ML21286A001

Email from P Bembia to a Snyder Dtd October 12, 2021, Response NYSERDA Radiation Protection Plan for the Retained Premises Amendment Application

ML21286A001
Person / Time
Site:	West Valley Demonstration Project, P00M-032
Issue date:	10/12/2021
From:	Bembia P State of NY, Energy Research & Development Authority
To:	Amy Snyder Reactor Decommissioning Branch
Snyder A
References
Download: ML21286A001 (5)

Text

From: Bembia, Paul J (NYSERDA)

To: Snyder, Amy Cc: Doell, Marlayna; Chapman, Greg; Dean, Janice A (NYSERDA); Mellon, Andrea L (NYSERDA); Cray, Daniel M (NYSERDA); Dueringer, Alita M (NYSERDA)

Subject:

[External_Sender] RE: FW: NYSERDA RPP Amendment Administrivia Date: Tuesday, October 12, 2021 3:18:31 PM Hi Amy, In regard to the two open items you identify in your October 7 email (below), NYSERDA provides the following responses:

1. NYSERDA will add a bullet to RP-RPP 500 when it is next revised, and will add information to procedure RP-RPP004, Training and Instruction of Radioactive Materials Users on the Retained Premises that states that the NYSERDA training supplement will identify anything that is presented in the DOE training that would be different under the NRC requirements and the Part 50 License.

2. NYSERDA confirms that NYSERDAs intent is to have the sensitivity of radiological detection instruments be at least that provided in Appendix C to the Retained Premises RPP, while also ensuring that no materials or equipment with detectable radioactivity will be allowed to be released from restricted or soil contamination areas of the site.

Please let me know if you have questions or need additional information.

Thank you, Paul Sent from Mail for Windows From: Snyder, Amy Sent: Thursday, October 7, 2021 4:36 PM To: Bembia, Paul J (NYSERDA)

Cc: Doell, Marlayna; Chapman, Greg

Subject:

RE: FW: NYSERDA RPP Amendment Administrivia ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

HI Paul, Response 5 below is acceptable to staff.

As we discussed, please clarify the following:

1. In the application, NYSERDA states that the radiation safety training will be provided in part by DOEWVDP, supplemented with training provided by NYSERDA. The application requires three levels of training for personnel requiring unescorted access in the restricted areas of the retained premises: Radiological Worker Training (RWT) Level I and Level II, as well as the use of a Retained Premises Briefing. Only the RWT Level II training is for individuals who will conduct hands-on work in radiation and contamination areas of the retained premises.

Also, NYSERDA indicates in its application that NYSERDA will provide a supplement to the DOEWVDP training that will inform workers of the following:

• radiological exposure limits, administrative limits, and ALARA considerations

• workers responsibility to report promptly to the licensee any condition which may lead to or cause a violation of NRC regulations and licenses, or unnecessary exposure to radiation and/or radioactive material

• the storage, transfer, or use of radiation and/or radioactive material (i.e., a current description of radiological conditions on the retained premises)

• the radiation exposure reports that workers may request pursuant to 10 CFR 19.13, Notifications and reports to individuals Since Rad Worker training is based in part of DOE requirements which may be different than NRC requirements and therefore that of the license, how will NYSERDA address that?

2. Please clarify your RAI response 1 dated September 10, 2021. Please confirm that NYSERDAs intent is to have the sensitivity of radiological detection instruments be at least that provided in Appendix C to the Retained Premises RPP, while also ensuring that no materials or equipment with detectable radioactivity will be allowed to be released from restricted or soil contamination areas of the site.

Thank you.

A From: Bembia, Paul J (NYSERDA) <Paul.Bembia@nyserda.ny.gov>

Sent: Tuesday, September 21, 2021 3:29 PM To: Snyder, Amy <Amy.Snyder@nrc.gov>; Conway, Kimberly <Kimberly.Conway@nrc.gov>

Cc: Doell, Marlayna <marlayna.doell@nrc.gov>; Longmire, Pamela <Pamela.Longmire@nrc.gov>;

Chapman, Greg <Gregory.Chapman@nrc.gov>

Subject:

[External_Sender] FW: NYSERDA RPP Amendment Administrivia Hi Amy and Kimberly, Please see NYSERDAs Sept 13, 2021 response (below) to NRCs questions sent via email on Sept 3, 2021 regarding NYSERDAs License Amendment Request.

Please let me know if you have any questions.

