March 23, 2011 – NRC Members Clarify Old Emails Which May Contain Nuances That Might Not Be Obvious

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From: Conatser, Richard•
Sent: Wednesday, March 23, 2011 8:26 AM
To: Werner, Greg; Henderson, Pamela; Dickson, Billy; Bonser, Brian
Cc: Garry, Steven; Pedersen, Roger; Jimenez, Manuel; Clemons-Webb, Candace; Shoop, Undine
Subject: RE: REMP Reporting Levels and Fukushima

All,
I just wanted to send a follow up email to clarify a particular nuance in the email below that may not be obvious on a casual reading. The licensee is only required to report exceeding the REPORTING LEVELS in the Radiological Environmental Monitoring Program when the activity is due to effluents from their facility and it is averaged over a calendar quarter. This is why my original email says:

If a nuclide concentration exceeds the REPORTING LEVES (averaged over a calendar quarter), the licensee may be required to report the data to the NRC
within 30 days. The licensee should take the actions listed in their ODCM.

Because the 1-131 (and possibly other radionuclides) from Fukushima will elevate the “background,” it will reduce the licensee’s ability to differentiate releases from their site. Strong data evaluation and analyses are appropriate at all times, and are particularly applicable at this time.

Here is the nuance that may (or may not) be obvious on a casual reading. If the licensee knows that all the activity in a REMP sample is from the Fukushima facility, then a 30-day report is not required. If, however, the licensee is not able to discern whether the activity is from their facility or not, then they would need to follow their ODCM and take the appropriate actions, which may include a 30-day report to the NRC. Lastly, if the
activity is from their facility, then the licensee would be required to make a 30-day report to the NRC.

The key issues are summarized below:
1. licensees need to be aware of their REPORTING LEVELS in their ODCMs,
2. the licensee’s data evaluation is extremely important to discern plant-related activity from non-plant related activity,
3. licensees should not immediately assume all activity in REMP samples is from Fukushima,
4. licensees need to take the actions as outlined in their ODCMs (this is always true),
5. if a licensee is unable to make a determination whether the activity is plant-related or not, they may choose to make a 30-day Special Report as listed in their ODCM, and
6. if a licensee knows that all the activity is due to Fukushima, then a 30-day Special Report is not required (as listed in their ODCM).

You may wish to pass this along to the Inspectors in your Regions.

Best Regards,
Health Physicist
Nuclear Regulatory Commission
301-415-4039
[email protected]

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