ML20035F923
| ML20035F923 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 03/23/1993 |
| From: | Knapp K FRAMATOME COGEMA FUELS (FORMERLY B&W FUEL CO.) |
| To: | Adensam E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9304230067 | |
| Download: ML20035F923 (2) | |
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BSi4f FUEL COMPANY ON An American Company with Worldwide Resources PD. Box 11646 Lynchburg. VA 24506-1646 7elephone: 804-522-6000 March 23, 1993 Ms. Elinor G. Adensam, Acting Chief Licensing Branch Division of Fuel Cycle Safety and Safeguards, NMSS Nuclear Regulatory Commission Washington, D.C.
20555
REFERENCE:
SNM-1168 License, Docket 70-1201
Dear Ms. A*..nsam:
Condition 17 of B&W Fuel Company's (BWFC) SNM License required us to evaluate our license against the Branch Technical Positions (BTP) and propose license conditions for compliance.
BWFC initial correspondence addressing this issue was submitted to NRC on March 16, 1992.
NRC requested additional information regarding our March 16 submittal on September 23, 1992.
Specifically under Item I:
Manacement Controls, Part B of the NRC correspondence, NRC requested "In Part I, the licensee should commit to conducting a safety analysis of the facility's operations to identify potential hazards, operational parameters, and specifications for these parameters.
Based on the safety analysis results, establish and document the basis for Requirements for Operation."
BWFC response provided in the November 4, 1992 correspondence stated "BWFC does not recognize the need for a safety analysis to be conducted for operations at the CNFP."
This response was based on BWFC's premise that the contents of a integrated safety analysis as described in the BTP's were directed for operations that involve special nuclear material (SNM) in solutions and chemical processes.
Dry, mechanical operations such as those conducted at the CNFP did not seem to be taken in consideration for the integrated safety analysis.
Consequently, BWFC did not see the applicability or benefit of performing such an analysis, f
l-220005 p(( yI 0 9304230067 930323 PDR ADOCK 07001201 C
i Sev'eral discussions and meetings between BWFC and NRC have since taken place.
A mutual understanding emerged from these discussions that our analysis would be appreciably different from other fuel cycle facility licensees due to the_ contrast in operations.,With this acknowledgment, BWFC will commit'to performing:the' safety' analysis by" Marc 6'31, 1995.l l
If you should have any questions regarding this matter, please feel free to call me at (804) 522-6202.
Sincerely, B&W FUEL COMPANY l
COMMERCIAL NUCLEAR FUEL PLANT bMV%w b kfp Kathryn S.
Knapp Manager, Safety & Licensing cc:
C. W. Carr h M l
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