ML20265A301

Framatome'S Response to a Request for Additional Information Dated September 14, 2020

ML20265A301
Person / Time
Site:	Framatome ANP Richland
Issue date:	09/21/2020
From:	Travis Tate Framatome
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
TJT:20:022
Download: ML20265A301 (4)

Text

framatome September 21, 2020 TJT:20:022 U.S. Nuclear Regulatory Commission Attn: Document Control Desk (03-H8)

One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738

Subject:

Framatome's Response to a Request for Additional Information Dated September 14, 2020

Reference:

1) Framatome Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1) dated August 3, 2020.

2) NRC Request for Additional Information Dated September 14, 2020.

3) Letter N. Ashkeboussi (NEI) to A. Szabo (NRC), "Industry Comments on the Information Collection for Domestic Licensing of Special Nuclear Material",

10/27/17.

4) Federal Register Notice, Vol. 56, No. 93, Page 19890, "Proposed Rules,"

dated May 14, 1990.

Dear Mr. Siurano-Perez:

Framatome Inc. is providing the attached response with the additional information that you requested on September 14, 2020 (Reference 2).

The attached Framatome reporting estimates are consistent with those previously provided by the Nuclear Energy Institute (NEI on behalf of its fuel cycle facility members (Reference 3).

If you have any information concerning this information, please contact me at 509 375-8550.

Sincerely, T. J. Tate, Manager Environmental, Health, Safety & Licensing TJT c: Damaris Marcano, USNRC NMSS R. Gibson, USNRC RII Framatome Inc .

2101 Horn Rapids Road Richland, WA 99354 fol: (509) 375-8100 www.fra matome.com 2270'JWA-8 (01/1212018)

US NRC T JT:20:022 September 21, 2020 Page 2 be: CD Manning 22709WA-8 (01/1212018)

US NRG TJT:20:022 September 21, 2020 Page 3 Attachment Framatome Inc. Response to NRG Request for Additional Information

RAI 1

Granting the requested exemption would require the NRG to make determinations in accordance with 10 CFR 70.17 which include, in part, finding that the exemption is in the public interest. Your application states the exemption would allow resources to be focused on other activities of higher significance or consequence. However, no data was provided to quantify the resources saved.

Response to RAI 1 Framatome takes its reporting responsibilities very seriously and commits a significant amount of time and resources to the evaluation and preparation of event reports to the NRG Operations Center. The time spent preparing the initial evaluation per 10 CFR70.50(b )( 1),

the resources required for the necessary initial event notification and follow-up reports is demanding in nature and substantial in resources and averages $68,000/event.

Assuming one such event per quarter, the total labor cost of such reporting is $272,000/year.

Granting the exemption would reduce the level of transparency to the public of unplanned contamination events. An estimate of the resources saved is needed to make a finding that a reduced level of transparency is justified. The resource estimate should be limited to costs incurred by reporting the event. Costs associated with investigations and corrective actions that would be performed even if no report was made should be excluded from the estimate.

Response to RAI 2 Framatome believes that granting this exemption request does not reduce the level of transparency to the public of unplanned contamination events. The NRG inspects Framatome an average of 6 or 7 times each year. The inspectors have full access to the Framatome Corrective Action Program where such events are documented and inspectors review the items in the corrective action program during each of their inspections. The NRC's inspections include a specific inspection of the facility's radiological program at least one time each year. The results of these inspections are documented in quarterly inspection reports and are publicly available in the Agency Document Administration and Management System (ADAMS).

Additionally, Reference 3 states: 'The intent of these amendments is to require prompt notification (either immediately or within 24-hours) to the NRG of events that would require prompt action by the NRG to protect public health and safety of the environment." The specific events, as noted in Framatome's exemption request (Reference 1), are located in an RCA and pose no public health and safety or environmental risk.

Finally, it should be noted that the nuclear power reactors, research and test reactors, and site-specific and standalone independent spent fuel storage installations are not subject to similar reporting requirements for unplanned contamination events.

227VJWA3J (0111212018)

US NRG TJT:20:022 September 21, 2020 Page4 Framatome believes this request to grant an exemption from the 10 CFR 70.50(b)(1) reporting requirement is consistent with the NRC's Principles of Good Regulation and is in the public interest as it provides clarity, reliability, and consistency with the regulatory reporting requirements of licensees with comparable Radiological Protection programs.

Furthermore, it allows limited resources to remain focused on activities of higher safety significance at Framatome.

2270'.JVVA-8 (01/12/2018)