ML20162A039
| ML20162A039 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 06/04/2020 |
| From: | Spangler D BWXT |
| To: | James Downs, Kevin Ramsey NRC/NMSS/DFM/FFLB |
| Downs J | |
| References | |
| EPID L-2019-LLA-0103 | |
| Download: ML20162A039 (4) | |
Text
From: Spangler, David L To: Downs, James; Ramsey, Kevin Cc: Yates, Julian R; Subosits, Stephen G; Terry, Chris T
Subject:
[External_Sender] RE: RE: RE: RE: BWXT NOG-L Response to Request for Additional Information - 70.50(b)(1)
Exemption Date: Thursday, June 04, 2020 11:33:39 AM
- James, Thank you and the team for working on this. We appreciate it very much. The wording is acceptable with one clarification. Thank you for considering a minor edit in item (a). I will explain.
We have Restricted Areas within buildings, but not all are surrounded by fence. Take for example, Building B at LTC. The doors are locked and access is controlled into the building. The fence connects to the east and west ends but does not surround it. It is also locked at the gates. The fence envelopes some radwaste storage and a couple of smaller restricted area buildings.
The second part of (a) is perfect in that access to the entire site is restricted at the road way by security (Owner Controlled Area) of SNM-42. Visitors to the site are controlled and processed through ACF (Access Control Facility). Security makes routine rounds assuring no public has come into the OCA. I think by adding or to the statement it could allow for the different types of construction utilized to achieve Restricted Areas. Or alternately we could strike in a building surrounded by a fence since b) really covers the essence of a Restricted Area (ie one where we plan for contamination before the event and no contamination is outside the Restricted Area)
Let me know what you and Kevin think.
Dave Spangler Nuclear Safety and Licensing Manager BWXT, NOG-Lynchburg 1570 Mt Athos Road Lynchburg, Va. 24504
( 434.522.5413 lFax: 434.522.5570 l Cell: 434-665-3472
- dlspangler@bwxt.com From: Downs, James <James.Downs@nrc.gov>
Sent: Thursday, June 4, 2020 10:25 AM To: Terry, Chris T <ctterry@bwxt.com>
Cc: Spangler, David L <dlspangler@bwxt.com>; Yates, Julian R <jryates@bwxt.com>; Subosits, Stephen G <sgsubosits@bwxt.com>; Ramsey, Kevin <Kevin.Ramsey@nrc.gov>
Subject:
EXTERNAL: RE: RE: RE: BWXT NOG-L Response to Request for Additional Information -
70.50(b)(1) Exemption
- Chris, Weve drafted the SNM-42 license amendment to grant the exemption to 70.50(b)(1).
Based on NMSS management feedback, the license condition is slightly different than what was requested. The draft condition reads:
Notwithstanding the requirements of 10 CFR 70.50(b)(1), the licensee is exempted from the requirement to report unplanned contamination events when the following conditions are met:
(a) The event occurs in a restricted area in a building or surrounded by a fenced area which is maintained inaccessible to the public by multiple access controls; (b) The area was controlled for contamination before the event occurred, the release of radioactive material is under control, and no contamination has spread outside the area; (c) Radiation safety personnel trained in contamination control are readily available; (d) Equipment and facilities that may be needed for contamination control are readily available; and (e) The otherwise reportable unplanned contamination event is documented in the licensees Corrective Action Program.
Please confirm that NOG-L has no objection to the draft language.
- Thanks, James From: Downs, James Sent: Thursday, May 07, 2020 10:55 AM To: Terry, Chris T <ctterry@bwxt.com>
Cc: Spangler, David L <dlspangler@bwxt.com>; Yates, Julian R <jryates@bwxt.com>; Subosits, Stephen G <sgsubosits@bwxt.com>; Ramsey, Kevin <Kevin.Ramsey@nrc.gov>
Subject:
RE: RE: RE: BWXT NOG-L Response to Request for Additional Information - 70.50(b)(1)
Exemption
- Chris, Lets try for next week. If NMSS management has feedback on the GNFA response/path forward, it would more efficient if we are able to discuss all the relevant information.
