ML20085F884

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SNM-42 - Relief Request from Force on Force Regulatory Requirements Due to COVID-19
ML20085F884
Person / Time
Site: BWX Technologies
Issue date: 03/19/2020
From: Burch B
BWXT
To: Andrea Kock
Office of Nuclear Material Safety and Safeguards
Downs J
References
20-023
Download: ML20085F884 (2)


Text

March 19, 2020 20-023 Ms. Andrea Kock OFFICIAL USE ONLY Director, Division of Fuel Managernent Office of Nuclear Materials Safety and Safeguards U.S Nuclear Regulatory Commission Washington D.C. 20555-001

Reference:

License No. SNM-42, Docket 70-27 Subject Request for Regulatory Relief from 10 CFR 73.46(b)(9)-COVID-19 Pandemic

Response

Dear Ms. Koek:

In response to the COVID-19 pandemic, BWXT Nuclear Operations Group - Lynchburg, Inc.

(BWXT NOG-L) has implemented social distancing and assembly restrictions to conform to: The President's Coronavirus Guidelines for America, CDC Interim Guidance for Businesses and Employers, OSHA 3990-03 2020 Guidance on Preparing Workplaces forCOVID-19, and Virginia Department of Health Interim Guidance: Considerations for Busrness and Employers, Coronavirus Disease 2019 (COVl[)..19}. Based on the guidance provided by these Federal and State Government agencies, BWXT NOG-L considers the request to be necessary, prudent and justified.

BWXT NOG-L seeks relief from the following requirements identified in 1 O CFR, Part 73.46(b)(9);

~subsequently, during each 12-month period commencing on the anniversary of the date specified in paragraph {i)(2)(ii} of this section, an exercise must be carried out at least every four months for each shift" "During each of the 12-rnonth periods, the NRC shall observe one of the force-on-force exercises which demonstrates overall security system performance. The licensee shall notify the NRC of the scheduled exercise 60 days prior to that exercise. u NOG-L specifically requests,regulatory relief from timeframes imposed in 1 o CFR, Part 73.46(b}(9). \\n response to revised guidance from Federal and/or State Government agencies, BWXT NOG-L will resume normal operations and reschedule all missed force on force exercises. BWXT NOG-L will communicate with the NRC to reschedule the annual observed exercise on a mutually agreeable date.

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OFFICIAL USE ONLY If you have questions or require additional information, please contact Chris Terry, Manager of Licensing and Safety Analysis, at ctterry@bwxt.com, or 434-522-5202.

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B. Joel Burch Vice President and General Manager BWXT Nuclear Operations Group, Inc. - Lynchburg cc:

NRC/NSIR, Shana Helton, Division Director NRC, James Downs, Senior Project Manager NRC, Region 11 NRC, Resident Inspector NRLFO OFFICIAL USE ONLY Fn,*~... " ~""'" *tr,1* :*; e,,f*

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