ML20132B797
| ML20132B797 | |
| Person / Time | |
|---|---|
| Issue date: | 03/01/1984 |
| From: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| To: | Jennifer Davis NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20132B800 | List:
|
| References | |
| FRN-50FR34708, RULE-PR-73 AB46-1-25, NUDOCS 8403140187 | |
| Download: ML20132B797 (3) | |
Text
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W D I lid 4 MEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM: C. J. Heltemes, Jr., Director Office for Analysis and Evaluation of Operational Data
SUBJECT:
PROPOSED REVISION TO 10 CFR 73.71, SAFEGUARDS REPORTING REQUIREMENTS As requested by your memorandum dated February 16, 1984, we have reviewed the proposed changes to 10 CFR 73.71. We strongly endorse the changes in 73.71 that reduce any potential for redundant reporting (e.g., pursuant to 73.71, 20.405, and 50.73). We also encourage the use of the LER format for reporting safeguards events. However, the LER format should be used only by holders of operating licenses for comercial nucicar power plants, and the LER format should not be used to submit routine periodic reports such as the quarterly reports required by 73.71(c). Our specific coments concerning the proposed 73.71 are enclosed.
Please call me or Fred 11ebdon (x24480) if you have any questions concerning our comments.
Dh N C . ite mmes J r ., Director 0 he for Anal is and Evaluation o Operational Data
Enclosure:
As stated ccw/enclosuhe':
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ABWIEnclosure PDE AEOD Comments on the Proposed 10 CFR 73.71
- 1. The following coments apply to the draf t Federal Register notice (Attachment I to the draf t Commission Paper).
- a. Section 73.71(a) label the first line "(11" and replace the text beginning on line 13 ("Each licensee who conducts ...") with the following:
,> "(2) The provisions of $73.71(g)(3) apply to all of these telephone reports.
(3) Each licensee who conducts a trace investigation shall, within 30 days of the onset of'the investigation, make a report in writing to the U.S. Nuclear Regulatory Commission, Docuinent Control Desk, Washington, DC 20555, with a copy to the appropriate NRC Regional Office listed in Appendix A of this part.
(4) For holders of an operating license for a commercial nuclear power plant, the incidents included in this paragraph must be reported in accordance with the procedures described in 550.73(b), (c), (d), (e),
and (g) of this chapter. Incidents reported in accordance with $50.73 of this chapter need not be reported by a duplicate report under this i paragraph." '
- b. Section 73.71(b) label the first line "(l)" and replace the text beginning on line ,14 ("The initial notification must be followed...") with the following:
"(2) The exemptions of $73.71(g)(3) apply to all of these telephone reports.
(3) Each licensee who makes a report under this paragraph shall, within 30 days of discovery of the safeguards event, make a report in writing to the U.S. Nuclear Regulatory Commission, Document Control Desk, Washington, DC 20555, with a copy to the appropriate NRC Regional Office listed in Appendix A of this part.
(4) For holders of an operating license for a commercial nuclear power plant, the incidents included in this paragraph must be reported in accordance with the procedures described in $50.73(b), (c), (d), (e), and
, (g) of this
- chapter. Incidents reported in accordance with 550.73 of
- this chapter need not be reported by a duplicate report under this paragraph."
- c. Delete Sections (d) and (e). The substance of these sections are included in the above changes. In addition, it should be noted that the LER form (NRC Form 366) should be used only by operating nuclear power plants.
- 2. The following comments apply to the Draft Guidance (Attachment 2 to the draft Commission Paper).
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- a. Page 2, delete the paragraph at the top of the page,
- b. Page 2, Regulatory Position I, replace the sentences that begin "If significant supplemental information is ascertained ..." and "For example, inform; tion..." with the following:
" Errors discovered in a report should be corrected in a revised report.
In addition, significant supplemental information should be reported in a revised report. The revised report should replace the previous report; therefore, the update should be a complete entity and not contain only supplementary or revised information.
Only substantial information (e.g., material located, discovery of reason for loss) that would significantly change a reader's perception of the course or consequences of an event need to be reported as a revised report."
- c. Page 3, delete the first paragraph
- d. Page 3, delete the sentence that begins,,"All written reports and log entries required under $73.71(b)...". The 1.ER Form (NRC 366) should be used only by holders of operating licenses for commercial nuclear power plants and should not be used for routine periodic reports such as those required by 73.7t(c).
- e. Page 3, add the following after the second paragraph "If the report contains Unclassified Safeguards Information and the LER form is used, it must be appropriately marked (i.e., Item 17 of NRC-366A).
Safeguards and security information should be included only in the text (Item 17) (i.e., safeguards and security information should not be included in the abstract (Item 16)). In addition, the text should clearly indicate the information that is safeguards or security information.
Finally, the requirements of $73.21(g) must be met when transmitting proprietary information."
- f. Delete Appendix B
- g. Appendix C, Page 1, replace the text beginning with " Suggested form to use..." and ending with "... supplement to a brief narrative." with the following:
" Holders of operating licenses for commercial nuclear power plants may use the LER forms (NRC Form 366, 366A, and 366B) to report events reportable under 73/74(a) or (b).
- 1. Co= ply with the guidance in NUREG-1022, " Licensee Event Report System" for completing the forms.
- 2. Include a brief narractive introduction on a copy of NRC-366 or NRC-366A and then use one or more copies of NRC-366A to provide the following l information in the format indicated below.
i l 3. Do not use the LER forms to submit the copies of the log required by I
73.71(c). The copies of the log requirgd to be submitted pursuant to
- 73.71(c) should be submitted by letter report.
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f6, UNITED STATES FoR
. /" *%,I., NUCLFAR HEGULATORY COMMisslON
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MAR 7 1984 s
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l ?f MEMORANDUM FOR: John G. Davis, Director Office of Nuclear Material Safety and Safeguards FROM: Robert B. Minogue Director Office of Nuclear Regulatory Research
SUBJECT:
PROPOSED REVISIONS T010 CFR 73.71, SAFEGUARDS REPORTING REQUIREMENTS In response to your memorandum dated February 16, 1984,' we have reviewed your proposed revisions to 10 CFR 73.71 and concur with these revisions. The following comments are provided for your consideration:
(1) We suggest that the term " vital island" as used in Appendix G, paragraph (c) be deleted. This tem is
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not defined nor is it used in the current Part 73 ,
of 10 CFR. '
.(2) We believe that licensees should be required to not only log but to report any major safeguards-related incidents as defined by the licensee's contingency plan.
byb b Robert B. Mi.nogue, Director Office of Nuclear Regulatory Research m *
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h, UNITED STATES !
y vt g NUCLEAR REGULATORY COMMISSION [j 3 E WASHING TON, D. C. 20555 MAR 5 194 Jj sJ MEMORANDUM.FOR: John G. Davis, Director Office of Nuclear Material Safety f(f 'bh1 6
and Safeguards FROM: Harold R. Denton, Director Office of Nuclear Reactor Regulation
SUBJECT:
PROPOSED REVISIONS TO 10 CFR 673.71, SAFEGUARDS REPORTING REQUIREMENTS In accordance with your memorandum dated February 16, 1984, subject as above, we have reviewed the draft rule package. We agree that the current reporting requirements of 10 CFR 673.71 can be relaxed without significantly affecting NRC's ability to respond to incidents on possible generic safeguards problems. We, therefore, concur with the draft rule package.
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Harold R. Denton, Director Office of Nuclear Reactor Regulation ,
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