ML20149K657

BWXT Nuclear Operations Group, Inc. (NOG-L) Response to the NRC Request for Additional Information (RAI) for an Exemption from the 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1)

ML20149K657
Person / Time
Site:	BWX Technologies
Issue date:	05/06/2020
From:	Burch B BWXT Nuclear Fuel Services
To:	James Downs NRC/NMSS/DFM/FFLB
Downs J
References
20-036
Download: ML20149K657 (12)

Text

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May 6, 2020 20-036 A TIN: James Downs, Senior Project Manager Office of Nuclear Material Safety and Safeguards Division of Fuel Management U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001

Reference:

1} License No. SNM-42, Docket 70-27 2} NRC Regulation 10 CFR 70.17, "Specific Exemptions"

3) Federal Register Notice, 55 FR 19890, May 14, 1990

4) Letter Dat~d April 24, 2019, BWXT (Burch) to NRC (Director NMSS),

BWXT Nuclear Operations Group, Inc. (NOG-L) Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1)

5) E-Mail dated March 12, 2020, J. Downs to C.T. Terry, "Request for Additional Information - exemption request from 24-hour Reporting Requirement"

Subject:

BWXT Nuclear Operations Group, Inc. (NOG-L) Response to the NRC Request for Additional Information (RAI) for an Exemption from the 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1)

Dear Mr. Downs:

BWXT Nuclear Operations Group, Inc., Lynchburg (BWXT NOG-L) is providing the attached response to the NRC's March 12, 2020 Request for Additional Information (Reference 5).

BWXT NOG-L is also providing, for completeness, Enclosure 2, Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b}(1}, April 24, 2019. (Reference 4).

If you have questions or require additional information, please contact Chris Terry, Manager of Licensing and Safety Analysis, at ctterry@bwxt.com or 434-522-5202.

B. Joel Burch Vice President and General Manager BWXT Nuclear Operations Group, Inc. - Lynchburg Enclosure cc: NRC, J. Zimmerman NRC, Region II NRC, Resident Inspector People Strong BWXT Nuclear Operalions Group, Inc.

RO. Box 785 Lynchburg, VA 24505 USA t

• 1.434.522.6000 www.bwxt.com INNOVATION DRIVEN >

ENCLOSURE1 BWXT NOG-L Response to NRC RAI Concerning Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1) 2 pages BWXT Nuclear Oper::illons Group, Inc.

People Strong P.O. Box 785 Lynchburg, VA 24505 USA t:

• 1.434.522.6000 www.bwXtcom INNOVATION DRIVEN >

BWXT NOG-L Response to NRC RAI Concerning Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1)

In response to NRC's request for additional information for BWXT NOG-L's request for exemption from the 24-Hour Reporting Requirement in 10 CFR 70.50(b)(1 ), the following responses are provided:

RAI 1

Granting the requested exemption would require the NRG to make determinations in accordance with 10 CFR 70. 17 which include, in part, finding the exemption is in the public interest. Your application states the exemption would allow resources to be focused on other activities of higher significance. However, no data was provided to quantify the resources saved.

RAI 2

Granting the exemption would reduce the level of transparency to the public of unplanned contamination events. An estimate of the resources saved is needed to make a finding that a reduced level of transparency is justified. The resource estimate should be limited to cost incurred by reporting the event. Costs associated with investigations and corrective actions that would be performed even if no report was made should be excluded from the estimate.

BWXT NOG-L Response to RAI 1 and RAI 2:

BWXT NOG-L takes its reporting responsibilities very seriously and commits a significant amount of time and resources to the evaluation and preparation of event reports to the NRC Operations Center. Specifically, the time spent preparing the initial event per 10 CFR 70.50(b)(1 ), the resource requirements for the Level 1 (highest level) Preventive/Corrective Action (PICA) investigation and 30-day follow-up report required by 10 CFR 70.50(c) is substantial.

BWXT NOG-L thoroughly evaluates unplanned contamination events against the 10 CFR 70.50(b)(1) reporting criteria. BWXT NOG-L estimates the resource expenditure associated with timely evaluation and reporting of an unplanned contamination event including the time to develop the event report write-up to be 54 person-hours or approximately $8,800 per event report. The additional resources to perform an in-depth investigation, provide management review and briefings, identify corrective actions and issue the 30-day follow-up report are estimated at 398 person-hours or approximately $60,500 per event report. The total expenditure per event that requires reporting per 10 CFR 70.50(b)(1) is estimated at 452 person-hours or

$69,300.

BWXT NOG-L estimates the frequency of contamination events within a Controlled Area that meet the NRC criteria of a potentially reportable unplanned contamination event to be 16 events per year. If not mitigated, the estimated cost of reporting these events would be $1,108,800 a year.

