ML23103A432

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Request for Exemption from 10 CFR 20.2206(c) Due to Issues Obtaining Data
ML23103A432
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 04/13/2023
From: Morgan J
South Texas
To:
Office of Nuclear Regulatory Research, Document Control Desk
References
NOC-AE-23003955
Download: ML23103A432 (1)


Text

April 13, 2023 NOC-AE-23003955 10 CFR 20.2301 10 CFR 20.2206(c)

STI: 35460702 Executive Director for Operations (EDO)

U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 South Texas Project Units 1 and 2 Docket Nos. 50-498; 50-499 Request for Exemption from 10 CFR 20.2206(c) Due to Issues Obtaining Data In accordance with 10 CFR 20.2301, Applications for exemptions, STP Nuclear Operating Company (STPNOC) requests an exemption from the requirement in 10 CFR 20.2206(c), which requires the submittal of the Radiation Exposure Information and Reporting System (REIRS) data by April 30 of each year. Since April 30, 2023, is a Sunday, the actual due date would be May 1, 2023. STPNOC is requesting an exemption to the May 1, 2023, deadline to allow for submittal of the REIRS data by August 31, 2023. STPNOC requests approval of this exemption request no later than May 1, 2023.

Background

The vendor processing the 2022 STPNOC dosimetry, Mirion Dosimetry, has not yet provided the data necessary for submittal of individual monitoring in accordance with 10 CFR 20.2206(c).

Specifically, Mirion Dosimetry has not provided 2022 data for over 800 Thermo Luminescent Dosimeters (TLD) badges sent to them for processing.

STPNOC has made numerous attempts to communicate with Mirion Dosimetry regarding this issue, but Mirion Dosimetry will not commit to providing the 2022 TLD data to STPNOC by May 1 and STPNOC does not have confidence that Mirion Dosimetry will provide the data by May 1. Therefore, pursuant to 10 CFR 20.2301, STPNOC is requesting a one-time exemption from 10 CFR 20.2206(c).

Justification for Exemption As stated in 10 CFR 20.2301, The Commission may, upon application by a licensee or upon its own initiative, grant an exemption from the requirements of the regulations in this part if it determines the exemption is authorized by law and would not result in undue hazard to life or property."

(1) The Requested Exemption is Authorized by Law The NRC has the authority under the Atomic Energy Act of 1954, as amended, to grant exemptions from its regulations if doing so would not violate the requirements of law.

This exemption is authorized by law as is required by 10 CFR 20.2301.

(2) The Requested Exemption Would Not Result in Undue Hazard to Life or Property The intent of 10 CFR 20.2206 is to establish requirements for monitoring the exposures of individuals for radiation and radioactive material and providing the NRC with reports

NOC-AE_23003955 Page 2 of 2 on the required monitoring. The year-to-date dose of radiation workers can be estimated with the electronic dosimeters for continued monitoring. The best available exposure data, either TLD data from Mirion Dosimetry or data fr6m exposure investigations, will be submitted to REIRS by August 31, 2023, if this exemption is granted. DatJfrom electronic dosimeters was reviewed and no individuais reachEd the regulatory limits stated in '10 CFR 20.1502 and no irregularities are expected between 6lectronic dosimeter data and the final record data to be submitied. Therefore, if granted, this exemption would not result in undue hazardto life or property Conclusion This exemption request provides sufficient basis to the NRC for granting STPNOC a one-time exemption from 10 CFR 2A.2206(c). lf the exemption is approved, STPNOC would submit the 2022lndividual Monitoring data to RETRS by August Sl, )OZg.

There are no commitments in this letter.

lf there are any questions about this report, please contact zachary Dibbern at (361 ) 972-4336 or me at (361) 972-4045.

an ealth Physics cc:

ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Regional Administrator, Region lV U.S. Nuclear Regulatory Commission 1600 E. Lamar Boulevard Arlington, TX 7601 1-4511