ML24268A132
| ML24268A132 | |
| Person / Time | |
|---|---|
| Site: | BWX Technologies |
| Issue date: | 02/01/2022 |
| From: | Freudenberger R NRC/RGN-II/DFFI |
| To: | Ladonna Suggs NRC/RGN-II |
| References | |
| 22-004, IR 2018001 | |
| Download: ML24268A132 (1) | |
Text
BWX Technologies, Inc.
February 1, 2022 22-004 ATTN: La Donna Suggs, Director Division of Fuel Facility Inspection U.S. Nuclear Regulatory Commission, Region II Marquis One Tower 245 Peachtree Center Ave. NE, Suite 1200 Atlanta, GA 30303-1257
References:
- 1) Letter dated December 21, 2017, NRC (Lesser) to BWXT (Burch), BWXT Nuclear Operations Group, Nuclear Regulatory Commission Inspection Report 70-27/2017-008
Subject:
- 2) Letter dated January 19, 2018 (18-004), B. Joel Burch to NRC, Response to Apparent Violations in Inspection Report 70-27/2017-008
- 3) Letter dated March 8, 2018, NRC (Lesser) to BWXT (Burch), BWXT Nuclear Operations Group - Program Adjustment Review of Licensed Activities (Nuclear Regulatory Commission Inspection Report 70-27/2018-001)
Annual Update on Implementation of Revision Controlled Nuclear Criticality Safety Evaluations
Dear Ms. Suggs:
In Reference 1, the NRC identified three Apparent Violations (AV) as a result of the follow-up inspections for Event Notification52840 involving the accumulation of uranium in desiccant containers in our Research and Test Reactor (RTR) manufacturing area. BWXT Nuclear Operations Group Lynchburg's (BWXT NOG-L) failure to maintain adequate process safety information for process systems as required by 10 CFR 70.62(b) was identified as AV 70-27/2017-008-003, "Inadequacy of Process Safety Information for Process Systems." In Reference 2, BWXT NOG-L provided corrective actions in response to the AVs. One of the corrective actions to AV 70-27/2017-008-003 was to improve safety design basis documentation by implementing revision controlled Nuclear Criticality Safety (NCS) evaluations. BWXT NOG-L committed to provide annual updates to the NRC on the status of this improvement. This letter provides a summary of BWXT NOG-L's progress on this corrective action during 2021.
The goal of improving BWXT NOG-L's safety basis documentation is to replace multiple NCS evaluations for a system or operation with a single revision controlled Process Analysis (PA).
The PAs represent a significant improvement in our process safety documentation and eliminate the revision control issues that contributed to EN 52840. Execution of the PA project plan continued in 2021, despite turnover in staff and lost time due to the COVID-19 pandemic.
Twelve PA work scopes identified in the implementation plan revision for 2021 were completed; several additional PAs are in the QA process. The PAs completed to date are in various stages sv,,xT Nuclee1r Oper.::it,on::: Group Inc PO Box 785 L,,nchburg VA :'.:4505 USA t
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of implementation. Several NRC inspectors examined a number of the PAs during their routine inspections of BWXT NOG-L's NCS program. The inspectors shared positive comments regarding the PAs they reviewed.
Continued staff turnover and COVID-19 protocols have impacted the original 5-year project completion goal. The original project plan assumed a fully staffed project team throughout the duration of the project. At the start of the year, the group consisted of three in-house engineers supplemented by one full-time and one part-time contract engineer. By the end of 2021, three additional full-time contract engineers had been added to the team. Significant time was invested in the onboarding of these new resources. The contract engineers are undergoing the BWXT NOG-L NCS qualification process and should be fully qualified by mid-2022, which will increase the project team's overall productivity. COVID-19 protocols for exposures and positive cases significantly affected the group in 2020 and 2021, resulting in the loss of multiple man-weeks of productivity. In summary, the accomplishments made in 2021 were consistent with the level of staffing for the project. Greater progress is expected in 2022 as additional resources achieve qualification.
If you have questions or require additional information, please contact Chris Terry, Manager of Licensing and Safety Analysis, at ctterry@bwxt.com or 434-522-5202.
Sincerely, 7U-R J~
Richard J. Freudenberger Manager, Environment, Safety, Health and Safeguards BWXT Nuclear Operations Group, Inc. - Lynchburg cc: NRC, Resident Inspector NRG, J. Downs BVVX r Nuc!ecir Oper.::ilion,:; Group inc PO Bo>. 785 Lynchburg VA ::'.4505 U:3A l
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