ML25154A414
| ML25154A414 | |
| Person / Time | |
|---|---|
| Issue date: | 06/02/2025 |
| From: | Marra A Office of Nuclear Material Safety and Safeguards |
| To: | Steve Wyman Office of Nuclear Material Safety and Safeguards |
| References | |
| Download: ML25154A414 (2) | |
Text
June 2, 2025 MEMORANDUM TO:
Steve Wyman, Chief Source Management and Protection Branch Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards
SUBJECT:
U.S. NUCLEAR REGULATORY COMMISSION RESPONSES TO PUBLIC COMMENTS ON DRAFT REGULATORY ISSUE
SUMMARY
- APPLICABILITY OF REQUIREMENTS DURING THE MOVEMENT OF RADIOACTIVE MATERIAL WITHIN A TEMPORARY JOBSITE Below are the U.S. Nuclear Regulatory Commission (NRC) staff responses to public comments made on Draft Regulatory Issue Summary: Applicability of Requirements During the Movement of Radioactive Material Within a Temporary Jobsite (ML24206A139). The comment period closed on May 5, 2025. The NRC received 3 comment submissions during the comment period from interested stakeholders. Public comments and responses are listed below.
Comment 1:
Mango Mussolini doesnt care about radiation Staff Response:
Out of scope.
Comment 2:
The draft RIS clarification is helpful for licensed service providers who may be on working within temporary job sites.
Staff Response:
The NRC agrees with this comment. This RIS provides helpful clarification for those working on temporary jobsites Comment 3:
I am writing on Docket ID NRC-2025-0055. I believe there should not be an exception for 10 CFR71.5(a) and 10 CFR 71.5(b) for the transport and packaging of nuclear materials, even on temporary jobsites. The draft RIS gives temporary job sites an exemption from these regulations. I believe when nuclear materials are being
transported, whether or not the job site is temporary, the materials should be properly labeled and regulations followed to ensure the material is accounted for at all stages of transport. Without proper transportation and packaging there is the risk of materials being mishandled or even lost. Mishandled nuclear materials can pose a serious threat to the handlers health and wellbeing. Lost nuclear materials, or orphan sources, pose great risk to people and the environment. When a piece of nuclear material is lost it can do a lot of damage. The radiation released from an orphan source can contaminate the soil, water and even plants in the area. Contaminated soil, water and plants are unfit for consumption by humans or other animals. Contaminated soil dramatically decreased the amount of diversity found in the area. It can disrupt the nutrient cycling by affecting plant growth and the amount, and types, of organisms living in the soil. The plants grown in contaminated soil are unfit for animals to consume. The radiation from nuclear material can last for hundreds of years, if not longer. A single radiation source can create disastrous, long-term ecological damage. There are already thought to be thousands of unaccounted for nuclear materials lost in the United States, we need to avoid adding to that number in any way we can. Allowing for the improper transportation and packaging of nuclear material on temporary job sites will ultimately lead to more orphan sources being lost in the environment. On a temporary job site it is even more imperative that all nuclear materials are transported and packaged correctly so no material is forgotten and left behind when the job site closes down.
Staff Response:
The NRC disagrees with the comment. As with any licensed site, the service provider is required to adhere to the applicable safety and security controls within the temporary jobsite, including dose requirements in 10 CFR Part 20, Standards for Protection Against Radiation; access and security controls pursuant to 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material; and any license-specific conditions regarding temporary jobsites, if applicable.
CONTACT:
Ally Marra, NMSS/MSST (301) 415-250