w4 /gf ~ >

&nnsrec Mee Mv x4mds- '

i Gs/x@. /fr//%s  ;

&;c znp b i bf4 i

j

i ,

4 ., ,

f - ,,

MEETING MINUTES Date: February 22, 1989 Place: . NRC Headquarters, One White _ Flint North Building Time: 1:30-4:30 p.m

Purpose:

. Meeting of NRC staff with nuclear industry representatives to discuss

. effects of revisions to 10 CFR Part 20 on nuclear fuel. fabrication facilities.

. Attendees: List attached.

Mr. Paul Stansbury of the General Electric Company's Wilmington,. N.C. reactor-fuel fabrication facility described the S-fold reduction in the allowable air concentration limit for insoluble uranium. He noted that a large portion of this change resulted mainly from the assumptions inherent in the ICRP revised task group on lung dynamics model that was used to calculate concentration

-limits for ICRP-30 and the revised Part 20 rather than the older ICRP-2 lung model. For an assumed 1-micron activity median aerodynamic diameter (AMAD) particle, the five-fold reduction in allcwable air-concentrations would present -

difficulties in~ demonstrating ccmpliance with the revised 10 CFR Part 20 l because fuel fabrication operations' as currently ~ implemented would result in air concentrations near the new limit.

ALnumber of measurements of the particle size of the airborne particulate at the GE plant indicated that during normal operations the particle size was more in the range of 3-4 microns AMAD vather than the 1-micron size assumed in calculating the Part 20 derived air concentrations (DACs). A correction for this difference in average particle size could be used to derive a DAC different from that used in Part 20. Section 20.204(c) of the revised Part 20 rule permits altering' the DAC with NRC approval based upon actual exposure conditions. Industry representatives indicated that they would examine the l effect of using a more representative particle size on the magnitude of the DAC in order to see whether more realistic aerosol parameters would help alleviate potential problems. However, particle size adjustments would be of limited I

I

f1

'* usefulness for assigning comitted dose from air sampling results because of the difficulty of determining particle size during a frequent operational perturbations causing elevated airborne levels. ~This limitation would not be significant in using action levels for controlling the workplace based on committed dose methodology.

Mr. Stansbury also discussed various monitoring methods _ including bioassay, whole body or lung counting, and air sampling. For insoluble uranium,-fecal analyses rather than urine analyses are required. Fecal samples are difficult-

.to-collect and analyze and subject to considerable variation. Lung counting lower limits of detection and associated sta'tistical uncertainty will not permit this bioassay technique. to be used to determine intakes frequently. It-was Mr. Stansbury!s conclusion that bioassay techniques are not suitable for the routine determination of intakes needed to demonstrate compliance with committed dose limits.

i Mr. Stansbury pointed out that use of a committed dose approach would result in significantly increased error in dose determination from lung counts. -This effect is due to the need to subtract successive lung counts to assess the intake' in the intervening period. The NRC staff agreed that this subtraction was necessary for the committed dose approach as the assigned commitment had to reflect only the intake that occurred in the year of interest. Mr. Stansbury stated that an annual dose approach would allow successive lung counts to be averaged which could reduce the overall error of measurement.

Mr. Philip Rosenthal of Combustion Engineering described an extensive air '

sampling program initiated at Combustion Engineering using lapel air samplers to measure " breathing zone" air concentrations. The lapel air samplers draw-2 or 4 liters per minute and when combined wIth appropriate analytical techniques can detect 7.1E-13 uCi/cc (LLD for a 4-hour sample or 2.4E-13 uCi/cc (LLD for a 12-hoursample.) Experience with the samplers has shown a failure rate of about 10% which necessitates that more air samplers be available than the number of workers being monitored. Additional samplers were also required because of the time to recharge and calibrate the samplers which can exceed 2 1

days. Also, it was mentioned that the power packs and samplers were cumbersome i and heavy. Extensive records of use were required for each sampler.

2

l'

.f,-,

i

' Mr. Richard Cunningham of the NRC mentioned that the fact that the ICRP lung model.did not accurately describe the behavior in 1 or 2 cases does not l

invalidate the model. The lung model was developed from a wide variety of l experimental data and parameters appropriate to these actual exposure conditions may not have been used. Mr. Cunningham noted that the lower DAC l limit required measurements that were at the limits of existing technology. He l

also noted that the limits were not ALARA values but basic health protection limits and that feasibility of showing compliance with the limits should not be 1 a major consideration in setting these limits. He also noted the NRC staff's concerns regarding the future employability of ex-fuel plant workers and about the burden on future employers of these workers for monitoring pre-existing body burdens of long-lived radionuclides.

