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
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.
Nuclear Regulatory Commission
- March 16th, 2011 – The NRC Thought The Best Response After Fukushima Was to Verify What Licensees Were Already Required To Do (enformable.com)
- March 17th, 2011 – What you ask for, isn’t always what you get – How the NRC internally communicates about the Freedom of Information Act (enformable.com)
- Intern at Rhode Island Nuclear Science Center Receives Unplanned 2-3 REM Dose In 5 Minutes – NRC Launches Special Inspection (enformable.com)
- March 17th, 2011 – Draft EDO Update – Concern about SFP at Fukushima Daiichi – 50 Mile Evacuation (enformable.com)
- March 11th, 2011 – Radioactive Steam Could Be Released From Fukushima Daiichi After NRC Knew Temperature in Reactor 1 Fuel Rods Up 50% Above Normal Levels (enformable.com)
- NRC Response to Events at Fukushima Reactor Site, Japan – As of March 24, 2011 (enformable.com)
- Palisades Nuclear Plant Venting Radioactive Steam After Leaks Discovered in Cooling System (enformable.com)
- March 13th 2011 – Detailed Report of Plant Status At Fukushima Daini As of 2:00 AM March 14th JST (enformable.com)
- March 15th, 2011 – DORL Looking at licensing actions with sensitivity to potential considerations from the ‘Japanese situation’ (enformable.com)
- November 1, 2011 Category 1 public meeting – NRC’s restart review and inspection of North Anna Nuclear Power Station following the earthquake of August 23, 2011 (enformable.com)
- March 11th, 2011 – Premonitions of North Anna EQ – Why does the NRC have confidence that an eq greater than DB cannot occur in the US (enformable.com)
- March 14th, 2011 – Indications of Breach of Containment at Reactor 2 (enformable.com)
- March 14th, 2011 – What to do with respect to Potassium Iodide for those going to Japan? (enformable.com)
- March 14th, 2011 – NRC Radiological Health Physics and Plume Modeling Expert Worked at Fukushima in the 1980s (enformable.com)
- March 14th, 2011 – Japan Requested US Supply 6 BWR 3 & 4 Experts to Assist in ‘Hour of Need’ at 2 different EOC locations (enformable.com)