ML24304B059
| ML24304B059 | |
| Person / Time | |
|---|---|
| Site: | 07007029 |
| Issue date: | 11/22/2024 |
| From: | NRC/NMSS/DFM/FFLB |
| To: | US Dept of Defense, Defense Threat Reduction Agency |
| Shared Package | |
| ML24304B058 | List: |
| References | |
| Download: ML24304B059 (1) | |
Text
Enclosure 1 SAFETY EVALUATION REPORT DOCKET NO.:
70-7029 LICENSE NO.:
SNM-7005 LICENSEE:
Defense Threat Reduction Agency
SUBJECT:
DEFENSE THREAT REDUCTION AGENCYLICENSE AMENDMENT FOR CHANGE OF RADIATION SAFETY OFFICER (ENTERPRISE PROJECT IDENTIFER L-2024-NFA-003)
I.
INTRODUCTION By submittal dated August 14, 2024 (Agencywide Documents Access and Management System Accession Number ML24234A137), the Defense Threat Reduction Agency (DTRA) submitted a license amendment request. Specifically, DTRA requested U.S. Nuclear Regulatory Commission (NRC) approval of Mr. Timothy Hart as DTRAs new radiation safety officer (RSO). With its submittal, DTRA enclosed the individuals qualifications - that enclosure is non-public since it contains personally identifiable information.
II.
REGULATORY REQUIREMENTS The regulation in Title 10 of the Code of Federal Regulations (10 CFR) 70.22, Contents of applications, (a)(6) requires that each application for a license shall contain the technical qualifications, including training and experience of the applicants staff members for engaging in the proposed activities.
The regulation in 10 CFR 70.23(a) states that an application for a license will be approved if the Commission determines, in part, that the applicant is qualified by reason of training and experience to use licensed material for the purpose requested.
III.
REGULATORY GUIDANCE The NRC staff evaluated the qualifications of the nominated RSO following the guidance in section 8.7.3, Radiation Safety Officer, of NUREG 1556, Consolidated Guidance About Materials Licenses, Volume 11, Program-Specific Guidance About Licenses of Broad Scope (ML17059D332), and associated guidance in section 2.1.2, Radiation Safety Officer, of draft NUREG-2212, Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but not Subject to the Requirements in 10 CFR Part 70, Subpart H, dated September 2022 (ML22335A087).
IV.
STAFF REVIEW AND ANALYSIS In its submittal, DTRA requested NRC approval for Mr. Timothy Hart as the new RSO. Mr. Hart would replace Mr. Daniel Sowers, the current RSO. Based on the information provided by DTRA in the enclosure to its submittal, Mr. Hart has 43 years of experience in radiation safety programs in the U.S. Navy, with much of that experience in a leadership role. It was noted that he has specific experience with special nuclear materials (SNM), and vast experience, including occupying a radiation protection manager position at the Naval Sea Systems Command, Radiological Affairs Support Office, where he oversaw all aspects of radiation safety for industrial
2 uses of radioactive materials and radiation producing machines at military commands throughout the U.S. Navy and Marine Corps. He served as former Director of Radiation Safety Programs for the U.S. Navy as well.
Mr. Hart also possess more than 40 years of experience working as a health physicist (HP) and in radiation safety positions in the Navy, as well as in multiple labs and clinics with varying levels of responsibility and authority including program administration, HP instruction, radiological work planning, supervision, and scheduling. With his resume, DTRA also included a list of the radiation safety trainings that Mr. Hart has completed. The list includes, amongst others, the following courses:
Radiation Safety Awareness for Readiness Personnel Special Nuclear material Training Radiation Safety and NRC License training for Site-Radiation Safety Officers and Authorized Users Transportation of Radioactive Materials Course (S-553-1111)
Department of Energy Transportation Physical Security Quality Assurance for Radioactive Material Packaging NAVSEA Radiation Protection Manager Training Nuclear Regulatory Commission Quality Assurance Training Root Cause Analysis Workshop NRC Security Systems and Principles Course Accelerator Radiation Physics, Regulation, and Management, USPAS, Rice University, Houston TX Accelerator Fundamentals, State University of New York at Stony Brook, Stony Brook N.Y MARSSIM Training (EVN-351)
Applied Health Physics Course, Oak Ridge Associated Universities, Oak Ridge TN Irradiator Regulatory and Licensing Review, Operation and Repair Training - JL Shepherd
& Associates NRC Licensing Practices and Procedures (G-109)
NRC Inspection Procedures (G-108)
Aspects of Industrial Radiology (NRC H-305)
NAVSEADET RASO Radiographic Safety Training Nuclear Propulsion Plant Operator (Mechanical)
Nuclear Power Fundamentals V.
EVALUATION FINDINGS Based on the review of the information provided by DTRA in its submittal dated August 14, 2024, the NRC staff finds that DTRA provided the necessary information for the NRC staff to evaluate the nominated RSO in accordance with the requirements in 10 CFR 70.22(a)(6). In addition, the NRC staff finds that the nominated individual meets the training and experience requirements discussed in section 8.7.3, Radiation Safety Officer, of NUREG-1556, Consolidated Guidance About Materials Licenses, Volume 11, Program-Specific Guidance About Licenses of Broad Scope (ML17059D332), and section 2.1.2, Radiation Safety Officer, of draft NUREG-2212, Standard Review Plan for Applications for 10 CFR Part 70 Licenses for Possession and Use of Special Nuclear Materials of Critical Mass but not Subject to the Requirements in 10 CFR Part 70, Subpart H, dated September 2022 (ML22335A087).
3 Therefore, in accordance with the regulation in 10 CFR 70.23(a), and as discussed above, the NRC staff finds that Mr. Timothy Hart is qualified by reason of training and experience to use licensed material for the purpose requested.
VI.
ENVIRONMENTAL REVIEW The regulation in 10 CFR 51.22(c)(14)(v) state that a proposed action is excluded from an environmental review if it is an amendment to a license issued pursuant to 10 CFR Part 70 authorizing the use of radioactive materials for research and development and for educational purposes. The NRC staff determined that DTRAs authorized activities fall under this category and, therefore, meet the above requirement. The NRC staff also determined that the proposed license amendment does not adversely impact public health and safety or the environment. Therefore, NRC staff determined that, in accordance with 10 CFR 51.22(c)(14)(v), DTRAs request does not require the preparation of an environmental assessment or an environmental impact statement.
VII.
CONCLUSION As discussed above, the NRC staff finds that DTRA has nominated, as RSO, an individual with extensive experience, education, and training in the radiation field and with the necessary qualifications to oversee the safe operation of its NRC-licensed program activities. The NRC staff also concludes that the nominated individual is qualified to use licensed material for the activities authorized by the license and, therefore, should be approved VIII.
PRINCIPAL CONTRIBUTOR Stephen Poy, NMSS/DFM