ML20035H279
| ML20035H279 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/15/1993 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| References | |
| FRN-58FR6098, RTR-NUREG-BR-0006, RTR-NUREG-BR-0007, RTR-NUREG-BR-6, RTR-NUREG-BR-7, RULE-PR-150, RULE-PR-40, RULE-PR-72, RULE-PR-74, RULE-PR-75 58FR6098-00003, 58FR6098-3, NUDOCS 9305040090 | |
| Download: ML20035H279 (3) | |
Text
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April 15, 1993 7
Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Docketing Service
Subject:
Response to Proposed Rule Appearing in FR, Vol. 50, No. 15, Dated 1/26/93, Page 6098
Reference:
NRC License SNM-1097, Docket 70-1113
Dear Sir:
In response to the subject proposed rule, GE's Nuclear Fuel and Components Manufacturing in Wilmington, N.C. hereby submits for your consideration the following comments.
GE-Wilmington agrees with the NRC objective to improve efficiency and reduce paper through computerized reporting of nuclear material transaction and inventory data.
This proposed regulation has laid the ground work for real advances in electronic transmission of nuclear material transaction and inventory data.
However, we do not agree with the floppy disk method proposed for submitting this data. 'As stated in the NMMSS Report D-24 in reference to floppy disks, "this is a very vulnerable' storage method", and the likelihood of damaged disk or lost data increases with-mailing.
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The D-24 Report provides instructions to use anti-static diskette mailers or cpecifically labeled I
cardboard for mailing disks, include a printed list of l
the data files, and a signed and dated submittal form.
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-This would increase paperwork, effort and costs for each data submittal.
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Secretary of the Commission j
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- April'15, _1993 Page 2 i
Most fuel fabricators and other licensees report l
I confidential nuclear material transaction and inventory data which does not require additional
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security methods for transmission.
Data integrity can i
be maintained through telecommunicated transmission and also_ provide other significant advantages over I
floppy disk, such as real reduction in paperwork, and
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cost reduction.
In lieu of the NRC proposed data transmission method, we recommend the following method i
as a viable alternative.
i Transmit and receive all DOE /NRC confidential data to and from NMMSS by modem using software provided by NMMSS.
Each RIS user would have their own i
personalized password, recognizable by the NMMSS computer, which will allow them to send and receive 1
nuclear material transaction and inventory data that 1
affects only their RIS.
Receivers of nuclear material access their data from NMMSS and not from the_ shipper.
Hard copy transactions would be required for imports and exports in addition to electronic transmission of l
data to NMMSS.
A hard copy would be provided to the i
foreign party of the import or export transaction.
The ADP Transcription Sheet, DOE Form DP-740 listed in the D-24 Report does not include a. signed and dated
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block corresponding to block 24T and-25T on the l
DOE /NRC Form-741.
These blocks should be added to the l
transmittal file for each of the forms.
The-following-l or similar statement should also be'added to the-D-24 Report concerning electronic signatures.
Licensee controls shall be established such that the printed name in the signature block of each form constitutes a signature and meets all NRC requirements for a signed form.
General Electric's' computer software for generation of l
the prescribed formatted data is not yet available..
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A schedule has been established for making other changes to our accounting software which will be
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complete in July, 1994.
The software changes needed for reporting of inventory and transaction data in the 1
-prescribed formats will be included in this schedule.
Affected regulations state that these prescribed computer-readable; forms replace:
DOE /NRC Form 740M DOE /NRC Form 741 DOE /NRC Form 742 DOE /NRC Form 742C I
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Secretary of'the-Commission April 15, 1993-Page 3 4
i With regards to replacement of these forms, the referenced NUREG/BR-0006 and NUREG/BR-0007 must also i
be revised with the issuance of this regulation.
The i
regulations or the NUREG should clearly document that licensees will no longer have the replaced forms once l
they begin transmitting data electronically.
Licensees 1
must continue to retain the previously used forms for J
the required retention period.
Electronically generated transaction and inventory data must be l
retained in the same manner as the transmission and available for NRC inspection.
Inspectors may view this data using their lap top personal computers or licensee equipment, as appropriate.
On page 6098 of the proposed rule, a statement is made concerning a disk that can be obtained from the NRC i
which includes appropriate formats and user prompts to facilitate the process of submitting required information.
We have made previous requests for a copy of this disk which we have not received, and we are again making this request.
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We appreciate the opportunity to comment on this proposed rule.
If you have any questions regarding our comments or would like to discuss them further, please contact me on (919) 675-5461.
r Sincerely, t
GE NUCLEAR ENERGY l
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Preston Winslow, Manager Licensing & Nuclear Materials Management' t
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cc:
TPW-93-022
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