ML25261A226
| ML25261A226 | |
| Person / Time | |
|---|---|
| Site: | Triso-X |
| Issue date: | 09/18/2025 |
| From: | Triso-X |
| To: | Office of Nuclear Material Safety and Safeguards |
| Shared Package | |
| ML25261A224 | List: |
| References | |
| TX0-REG-LTR-0087 | |
| Download: ML25261A226 (1) | |
Text
TX0-REG-LTR-0087 Enclosure - Supplemental Information for Set 19 Environmental Safety RAI-1 Response Page 1 of 2 RAI-1 Transuranic and Fission Product Contaminants in Effluents Regulatory Basis:
Title 10 of the Code of Federal Regulations (10 CFR) Section 20.1302(a) states The licensee shall make or cause to be made, as appropriate, surveys of radiation levels in unrestricted and controlled areas and radioactive materials in effluents released to unrestricted and controlled areas to demonstrate compliance with the dose limits for individual members of the public in § 20.1301. The dose limits in § 20.1301 apply to the total effective dose equivalent from the licensed operation.
Description of Issue:
The applicant stated that feed material may contain transuranic and fission product contamination.
Although the survey program is described in LA chapter 4, there is limited information on the monitoring of transuranic and fission product activities in effluents. Additional information is needed to evaluate the proposed emissions controls with respect to transuranic and fission product contamination.
Information Needed:
Incorporate in the LA or by cross reference a sufficient description of the methods, such as action levels related to receipt of contaminated feed material, to determine when it is appropriate to survey for transuranic or fission product contamination in effluents.
TRISO-X Response to RAI-1:
License Chapter 1, Section 1.2.4, Type, Quantity, and Form of Licensed Material, includes transuranic and fission product limits that are applied to the contaminants in enriched uranium feedstock. TRISO-X performed effluent activity concentration calculations which demonstrate if feedstock with contaminants up to these specified limits is received and processed, then any offsite receptor would receive significantly less than 10 mrem per year, which meets 10 CFR 20 requirements. Supplier sampling documentation is independently reviewed to ensure source material contaminant values are less than specified limits. Source material with contaminants greater than the limits specified in License Chapter 1, Section 1.2.4 will not be accepted by TRISO-X. Therefore, surveys for specific transuranic or fission product contamination in effluents are not necessary to demonstrate compliance with 10 CFR 20.
The above response is unchanged from the RAI-1 response transmitted by letter dated August 6, 2025. The license changes shown below are new.
License Changes:
License Chapter 9, Section 9.5, Environmental Monitoring, will be revised as shown below (changes in red).
9.5 Environmental Monitoring TRISO-X conducts a routine environmental surveillance program. Compliance with 10 CFR 20.1301 is achieved using the option provided in 10 CFR 1302(b)(2)(i) to demonstrate that the annual average concentrations of radioactive material released in gaseous effluents at the boundary of the unrestricted area (the point of stack discharge) do not exceed the values specified in Table 2 of Appendix B to Part 20. Demonstration is accomplished by calculation and validated by measurement. This ensures that environmental concentrations at the site boundary and offsite are well below regulatory limits. TRISO-X evaluated potential transuranic and fission product contaminants in uranium feed material and established the contaminant limits in Section 1.2.4, Item 1 to ensure that surveys of transuranic and fission product radionuclides are not required to maintain compliance with 10 CFR 20. TRISO-X will maintain approved procedures that
TX0-REG-LTR-0087 Enclosure - Supplemental Information for Set 19 Environmental Safety RAI-1 Response Page 2 of 2 prevent TRISO-X from receiving uranium feed material with contaminants in excess of these limits. This approach demonstrates that specific surveys for transuranic and fission products are not needed for compliance with 10 CFR 20.