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Re: locating NRC Information Notices?



There is a file of NRC "Generic Communications" which has this. The URL is: 
http://www.fedworld.gov/ftp/nrc-gc/nrc-gc.htm 
 
A copy of IN96-18 is pasted, below. 
 
The opinions expressed are strictly mine. 
 
Bill Lipton	liptonw@detroitedison.com     
 
UNITED STATES 
                           NUCLEAR REGULATORY COMMISSION 
                 OFFICE OF NUCLEAR MATERIAL SAFETY AND SAFEGUARDS 
                               WASHINGTON D.C. 20555 
 
                                  March 25, 1996 
 
 
NRC INFORMATION NOTICE 96-18:  COMPLIANCE WITH 10 CFR PART 20 FOR AIRBORNE      
                               THORIUM 
 
 
Addressees 
 
All material licensees authorized to possess and use thorium in unsealed form. 
 
Purpose 
 
This notice is provided to alert recipients to radiological problems that may 
be encountered in using thorium in unsealed form.  These problems were 
identified by U.S. Nuclear Regulatory Commission (NRC) inspectors, during 
inspections of the approximately 120 licensees authorized to use unsealed 
thorium, some of which are engaged in processing and manufacturing activities 
that pose a potential for generating significant airborne radioactive 
contamination.  It is expected that recipients will review the information for 
applicability to their facilities and consider actions, as appropriate, to 
avoid similar problems.  However, suggestions contained in this information 
notice are not NRC requirements; therefore, no specific action or written 
response is required.  
 
Description of Circumstances 
 
NRC inspections at facilities using thorium in unsealed form revealed a number 
of programmatic weaknesses in the control and monitoring of airborne thorium 
hazards at an unexpectedly high proportion of these facilities.  One of the 
areas of weakness frequently encountered was worker intake monitoring programs 
that did not appear capable of adequately quantifying intakes for purposes of 
demonstrating compliance with the requirements of 10 CFR Part 20, particularly 
the annual limits on intake (ALI).  A second area of concern was the frequent 
lack of adequate licensee efforts to maintain exposures as low as reasonably 
achievable (ALARA), as required by 10 CFR 20.1101(c).  NRC inspectors 
repeatedly observed intakes and resulting organ doses that appeared to be 
unnecessary, or avoidable, in view of the potential to reduce them by 
implementation of relatively simple ALARA measures.  Some of the intakes in 
these cases were evaluated and produced organ doses in the 0.2 to 0.3 Sv  
(20 - 30 rem) range in a year.  Such high doses, representing a substantial 
fraction of the maximum permissible organ doses, cannot be viewed as 
acceptable unless justified by a thorough ALARA analysis.  In most of the 
observed cases, however, an adequate ALARA assessment had not been performed. 
 
 
 
 
 
 
 
9603200218                                                               IN 
96-18 
                                                               March 25, 1996 
                                                               Page 2 of 5 
 
 
Demonstration of compliance with dose limits to members of the public, from 
airborne thorium, was also found, in some cases, to have been less than 
adequate.  In some cases, the licensees were found to have no adequate  
monitoring systems for their airborne effluents, and in others the methods 
used to quantify these effluents did not possess sufficient sensitivity to 
enable demonstration of compliance.  
 
In response to the regulatory violations noted above, NRC issued Confirmatory 
Action Letters (CALs) to a number of licensees, confirming commitments to 
taking specific actions to correct these deficiencies.  Notices of Violation 
and other enforcement actions were also taken by NRC, in some cases.  These 
actions, as well as extensive discussions with licensees, to alert them to the 
problems, have resulted in substantial improvements in most licenseesū 
programs. 
 
Discussion 
 
The programs that licensees should develop for control of airborne hazards 
arising from the use of unsealed thorium do not differ in any basic respect 
from those needed in the case of programs to control the hazards from any 
airborne radioactive material.  Facilities using thorium, however, must make 
allowances for certain constraints imposed by the nature of the thorium decay 
chain.  The major constraint is the difficulty of measuring thorium-232  
(Th-232) in the body after an intake using bioassay methods, either in vivo, 
such as whole body counting, or in vitro, such as urine analysis.  This is 
caused, in part, by the relatively low ALI for Th-232, which is 37 Bq (1 nCi) 
for class W, and 111 Bq (3 nCi) for class Y aerosols, as well as the type of 
radiation emissions from the thorium decay chain, which are mostly alpha and 
beta radiations, with only relatively low-intensity gamma radiations. 
 
The difficulties regarding the use of bioassay methods were increased after 
implementation of the revised 10 CFR Part 20, which became mandatory for all 
licensees on January 1, 1994.  Intakes of Th-232 by inhalation before the  
Part 20 revisions were limited to 520 MPC-hours per quarter, where MPC was the 
maximum permissible concentration tabulated in the old Appendix B to 10 CFR 
Part 20.  This was equivalent to an intake of about 700 Bq (19 nCi) per 
quarter for both the soluble and insoluble forms of thorium, or about 2800 Bq 
(75 nCi) per year.  The revised Part 20 lowered that limit to ALIs of about  
40 Bq (1 nCi) and 100 Bq (3 nCi) for classes W and Y aerosols, respectively.  
Therefore, bioassay methods that may have been capable of detecting intakes 
that were a small fraction of the allowable limits in the old Part 20 were no 
longer capable of the same performance under the revised Part 20 limits, and 
could therefore not serve the same monitoring functions in a routine airborne 
radioactivity control program as they did previously.                     
 
