ML20199M167

NRC Letter and SER Authorizing USGS to Use an Alternate A2 Value

ML20199M167
Person / Time
Site:	U.S. Geological Survey
Issue date:	07/20/2020
From:	John Mckirgan Storage and Transportation Licensing Branch
To:	Manning C US Dept of Interior, Geological Survey (USGS)
BHWhite NMSS/DFM/STL 415.6577
Shared Package
ML20199M166	List: ML20199M167
References
CAC A33010, EPID L-2020-LLA-0106
Download: ML20199M167 (3)

Text

July 20, 2020 Mr. Clayton Manning, Health Physicist U.S. Geological Survey TRIGA Reactor Department of the Interior U.S. Geological Survey Box 25046 MS-974 Denver CO, 80225

SUBJECT:

APPROVAL OF ALTERNATE A2 VALUE

Dear Mr. Manning:

This is in response to your request dated August 9, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18236A551), requesting the authority to use an alternate A2 value for Bromine-80 metastable (Br-80m) than the general A2 value in Table A-3, Appendix A to Title 10 of the Code of Federal Regulations Part 71. In accordance with Section II.a in Appendix A to 10 CFR Part 71, the U.S. Nuclear Regulatory Commission is authorizing the U.S. Geological Survey to use 0.40 Terabecquerel (11.0 Curies) as the A2 value for Br-80m for domestic transport. This approval expires on November 1, 2023.

If you have any questions regarding this certificate, please contact Bernard White of my staff at (301) 415-6577.

Sincerely, John B. Digitally signed by John B.

McKirgan McKirgan Date: 2020.07.20 11:01:22

-04'00' John B. McKirgan, Chief Storage and Transportation Licensing Branch Division of Fuel Management Office of Nuclear Material Safety and Safeguards CAC No. A33010 Docket No.: 50-274 EPID: L-2020-LLA-0106

Enclosures:

1. DOT Approval

2. Safety Evaluation Report cc w/encls. 1& 2: R. Boyle, DOT J. Shuler, U.S. DOE c\o L. F. Gelder

C. Manning

SUBJECT:

APPROVAL OF ALTERNATE A2 VALUE DATED: July 20, 2020 DISTRIBUTION:

DSFM r/f NMSS r/f D. Marcano G. Warnick, RIV Closes EPID No. L-2020-LLA-0106 ADAMS Package No.: ML20199M166 Letter Accession No.: ML20199M167 DOT Letter Accession No.: ML20199M168

• via email OFFICE: NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DFM NMSS/DSFM NAME: BWhite SFigueroa* MCall* RChang* JMcKirgan DATE: 7/6/2020 7/6/2020 7/6/2020 7/7/2020 7/20/2020 OFFICIAL RECORD COPY

U.S. Geological Survey TRIGA Reactor Docket No. 50-274 Safety Evaluation Report for Alternate A2 Value for Domestic Transportation The U.S. Geological Survey (USGS) submitted a request to approve use of 0.40 Terabecquerel (TBq) (11.0 Curies) as the A2 value for the radionuclide Bromine-80 metastable (Br-80m).

Appendix A of Title 10 of the Code of Federal Regulations (10 CFR) Part 71 does not include a specific A2 value for this nuclide (neither do the standards of the International Atomic Energy Agency in Regulations for the Safe Transport of Radioactive Material, Specific Safety Requirements No. 6, 2018 Edition). In its place, the U.S. Nuclear Regulatory Commission authorizes, by rule in Appendix A to 10 CFR Part 71, Determination of A1 and A2, use of a generic A2 value in Table A-3, General Values for A1 And A2, of 0.02 TBq (0.54 Curies) for nuclides that only emit beta or gamma radiation. The USGS stated that this value, 0.02 TBq (0.54 Curies), is too limiting for its needs and has proposed a value that is equal to the value for Br-82. The USGS produces Br-82 in its TRIGA reactor for industrial purposes. This process also results in some amount of Br-80m also being produced. Since the product is shipped in Type A containers, the A2 value is important.

The USGS referred to the NRCs 10 CFR Part 20 Appendix B, Annual Limits on Intake (ALIs) and Derived Air Concentrations (DACs) of Radionuclides for Occupational Exposure; Effluent Concentrations; Concentrations for Release to Sewerage, for both the Br-82 and Br-80m nuclides. The ALIs for Br-82 are more limiting than the limits for Br-80m, by a factor of 2 to 3 (i.e., the Br-80m limits are about 2 to 3 times higher than the Br-82 limits). The USGS also noted the differences in the half life and gamma energies for each nuclide; Br-80m has a noticeably shorter half-life and emits significantly lower energy gammas. Based on these arguments, the USGS proposed that using the Br-82 A2 value for Br-80m would be conservative.

For its evaluation of the USGSs proposed A2 value, the staff considered several factors. These include the information in Appendix B to 10 CFR Part 20; consideration of any radioactive progeny of the two nuclides and their potential contributions; data available to the staff regarding the radiations emitted by these two nuclides and any progeny; and data available to the staff indicative of the relative significance of the doses from these nuclides and any progeny. The data included information related to external and internal doses from the nuclides. Based on this information, the staff found that the Br-82 would be bounding in terms of dose for nearly every scenario the staff considered.

In some limited cases, however, the information indicated that Br-82 may not be bounding.

However, the U.S. Department of Transportation also completed its own review of this same request. For that review, calculations of an A2 value for Br-80m resulted in a value that equals the A2 value for Br-82. For such calculations, the appropriate considerations for internal and external doses and for any progeny of Br-80m would have been addressed. This would include appropriate inclusion of factors that would encompass or address the limited cases that the staffs evaluation indicated that Br-82 may not be bounding.

Thus, based on its own evaluation and the evaluation that supported the U.S. Department of Transportations review, the staff finds the use of the proposed A2 value of 0.40 TBq (11.0 Curies) for Br-80m to be acceptable.

Enclosure 2