ML24065A014
| ML24065A014 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 02/29/2024 |
| From: | Spiva E BWXT |
| To: | Document Control Desk, Office of Nuclear Material Safety and Safeguards |
| References | |
| 24-012, EPID L-2023-SPR-0013 | |
| Download: ML24065A014 (1) | |
Text
aWXr BWX Technologies, Inc.
February 29, *2024 *
- 24-012 A TIN: Document Control *Desk
.. -Director, Office *ofNuclear Materials*safety*and Safeguards
- u.S. Nuclear Regulatory Commission*
- Washington,.D.C. *20555~000_1 *
Reference:
REQUEST FOR ADDITIONAL INFORMATION REGARDING SUBMITTAL FOR EXEMPTION FROM IMPLEMENTATION_OF SECURITY.EVENT NOTIFICATION
- AND SUSPICIOUS ACTIVITY REPORTING - ENTERPRISE PROJECT *
- IDENTIFIER L-2023-SPR-0013
Subject:
- . Response to. Request.for Additional Information Regarding Submittal For * *
. _ Exerr1ption From. Implementation of Security Event Notification
.. and* Suspiciou$ Activity. Reportin*g_
Dea'r Sir or Madam, *.
- By our letter dated November 16, 2023, BWXT Nuclear Operation~ Group; Inc. _: Lynchburg
.(BWXT NOG~L)*reqµested an ex~mption:from c.ertain s~curityt:iventnotification anC, suspicious activity* reporting* implementation in accordance*with *Title* 10 of the* Code of Federal Regulations
(.10 CFR) Section* 73:5.
BWXT is providing*the enclosed responses to the NRC Request for Additional Information; received on February 9, 2024.
- .If you have :questions or-require. additional.information, please contact m~ at 434-522~5696* or by.email at ejspiva@bwxt.com.
Sincerely,
. E. Jay Spiva.
.
- Security Director I Department Manager BWXT-Nuclear Operations Group, Inc. - Lynchburg Enclosure.
cc: NRC, James Downs, Senior Project Manager cc: us NRC R1:1gion II cc: NRC R_esident*lnspector
- . BWXT NUclearOperatlons Group: Inc.
P.O. Box 785 Lynchburg, VA 24505 LJSA *
- t.+1.434.522.6000 www.bwxt.com s o*-o.lfl.
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People Stro.ng
- INNOVATION DRIVEN >
Enclosure*
BWXT NOG-L response to the NRC Request for Additional Information
RAl-1: In the submitted exemption request, BVVXT NOG-L stated that the site will continue to comply with security event reporting, as previously required in 1 O CFR 73, Appendix G, "Reportable Safeguards Events." Confirm whether BWXT NOG-l will continue to comply with the requirements of 10 CFR 73.71, "Reporting of Safeguards Events," and.10 CFR 73, Appendix G that were required prior to March 2023, for the duration of the requested exemption term..
BWXT NOG-L Response (RAl-1 ):
NOG-L confirms it will continue to comply with the.requirements of 10 CFR 73. 71, "Reporting of Safeguards Events," and 10 CFR 73, Appendix G that were required prior to *March 2023, for the duration of the requested exemption term.
RAl-2: In its exemption request, BVVXT NOG-L states that the site currently complies with the definition for "Time of Discovery" provided in NRG-endorsed document NEI 03-12, Template for.the Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, [and Independent Spent Fuel Storage Installation Security Program]," and R.egulatory Guide 5.62, Revision 1. However, NRC.staff could not find a definition for the term "Time of Discovery" either in.NRG Regulatory*Guide 5:62, or in the referenced:NEI 03-12 document. In addition, staff could not find a definition for this term.in the BVVXT NOG:..L site security plan. NEI 03-12, Revision 7 (ML11301A066), contains the term "Pisc.overy (time of}." Confirm whether BWXT NOG-L currently complies with the definition of "Discovery (time of)° from NEI 03-12, for implementing the site security plan, and_ that it will continue to comply with i~ for the duration of the requested exemption term. Alternatively, a definition for "Time of Discovery" could be prnposed for implementing the site security plan for t~e duration of the requested exemption
- term.
BWXT NOG-L Response (RAl-2):
NOG-L confirms current compliance with the definition of "Discovery.(time 9f) 11 from NE! 03-12, for-implementing the site security plan, and continued compliance for.the duration of the requested exemption term.
- RAl-3: Prior to the effective date of April 13, 2023, licensees voluntarily reported suspicious activity to the NRC and other federal agencies. *Confirm whether BWXT NOG-L will continue to be capable of voluntarily reporting suspicious activity to the NRC and other federal agencies for the duration of the requested exemption term.
BWXT NOGcL Response (RAl-3):
NOG~L confirms it will continue to maintain the capability to voluntarily report suspicious activity to the NRC and other federal agencies for the duration of the requested exemption term.