ML23094A148
| ML23094A148 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/30/2023 |
| From: | Devik T TMI-2 Solutions |
| To: | Amy Snyder Reactor Decommissioning Branch |
| Snyder A | |
| References | |
| Download: ML23094A148 (5) | |
Text
From: Tim Devik To: Amy Snyder Cc: Glenn Tuttle; Amy C. Hazelhoff; Chad S. Miltenberger; Barb Dotson; Hannah E. Pell
Subject:
[External_Sender] RE: RE: RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments Date: Thursday, March 30, 2023 7:40:55 PM Attachments: exemptions -TMI-2.msg
Dear Ms. Amy,
There is an error in the below response. TMI-2S does not have an exemption for 74.19(a)(1). In the RAI 14 response from ML22276A024, TMI-2S states:
The Program Description, included in the response to RAI 10, describes the overall material control and accountability program, requirements for records meeting 10 CFR 74.19(a) are included in the associated written procedures.
10 CFR 74.19(a)(1): TMI-2 does not intend to receive or acquire SNM thus there is no program or procedures addressing receipt of SNM.
Physical inventory is exempted for in situ material per Reference 1. Upon removal from its in situ condition and packaged for dry storage or packaged in small quantities within LLRW or samples, physical inventory will occur, including the associated records per written procedure.
Records for transfer or disposal will be generated per written procedure.
Reference 1 referred to is attached hereto. My apologies for the miss-statement in the previous email. It was overlooked in the review and the incorrect item was copy/pasted to the email.
10 CFR 74.19(a)(1) states:
(1) Each licensee shall keep records showing the receipt, inventory (including location and unique identity), acquisition, transfer, and disposal of all special nuclear material in its possession regardless of its origin or method of acquisition.
Due to the nature of the fuel bearing material (which includes special nuclear material) at TMI-2 leftover from the initial cleanup of the accident during which 99% of the core was transported off-site and accounted for. The remaining material is not in a configuration that lends itself to being uniquely identified as it is located in various conditions (dry dust on floor, material adhered to existing plant systems / structures, etc.). Once the material is removed from its in situ location in the plant, it will be placed in a container and then will be assessed, given a unique identifier and controlled IAW 74.19(a)(1) from that point.
If you have any additional questions, please let me know.
Respectfully, Tim Timothy Devik Licensing Manager
Mobile: 603.384.0239 Email: trdevik@energysolutions.com From: Amy Snyder <Amy.Snyder@nrc.gov>
Sent: Thursday, March 30, 2023 5:39 PM To: Tim Devik <trdevik@energysolutions.com>
Cc: Glenn Tuttle <Glenn.Tuttle@nrc.gov>; Amy C. Hazelhoff <achazelhoff@energysolutions.com>;
Chad S. Miltenberger <csmiltenberger@energysolutions.com>; Barb Dotson
<bedotson@energysolutions.com>; Hannah E. Pell <hepell@energysolutions.com>
Subject:
RE: RE: RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments EXTERNAL: This message is from a NON-EnergySolutions sender, please ensure it is from a legitimate source.
DO NOT click links or open attachments if sender is unknown or the message seems suspicious in any way.
Thank you Acknowledge receipt A
From: Tim Devik <trdevik@energysolutions.com>
Sent: Thursday, March 30, 2023 5:38 PM To: Amy Snyder <Amy.Snyder@nrc.gov>
Cc: Glenn Tuttle <Glenn.Tuttle@nrc.gov>; Amy C. Hazelhoff <achazelhoff@energysolutions.com>;
Chad S. Miltenberger <csmiltenberger@energysolutions.com>; Barb Dotson
<bedotson@energysolutions.com>; Hannah E. Pell <hepell@energysolutions.com>
Subject:
[External_Sender] RE: RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments
Dear Ms. Amy,
Good afternoon.
10 CFR 74.19(a)(1) states:
(1) Each licensee shall keep records showing the receipt, inventory (including location and unique identity), acquisition, transfer, and disposal of all special nuclear material in its possession regardless of its origin or method of acquisition.
