ML20029A715
| ML20029A715 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/18/1991 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | Sherr T NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 9103040105 | |
| Download: ML20029A715 (5) | |
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Director Office of Nuclear Materials Safety & Sofeguards b,3 g'ef i
U. S. Nuclear Regulatory Commission Washington, D.C.
20555 i
Attentiont Mr. Theodore S. Sherr, Branch Chief Domestic Safeguards Branch j
Mail Stop 4E4 J
One White Flint North
Dear Sir:
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Subject:
COMMENTS ON DRAFT NUREG/BR-XXXX REV. O, DECEMBER 17, 1990 - INSTRUCTIONS AND GUIDANCE FOR COMPLETING PHYSICAL INVENTORY
SUMMARY
REPORTS (NRC FORM 327)
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We feel the proposed NUREG will be very beneficial to 1Acensees and w. appreciate this advanced opportunity to provido comments.
In general, additional details are given for many definitions which are helpful; however, for consistency the definitions must be compatible with those stated in the appropriate 10CFR i
regulations.
Where applicable, the 10CFR regulation def$nitions should be revised accordingly.
With respect to discards and waste, the definitions and instructions contained in this proposed NUREG are inconsistent with the IAEA's safeguards implementation of 10CFR75 and with GE's NRC approved Fundamental Nuclear Material Control Plan (FNMCP).
Waste generated on site, is deemed not economically recoverable for reuse, and discarded from our material balance area by DOE /NRC form 741 transactions, but is not transferred to a waste holding account.ae would be required by r.hese proposed NUREG instructions.
Comments relative to these concerns and other recommendations are itemized as fol. lows:
Page 1, Purpase and Scope - The NRC Form 742 Material Balance Report includes some of the same information as the NRC Form 327 with different instructions for reporting the measurement bias, prior period adjustments and the ID.
This results in reportics of different totals for the same information.
Since this information is currently required for both reports and to meet the objectives of items (1) and (2) GE recommends revision
-as needed in this NUREG,-the MBR NUREG or both to accomplish consistency of information for both NRC forms.
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Office of Nuclear _ Materials Safety & Safeguards February 18, 1991 Page 2 l
Page 2, Definitions, Additions La Inventory - The definition provided simply means receipts.
The Additions to Inventory should be deleted and the word receipts shov1d replace " additions to inventory" on line 2 of the NRC Form 327 This should improve ease of interpretations and provide consistency with the manner in which shipments are listed on the tovised Form 327, Page 3, Depleted Urenium - Because of the measuremet.'
uncertainty for ceasuring natural or depleted uranium with gamma spectroscopy, this limit should be " loon than 0.680" not 0.700.
Page 6, Limit of Error of the Inventory Di/fotence (LEIO) - Under our NRC approved FNMCP, the old LEMUF and urrent LEID are not the same.
SEID is the equare root i
of the sum of SEM2 + SEP2 Where 2 SEM is the old LEMUF or LEID and SEP is the standard error for i
non-measurement variability contribution.
l Pago 6, LEID Limit - For licensees subject to 4
10CFR74. 31 (c) (4 ) the limit 10 0.25% AI.
This should be added to this definition.
Page 8, Measured Dis:6rde - As written this deflaition F
implies that: measured discards must be discarded to a waste holding account if it is possoased by the Licensee (on GE property).
This definition must allow waste to 3
be..." appropriately discarded _from~the MBA and transferred from the facility ledger via a DOE /NRC 741 transaction."
Page 8,- Definitiona, Normal Uranium - This clarifles the distinction.fer naturally occurring-uranium-through r
nature for most regions or the earth.
Normal uranium and-natural uranium have been previvusly used to mean the same and were used interchangeably.
Since measurements don't usually provide the finite accuracy
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and precision to uake this-conclusion.
GE-Wilmington would only receive normal; uranium. 'Also the bounds for n
normal uranium need to be expanded to 0.60% to 0.74% to L'
accommodate-measurement errors.
NUREG/BR-0006 continues p
to_use~these terms interchangeably.
GE suggeste that
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1ess confusion may b9. caused with only-the definition for; natural. uranium with expansion of bounds for l'-235 for 0.68 to 0.74. - This redefinition also affects the definition of depleted uranium as suggested previously.
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Office of 14uclear Materials Safety & Safeguards February 18, 1991 Page 3 Pace 9, Prior Period Adjustment - Assuming a PPA to the adjacent prior period is made on t he M for the prior period was correct, t. hen PPA must af f ec: either additions r
(receipts), removals (shipments and dincards) or an cadirg in"entory quantity.
Transactiot.s and reports must be chang <d accordingly.
In April of 199'. GE completed a deta11 N review of the 1989 uranium invr.ucry reports lL from whith e determined that 20 items on tnr-ending inventor) de'e listed incorrectly.
