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MONTHYEARML20092N9612020-04-0101 April 2020 Request to Extend the Due Date for Submitting Doe/Nrc Forms 742, 742C, and NRC Form 327 Following Inventory at Framatome Inc.'S Richland, Washington Site; License No. SNM-1227, Docket No. 70-1257 Project stage: Request ML20216A6112020-08-0303 August 2020 Framatome Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1) Project stage: Request ML20253A1472020-09-14014 September 2020 Acceptance of Framatome Inc.'S Request for Exemption from 10 CFR 70.50(b)(1)and Request for Additional Information Project stage: RAI ML20265A3012020-09-21021 September 2020 Framatome'S Response to a Request for Additional Information Dated September 14, 2020 Project stage: Response to RAI ML20275A3382020-11-0505 November 2020 Enclosure 2: SNM-1227 Amendment 15 Non-Sensitive Conditions Project stage: Other ML20275A3352020-11-0505 November 2020 NRC Response Approving Framatome Inc.'S Request for Exemption 10 CFR 70.50 (B) (1) Project stage: Request ML20275A3372020-11-0505 November 2020 Enclosure 1: Safety Evaluation Report Project stage: Approval ML20275A3362020-11-0505 November 2020 Letter: NRC Response Approving Framatome Inc.'S Request for Exemption 10 CFR 70.50 (B) (1) Project stage: Other 2020-08-03
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Category:Letter
MONTHYEARML24026A2792024-01-31031 January 2024 Framatome - Richland Integrated Inspection Report 07001257/2023004 ML24031A5432024-01-23023 January 2024 Triennial Update to Decommissioning Funding Plan (DFP) for the Framatome Inc., Richland Nuclear Fuel Fabrication Facility Cover Letter ML23352A3912023-12-20020 December 2023 Framatome Inc. - Richland Material Control and Accounting Program Inspection Report 07001257-2023401-Public Cover Letter ML23313A0772023-11-27027 November 2023 Framatome Inc. - Request to Amend License and Approve Criticality Safety Methods - License Amendment 19 (Enterprise Project Identification Number L-2023-LLA-0073) ML23296A0072023-10-25025 October 2023 Framatome-Richland - Core Inspection Report 07001257/2023003 ML23291A2042023-10-18018 October 2023 Framatome Inc., Richland Nuclear Fuel Fabrication Facility'S Request to Amend License No. SNM-1227 and Approval of Criticality Safety Methods ML23255A2892023-09-15015 September 2023 Framatome-Richland Inspection Schedule for Calendar Year 2024 ML23254A2502023-09-13013 September 2023 Request of Additional Information Letter to Framatome ML23202A2022023-07-24024 July 2023 Framatome Richland Core Inspection Report 07001257/2023002 ML23198A3172023-07-17017 July 2023 Framatome Inc. Richland Nuclear Fuel Fabrication Facility'S Revised Chapter 1 of License No. SNM-1227 ML23144A3092023-06-21021 June 2023 Acceptance Letter for Request by Framatome for a License Amendment for an Approval of Criticality Safety Methods ML23144A3372023-06-12012 June 2023 Letter to Framatome Approval of Request to Withhold Proprietary Information ML23145A3082023-06-0202 June 2023 Framatome - Licensing Project Manager Change Letter ML23137A3962023-05-17017 May 2023 Framatome, Inc., Richland Nuclear Fuel Fabrication Facilitys Request to Amend License No. SNM-1227; and Approval of Criticality Safety Methods ML23137A4062023-05-17017 May 2023 Framatome, Inc., Submittal of NRC Form 327s Which Report the Results of Material Balance Accounting and Seid Calculations for the Period March 22, 2022 to March 20, 2023 ML23089A2592023-04-10010 April 2023 2023-001 Framatome-Richland - NRC Integrated Inspection Report 07001257/2023001 ML23089A2602023-03-30030 March 2023 Framatome, Inc. - 2023 Fee Increase for Fuel Cycle Licensees; License No. SNM-1227; Docket No. 70-1257 ML23054A2562023-02-23023 February 2023 60-Day Report to January 2, 2023, Incident Reported Under 10 CFR 70 Appendix a Concurrent Report (NRC Event No. 56292); Framatome Richland Facility; License No. SNWI-1227; Docket No. 70-1257 ML22336A0992023-02-0303 February 2023 Cover Letter - Framatome Proprietary Approval 3x Letter of Intent Submittals 11/21/2022 and 11/29/2022 ML23030B6172023-01-31031 January 2023 Framatome-Richland - Core Inspection Report 07001257/2022004 ML23025A3172023-01-25025 January 2023 Submittal of Integrated Safety Analysis (ISA) Summary Annual Update for Framatome Inc.'S (Framatome'S) Richland, Washington Fuel Fabrication Facility ML22341A1562022-12-0707 December 2022 60-day Follow Up Report for an