                                                               IN 96-18 
                                                               March 25, 1996 
                                                               Page 3 of 5 
 
 
Although bioassay techniques are still useful in assessing relatively large 
intakes, they are not capable of providing routine monitoring for intakes 
substantially below the ALI.  The air monitoring program therefore usually 
must assume a much greater importance at facilities using unsealed thorium 
than for other radionuclides.  Facilities using thorium need to rely on 
accurate air sampling to estimate intakes that cannot be detected by bioassay 
techniques, which, in effect includes all intakes other than those that 
approach or exceed the ALI.  Because of this reliance on air sampling to show 
compliance and assess internal doses, the air sampling program must be  
carefully designed to provide accurate intake estimates for all occupationally 
exposed workers, as well as members of the public who may be exposed to 
airborne thorium as a result of licensed operations.  However, appropriate 
bioassay procedures should be established and available for use in assessing 
accidental or suspected high exposures, and for use in cases where adequate 
air sampling was inadvertently not provided.  In this latter case, bioassay 
would provide an upper limit on the magnitude of any intake that may have 
occurred, even though it may not be capable of quantifying intakes below an 
ALI.  
 
Air Sampling 
 
The major deficiencies noted in air sampling programs at some of the inspected 
facilities included programs that did not provide samples that are representa- 
tive of the intake by each exposed worker, monitoring frequencies that were 
far too low to be capable of detecting changes in air concentrations over 
time, and counting techniques that did not possess adequate sensitivity for 
their intended purpose. 
 
One of the factors that led to non-representative samples was the excessive 
reliance on general area air sampling to monitor worker intakes in that area.  
Studies have repeatedly shown that air concentrations in a work area can vary 
by several orders of magnitude over distances of only a few feet, and a 
general area sample is most likely to grossly underestimate the intake of a 
worker involved in activities that generate aerosols.  With rare exception, 
the most reliable method of assessing worker intakes is by use of personal air 
samplers.  In the case of effluent sampling, the method chosen should be 
capable of obtaining a representative sample from the exhaust duct or other 
outlet.  For aerosols, this usually means use of isokinetic sampling methods, 
and licensees should determine, for their particular case, whether such 
sampling methods are needed. 
 
The choice of method of analysis should also be given careful consideration.  
This includes choice of the filter medium to use in the air sampler, air flow 
rates, as well as choice of counting techniques.  These factors should be      
                                                          IN 96-18 
                                                               March 25, 1996 
                                                               Page 4 of 5 
 
 
selected to ensure that the desired monitoring sensitivity, expressed as a 
lower limit of detection (LLD), is achieved.  A good guide as to the appro- 
priate LLD to use in any application is that it should not exceed 10 percent 
of the value to which compliance is to be demonstrated. 
 
ALARA 
 
Licensees are required, by 10 CFR 20.1101(b), to demonstrate that the doses 
received by their workers, or by members of the public, as a result of their 
activities, are ALARA.  The most effective method to maintain internal doses 
ALARA is usually to contain the radioactive material and prevent it from 
entering the air in the work space.  Other methods might be use of wet pro- 
cesses, which have the effect of preventing or minimizing the generation of 
aerosols, or use of other engineering controls, depending on the details of 
the aerosol-generating process and the configuration of the workplace.        
Regardless of the choice of engineering controls, their use must include 
periodic maintenance to ensure continued effectiveness, as well as periodic 
checks to ensure that the systems remain effective. 
 
If engineering controls fail to maintain airborne concentrations at suffi- 
ciently low levels, then other methods may be used, such as limiting stay 
times, or restricting access to the contaminated areas.  Alternatively, 
respirators may be used to limit intakes during periods when other measures 
are not sufficiently effective.  It should be noted, however, that 10 CFR  
Part 20 specifies that respirators are to be used only when other methods of 
control of intake fail to achieve the desired result or are impractical. 
 
The above discussion on air sampling and ALARA is not exhaustive, and only 
highlights some of the most frequently encountered problems.  Licensees should 
thoroughly evaluate their operations, and design and implement programs that 
would properly protect the workers, minimize intakes, and show compliance with 
applicable regulations.  These evaluations are not one-time efforts, but 
should be ongoing and integral parts of the overall radiation protection 
program on site. 
 
                                                               IN 96-18 
                                                               March 25, 1996 
                                                               Page 5 of 5 
 
 
This information notice requires no specific action or written response.  If 
you have any questions about this matter, please call one of the technical 
contacts listed below or the appropriate regional office. 
 
 
                                            signed by 
 
                                      Donald A. Cool, Director 
                                      Division of Industrial and 
                                        Medical Nuclear Safety 
                                      Office of Nuclear Material Safety 
                                        and Safeguards 
 
Technical contacts:  Sheri Arredondo, Region I 
                      (610) 337-5342 
                      Internet:saa1@nrc.gov 
 
                      Sami Sherbini, NMSS 
                      (301) 415-7902 
                      Internet:sxs2@nrc.gov




I would really appreciate some help locating NRC information notice 96-18.
Haven't been able to locate it through the NRC homepage or fedworld. Thanks.
Tony Mason, CHP
trmasonhp@aol.com
tony.m@gpimail.com