As a coreequence, we k
i were reqN 'ed to revise the following documents:
(1)
DOE /!1RC 74
":Mierial Brilance Report", (2) DOE /lJRC 742C
" Physical i emntory Listing", (3) DOE /t1RC 741 "tiucl e a r Material ',ancv: tion Report", (4) 11RC 327 "Special Hu: lear Ms erial Physical Invent.ory Summary Repor t" and bcgind ng ledger and other internal acce :nting t
Jords.
The PPA concept stated in this !JUREG is incorn.: s'. int with the 11MMSS transaction and reporting syste.a.
E af.preciates the intent to standardize the inf ormeti an and f orM, of !JRC reported physical inventory resub " as stated in 1 om (2) of the Purpose and Scope.
There;
'a, C sur.qeits
- vision t.o these PPA proposed recuiremc.'t 1 cesd/or NREG> $. :-0007 " Instructions for Completirn
=
Material BMan o Reports and Physical Inventory id s t i ng s".
m Page 9, Removals from Inventory - This definition should read...of chipmente and measered discards (see definition of measured d!.scards) t.h a t are transf e2 red f rom the MBA via a DOE /tJRC Form 741.
Page 9<
Romovals from Precess - This definition should be 3Qj.sd as f ollows:
Includes all SM or S!1M which talls wa-tr. tt.e categories of (1) generation of ultimate pr ciuct that is maintained under tamper-safing, (2) Ceneratie of sua
'd sources or encapsulated material, (3) Oneras..n of measured discards, and (4) shipment of any k Rorials not described by categories (1), (2) or (3).
Page 10, Special Nuc1( or Materials - Use only the first definition, and ending the sentence on the fourth line after Stim.
The Stm in iach significance level will always tal.1 within the irst definition.
Delete the 2nd clause, any material art.ificially enriched in any of the foregoings.
The remaina r of the defini'. ion is an excellent clatifiertion d strategic sig.'ificance level cf Sl4M and should amain here.
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' Office of Nuclear Materials Safety & Safegiards February 18, 1991
.Page14 je Page 11, Standard Error'- This use f standard error is so seldom used and is in conflict w4th the definition of
'" Standard Error of Inventory Difference (SEID)" it should be dropped.
Page 11, Standard Error of Inventory Difference (SEID)
This is as understood, but is inconsistent with the definition of LEID on page 6.
The definition of LEID should be. changed to be consistent with this.
Page.11, SEID Limit - The definition at item (1) chould read:
(1) For Licensees subject-to 10CFR74.31(c) (4),
the-maximum Oliowable value for SEID is the larger of 9,0001 grams U-235 or 0.25 percent of the active inventorv.
Page.12, Weste should read... (2) at the time of discard is dr,termined to be b0 economically re overable for reuse.
Page.15, Block.F, Beginning Date and Ending Date - The EI da?,e of the pre?ious inventory period should not overlag into the1next period.
To avoid using time-as well.at date in calc 21ating the AI and production rates, it=is'cansistent wit,h general accounting principles to end the accounting period at the 12th hour and begin the s
new perioa at 12:01 am~of the next day, otherwise transactions generated onlthe last. day of the accounting y
period may be duplicated in the first day of the new
' period.
GE recommends that the second sentence should read:
For the beginning date, add 1 day to the cut-off date for the previous material balance period.
Page 15, Block - H, LLicensee's Certifying Of ficial - The certifying official is the authorized. representative of the licensee.and may not be a manager or supervisor but-will be the authorized representative.
GE recommends replacing the words:" supervisor or' manager" with the word authorized representative.-
Page-17, Beginning Inventory, note previous comments for resolving-PPA and BI -inconsistencies must-also be incorporated in.this section.
Since the IAEA and NMMSS require entry:to-the ledger of all transactions that
' occur within the material balance period, GE suggests entering'the. offset quantity to these PPA in line 8.
1
-Line 6 would then equal the MRB total.
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Office of Nuclear Materials Safety & Safeguards February 18, 1991 Page 5
? age 17, Addition to Inventory - Note previous comment to define additions to inventory as simply - receipts.
h-Page 18, Measured Discards - Shipments of solid waste to a burial site are considered shipments by the IAEA.
The IAEA will not accept the reporting of waste box shipments as measured discards.
Also the note should be revised to state...any waste (liquid or solid) that is stored within the MBA, but...
Page 19, Prior Period Adjustments - Note previous comments for PPA.
All transactions of nuclear materials that occur within the current period must be reportad as occurring within the current period even though the transaction is a correction to a previous transaction.
An offset to the PPA should be recorded in Block 8 of the revised Form 327 Page 20, Active Inventory - The AI is calculated from quantities of inventory items using identification and item generation dates to determine the covariant effects.
The book inventory system provides quantities for completion of the Form 327, but does not provide means to calculate the AI.
Sincerely, GE NUCLEAR ENERGY W
T.
Preston Winslow, Manager Licensing & Nuclear Materials Management cc:
TPW-91-025 D.
Joy - USNRC
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