ML23107A251
| ML23107A251 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 04/17/2023 |
| From: | Morgan J South Texas |
| To: | NRC/EDO, Office of Nuclear Regulatory Research, Document Control Desk |
| References | |
| EPID L-2023-LLE-0009, NOC-AE-23003957, 35462798 | |
| Download: ML23107A251 (1) | |
Text
April 17, 2023 NOC-AE-23003957 10 CFR 20.2301 10 CFR 20.2206(c)
STI: 35462798 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 Revised Request for Exemption from 10 CFR 20.2206(c)
Due to Issues Obtaining Data (EPID: L-2023-LLE-0009)
Reference:
Letter from J. Morgan, STPNOC; to Executive Director for Operations, NRC; Request for Exemption from 10 CFR 20.2206(c) Due to Issues Obtaining Data; April 13, 2023; NOC-AE-23003955; ML23103A432.
STP Nuclear Operating Company (STPNOC) requests that this letter replace the above-referenced letter dated April 13, 2023 in its entirety. This replacement letter contains information showing that the requested exemption meets the eligibility criteria for categorical exclusion from environmental review.
In accordance with 10 CFR 20.2301, Applications for exemptions, 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 a one-time exemption to the May 1, 2023, deadline to allow for submittal of the REIRS data by August 31, 2023. This exemption is for the period from May 1, 2023, to 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).
NOC-AE-23003957 Page 2 of 4 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 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 from exposure investigations, will be submitted to REIRS by August 31, 2023, if this exemption is granted. Data from electronic dosimeters was reviewed and no individuals reached the regulatory limits stated in 10 CFR 20.1502 and no irregularities are expected between electronic dosimeter data and the final record data to be submitted. Therefore, if granted, this exemption would not result in undue hazard to life or property.
Environmental Considerations The proposed exemption has been evaluated against the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(25):
(i) There is no significant hazards consideration; STPNOC has evaluated the proposed exemption to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92(c) as discussed below:
- 1. Does the proposed exemption involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed exemption involves a one-time extension to the reporting requirement delineated in 10 CFR 20.2206(c). This proposed change has no effect on any facility structures, systems, and components (SSCs) or their capability to perform design functions, and therefore would not increase the likelihood of a malfunction of any facility SSC, or affect the performance of any SSCs relied upon to mitigate the consequences of an accident previously evaluated. The means by which SSCs are operated, maintained, modified, tested, or inspected are also not affected.
Therefore, the proposed exemption does not involve a significant increase in the probability or consequences of an accident previously evaluated.
NOC-AE-23003957 Page 3 of 4
- 2. Does the proposed exemption create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed exemption does not involve a physical alteration of the facility, and no new or different type of SSCs will be installed, therefore there are no physical modifications to existing equipment that could result from the exemption. The proposed exemption does not involve modifications which could modify the manner in which facility SSCs are operated and maintained, and does not result in any changes to parameters within which the facility is normally operated and maintained.
Therefore, the proposed exemption does not create the possibility of a new or different kind of accident from any previously evaluated.
- 3. Does the proposed exemption involve a significant reduction in a margin of safety?
Response: No.
The proposed exemption from the reporting requirement delineated in 10 CFR 20.2206(c) is unrelated to any facility operation. As such, the exemption would not affect any equipment of the facility.
Therefore, the proposed exemption does not involve a significant reduction in a margin of safety.
Based on the above, STPNOC has determined that the proposed exemption presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.
(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; The requested exemption to certain reporting requirements specified in 10 CFR 20.2206(c) will not result in changes to any facility SSCs or design functions associated with monitoring or limiting the release of effluents. There are no expected changes in the types, characteristics, or quantities of effluents discharged to the environment as a result of the exemption. The exemption would not introduce any materials or chemicals into the facility that could affect any of the amounts or types of effluents released offsite. Therefore, there is no change in the types or increase in the amounts of any effluents that may be released offsite.
(iii) There is no significant increase in individual or cumulative public or occupational radiation exposure; The requested exemption proposes to extend the reporting date due date from May 1, 2023 to August 31, 2023. The one-time extension to the reporting requirement would not result in any change to the consequences of the accident previously evaluated, and does not involve any significant change in the types of amounts of effluents that may be released offsite, as evaluated above. The proposed reporting requirements contained within this exemption request does not result in any physical changes to the facility SSCs, the manner in which they are operated or maintained, and does not involve a change to land use at the STP Electric Generating Station.
Therefore, there is no significant increase in individual or cumulative public or occupational radiation exposure.