Incident Reported Under 10 CFR 70 Appendix a (C) Concurrent Report (NRC Event No.56713); Framatome Richland Facility ML22272A0252022-10-0404 October 2022 Framatome-Richland -Integrated Inspection Report 07001257/2022003 ML22263A4652022-09-20020 September 2022 Framatome, Inc. Submittal of Revised Fundamental Nuclear Material Control Plan ML22255A0122022-08-31031 August 2022 Framatome Inc. - Required Reporting of Effluents Per 10 CFR 70.59 ML22238A1602022-08-24024 August 2022 Framatome Richland Facility Emergency Plan Version 16.0 ML22236A5872022-08-23023 August 2022 Framatome Inc., Richland Nuclear Fuel Fabrication Facility'S Intent to Amend License No. SNM-1227; ML22201A5352022-07-21021 July 2022 Framatome 2022-002 Integrated Quarterly Inspection Report ML22192A1272022-07-11011 July 2022 Framatome, Inc., 60-day Report for a May 12, 2022 Incident Reported Under 10 CFR 70 Appendix a 24-hour Report (NRC Event No. 55897) ML22154A4382022-07-11011 July 2022 Cover Letter - Framatome Inc. - Request to Amend License and Approve Criticality Safety Methods - License Amendment 18 (Enterprise Project Identification Number L-2021-LLA-0218) ML22187A1892022-06-29029 June 2022 Framatome-Richland - Inspection Schedule for Calendar Year 2023 ML22187A0392022-06-28028 June 2022 Framatome Documentation Request - 2022-003 PMT ML22137A1282022-06-23023 June 2022 Cover Letter - Framatome- DFP Info and Form 327 Proprietary Review ML22166A3432022-06-10010 June 2022 Framatome Lnc., Submittal of Quality Assurance Program, FS1-0011462, Revision 8.0, 10 CFR 71, Subpart H Quality Assurance Program Description for Packaging and Transportation of Radioactive Materials for Us Fuel ML22132A2292022-05-12012 May 2022 Framatome, Inc., Submittal of NRC Form 327 ML22132A2952022-05-12012 May 2022 Framatome, Inc., Submittal of Triennial Update to Decommissioning Funding Plan (DFP) for the Richland Nuclear Fuel Fabrication Facility ML22087A1212022-03-31031 March 2022 Cover Letter Framatome Inc., - Request for Additional Information Regarding License Amendment Request for Approval of Criticality Safety Methods (Enterprise Project Identification Number L-2021-LLA-0218) ML22059A7582022-03-0303 March 2022 Framatome, Inc., Licensee Performance Review (Nuclear Regulatory Commission Inspection Report 0701257/2022005) ML22060A1262022-03-0101 March 2022 60-day Report to January 4, 2022 Incident Reported Under 10 CFR 70 Appendix a Concurrent Report (NRC Event No. 55686); Framatome Richland Facility; License No. SNM-1227; Docket No. 70-1257 ML22066B2732022-02-28028 February 2022 Framatome, Inc. - Required Reporting of Effluents Per 10 CFR 70.59 for July-December 2021 ML22033A1722022-01-27027 January 2022 Framatome, Inc. Richland Washington Fuel Fabrication Facility Submittal of Update to Integrated Safety Analysis (ISA) ML22025A3902022-01-25025 January 2022 60-day Report to January 4, 2022 Incident Reported Under 10 CFR 70 Appendix a Concurrent Report (NRC Event No. 55686); Framatome Richland Facility ML22024A2152022-01-25025 January 2022 Framatome, Inc. - Richland, U.S. Nuclear Regulatory Commission Integrated Inspection Report 07001257/2021004 ML22024A4832022-01-24024 January 2022 60-Day Report to December 20, 2021 Incident Concurrently Reported Per 10 CFR 70 Appendix A(C) (NRC Event No. 55666); Framatome Richland Facility ML22007A3592022-01-0707 January 2022 Framatome, Inc., 30-Day Report to December 8, 2021 Incident Reported Under 10 CFR 70.50(b)(3) (NRC Event No. 55634) ML21335A3282021-12-23023 December 2021 Response to Framatome Request of 11-1-21 for Withholding Due to Proprietary Information ML21336A7572021-12-0202 December 2021 Framatome, Inc., Richland Facility, 30-day Report to October 12, 2021 Incident Reported Under 10 CFR 70.50(b)(1) (NRC Event No. 55517) 2024-01-31
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML20265A3012020-09-21021 September 2020 Framatome'S Response to a Request for Additional Information Dated September 14, 2020 2020-09-21
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framatome September 21, 2020 TJT:20:022 U.S. Nuclear Regulatory Commission Attn: Document Control Desk (03-H8)
One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738
Subject:
Framatome's Response to a Request for Additional Information Dated September 14, 2020
Reference:
- 1) Framatome Request for Exemption from 24-Hour Reporting Requirement of 10 CFR 70.50(b)(1) dated August 3, 2020.
