ML19357A071
| ML19357A071 | |
| Person / Time | |
|---|---|
| Site: | Erwin, 07001113, BWX Technologies |
| Issue date: | 01/02/2020 |
| From: | Kevin Ramsey NRC/NMSS/DFM/FFLB |
| To: | Jacob Zimmerman NRC/NMSS/DFM/FFLB |
| Ramsey K | |
| Shared Package | |
| ML19357A039 | List: |
| References | |
| Download: ML19357A071 (2) | |
Text
SUMMARY
OF PUBLIC MEETING TO DISCUSS FUEL FACILITY EXEMPTION REQUESTS DATE AND TIME: December 10, 2019, 01:00 PM to 02:00 PM LOCATION: NRC Two White Flint North, Room 7D30 11545 Rockville Pike Rockville, MD PURPOSE:
The purpose of this meeting was to discuss Nuclear Regulatory Commission (NRC) concerns with requests for an exemption from the reporting requirement for unplanned contamination events and alternatives the NRC would consider.
BACKGROUND:
The applications are available in the Agencywide Document Access and Management System (ADAMS). ADAMS is accessible at http://www.nrc.gov/reading-rm/adams.html. The Global Nuclear Fuel-Americas application was submitted by letter dated January 9, 2019 (ADAMS Accession No. ML19009A271). The BWX Technologies application was submitted by letter dated April 24, 2019 (ADAMS Accession No. ML19120A285). The Nuclear Fuel Services application was submitted by letter dated May 15, 2019 (ADAMS Accession No. ML19154A368).
DISCUSSION:
The reporting requirement is in Title 10 of the Code of Federal Regulations, Paragraph 70.50(b)(1). The applications request that the licensee be exempted from reporting any unplanned contamination events inside an established contamination controlled area. The NRC staff discussed several concerns including the following:
- 1. If no unplanned contamination events in the areas were reported, the NRC would lose an opportunity to promptly evaluate whether the event and the extent of condition was understood.
- 2. The exemption requests are inconsistent with a previous finding that the reports are necessary to ensure contaminated areas are being decontaminated in a safe and timely manner. The finding is documented in a letter dated October 5, 2018 (ADAMS Accession No. ML18236A321).
- 3. The burden of reporting (considered low) may not justify the risk of missing a significant event (potentially high).
The NRC staff stated that it was open to an alternative where additional controls in these areas could be imposed for a longer period of time. However, if the additional controls were still required at the end of the extended time period, a report would be required.
Licensees responded that they did not see a need to report any unplanned contamination events in areas controlled for contamination. They discussed several reasons for this position including the following:
- 1. The licensees have an Integrated Safety Analysis which identifies significant accident scenarios and none of the scenarios are driven by contamination levels.
- 2. Unplanned contamination events inside controlled areas pose almost no risk.
Enclosure 1
- 3. Reactors do not have a similar requirement.Fuel facilities differ significantly from other materials licensees.
- 4. Some facilities have a Resident Inspector who can evaluate every event.
- 5. These events are entered into the licensees corrective action program which inspectors review routinely.
RESULTS:
No specific actions were identified at this meeting. All parties agreed to consider the feedback received. The NRC staff stated that it would issue a meeting summary.
ATTACHMENTS:
- 1. The agenda is part of the meeting notice which is available at ADAMS Accession No. ML19336A024.
- 2. The meeting slides are available at ADAMS Accession No. ML19336B300.
Docket: 07000027 License: SNM-42 07000143 SNM-124 07001113 SNM-1097 2