ML22251A240
| ML22251A240 | |
| Person / Time | |
|---|---|
| Issue date: | 08/23/2024 |
| From: | Kevin Williams NRC/NMSS/DMSST |
| To: | Office of Nuclear Material Safety and Safeguards, NRC Region 1, NRC/RGN-II, NRC/RGN-III, NRC Region 4, State of CT, State of IN, State of WV, State, Agreement States |
| Fisher J | |
| Shared Package | |
| ML22251A239:ML22251A239 | List: |
| References | |
| STC-24-035 | |
| Download: ML22251A240 (3) | |
Text
ALL AGREEMENT STATES CONNECTICUT, INDIANA, WEST VIRGINIA NRC NMSS, NRC REGIONS I, III, AND IV AVAILABILITY OF REVISIONS TO PROCEDURE SA-300 AND THE HANDBOOK ON NUCLEAR MATERIAL EVENT REPORTING FOR THE AGREEMENT STATES (STC-24-035):
Purpose:
The Office of Nuclear Material Safety and Safeguards (NMSS) has completed its revision of the State Agreements (SA)-300 procedure, Reporting Material Events, and the Handbook on Nuclear Material Event Reporting for the Agreement States. These documents and the Resolution of External Comments chart can be obtained from the Agencywide Documents Access and Management System (ADAMS) at https://www.nrc.gov/reading-rm/adams.html. The ADAMS Package Accession No. is ML22251A239.
The NRC will provide another 45-day period in which errors can be identified, as the handbook underwent significant revision to address the comments received. New sections were added to the handbook to address identified gaps. Please provide comments on any identified discrepancies.1 If no comments are received, then the SA-300 handbook will be marked as final at the end of the 45-day period. Comments should be submitted by October 7, 2024.
No comments were received on the SA-300 procedure, Reporting Material Events, and only administrative changes were made.
The SA-300 procedure and associated handbook can also be found on the NRCs public website, titled NMSS State Agreement (SA) Procedures; https://www.nrc.gov/reading-rm/doc-collections/nmss-procedures/state-agreement.html.
Discussion: On August 3, 2022, the interim procedure SA-300, Reporting Material Events (ML21165A163), and the Interim Handbook on Nuclear Material Event Reporting for the Agreement States ( ML21165A162) were issued, along with the STC-22-033 letter (ML22035A083). The interim procedure and interim handbook were approved for interim use and a six month comment period was initiated. NRC staff presented changes on the interim procedure and interim handbook at the Annual Meeting of the Organization of Agreement States on August 15, 2022.
1 This information request has been approved by Office of Management and Budget (OMB) approval number 3150-0029, which expires 1/31/2025. The estimated burden per response to comply with this voluntary collection is approximately 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Send comments regarding the burden estimate to the FOIA, Library, and Information Collections Branch, U.S. Nuclear Regulatory Commission, Washington, DC 20555- 0001, or by e-mail to infocollects.resource@nrc.gov, and to OMB Office of Information and Regulatory Affairs (3150- 0029), Attn: Desk Officer for the Nuclear Regulatory Commission, 725 17th Street, NW Washington, DC 20503. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
August 23, 2024 STC-24-035 2
In response to the STC-22-033 letter, multiple stakeholders submitted comments or questions to make improvements to the handbook. A letter from the Texas Department of State Health Services, dated October 4, 2022 (ML22279B060) and a letter from the Organization of Agreement States, dated February 3, 2023 (ML23059A432) were included in the review as well as emails from Agreement State staff in Arkansas, California, and Texas.
NRC staff supported a Government to Government meeting on November 15, 2022, in which changes to the interim handbook were discussed with Agreement State staff. NRC staff captured comments from the Agreement State staff as discussion occurred on timeliness requirements, jurisdiction, follow-up reports, and units. The Agreement State staff also asked for examples to be added into the handbook. These comments were included in the Resolution of External Comments chart (ML22035A082) and the corrections were incorporated into the handbook.
On November 28, 2022, the STC-22-065 Letter, Availability of the Revised Interim Handbook on the Nuclear Material Event Reporting for the Agreement States (ML22266A092), and the revised interim SA-300 Handbook (ML22266A091) were issued to correct reporting requirement errors that existed within Appendix A, NRC Reporting Requirements, of the interim handbook.
The corrections included in the revised interim SA-300 Handbook as redline strikeout were included in this updated handbook.