Because of the extraordinary cost of reporting these low to no risk events, BWXT NOG-L applies numerous resources including operators, maintenance, area supervision, safety engineers, safety management and senior staff to ensure the contaminated area within the Controlled Area is released within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The event response, which begins immediately, includes an assessment of reportability, entry of the event in PICA system, an investigation, development of corrective actions and management review. It is important to note this resource estimate only includes those hours above and beyond the cost associated with commensurate BWXT Nuclear Operations Group, Inc.

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risk incidents which arise in a Controlled Area (e.g. responding to a smear or area air sample above the action level). That is why it is important to include it in the true costs. Were it not for the potential regulatory 24-hour report, these costs would not be incurred. The resource estimate is 94 person-hours or $14,500 per occurrence or $232,000 per year.

BWXT NOG-L takes exception to any assertion that granting of this exemption would reduce the level of transparency to the public of unplanned contamination events. Spills or contamination events are documented in an Unusual Incident Report (UIR) and the site Preventive/Corrective Action (PICA) system. Lesser spills or contamination events are documented in Radiological Safety Incident Notices (RSINs) by our Radiation Protection (RP) organization. In addition, the BWXT NOG-L facility has a full-time NRC resident inspector assigned to it who has unfettered access to and routinely tours and inspects the radiologically controlled areas of the facility. The resident inspector at BWXT NOG-L has computer access to the site PICA system as well as access to paper copies of RSINs. In the course of completing approximately 797 hours0.00922 days <br />0.221 hours <br />0.00132 weeks <br />3.032585e-4 months <br /> of core inspection during a calendar year, the resident inspector has the opportunity to observe operations and maintenance activities in the site's controlled areas and follow up on issues such as radiological spills and contamination events. Each calendar year the NRC resident inspector's follow-up activities at BWXT NOG-L are supplemented by approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of core inspection review of our RP program by an inspector from NRC Region II. The annual RP core inspection includes a review of RSINs and RP-related items in the PICA system and the results of the inspections are documented in quarterly inspection reports which are publicly available in the Agency Document Administration and Management System (ADAMS).

It is worth pointing out that there are approximately 96 operating nuclear power reactors, 20 power reactors undergoing decommissioning, 31 research and test reactors and 25 site-specific and standalone independent spent fuel storage installations who are not subject to a similar reporting requirement for unplanned contamination events in their respective licensing chapters of 10 CFR. BWXT NOG-L believes this request to grant an exemption request from the 10 CFR 70.50(b)(1) reporting requirement is consistent with NRC's Principles of Good Regulation and is in the public interest as it provides clarity, reliability and consistency with the regulatory reporting requirements of licensees with comparable RP programs. Furthermore, it allows the significant expenditure of resources to remain focused on safety significant processes.

People Strong BWXT Nuclear Operations Group, Inc.

P.O. Box 785 Lynchburg, VA 24505 USA 1;

• 1.434.522.6000 www.bwxt om I NNOVATION DRIVEN >

ENCLOSURE2 Letter Dated April 24, 2019, BWXT (Burch) to NRC (Director NMSS), BWXT NOG-L Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1) 7 pages BWXT Nuclear Operations Group, tne.

People Strong PO . Box 785 Lynchburg, VA 24505 USA t: + 1.434.522.6000 www.bwxt.com I NNOVATION DRIVEN >

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April 24, 2019 19-020 ATTN: Document Control Desk Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555--0001

Reference:

1) License No. SNM-42, Docket 70-27

2) NRC Regulation 10 CFR 70.17, "Specific Exemptions"

3) Federal Register Notice, 55 FR 19890, May 14, 1990

Subject:

BWXT Nuclear Operations Group, Inc (NOG-L) Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b}(1)

Dear Sir or Madam:

In accordance with 10 CFR 70.17, BWXT Nuclear Operations Group, Inc., Lynchburg (NOG-L) is requesting an exemption from the 24-hour reporting requirement in 10 CFR 70.50(b)(1) for situations that require the imposition of additional radiological controls for greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> due to an unplanned contamination event inside an established controlled area. The exemption would apply to NOG-L controlled areas as defined in Chapter 4, Radiation Safety, of the SNM-42 License Application.

The Enclosure to this letter provides NOG-L's justification and evaluation criteria for the exemption pursuant to 10 CFR 70.17 (Reference 2).

If you have questions or require additional information, please contact Chris Terry, Manager of Licensing and Safety Analysis, at ctterry@bwxt.com or 434-522-5202.

