ML21232A125
| ML21232A125 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 08/20/2021 |
| From: | Murray S Global Nuclear Fuel - Americas |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| M210102 | |
| Download: ML21232A125 (2) | |
Text
Global Nuclear Fuel Scott P. Murray Manager, Facility Licensing 3901 Castle Hayne Road P.O. Box 780 Wilmington, NC 28402 USA M210102 T (910) 819-5950 Scott.murray@ge.com August 20, 2021 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk
Subject:
Request to Extend the Date for Conducting the GNF-A Biennial Evaluated Emergency Exercise
References:
- 1) NRC License SNM-1097, Docket 70-1113
- 2) NRC Temporary Staff Guidance No. TSG-DFM-2020-01, Fuel Facility Requests for Regulatory Relief Related to COVID-19, 4/21/20
Dear Sir or Madam:
The Global Nuclear Fuel Americas (GNF-A) facility in Wilmington, NC hereby requests a onetime extension for conducting the 2021 Biennial Evaluated Emergency Exercise for the SNM-1097 license (Reference 1).
Pursuant to the GNF-A Radiological Contingency and Emergency Plan (RC&EP) Section 7.3, GNF-A will conduct at least one exercise every other year to simulate an on-site emergency condition that will require participation by the site Emergency Organization (EO) and a number of off-site support agencies. The last GNF-A biennial evaluated exercise was conducted in October 2019. The purpose of this correspondence is to request a onetime extension for conducting the 2021 evaluated exercise. If this request is granted and contingent on how COVID-19 continues to affect the local community, GNF-A plans to conduct the exercise on or before June 30, 2022.
The exercise scenario requires participation by a designated on-site controller/evaluator (C/E) team, the on-site security organization, the on-site emergency response organization (ERO) and other site personnel. The exercise is evaluated by the designated C/E team and NRC Staff. Offsite agencies that agreed to participate prior to the surge of highly transmissible COVID-19 Delta variant would further increase the population of personnel in the Emergency Control Center (ECC).
This will result in a large group of individuals together in the site emergency response center that could challenge several COVID-19-related isolation guidelines (e.g., social distancing and group size limitations).
The reason for requesting this exemption is because COVID-19 related changing local conditions prevent GNF-A from safely conducting the biennial exercise as planned. In late July 2021, New Hanover County (where GNF-A is located) reported a concerning resurgence in new positive COVID-19 tests. The county provided an update on August 19 that there have been continued increases in new COVID-19 cases in the local area due to the highly contagious Delta variant, with weekly case counts more than quadrupling in the past four weeks. In the past three weeks alone, the county reported 1,658 new positive COVID-19 cases continuing the countywide trend of increased viral spread. The county also asked for everyones help to prevent this trend from
M210102 8/20/21 Page 2 of 2 continuing. Recently CDC, North Carolina, New Hanover County, and the GNF-A facility reinstated several COVID-19 protective measures for individuals regardless of vaccination status.
Because of the rising positive COVID-19 cases in the local area and the increased number of personnel involved in an evaluated exercise versus a response to a real event GNF-A concludes that an evaluated exercise cannot be conducted as scheduled in October without unnecessarily increasing the risk of exposing GNF-A staff, off-site responders, and potentially members of the public to the COVID-19 virus. Approval of this temporary exemption request will continue to support facility workplace protocols necessary to protect essential site personnel. GNF-A will continue to perform other periodic emergency drills, training and surveillances that allow personnel to stay within COVID-19 protocols and maintain emergency response proficiency. 1 NRC regulation 10 CFR 70.17, "Specific Exemptions," allows the NRC, upon application of any interested person or upon its own initiative, to grant such exemptions from the requirements of Part 70 as it determines are authorized by law and will not endanger life or property or the common defense and security and are otherwise in the public interest. The subject requirements in GNF-A's RC&EP concern the schedule for conducting an evaluated exercise. NRC regulations specifically provide for exemptions in certain circumstances, and no other statutory provision would prevent the issuance of a temporary exemption from the prescribed date.
There is no undue risk to public health and safety from granting the requested temporary exemption. The exemption is otherwise in the public interest because it will minimize the risk of exposure to the COVID-19 virus. The requested exemption also does not decrease the effectiveness of the RC&EP, nor involve changes to security at the facility. Therefore, there is no impact on common defense and security from granting the requested temporary exemption.
Pursuant to 10 CFR 51.22(b), no environmental assessment or environmental impact statement need be prepared in connection with the approval of this request. The request is categorically excluded under 10 CFR 51.22 (c)(25)(vi)(G), and there are no extraordinary circumstances present that would preclude reliance on this exclusion. Approval of the requested exemption involves no significant hazards consideration; no significant change in the types or significant increase in the amounts of any effluents that may be released offsite; no significant increase in individual or cumulative public or occupational radiation exposure; no significant construction impact; and no significant increase in the potential for or consequences from radiological accidents. As such, there are no extraordinary circumstances present that would preclude reliance on this categorical exclusion.
We appreciate NRC's consideration of this request. Please feel free to contact me at (910) 819-5950 if you have any questions or would like to discuss this matter further.
Sincerely, geay.e!!l~
Facility Licensing r Cc: J. Rowley, NRC/DFM/FFLB M. Ruffin, NRC/RII/DFFI SPM 21-021