ML20149L950
| ML20149L950 | |
| Person / Time | |
|---|---|
| Issue date: | 11/30/1996 |
| From: | Troup G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | NRC |
| References | |
| DSI-G-2-00010, DSI-G-2-10, NUDOCS 9612110032 | |
| Download: ML20149L950 (3) | |
Text
_ . . . . - - - - - _ . . _ .- .. -. _ . _ - .
, ,, bSI 62 -
Gerald Troup Q
! From:
To: WND1.WNP7.JWC1 11/30/96 5:27pm 8 Date: 9
\3
Subject:
comments on strategic initiative 4 ,
RECBvE0 Attached are my personal comments on the intiative.
i m7 DEC 2 1996 5 l otticeof the j
.a Secretary C i
i 4
i i
1 i
4 i
b 9
4 9612110032 PDR NRCSA I 961130 GEN PDR
~
u E)5 /3
l
~
November 30,1996 Gerald L. Troup i Sr. Fuel Facilities Inspector Fuel Facilities Branch Division of Nuclear Ma:erials Safety I Region 11
SUBJECT:
COMMENTS ON STRATEGIC ASSESSMENT AND REBASELINING INITIATIVE In reviewing the list of Direction Setting Issue (DSI) Paper Development, I note that there is no DSI addressing the nuclear fuel cycle or related facilities. There are DSIs for the Department of Energy, Spent Fuel, and Operating Reactors. How can we say we are addressing the agency's future direction if we ignore such activities as uranium hexafluoride conversion, uranium enrichment (including the USEC and LES facilities), and light water reactor fuel fabrication facilities (5 facilities). There is also the issue of the high enriched uranium facilities that produce fuel for DOE. The future of licensing, inspection, oversight of new facilities (such as being constructed at Siemens and General Electric), and decommissioning of facilities under the Timeliness Rule should be addressed as part of the Strategic Assessment.
The fuel cycle has many issues which have never been resolved or codified in the regulations.
Facilities are being required to dig up burials of material on site and to remediate old areas where spills had occurred under the Timeliness Rule. However, the criteria for residual contamination that is being specified by ONMSS are listed in a DRAFT Branch Technical Position which was published "For Comment" in the Federal Register (46 FR 52601) on )
October 23,1981. I feel that Rebaselining should address issuing definitive rules in 10 CFR regarding acceptable residual contamination limits. Fifteen years of using a " DRAFT" is too long and it should be a rule, not a " Branch Technical Position."
Following the rupture of a Model 48-Y uranium hexafluoride cylinder at Sequoyah Fuels (Gore, Oklahoma) on January 4,1986 (documented in NUREG-1179), the NRC initiated a series of Operational Safety Assessments (OSAs) at the fuel cycle facilities. The results of these OSAs showed major weaknesses in four major areas. This resulted in the issuance of four draft Branch Technical Positions (BTPs) in the Federal Register (54 FR 11590) on March 21,1989. As of 1996, only one BTP (Fire Protection) has been issued in final form in the Federal Register (57 FR 35607) in 1992. The Regulatory Guide and Standard Review Plan which were to have been issued to implement this BTP (see letter to licensees from the Chief, Fuel Cycle Safety Branch, October 6,1992) have not been issued. Even though the BTPs are only issued in " draft" form, implementing the BTPs has been included as license conditions in some facility operating licenses. Guidance documents which were identified in the initial Federal Register notice have not been issued after 9 years. Even so, the NRC has
J
,o )
- . j 2
issued an inspection program for chemical safety (NRC MC 2603) and is conducting an l inspection program. Given that licensees have no regulatory requirements, except as issued l
! by OSHA and EPA for chemical safety, and no guidance on expectations, licensees have i expressed concern about this program.
3 Another fuel cycle issue is that of Integrated Safety Assessments (ISAs). Many licensees have j committed to performing these reviews and some have started. There are no NRC-approved j or issued guidelines or criteria for what will be considered by the staff to be an " acceptable" j ISA. Requirements are specified in OHSA regulations (29 CFR 1910) and EPA regulations
- (40 CFR 68) and detailed guidance is available from the American Institute of Chemical i Engineers. Ilowever, none of this addresses such issues important to the NRC such as nuclear criticality safety. Given the cost and resources required to perform an ISA, licensees
. should have some form of guidance or objective criteria regarding expectations and l
j acceptance criteria. Licensees should not have to complete the ISA and submit the results to 4 the NRC only to be told "this does not meet the draft criteria we are working on." The l Commission told NEl to submit a PRM regarding this, but a final rule and supporting j guidance needs to be in the plan, i
i i
s i
l
}
i i
1 i.
i i
3 i
a 3
2
, - .