ML24065A016

Nuclear Fuel Services, Inc., Response to Request for Additional Information Concerning Request for Exemption from Implementation of Security Event Notification and Suspicious Activity Reporting

ML24065A016
Person / Time
Site:	Erwin
Issue date:	02/19/2024
From:	Knowles T BWXT Nuclear Fuel Services, Nuclear Fuel Services
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
24G-24-0004, GOV-01-55-10, ACF-24-0040, EPID L-2023-SPR-0014
Download: ML24065A016 (1)

Text

24G-24-0004 Nuclear Fuel Services, Inc. GOV-01-55-10 1205 Banner Hill Rd ACF-24-0040

-Erwin, TN 37650 February 19th, 2024

Director, Office of Nuclear Material Safety & Safeguards.

• U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTN: Document-Control Desk

Reference:

Docket No.70-143; $NM License 124 Enterprise -Project_ Identifier: L-2023-SPR-0014.

Subject:

_ Response to Nuclear Fuel Services, Inc., Request for Additional*

Information Concerning Request for Exemption from Implementation of Security Event Notification and Suspicious Activity Reporting

Nuclear Fuel Services, Inc. received a Requ~st for Additional Information (RAI) from the Nuclear Regulatory Commission (NRC) on February 9, :2024 concerning the Requestfor Exemption_

from Implementation of Security Event Notification and Suspicious Activity Reporting.

• Response to the RAI is as follows:

NRC RAl-1

In the submitted exemption-request, NFS stated that the site will continue.to comply with.

security event reporting, as previously required in 10 CFR 73, Appendix G, "Reportable Safeguards Events." Confirm whether NFS will continue to comply with*the requirements of 10 CFR 73. 71, "Reporting of Safeguards Events," and 1 O CFR 73, Appendi~ G that'were required* prior to March 2023, for the duration of the requested exemption term,

Nuclear Fuel Services, Inc~ response to RAl-1

Nuclear Fuel Services, Inc. confirms to remain in compliance with the security.event reporting as previously required in 1o*cFR 73.71, "Reporting of Safeguard Events", and 10 CFR 73, Appendix G,: "Reportable Safeguards Events", for the duration of the requested exemption term.

NRC RAl-2

In its exemption request, NFS states that the site currently complies with the definitionfor "Time of Discovery" provided in NRG-endorsed documentNEI 03-12, "Template forthe Security Plan,

• Training and Qualification Plan, Safeguards Contingency Plan, [and Independent Spent *Fuel Storage Installation Security Program]," and Regulatory Guide 5,62, Revision 1. However, NRC staff could not find a definition for the term "Time of Discovery" eithet in NRC Regulatory Guide 5.62, orin the.referenced NEI 03-12 document. In addition; staff.could notfind a definition for

• this term in the NFS site security plan. NEI 03-12,.Revision 7 (ML11301A066), contains the term "Discovery (time of)." Confirm whether NFS 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_t for tile duration of tne requested.exemption term. Alternatively; a definition for *., 1, 1 /7_

"Time of Discovery" could be proposed.for implementing the site security plan for the. duration of ~ {)u/rr

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24G-24.:QQ04

• GQV-01.-55-10 *

• ACF-24-0040

the requested exem_ption term.

Nuclear Fuel Services, lnc.-response to RAl-2*.

Nucl_ear Fuel Services, Inc. confirms to remain in compliance with the. definition bf "Discovery '

(time of)" being "a supervisor or manager'makes determination that a verified degradation of a security safeguards' measure or a contingency situation exists" from NEI 03-12; for..

implenientirig the site security plan for the durati_on of the requested exemption.-

- NRC RAl-3

-Prior to the effective date ofApril 13, 2023; licensees voluntarily reported suspicious activity to the NRC and other federal agencies. Confirm whether NFS will continue to be capable of..

voluntarily reporting suspicious activity to the NRC and other federal agencies fo'r the :duratio*n of

• the req*uested exemption term. * * * *

• Nuclear Fuel Serv.ices, Inc. resp*onse.to-RAl:.a. * **

Nuclear Fuel Services*, Inc. confirms to be-capable:of voluntarily reporting of suspicious activity

• to the NRC and other federal agencies for. the duration of the requested exemption.

• If you or your staff-have any questions; require additional information, or wish to _discuss this,

'please contact Ms. Natalie Willis, Security director, at (4i3) 743-1720 or me. -Please reference

• our unique document identification number (~4G-24-0004).. *

• Respectfully, Nuclear Fuel Service_s Inc~. *

. * ~, Y*. */7 J AA4. * / {~u,,,-f~-6

.. Tim Knowles -

• Safety and Safe_guards'Director

/