Due to the nature of the fuel bearing material (which includes special nuclear material) at TMI-2 leftover from the initial cleanup of the accident during which 99% of the core was transported off-site and accounted for. The remaining material is not in a configuration that lends itself to being uniquely identified as it is located in various conditions (dry dust on floor, material adhered to existing plant systems / structures, etc.). TMI-2 currently has an exemption from 74.19(a)(1) because of this condition. Once the material is removed from its in situ location in the plant, it will be placed in a container and then will be assessed, given a unique identifier and controlled IAW 74.19(a)(1) from that point.
If you have any additional questions, please let me know.
Respectfully, Tim From: Amy Snyder <Amy.Snyder@nrc.gov>
Sent: Thursday, March 30, 2023 4:16 PM
To: Tim Devik <trdevik@energysolutions.com>
Cc: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Subject:
FW: RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments EXTERNAL: This message is from a NON-EnergySolutions sender, please ensure it is from a legitimate source.
DO NOT click links or open attachments if sender is unknown or the message seems suspicious in any way.
Please answer question below.
A From: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Sent: Thursday, March 30, 2023 11:48 AM To: Amy Snyder <Amy.Snyder@nrc.gov>; James Rubenstone <James.Rubenstone@nrc.gov>
Cc: Angela Coggins (She/Her/Hers) <Angela.Coggins@nrc.gov>
Subject:
RE: RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments Still not sure why 74.19(a)(1) is left out.
From: Amy Snyder <Amy.Snyder@nrc.gov>
Sent: Thursday, March 30, 2023 10:39 AM To: James Rubenstone <James.Rubenstone@nrc.gov>; Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Cc: Travis Jones (He/Him) <Travis.Jones@nrc.gov>; Angela Coggins (She/Her/Hers)
<Angela.Coggins@nrc.gov>; Shaun Anderson <Shaun.Anderson@nrc.gov>
Subject:
RE: RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments Importance: High Hi Jim and Glenn, You okay with their proposed change to the MC&A TS 6.0 condition? See attached.
Please advise.
- Thanks, A
From: Tim Devik <trdevik@energysolutions.com>
Sent: Thursday, March 30, 2023 10:35 AM To: Amy Snyder <Amy.Snyder@nrc.gov>
Cc: James Rubenstone <James.Rubenstone@nrc.gov>; Glenn Tuttle <Glenn.Tuttle@nrc.gov>; Travis Jones (He/Him) <Travis.Jones@nrc.gov>; Angela Coggins (She/Her/Hers) <Angela.Coggins@nrc.gov>;
Chad S. Miltenberger <csmiltenberger@energysolutions.com>; Amy C. Hazelhoff
<achazelhoff@energysolutions.com>; Hannah E. Pell <hepell@energysolutions.com>; Becca Brown
<rebrown@energysolutions.com>
Subject:
[External_Sender] RE: [EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments
Dear Ms. Amy,
You have explained it correctly. TMI-2S has existing exemptions against the MC&A requirements for the material that is left over from the accident that is not in containers or in a configuration that allows for discrete identification, marking, tracking and classification. The procedures for MC&A at
TMI-2S have provisions to initiate tracking of material once it is moved from its in situ position to a container (either for sample, interim storage or final storage) that can be controlled (i.e. sealed) and marked with unique identification for tracking. This was explained in our responses to the RAIs received and clarified in discussions with the NRC. If the staff feels that an additional clarification call is warranted, please let me know.
Respectfully, Tim Timothy Devik Licensing Manager Mobile: 603.384.0239 Email: trdevik@energysolutions.com From: Amy Snyder <Amy.Snyder@nrc.gov>
Sent: Wednesday, March 29, 2023 4:35 PM To: Tim Devik <trdevik@energysolutions.com>
Cc: James Rubenstone <James.Rubenstone@nrc.gov>; Glenn Tuttle <Glenn.Tuttle@nrc.gov>; Travis Jones (He/Him) <Travis.Jones@nrc.gov>; Angela Coggins (She/Her/Hers) <Angela.Coggins@nrc.gov>
Subject:
[EXTERNAL] FW: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3-17-23_Admin Controls-TMI2S comments EXTERNAL: This message is from a NON-EnergySolutions sender, please ensure it is from a legitimate source.