How does 1100 on Tuesday look?
-James From: Terry, Chris T <ctterry@bwxt.com>
Sent: Thursday, May 07, 2020 10:29 AM To: Downs, James <James.Downs@nrc.gov>
Cc: Spangler, David L <dlspangler@bwxt.com>; Yates, Julian R <jryates@bwxt.com>; Subosits, Stephen G <sgsubosits@bwxt.com>; Ramsey, Kevin <Kevin.Ramsey@nrc.gov>
Subject:
[External_Sender] RE: RE: BWXT NOG-L Response to Request for Additional Information -
70.50(b)(1) Exemption I think it is best if we talk about this on a conference call. It is hard to express the amount of work
that goes in to get stuff done to not have to report issues to the NRC. How does this afternoon work for you? Maybe around 3:00 today?
Christopher Terry Manager, Licensing & Safety Analysis BWXT NOG-L 434-522-5202 w 434-382-8595 c From: Downs, James <James.Downs@nrc.gov>
Sent: Wednesday, May 6, 2020 11:31 AM To: Terry, Chris T <ctterry@bwxt.com>
Cc: Ward, David C <dcward@bwxt.com>; Spangler, David L <dlspangler@bwxt.com>; Yates, Julian R
<jryates@bwxt.com>; Subosits, Stephen G <sgsubosits@bwxt.com>; Ramsey, Kevin
<Kevin.Ramsey@nrc.gov>
Subject:
EXTERNAL: RE: BWXT NOG-L Response to Request for Additional Information - 70.50(b)(1)
Exemption
- Chris, Where did the estimate of 16 unplanned contamination events per year come from? I was told that 1994 was the last time NOG-L reported an unplanned contamination event.
Its understandable to have some cost associated with the timely evaluation of events that could potentially meet the threshold for reporting, but wouldnt that be closer to the $8,800 figure provided in the RAI response? It might even be less than $8,800 since that figure includes reporting of an unplanned contamination event including the time to develop the event report write-up, but Im not clear on the internal process that NOG-L follows for these sorts of things.
Is in-depth investigation, provide management review and briefings, identify corrective actions and issue the 30-day follow-up report are estimated at 398 person-hours or approximately $60,500 per event report performed for unplanned contamination events that are not reportable to the NRC?
This week, the NRC staff is briefing NMSS management on the GNFA responses to the RAIs on its similar exemption request. Ill keep you updated on relevant feedback we receive.
-James From: Subosits, Stephen G <sgsubosits@bwxt.com>
Sent: Wednesday, May 06, 2020 10:07 AM To: Downs, James <James.Downs@nrc.gov>
Cc: Ward, David C <dcward@bwxt.com>; Spangler, David L <dlspangler@bwxt.com>; Terry, Chris T
<ctterry@bwxt.com>; Yates, Julian R <jryates@bwxt.com>
Subject:
[External_Sender] BWXT NOG-L Response to Request for Additional Information - 70.50(b)
(1) Exemption
- James, Please see the attached file for our response to the March 12, 2020 Request for Additional Information - Exemption Request from 24-hour Reporting Requirement. A paper copy is being mailed to NRC HQ.
Steve Subosits Engineer, Licensing and Safety Analysis BWXT NOG-Lynchburg Phone: 434-522-5170
This message is intended only for the individual or entity to which it is addressed and contains information that is proprietary to BWX Technologies, Inc and/or its affiliates, or may be otherwise confidential. If the reader of this message is not the intended recipient, or the employee agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-mail and delete this message from your computer. Thank you.
This message is intended only for the individual or entity to which it is addressed and contains information that is proprietary to BWX Technologies, Inc and/or its affiliates, or may be otherwise confidential. If the reader of this message is not the intended recipient, or the employee agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-mail and delete this message from your computer. Thank you.
This message is intended only for the individual or entity to which it is addressed and contains information that is proprietary to BWX Technologies, Inc and/or its affiliates, or may be otherwise confidential. If the reader of this message is not the intended recipient, or the employee agent responsible for delivering the message to the intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify the sender immediately by return e-mail and delete this message from your computer. Thank you.