ML20197B579
| ML20197B579 | |
| Person / Time | |
|---|---|
| Site: | Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant |
| Issue date: | 02/27/1998 |
| From: | Toelle S UNITED STATES ENRICHMENT CORP. (USEC) |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-63FR275, RTR-REGGD-05.062, RTR-REGGD-5.062, TASK-*****, TASK-RE 63FR275-00012, 63FR275-12, GDP-98-0026, GDP-98-26, NUDOCS 9803110191 | |
| Download: ML20197B579 (3) | |
Text
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GDP 98-0026 Chief, Rules and Directives Branch Division of Administrative Services
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I)ocket Nos. 70-7001 & 70-7002 0
III USEC Comments on Draft NUREG-5008,63 Fed. Reg. 275 (January 1998) b.O D
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Dear Sir:
On behalf of the United States Enrichment Corporation (USEC), I am pleased to provide comments on Drall NUREG 5008, " Reporting of Safeguards Events." in general, USEC found this guidance usefult however, there were some areas where further clarification would be helpful. Those instances are noted in the enclosed remarks.
If there are questions concerning these comments, please contact hir. Bern Stapleton at (301) 564 3492 or his. Amy Rebuck of my staff at (301) 564-3246.
Sincerely,
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I Steven A. Toelle Nuclear Regulatory Assurance and Policy hianager Enclosure cc: NRC Region 111 NRC Resident inspector - PGDP NRC Resident inspector - PORTS NRC Special Projects Branch. NhtSS g g ggg 9003110191 900227 FDR ADOCK 07007001 C
PDR 6903 Rockledge Drhe. Bethesda. MD 20817-1818 Telephone 301464 3200 Fax 301464-3201 http://wn mec.com 00kn in thermore. CA Paducah, KY Ibrismouth. OH Washington, DC
GDP 98 0026 Page1of2 USEC COMMENTS ON DRAFT NUREG-5008,63 FED. REG. 275 Section 2.2, Examples of Safeguards Events to be Reported within One llour 1.
Homb Threats NRC is inconsistent in its application of the bomb threat event. Such event notifications should distinguish between significant and non significant bomb threat events. Only credible events or actual security compromises should be considered significant and reported within one hour to NRC. Other events listed in the reportability appendix have bo:h significant and non-significant instances. One hour reports should only be required if the security system fails ta operate as designed or required by NRC regulations and an actual event (not a threat) oc-urs.
Submission of this information does not appear to permit NRC " analysis of safeguards system reliability and availability" which is the stated goal of one hour reports. NRC may wish to consider the following:
Examples of significant bomb threat events requiring a one hour report would be:
1)
A bomb threat and a simul, ( ; or real device found on plant property.
2)
A bomb threat and indication that the security system has been compromised.
3)
A bomb threat and an evacuation.
Examples ofless significant bomb threat events requiring logging would be:
1)
A bomb threat with no indication of security system compromise.
2)
A generic bomb or extortion threat to a person or company without specifics.
2.
Dual reporting required for classified documents should be climinated.
item #4, " Discovery of thefl or loss of classified documents or significant unclassified safeguards infonnation outside 'he protected area pertaining to facility or transport safeguards for which compensatory measures have not been implemented."
The loss of classified ir. formation is already covered under 10 CFR Pan 95. To avoid multiple reporting of the same event, the NRC should use the same language as in item #5 concerning duplicate repons. (i.e. " Note: Events reportable under 10 CFR 95.57 do not require duplicate repons under 10 CFR 73.71.")
GDP 98-0026
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Page 2 0f 2 i
Currently, the NRC requires the loss of classified documents to be reported to three different -
entities within the NRC, all within one hour. Part 73.71 requires a one hour report be made to the NRC 1leadquarter's Duty Officer and Part 95.57 requires the same report to also be made I
to the Regional Administrator and the Division of Security and Facilities. This does not appear
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cffective and is an unnecessary burden on those regulated.
3.
Inconsistency in application of reportable events USEC agrees with the staff that the reportability of the loss of safeguards information is dependent on the infomiation's signifierace. Part 73 allows such a distinction. This appears inconsistent with 10 CFR Part 95 which requires that all such incidents to be reported regardless of their signincance. Part 73 should not contain redundant reporting requirements. Part 95 should recognize the significance ofinformation on the security system as Part 73 currently does.
4.
Classified Parts Also, the current requirements of 10 CFR Part 73.71 consider the loss or theft ofclassified parts (machinery or equipment) as a loggable event. USEC agrees; however,10 CFR Part 95 defines the same event as reportable. Part 73 should be revised so that the loss of class 10cd parts are treated the same as the loss of nuclear material or classified documents. The loss of classification parts is as significant as the loss of documents describing such parts.
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