Paul NYSERDA logo Paul Bembia l Director, West Valley Site Management Program New York State Energy Research and Development Authority l9030-B Route 219 l West Valley, New York 14171-9500 P: 716.942.9960 x4900 l F: 716.942.9961 l E: paul.bembia@nyserda.ny.govl W: nyserda.ny.gov Follow : Friend : Connect with NYSERDA From: Bembia, Paul J (NYSERDA)

Sent: Monday, September 13, 2021 10:56 AM To: Longmire, Pamela <Pamela.Longmire@nrc.gov>

Cc: Chapman, Greg <Gregory.Chapman@nrc.gov>; Dean, Janice A (NYSERDA)

<Janice.Dean@nyserda.ny.gov>; Mellon, Andrea L (NYSERDA) <Andrea.Mellon@nyserda.ny.gov>;

Cray, Daniel M (NYSERDA) <Daniel.Cray@nyserda.ny.gov>; Dueringer, Alita M (NYSERDA)

<Alita.Dueringer@nyserda.ny.gov>; Doell, Marlayna <marlayna.doell@nrc.gov>

Subject:

RE: NYSERDA RPP Amendment Administrivia

Pamela, In response to the proposal from NRC in the September 3, 2021 email (below) to add an additional condition to License CSF-1 through the current License Amendment Request (LAR) process, NYSERDA provides below a slight modification to the language proposed by NRC. The language NRC proposes states that NRC will approve a revised RP-RPP, while under the current approval framework, the RP-RPP is reviewed by NRC as part of the supporting documentation for the LAR, but is approved by the NYSERDA Retained Premises Radiation Safety Committee. The modified language proposed by NYSERDA is consistent with this approval framework and assumes another License Amendment will be required prior to NYSERDA assuming responsibility for any part of the WVDP Premises that is presently under the possession of DOE. NYSERDA proposes the following:

(5) Prior to assuming responsibility of any of the WVDP facilities or site areas (when the U.S.

Department of Energy returns oversight of the WVDP to NYSERDA), NYSERDA will submit to NRC a License Amendment Request that will include, as appropriate, an updated Radiation Protection Plan.

Please let me know if the proposed language is acceptable to the NRC.

Thanks, Paul

From: Doell, Marlayna <marlayna.doell@nrc.gov>

Sent: Friday, September 3, 2021 6:22 PM To: Bembia, Paul J (NYSERDA) <Paul.Bembia@nyserda.ny.gov>

Cc: Longmire, Pamela <Pamela.Longmire@nrc.gov>

Subject:

RE: NYSERDA RPP Amendment Administrivia ATTENTION: This email came from an external source. Do not open attachments or click on links from unknown senders or unexpected emails.

Hi again!

One more query and then I think I am really done: would NYSERDA consider consenting to an additional bullet being added to the proposed license condition for the RPP, as highlighted below? I think even though we all know that you will not take back over the WVDP without updating the NYSERDA site documents appropriately, it seems prudent to make it extra clear if we can.

E. Retained Premises Radiation Protection (1) As the sole licensee under provisional operating license CSF-1 for the Retained Premises [i.e., the non-West Valley Demonstration Project (WVDP), non-State Licensed Disposal Area (SDA) portions of the Western New York Nuclear Service Center (WNYNSC)], NYSERDA provides for radiation protection in accordance with NRC regulation 10 CFR Part 20: Standards for Protection Against Radiation and in keeping with the ALARA (As Low As Reasonably Achievable) philosophy.

(2) NYSERDA will implement a Retained Premises Radiation Protection Plan (RP-RPP500) to keep doses to workers and the public both ALARA, and in compliance with the 10 CFR Part 20 requirements for radiation protection.

(3) For activities performed within the Retained Premises, the requirements and procedures described in RP-RPP500 supersede and replace radiation protection program requirements described in the Final Safety Analysis Report (FSAR) referenced herein.

(4) RP-RPP500 and the associated procedures will be maintained in accordance with the requirements in 10 CFR Part 20, Subpart B, Radiation Protection Programs. Changes to RP-RPP500 or associated procedures will be documented, reviewed and approved by the licensee's Radiation Safety Committee prior to implementation.

(5) NYSERDA will review, revise as appropriate, and submit for NRC approval before implementation, an updated Radiation Protection Plan prior to assuming responsibility of any of the WVDP facilities or site areas (when the U.S.

Department of Energy returns oversight of the WVDP to NYSERDA).

Please let me know if this would be acceptable, and if you have any proposed edits that is fine too!

Since we have to have confirmation on the docket that the licensee accepts any license conditions being proposed, if you want to just wrap this discussion in with the information requested on 8/27 I (or Pam!) can have everything added to ADAMS and we will be set. Let me know if you have any comments or concerns in the meantimeI am still around until you get my out of office message Thanks and have a great weekend!

Marlayna 301.415.3178 Marlayna Vaaler Doell

~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Decommissioning Project Manager U.S. Nuclear Regulatory Commission NMSS/DUWP//RDB Phone: 301.415.3178 Mobile: 440.668.7399 Home: 605.348.2334 E-mail: marlayna.doell@nrc.gov Office Location: Fulltime Telework from Rapid City, South Dakota!

Mail Stop: T-5A10