- 2) NRC Request for Additional Information Dated September 14, 2020.
- 3) Letter N. Ashkeboussi (NEI) to A. Szabo (NRC), "Industry Comments on the Information Collection for Domestic Licensing of Special Nuclear Material",
10/27/17.
- 4) Federal Register Notice, Vol. 56, No. 93, Page 19890, "Proposed Rules,"
dated May 14, 1990.
Dear Mr. Siurano-Perez:
Framatome Inc. is providing the attached response with the additional information that you requested on September 14, 2020 (Reference 2).
The attached Framatome reporting estimates are consistent with those previously provided by the Nuclear Energy Institute (NEI on behalf of its fuel cycle facility members (Reference 3).
If you have any information concerning this information, please contact me at 509 375-8550.
Sincerely, T. J. Tate, Manager Environmental, Health, Safety & Licensing TJT c: Damaris Marcano, USNRC NMSS R. Gibson, USNRC RII Framatome Inc .
2101 Horn Rapids Road Richland, WA 99354 fol: (509) 375-8100 www.fra matome.com 2270'JWA-8 (01/1212018)
US NRC T JT:20:022 September 21, 2020 Page 2 be: CD Manning 22709WA-8 (01/1212018)
US NRG TJT:20:022 September 21, 2020 Page 3 Attachment Framatome Inc. Response to NRG Request for Additional Information
RAI 1
Granting the requested exemption would require the NRG to make determinations in accordance with 10 CFR 70.17 which include, in part, finding that the exemption is in the public interest. Your application states the exemption would allow resources to be focused on other activities of higher significance or consequence. However, no data was provided to quantify the resources saved.
Response to RAI 1 Framatome takes its reporting responsibilities very seriously and commits a significant amount of time and resources to the evaluation and preparation of event reports to the NRG Operations Center. The time spent preparing the initial evaluation per 10 CFR70.50(b )( 1),
the resources required for the necessary initial event notification and follow-up reports is demanding in nature and substantial in resources and averages $68,000/event.
Assuming one such event per quarter, the total labor cost of such reporting is $272,000/year.
Granting the exemption would reduce the level of transparency to the public of unplanned contamination events. An estimate of the resources saved is needed to make a finding that a reduced level of transparency is justified. The resource estimate should be limited to costs incurred by reporting the event. Costs associated with investigations and corrective actions that would be performed even if no report was made should be excluded from the estimate.
Response to RAI 2 Framatome believes that granting this exemption request does not reduce the level of transparency to the public of unplanned contamination events. The NRG inspects Framatome an average of 6 or 7 times each year. The inspectors have full access to the Framatome Corrective Action Program where such events are documented and inspectors review the items in the corrective action program during each of their inspections. The NRC's inspections include a specific inspection of the facility's radiological program at least one time each year. The results of these inspections are documented in quarterly inspection reports and are publicly available in the Agency Document Administration and Management System (ADAMS).
Additionally, Reference 3 states: 'The intent of these amendments is to require prompt notification (either immediately or within 24-hours) to the NRG of events that would require prompt action by the NRG to protect public health and safety of the environment." The specific events, as noted in Framatome's exemption request (Reference 1), are located in an RCA and pose no public health and safety or environmental risk.
Finally, it should be noted that the nuclear power reactors, research and test reactors, and site-specific and standalone independent spent fuel storage installations are not subject to similar reporting requirements for unplanned contamination events.
227VJWA3J (0111212018)
US NRG TJT:20:022 September 21, 2020 Page4 Framatome believes this request to grant an exemption from the 10 CFR 70.50(b)(1) reporting requirement is consistent with the NRC's Principles of Good Regulation and is in the public interest as it provides clarity, reliability, and consistency with the regulatory reporting requirements of licensees with comparable Radiological Protection programs.
Furthermore, it allows limited resources to remain focused on activities of higher safety significance at Framatome.
2270'.JVVA-8 (01/12/2018)