ML20148G079
| ML20148G079 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 05/29/1997 |
| From: | Woolley R UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | Shelton B NRC |
| References | |
| RTR-NUREG-BR-0007, RTR-NUREG-BR-7 GDP-97-0086, GDP-97-86, NUDOCS 9706050153 | |
| Download: ML20148G079 (3) | |
Text
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/hf7 United StItes Enrichment Corporation 2 oemocracy Center 6903 Rockledge Drive Bethesda. MD 20817 Tel: (301)564-3200 Fax:(301) 564-3201 1
r May 29,1997 i
I Ms. Brenda Jo Shelton SERIAL: GDP 97-0086 NRC Clearance Officer US Nuclear Regulatory Commission, T-6 F33 Washington, D.C. 20555-0001 1
Paducah Gaseous Diffusion Plant (PGDP)
Portsmouth Gaseous Diffusion Plant (PORTS)
Docket Nos. 70-7001 and 70-7002 USEC Comments on NRC Material Balance Reporting Requirements, Federal Register Volume 62, Number 59, Page 14706-14707, dated March 27,1997
Dear Madame:
On behalforthe United States Enrichment Corporation (USEC), I am pleased to provide comments regarding N~RC Form 742, " Material Balance Report"; 742C, " Physical Inventory Listing"; and NUREG/BR-0007, " Instructions for Completing Material Balance Report and Physical Inventory Lisdng" for your consideration. USEC realizes that the closing date for these comments was May 27, 1997, but asks that you consider them due to their significance. Each question posed by the NRC in Federal Register Volume 62, Number 59, Pages 14706-14707, dated March 27,1997 is listed below with the corresponding USEC comments. Please note that some of these comments were discussed with the NRC in a closed meeting at USEC's offices on May 20,1997.
NRC Question 1:
Is the proposed collection ofinformation necessary for the NRC to properly perform its functions?
Does the information have practical utility?
l USEC Response:
It is difficult for USEC to fully determine whether the proposed collection ofinformation is necessary for the NRC to properly perform its function, therefore, USEC's response is based purely on our perception of how the information contained in the required forms is used by the NRC and feedback 9706050153 970529 hl l llf}ll}{ll{!l{l[!ffll O
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hfs. Brenda Jo Shelton hiay 29,1997 GDP 97-0086 Page 2 obtained directly from NRC. Nuclear material inventory data for the Gaseous Diffusion Plants are provided to NRC on a bimonthly basis for material in cascades and annually for all material types. The Forms 742 and 742C are not transmitted directly to NRC;They are forwarded to the Nuclear Assurance Corporation (NAC) which operates the Nuclear hiaterials hianagement and Safeguards System (NhihiSS). Feedback obtained from NRC in the past indicates the information contained in the 742 or 742C reports is not fully utilized by the NRC with the exception ofverifying that the current requirement for submittal has been complied with. The NRC summary in the subject Federal Register notice indicates that the information is used by NRC to fulfill responsibilities originating from IAEA and bilateral agreements, however, we believe these data are actually obtained directly from NMh1SS. The 742 and 742C reports do not appear to have significant value.
NRC Question 2:
Is the burden estimate (in the Federal Register notice) accurate?
USEC Response:
The estimated burden for the Paducah and Portsmouth Gaseous DitTusion Plants (GDPs) is valid for current practices, i.e., reconciliation of GDP data with NhihtSS-provided hi-742 reports. However, strict compliance with NUREG/BR-0007, specifically associated with requirements to provide country-of-origin data, would substantially increase the burden on USEC. Tracking of country-of-origin would require development of a new database and system of accounting for nuclear materials at the z
GDPs. Historically, under DOE this information was not provided. It appears that allinternational, IAEA, or other obligations have historically been met without this data being available previously for j
the GDPs. Implementing this requirement would involve a significant amount of effort by the GDPs.
l Similarly, the internally-generated CIDI report has been suflicient under DOE to provide inventory data. Conversion to a separate 742C report would require compilation of data using different formats.
Inventory information is available to NRC in the Form 327 inventory reports which are submitted bimonthly and annually.
NRC Question 3:
Is there a way to enhance the quality, utility, and clarity of the information being collected?
USEC Response:
Yes. The following suggestions are provided:
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i his. Brenda Jo Shelton May 29,1997 GDP 97-0086 Page 3 i
a) Consider eliminating the separate lines for government owned material versus non-government owned materials on the Form 742 report.
1 b) If 742C reports are required, change the categories of enrichment ranges to be consistent with those on the Form 327. Current ranges of El-E4 are used for categorizing materialinto 4 ranges of 1
enriched uranium. The Form 327 separates matuials into only 2 enrichment ranges. The 742C
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report could be improved by using the same ranges as are on the Form 327.
c) Eliminate the requirement to include shipper-receiver difference data and bias requirements on Form 742. These are provided on Form 327.
NRC Question 4:
How can the burden of the information collection be minimized, including the use of automated collection techniques or other forms ofinformation technology?
USEC Response:
Utilize information already in the national NMMSS database, without requiring submittal of separate Forms 742 and 742C.
We would be pleased to discuss these comments with you. Please contact me at (301) 564-3413 or Mark Lombard at (301) 564-3248 if you have any questions regarding this information.
I Sincerely,
&c Robert L. Woolley Nuclear Regulatory Assurance and Policy Manager