4 Mr. Richard Burklin of the Westinghouse Electric Company, presented a proposal for an alternative to the sole use of comitted dose equivalent in the revised Part 20 and to the original 520.205 in the proposed Part 20 rule. The proposal made by Mr. Burkland was that each licensee should be given the option of controlling exposures either on: (a) the basis of the comitted dose equivalent or (b) a shared annual dose equivalent and a residual 50-year comitted dose equivalent. Alternative (a) is that currently in the revised 10 CFR Part 20. Alternative (b) would involve the following:

1. The external and internal annual dose, with the appropriate weighting factors, shall be sumed. The annual dose equivalent resulting from exposure to radioactive material at the licensee's facility plus the comitted dose equivalent resulting from exposure to radiation at any ,

other licensee's facility shall not exceed 5 rem.

1

2. Within 90 days of the end of each calendar year (or employment period),

the ' residual' 50 year comitted dose equivalent shall be estimated.

3. The grand total of the annual dose equivalents and the last residual 50 year comitted dose equivalent from exposure to radiation at the licensee's facility plus the 50 year committed dose equivalent received at other licensee's facilities shall not exceed SN, where N is the integer 3

J...

• y T'

number of calendar years the worker was exposed to radioactive material at-the facility.

An examplo calculation using hypothetical data'was presented showing how this concept would work. However, NRC staff noted that the residual comitted dose corresponding to an initial 1 rem annual dose was 0.8 rem, whereas for  !

uranium-238 approximately 20% of the 50-year comitted dose is delivered in the first year so the actual residual comitment for 1-rem annual dose would be closer to 4 rem. .

It was agreed that:

1. NUMARC would provide to NRC within 1-2 weeks an estimate of the time it  !

would take to evaluate their proposal using data based upon the retention models for insoluble uranium of ICRP-30.

2. .The fuel manufacturers would examine and report to NRC through NUMARC the impact of using more realistic particle size distributions together with the provisions of $20.204(c) to request modified DACs specific to each plant or process areas, and

3. .The NRC staff would evaluate the new industry proposal and provide the results of this evaluation to the Comission and NUMARC.

4. NUMARC would provide an assessment of how the proposal would affect (a) worker employability and (b) new employers who would have to account for dose monitoring of workers with body burdens from previous employment.

1 l

l l

4 I 1

t e_______________________-__

h f.l ,

j

. . i i

M-ATTENDEES AT.-

02/22/89 MEETING 0N INTERNAL DOSES.

NAME. AFFILIATION 1

Lynne fairobent NUMARC John F. Schmitt NUMARC

, Philip R. Rosenthal Combustion Enginering C. W. Malody Advanced Nuclear Fuel Richard Burklin Westinghouse Paul Stansbury General Electric Altheia Wyche SERCH' Licensing /Bechtel J. R. Clark' Nuclear Fuel Services.

~ Rob Woolley General Atomics Judith D. Foulke DOE Dianne D'Arrigo Nuclear Information Research Services Bill M.. Morris NRC/RES Zoltan Rosztoczy NRC/RES Stephen McGuire NRC/RES Barbara Brooks NRC/RES Harold T. Peterson, Jr. NRC/RES Walter Cool NRC/ Consultant Richard Cunningham NRC/NMSS Leland C. Rouse NRC/NMSS.

Donald A. Cool NRC/NHSS John D. Buchanan NRC/NRR Joanna Becker NRC/0GC Sher Bahadur NRC/0CM/LZ Janice Dun Lee NRC/0CM/LZ Gail Marcus NRC/0CM/XR Margaret Federline NRC/0CM/XC

,;. .,.,t.

, .4

.. I '

NOTE TO: Document Control Remm4Mr %iOOMWR8 FROM:'

-Please place the attached document in the PDR using the following file and file peints:

PDR File Related Documents (SelectOne) (Enterifappropriate)

/WOtt D/f'R '6 79$

Proposed Rule'(PR) ACRS Minutes No. ,f, Reg. Guide Proposed Rule (PR) /'), v e6V ro FA Draft Reg. Guide Draft Reg.-Guide '

J'~719n

' Petition (PRM) Reg. Guide Effective Rule (RM) Petition (PRM)

Effective Rule (RM)

Federal Register Notice

. SD Task No.

W NUREG Report-Contract No.

Subject:

/8 Cf99 d% YMcYrbnf

+ + ena mar na f

&W  !

l gg

&x ngyo u_

PlS "I