DO NOT click links or open attachments if sender is unknown or the message seems suspicious in any way.
- Tim, See email string. Perhaps you can clarify.
A From: Amy Snyder Sent: Wednesday, March 29, 2023 4:34 PM To: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Cc: James Rubenstone <James.Rubenstone@nrc.gov>; Travis Jones (He/Him)
<Travis.Jones@nrc.gov>; Angela Coggins (She/Her/Hers) <Angela.Coggins@nrc.gov>
Subject:
RE: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3 23_Admin Controls-TMI2S comments TMI-2 will perform physical inventory of the resulting containers- they do not want to be held accountable for inventorying before stuff is containerized- that is their point to clarify its just for containerization.
TMI-2 says that 74.19 (a)1 does not apply to them other than from containerization on.
(1) Each licensee shall keep records showing the receipt, inventory (including location and unique identity), acquisition, transfer, and disposal of all special nuclear material in its possession regardless of its origin or method of acquisition.
From: Glenn Tuttle <Glenn.Tuttle@nrc.gov>
Sent: Wednesday, March 29, 2023 3:31 PM To: Amy Snyder <Amy.Snyder@nrc.gov>
Cc: James Rubenstone <James.Rubenstone@nrc.gov>; Travis Jones (He/Him)
<Travis.Jones@nrc.gov>; Angela Coggins (She/Her/Hers) <Angela.Coggins@nrc.gov>
Subject:
RE: HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3 23_Admin Controls-TMI2S comments Not sure I get what the issues are here based on TMI-2 comments. Or just confused about what a TS is.
TMI-2 is exempted from performing an annual inventory, but they indicate in the response to RAI 16 that:
Notwithstanding the current exemption applicability, upon packaging material into a container TMl-2 Solutions will perform physical inventory of the resulting containers per written procedures. This will include SNM in any packages physically on site (to include LLRW or samples awaiting shipment, interim storage of FBM, and FBM in Dry Storage Canisters) at the time of the annual inventory.
They are exempt from inventorying a debris pile (makes sense) but they do indicate that they will do an inventory when they have material containerized. Are they exempt from inventory or not?
Also TMI-2 suggested leaving out the reference to 10 CFR 74.19(a)(1) in TS 6.16.1. But in the response to RAI 14 they do commit to having records of transfer and disposal, and they do talk about having records of containerized debris material:
Physical inventory is exempted for in situ material per Reference 1. Upon removal from its in situ condition and packaged for dry storage or packaged in small quantities within LLRW or samples, physical inventory will occur, including the associated records per written procedure. Records for transfer or disposal will be generated per written procedure.
Im not sure I get this issue either.
My comments for what they are worth.
Glenn From: Amy Snyder <Amy.Snyder@nrc.gov>
Sent: Wednesday, March 29, 2023 2:16 PM To: David Esh <David.Esh@nrc.gov>; Chris McKenney <Christepher.McKenney@nrc.gov>; Glenn Tuttle <Glenn.Tuttle@nrc.gov>; James Rubenstone <James.Rubenstone@nrc.gov>
Cc: Shaun Anderson <Shaun.Anderson@nrc.gov>; Travis Jones (He/Him) <Travis.Jones@nrc.gov>;
Angela Coggins (She/Her/Hers) <Angela.Coggins@nrc.gov>
Subject:
HIGH PRIORITY- TMI-2 PROPOSED CHANGES TO TS CONDITIONS License DPR-73 3 23_Admin Controls-TMI2S comments Importance: High HI Please see attached proposed changes to TS 6.0 conditions.
TMI-2 suggests combining two accident analysis conditions into one condition and clarified the MC&A condition.
Please see attached and let me know if acceptable as soon as possible.
Thank you A