B. Joel Burch Vice President and General Manager BWXT Nuclear Operations Group, Inc. - Lynchburg Enclosure cc: NRC, J. Zimmerman NRC, M. Baker NRC, Region II NRC, Resident Inspector People Strong SWXT Nucle.:u Oper:lltonc Group, Inc.

PO. Box 785 Lync:hbvtQ. v;,.. :4G05 USA INNOVATION DRIVEN >

1. + 1.434.522.6000 www bwx1 com

ENCLOSURE TECHNICAL JUSTIFICATION FOR 10 CFR 70.50 (b)(1)

EXEMPTION REQUEST 6 pages BWXT Nucle'11 Oper:>lion~ Group, Inc People Strong PO. 60>< 785 Lynchb*Jtg, w,. .:-icos U:lA INNOVATION DRIVEN >

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TECHNICAL JUSTIFICATION FOR 10 CFR 70.50(b)(1) EXEMPTION REQUEST Exemption Request BWXT Nuclear Operations Group, Inc., Lynchburg (NOG-L) is the holder of NRC License SNM-42 for a fuel manufacturing facility at the Lynchburg, VA site.

NOG-L is requesting an exemption from the 24-hour reporting requirement in 10 CFR 70.50(b)(1) for situations due to an unplanned contamination event inside a radiological controlled area that requires worker access to the contaminated area to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area.

It should be noted that NOG-L is not seeking an exemption that would alter reporting requirements in 10 CFR 70.50{b)(1} for situations due to an unplanned contamination event outside an established controlled area. NOG-L will continue to notify NRC of an unplanned contamination event outside an established controlled area that requires worker access to an area to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area. This includes non-controlled areas such as adjacent hallways, rooms, rooftops and outdoor areas. The exemption would not preclude reporting of unplanned contamination events by other NRC requirements such as 10 CFR 20.2202 "Notification of Incidents", 10 CFR 20.2203 "Reports of Exposures, Radiation Levels and Concentrations of Radioactive Material Exceeding the Constraints or Limits" and Appendix A to Part 70 "Reportable Safety Eventsn that result in a failure to meet the performance criteria of 10 CFR 70.61 (i.e. high or intermediate consequence event).

Basis for Exemption Licensed activities at the NOG-L fuel manufacturing facility include the establishment of controlled areas that are controlled as contaminated areas described in the NRC approved license. In Chapter 4, Radiation Safety, of the SNM-42 License Application, a controlled area at NOG-L is defined as an area in which readily dispersible radioactive material is handled. The function of a controlled area at NOG-L is to control process and manufacturing areas where unencapsulated uranium is routinely handled. These areas are designed to safely contain and control releases of radioactive material that may occur as the result of operations or maintenance activities. The design of these areas is intended for the continued protection of the health and safety of occupational workers, members of the public, and the environment. In other words, contamination inside the controlled areas is planned for by the granting of the SNM-42 license and the controls imposed therein. NOG-L does not believe it was the NRC's intent for these unplanned instances, which occur inside controlled areas, to be reported. The NRC stated in Federal Register Notice, 55 FR 19890, when the proposed revision to Part 70 was issued for comment, "The intent of these amendments is to require prompt notification (either immediately or within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s} to the NRC of events that would require prompt action by the NRC to protect public health and safety or the environment.*

Because minor levels of contamination in a controlled area is common, typical radiological control methods are used to minimize worker exposures, which include engineered controls, ventilation, access controls, protective clothing, respiratory protection, routine contamination surveys, airborne monitoring, exit monitoring, and if necessary, area access restrictions.

Adjustments to controls are made as necessary, depending on airborne or contamination levels encountered during normal manufacturing operations (i.e. production and planned maintenance) and abnonnal conditions (i.e., loss of containment).

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Technical Justification NOG-L proposes to commit to the following six criteria and provides a technical justification describing how each criterion will be met.

1) The majority of established and posted controlled areas that may require additional controls reside within the site's Protected Area (PA), which is not accessible to the public. The Lynchburg Technology Center (LTC) and the Waste Treatment Facility controlled areas reside within the site's Owner Controlled Area (OCA). The PA is surrounded on all sides by the OCA, which is also isolated from the public.

The PA and OCA are maintained in accordance with applicable NRC security requirements of 10 CFR 73 and the site Physical Security Plan. Within the PA the established controlled areas are clearly posted and reside within an area encompassed by physical barriers with restricted access. The PA is controlled as a Restricted Area as defined in 10 CFR 20.1003. Access to the PA is restricted to either individuals with security clearances and current safety training or individuals that are formally escorted by trained security/safety escorts. At no time can members of the public access the PA without being escorted or trained. The controlled areas within the OCA at the LTC and the Waste Treatment Facility are clearly posted and are controlled as Restricted Areas as defined in 10 CFR 20.1003. Access to the OCA requires an individual to either be escorted or to have completed General Employee Safety training (GEST) and don dosimetry for the duration of their time on-site.