The Office of the Inspector General (OIG) Audit of the U.S. Nuclear Regulatory Commissions Oversight of Irretrievable Well Logging Source Abandonments (OIG-23-A-04), dated May 4, 2023, contained five recommendations for the NRC to improve their processes. Only Recommendation 2.1 of the audit impacts this handbook. This recommendation promotes consistency in documenting well logging source abandonment notifications and licensee reports received. To address the record retention deficiencies identified in the audit, the section, Irretrievable Well Logging Sources, was added.
Significant Changes or New Sections:
- 1) When the compatible Agreement State regulations specify immediate and as soon as possible (ASAP) reporting, the NRC accepts Agreement State reporting within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of the receipt of the event report.
- 2) A new section titled Jurisdiction was added. The Agreement States asked for clarification on which Agreement State should report events when incidents are impacting multiple Agreement States.
- 3) A new paragraph was included to detail how reports of suspicious activity occurring at or around facilities are handled. When the NRC Headquarters Operation Center (HOC) receive these reports, the HOC generates a Security Information Database (SID) report.
These are reviewed by Office of Nuclear Security and Incident Response (NSIR) staff who act, as needed.
- 4) The terms NMED report and written report are no longer used interchangeably in the handbook. Compatible Agreement State regulations require licensees to submit written reports and, in some cases, provide specific topics that should be included in these STC-24-035 3
reports. When the Agreement State receives these reports from the licensee, they should be added to the NMED record.
- 5) The section titled Units was removed. Agreement States are encouraged to include both conventional and SI units in their NMED reports. The guidance in the interim handbook had included a should (not a shall). This guidance was not a requirement, and it was removed from the handbook. An NMED report with either conventional or SI units is adequate, so long as it can be understood.
- 6) Detail was removed from the section titled Follow-up Written Reports. The SA-300 Handbook Appendix C, Minimum Required Event Information, contains the type of information that should be communicated by follow-up NMED reports to complete the NMED record.
- 7) A new section was added titled Reporting Transportation Events. The reporting regulation associated with the U.S. Department of Transportation (DOT) is still required, however was removed from the SA-300 Handbook Appendix A. The reporting regulation is unique as reports are made to the National Response Center. By moving this content into the body of the handbook, the coordination associated with these reporting requirements could be further explained. Examples of transportation event reports were added to clarify the reporting thresholds.
- 8) The section Voluntary Reports and Non-Reportable Reports was transitioned to Reportability Threshold. The previous section title was confusing since new records of voluntary reporting are no longer supported in NMED. On April 1, 2019, NMED ceased capturing non-reportable events. This change was a result of budgetary constraints.
Since the reportability threshold is necessary to determine whether NMED will retain records, additional subsections were added to clarify certain regulations.
- A section titled Leaking Sealed Sources was added. NMED tracks all sealed sources with leak test results of 185 Bq (0.005 µCi) or more.
- A section titled Scrap Metal Recycling Facilities and Incinerator Facilities was added to consider nuclear material identified at unlicensed facilities.
- A section titled Industrial Radiography was added to ensure that both 10 CFR 34.101(a) and 10 CFR 30.50(b)(2) are considered.
- A section titled Fixed Gauge with Shutter Failure was added to assist the Agreement State in the identification of the reporting requirements, which depends on the type of license issued to the fixed gauge user.
- 9) A new section titled Agency Action Review Meeting (AARM) was added. The NRC has the lead for the discussion on Agreement State licensees, however the NRC will contact the Agreement State to discuss their participation in the AARM process, as needed.
10)Clarification was provided in SA-300 Handbook Appendix A, NRC Reporting Requirements, that the tables do not include reporting requirements from 10 CFR Part 21, Reporting of Defects and Noncompliances. This is because licensees regulated by an Agreement State are not required to comply with this regulation.
STC-24-035 4 If you have any questions regarding this correspondence, please contact me at (301) 415-3340, or the individual listed below:
POINT OF CONTACT: Jennifer Fisher E-MAIL: Jennifer.Fisher@nrc.gov TELEPHONE: (301) 415-1456 Kevin Williams, Director Division of Materials Safety, Security, State, and Tribal Programs Office of Nuclear Material Safety and Safeguards Signed by Williams, Kevin on 08/23/24
- via email OFFICE NMSS/MSST NMSS/MSST/MSEB NMSS/MSST/SMPB* NMSS/MSST
/MSEB
- NAME JFisher JFCEinberg CE AGiantelli AG KWilliams KW DATE Jun 11, 2024 Jun 24, 2024 Jun 26, 2024 Aug 23, 2024