ML19336B300

Slides for December 10 Public Meeting on Exemption Requests (L-2019-LLA-0114)

ML19336B300
Person / Time
Issue date:	12/10/2019
From:	Office of Nuclear Material Safety and Safeguards
To:
Ramsey K
References
Download: ML19336B300 (10)

Text

Public Meeting on Requests for Exemption from a Reporting Requirement December 10, 2019 1

Agenda

• Introductions - NRC

• Discussion of Exemption Requests - NRC, BWXT, NFS, GNFA

• Comments and Questions - Everyone

• Closing Remarks - NRC

• Adjourn Meeting 2

2

Objectives

• Discuss NRC feedback on the requests

• Review a possible alternative approach

• Obtain stakeholder input

• Answer questions 3

3

Background

Three applications were received for exemption from the reporting requirement for unplanned contamination events in 10 CFR 70.50(b)(1):

• GNFA application dated 1/9/2019 (ADAMS Accession no. ML19009A271)

• BWXT application dated 4/24/2019 (ADAMS Accession no. ML19120A285)

• NFS application dated 5/15/2019 (ADAMS Accession no. ML19154A368) 4 4

Background

The requirement in 10 CFR 70.50 states -

• (b) Each licensee shall notify the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after the discovery of any of the following events involving licensed material:

• (1) An unplanned contamination event that:

• (i) Requires access to the contaminated area, by workers or the public, to be restricted for more than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> by imposing additional radiological controls or by prohibiting entry into the area;

• (ii) Involves a quantity of material greater than five times the lowest annual limit on intake specified in Appendix B of §§ 20.1001-20.2401 of 10 CFR part 20 for the material; and

• (iii) Has access to the area restricted for a reason other than to allow isotopes with a half-life of less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to decay prior to decontamination.

5 5

Proposed License Condition The licensee is exempt from reporting unplanned contamination events inside an established contamination controlled area. The licensee commits to the following:

1. Post contamination controlled areas that are inaccessible to the public.

2. Impose controls to keep exposures and releases ALARA.

3. Ensure radiation protection personnel are readily available.

4. Provide equipment and facilities for contamination control.

5. Perform surveys and provide records upon request.

6. Train unescorted workers on methods to reduce exposures and respond to upset conditions.

6 6

NRC Feedback

1. Lost opportunity to promptly evaluate whether the event and the extent of condition is understood.

2. Inconsistent with previous finding that reports are necessary to ensure contaminated areas are being decontaminated in a safe and timely manner.

3. Burden of reporting (considered low) may not justify risk of missing a significant event (potentially high).

4. It may be difficult to identify event records mixed with large volume of routine contamination surveys.

5. The NRC would lose some operational data.

7 7

Alternative Approach We are open to an alternative which addresses NRC concerns listed on Slide 7.

• Event occurs in contam controlled area.

• Release has been stopped.

• No contam spread outside area.

• Additional controls imposed for longer time period before reporting.

• Basis for finding that alternative is in the public interest.

8 8

Next Steps

1. Licensees decide how they wish to proceed.

a. Commitment to alternative reporting requirement would be processed as separate license amendment action.

b. Amendment would have opportunity to request a hearing.

2. NRC prepares meeting summary.

9 9

Comments and Questions 10 10