2) Controls are imposed as necessary to keep radiation exposures and releases as low as reasonably achievable.

NOG-L maintains and implements an effective Radiation Protection Program to keep worker exposures As Low as Reasonably Achievable (AL.ARA). These radiation protection principles are necessary to implement NRC ALARA requirements in 10 CFR 20.1101 and include engineering and other exposure control practices such as action levels to protect workers described in approved standard operating procedures. These principles are an integral part of the overall Radiation Protection Program that is routinely inspected by the NRC. Routine control adjustments to minimize exposures include modifications to protective clothing, adding respiratory protective equipment or restricting access to portions of a controlled areas and are anticipated, allowed, and at times prudent. Operations are conducted In accordance with approved procedures for routine work in controlled areas that provide flexibility for upgrading and downgrading controls in response to changing radiological conditions.

3) Facility Safety and Radiation Protection personnel are trained and qualified in contamination control and response and are readily available.

NOG-L provides sufficient Radiation Control Technician (RCT) staffing on each production shift {day shift, second shift and third shift) to support and respond to radiological conditions in a controlled area to ensure appropriate and timely actions are taken. The RCTs are trained in contamination control procedures and techniques required for responding to a contamination event and are readily available to respond as needed. The RCTs must successfully complete a rigorous training and qualification program prior to performing unsupervised activities and complete annual refresher People St r ong 8WXT Nucle::,r Oper'1tion~ Gccup Inc:

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training to continue unsupervised work. These personnel are augmented as needed with emergency response personnel trained in handling hazardous and radiological materials in normal and abnormal conditions. Radiation Safety Professionals provide guidance and technical radiation safety expertise to the RCTs and Emergency Response personnel. Radiation Safety Professionals support is augmented by Nuclear Criticality Safety (NCS) Engineers, Environmental Engineering, Industrial Hygiene specialists and facility engineering who provide discipline-specific support and technical guidance as appropriate.

4} Equipment and facilities that may be needed for contamination control are readily available.

Controlled areas are designed to control contamination in process and manufacturing areas at the facility where unencapsulated uranium is routinely handled. These controls include engineered features such as ventilated areas designed to provide air flow from areas of lesser potential contamination to areas of higher potential contamination.

Activities and process equipment that could potentially generate airborne uranium are designed with ventilated containment enclosures, hoods, dust capturing exhaust ports, local exhaust systems and other devices to minimize the release of uranium in work areas. The air and gasses from fuel manufacturing processes are exhausted as appropriate through filter media prior to being recirculated back into work areas or exhausted to the environment. Routine engineered and facility control adjustments to minimize exposures and the extent of a release include shutting down equipment, adding localized exhaust ventilation and closing or reducing containment hood openings.

Specialized radiation protection contamination control equipment is available for contamination control response.

5) Radiation surveys of unplanned contamination events in controlled areas are performed and are available for NRC inspection upon request.

Appropriate radiation surveys are performed by qualified personnel during or after an unplanned contamination event as necessary to assess radiological conditions and provide the appropriate response. The type of survey is determined by staff Radiation Safety Professionals as described in the NRC approved license and in accordance with approved procedures. Survey results are compared to specified action guides and when contamination levels in excess of action levels are found, appropriate actions are taken, and the affected area is decontaminated in a safe and timely manner. Survey records for contamination events are documented pursuant to 10 CFR 20.2103 and are available for review.

6) Unescorted workers in controlled areas are trained on methods to reduce radiation exposures including contamination controls and response actions for abnormal or upset conditions.

Formal nuclear safety training is required for unescorted workers entering a controlled area. Visitors to a controlled area are escorted by trained personnel. The training inc,udes information about radiation and radioactive materials, precautions or procedures to minimize exposure, the purposes and functions of protective devices employed; and their responsibility to report promptly to the licensee any condition which may lead to or cause a violation of NRC regulations and licenses or unnecessary exposure to radiation and/or radioactive material. The training also includes the Peop l e Strong 81/1/XT Nucle:ir Open.1 .on o Groq:, Inc P.O. BO>< 765 1.+'n<:nou19, VA :C4 !i05 UCA INNOVATION DRIVEN >

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appropriate response to warnings made in the event of any unusual occurrence or malfunction that may involve exposure to radiation and/or radioactive material and nuclear criticality safety principles. Training policy requires that workers must complete nuclear safety training prior to unescorted access in the controlled area. The training Is typically provided using computer-based training but may be performed by authorized instructors. Previously trained workers who are allowed unescorted access to the controlled area are retrained annually. The effectiveness of the training program is evaluated by either initial training exam or re-training exam.

