ML25203A121
| ML25203A121 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 07/23/2025 |
| From: | Ekaterina Lenning Licensing Processes Branch |
| To: | |
| Lenning E, NRR/DORL/LLPB | |
| References | |
| EPID L-2025-LRO-0004 | |
| Download: ML25203A121 (1) | |
Text
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION FEEDBACK AND OBSERVATIONS REGARDING WESTINGHOUSE ELECTRIC COMPANY COBALT-60 DIGITAL SERIALIZATION APPROACH WHITE PAPER DOCKET: 99902038; EPID: L-2025-LRO-0004 Document Information
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Background===
By letter dated February 7, 2025 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML25038A126), Westinghouse Electric Company (Westinghouse) submitted to the U.S. Nuclear Regulatory Commission (NRC) its cobalt-60 (Co-60) Digital Serialization Approach white paper describing a digital serialization methodology for Co-60 sources. The NRC staff met with Westinghouse on April 17 and May 15, 2025, to discuss the progress of the review (ADAMS Meeting Summary Accession No. ML25136A012). By letter dated May 29, 2025, Westinghouse submitted a supplement to the white paper (ADAMS Accession No. ML25150A420).
Purpose of the White Paper Westinghouse stated that the purpose of the white paper is to describe its proposed method for uniquely identifying and tracking Co-60 sealed sources within the National Source Tracking System (NSTS) using a digital serialization approach. Specifically, the white paper describes the
[
]
Action Requested Westinghouse requested the NRC staffs feedback and observations on the information and approach described in the white paper.
Feedback and Observations The NRC staff has considered the information and approach provided in Westinghouses white paper and offers the following feedback and observations. This letter and enclosures do not constitute regulatory action or approval.
I.
NRC Feedback on the Digital Serialization Approach During a closed meeting on April 17, 2025, Westinghouse provided a detailed explanation of its proposed digital serialization methodology and proprietary source recovery equipment.
Westinghouse explained that each [
] The harvester, as described, maintains the one-to-
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION one correspondence and the assigned digital serial number uniquely identifies [
] Westinghouse documented this positional correlation in a supplemental submittal to the white paper (ADAMS Accession No. ML25150A419 (Non-publicly available/Proprietary)). Based on the described configuration and supporting documentation, the NRC staff agrees that the sources could be considered uniquely identifiable using the digital serialization methodology, [ ]
The NRC staff also considered the potential risks associated with [
] particularly the possibility of source disassociation or misidentification. If one or more sources were to be unintentionally removed from the source cage, the ability to maintain unique identification could be compromised. However, the NRC staff observed that the likelihood of such an occurrence, whether accidental or unauthorized, is low due to the [
] In the unlikely event that one or more sources were removed, and the digital identification link was lost, Westinghouses serialization approach would accordingly still support reliable accountability. Specifically, the configuration would enable determination of the number of missing sources and an estimate of their activity, to the extent the sources within the cage are expected to exhibit similar levels of radioactivity.
Based on these technical considerations, Westinghouses digital serialization methodology would satisfy the unique identification requirements of Title 10 of the Code of Federal Regulations (10 CFR) 32.201, Serialization of Nationally Tracked Sources, to the extent the sources are subject to NSTS reporting requirements.
II.
NRC Feedback on NSTS Reporting Applicability The NRC staff also considered the applicability of the NSTS reporting requirements to the Co-60 sources that Westinghouse plans to produce at its reactor site. Westinghouse expects that each encapsulated Co-60 source would [
] Under some circumstances, such sources would be reportable to the NSTS as a nationally tracked source as defined in 10 CFR 20.1003, Definitions.
Under Westinghouses proposed method, however, the Co-60 sources [
] Rather, they are intended for [
] Within the industry, source producers and manufacturers commonly refer to this type of radioactive material as bulk material. Although the term is not defined in the NSTS final rule, it is generally understood to refer to precursor radioactive materialsealed or unsealedused in the fabrication of sources.
Based on the technical assessment of Westinghouses proposed source manufacturing process, and because the Co-60 sources to be produced by Westinghouse [ ]
OFFICIAL USE ONLY - PROPRIETARY INFORMATION OFFICIAL USE ONLY - PROPRIETARY INFORMATION
[
] the NRC staff considers these sources to fall outside the scope of the nationally tracked source reporting requirements in 10 CFR 20.2207. Consequently, they would also not be subject to the serialization requirements in 10 CFR 32.201, even though they contain [ ] Therefore, given the information Westinghouse has provided about its proposed manufacturing process and business model, Westinghouse would not be required to report the sources to the NSTS and assign unique serial numbers. If Westinghouse elects to pursue a different business model (for example, [
]) this conclusion may not apply.
While NSTS reporting would not be required, the transportation of these sources remains subject to applicable NRC and U.S. Department of Transportation (DOT) regulations, including 10 CFR Part 71, Packaging and Transportation of Radioactive Material, and DOT hazardous materials transportation requirements. In addition, the security provisions in 10 CFR Part 37, Physical Protection of Category 1 and Category 2 Quantities of Radioactive Material, apply to both storage and transportation of the sources.
The NRC staff encourages continued engagement as Westinghouse proceeds with the implementation of its source tracking and shipment plans, particularly if any changes in production or material configuration could affect the regulatory classification of the material.