ML22077A087

NFS Request to Revise SNM-124, Amendment 16, Condition SG-3.8

ML22077A087
Person / Time
Site:	Erwin
Issue date:	03/11/2022
From:	Knowles T Nuclear Fuel Services
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
21G-22-0036, ACF-22-0077, GOV-01-55-04
Download: ML22077A087 (4)

Text

I Nuclear Fuel Services, Inc.

Certified Mail 21 G-22-0036 Return Receipt Required GOV-01-55-04 ACF-22-0077 March 11, 2022 Director, Office of Nuclear Material Safety and Safeguards U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Attn: Document Control Desk

Reference:

Attachment - Complete Reference History

Subject:

NFS Request to Revise SNM-124, Amendment 16, Condition SG-3.8

Dear Sir:

By our letter dated October 14, 2021, Nuclear Fuel Services, Inc. (NFS) responded to the NRC Request for Supplemental Information on the NFS Request for Exemption from the NRG-Observed Force--0n-Force (FoF) exercise. (Reference 7)

As a result, by letter dated November 9, 2021, NRC issued Materials License SNM-124, Amendment 16, to add Condition SG-3.8 as follows (Reference 8):

Notwithstanding the requirements of 10 CFR 73.46(b)(9), the licensee is exempt from conducting force-on-force exercises through December 31, 2021; after that date, the licensee shall resume exercises at their regular frequency.

Furthermore, the licensee commits to communicating with the NRG to reschedule the annual observed exercise on a mutually agreeable date during the 1st Quarter of calendar year 2022.

The request for regulatory relief was directly related to the COVID-19 pandemic (Reference 4). Through~ut the pandemic, NFS has continuously monitored COVID-19 cases to determine impact to plant operations. Specifically, the spike in cases associated with the Omicron Variant began in late November 2021 *and continued until late February 2022. The second week of January 2022, NFS experienced the peak.

case load with more than 100 personnel in quarantine. As the Omicron Variant continued into the first quarter 2022, NFS maintained a general safety concern related *1_ C) to conducting FoF exercises. . ' ~;lo l

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1205 Banner Hill Rd, Erwm, TN 37650 People Strong t + 1 423 743 9141 f + 1 423 743 0140 www nuclearfuelservices com INNOVATION DRIVEN >

21 G-22-0036 GOV-01-55-04 ACF-22-0077 NFS recently resumed FoF exercises at the required regulatory frequency, including one (1) FoF exercise in the first quarter 2022. However, the site continues to take precautions during these exercises as a result of the ongoing Public Health Emergency (PHE). Furthermore, the uncertainty of when the impacts from the PHE will recede both on-site and in the local area have prevented sufficient lead time for NFS and the NRC to establish a mutually agreeable date for an observed exercise to occur by March 31, 2022.

NFS requests agency action to remove the second paragraph from SNM-124, Amendment 16, Condition SG-3.8. By taking this action, the licensee will remain exempt from conducting FoF exercises through December 31, 2021 and then resume exercises at their regular frequency. NFS will notify NRC, as required, for the regularly scheduled annual NRG-Observed FoF exercise to occur in calendar year 2022.

If you or your staff have any questions, require additional information, or wish to discuss this matter further, please contact me at (423) 743-1705, or Tom Holly, Licensing Manager, at (423) 743-2595. Please reference our unique document identification number (21 G-22-0036) in any correspondence concerning this letter.

Sincerely, NUCLEAR FUEL SERVICES, INC.

j~/~

Tim Knowles Safety and Safeguards Director TCH/smd

Attachment:

Complete Reference History 2

21 G-22-0036 GOV-01-55-04 ACF-22-0077 Copies:

Mr. James Downs Senior Project Manager Division of Fuel Management Office of Nuclear Material Safety and Safeguards US Nuclear Regulatory Commission Two White Flint North 11555 Rockville Pike Rockville, MD 20852-2738 Regional Administrator US Nuclear Regulatory Commission, Region II 245 Peachtree Center Ave., NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Joel Rivera-Ortiz Senior Fuel Facility Inspector U.S. Nuclear Regulatory Commission, Region II 245 Peachtree Center Avenue NE, Suite 1200 Atlanta, GA 30303-1257 Mr. Larry Harris NRC Senior Resident Inspector 3

21 G-22-0036 GOV-01-55-04 ACF-22-0077 Attachment Complete Reference History

1) Docket No.70-143; SNM License 124

2) NFS Physical Protection Plan

3) NFS Letter, NRG-Observed Force-on-Force Exercise dated June 8, 2021 (24Y 0001)

4) NRC Temporary Staff Guidance No. TSG-DFM-2020-01, "Fuel Facility Requests for Regulatory Relief Related to COVID-19", April 21, 2020

5) NFS Letter, Request for Exemption for NRG-Observed Force-on-Force Exercise (U), dated September 14, 2021 (21G-21-0145)

6) NHC Email, J. Downs to D. Rogers, Request for Supplemental lnfonnation on the NFS Request for Exemption from the NRG-Observed Force-on-Force Exercise, dated September 29, 2021

7) NFS Letter, Response to NRC Request for Supplemental lnfonnation on the NFS Request for Exemption from the NRG-Observed Force-on-Force Exercise, dated October 14, 2021 (21 G-21-0155)

8) NRC Letter, Materials License SNM-124 Amendment 16 -Approval of Request for Exemptions from Certain Force-on-Force Exercise Requirements, dated November 9, 2021 4