10 CFR 70.17 Evaluation Criteria Pursuant to 10 CFR 70.17(a), the NRC may grant an exemption from the requirements of 10 CFR Part 70 if the staff determines that the exemption is authorized by law, will not endanger life or property or the common defense and security, and is otherwise in the public interest.

NOG-L has determined that granting the proposed exemption will not result in a violation of the Atomic Energy Act of 1954. as amended, other laws, or the Commission's regulations. Therefore, the requested exemption is authorized by law.

NOG-L has also determined that an exemption from the requirement to report within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a situation due to an unplanned contamination event inside an established controlled area that requires worker access to the contaminated area to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area, will not endanger life or property or the common defense and security. As described above, NOG-L has established controlled areas that are designed to safely contain releases of radioactive material that may occur as a result of operations or maintenance activities that are within a restricted area with no unescorted public access.

The additional controls imposed by the license and implemented through procedures for controlled areas make it unlikely that an event would occur which would require prompt action by the NRC to protect public health or safety or the environment. An internal review has revealed that in 63 years of NOG-L operations, no unplanned contamination incident inside a controlled area has required prompt action by the NRC or its predecessor, the Atomic Energy Commission, to protect public health and safety or the environment. In addition, NOG-L uses trained and qualified radiation protection personnel who have appropriate equipment readily available. While the exemption request would eliminate the 24-hour reporting requirement for unplanned contamination events inside a controlled area, NOG-L will continue to make required reports of situations due to an unplanned contamination event outside an established controlled area, maintain records of these events, and would provide this information to NRC for inspection upon request. Also, from a regulatory oversight and response perspective, it should be noted that the NOG-L site has a full-time NRC Resident Inspector who conducts safety and compliance inspections of plant activities under NRC purview on a daily basis. The NRC Resident Inspector at NOG-L performs routine reviews of radiological conditions of the controlled areas during his inspections of the facility under Inspection Procedures (IP) 88135, Resident Inspection Program for Category I Fuel Cycle Facl1ities and IP 88135.02, Resident Inspection Program Plant Status Activities.

The elimination of the 24-hour reporting requirement also does not involve information or activities that could potentially impact the common defense and security of the United States. Rather, the requested exemption is administrative in nature and would reduce BV,IXT Nl.Cl&:1f Oper;1t,ons Group Inc People Strong

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the number of licensee actions triggered by an event that imposes additional radiological controls or by prohibiting entry into an area. Based on its review of this information, NOG-L concludes that granting this exemption request would not endanger life or property or the common defense and security.

Finally, granting this exemption request is otherwise in the public interest because it promotes regulatory efficiency by relieving NOG-L from a reporting requirement that is of low safety significance given the site-specific conditions and programs described above. The exemption would relieve NOG-L from generating initial notification reports within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and written follow-up reports within 30 days of certain contamination events and the NRC staff from receiving and processing these reports, thereby allowing resources to be focused on other activities of higher significance or consequence.

Conclusion:

Based on the above, NOO-L has concluded that the activities to be authorized by the issuance of an exemption are in compliance with law, and will not endanger life or property or the common defense or security. NOG-L also concludes that granting the exemption is in the public interest by promoting regulatory efficiency with no adverse impacts on public health and safety or the environment.

Accordingly, NOG-L requests an exemption from the 24-hour reporting requirement in 10 CFR 70.SO(b)(1) for situations due to an unplanned contamination event inside an established radiological controlled area that requires worker access to the contaminated area to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area.

NOG-L proposes a new Safety License Condition S-16 be issued to reflect the exemption from reporting as follows:

S-16 Notwithstanding the requirements of 10 CFR 70.50(b)(1), the licensee is exempt from the requirement to notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of unplanned contamination events inside an established controlled area that requires worker access to the controlled area, or any portion thereof, to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area.

The licensee commits to 1) Establish and post controlled areas that reside within the licensed Protected Area (PA) or Owner Controlled Area (OCA) which is not accessible to the public without escort, 2) Impose controls as necessary to keep radiation exposures and releases as low as reasonably achievable, 3) Ensure radiation protection personnel are trained and qualified in contamination control and are readily available, 4) Provide equipment and facilities that may be needed for contamination control, 5) Perform radiation surveys of unplanned contamination events in controlled areas and provide records for NRC inspection upon request, 6) Train unescorted workers in controlled areas on methods to reduce radiation exposures including contamination controls and response actions for abnormal or upset conditions.

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