ML20205Q383
| ML20205Q383 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 01/28/1986 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF THE SECRETARY (SECY) |
| Shared Package | |
| ML20205Q362 | List: |
| References | |
| NUDOCS 8605280276 | |
| Download: ML20205Q383 (2) | |
Text
_
Mr. K. P..Barr April 28, 1986 a
GENERALh ELECTRIC ATTACHMENT 3 i NUCLEAR FUEL MANUFACTURING DEPARTMENT GENERAL ELECTmC COMPANY + P.o. BOX 780 + WILMINGTON. NORTH CAROUNA 28402 January 28, 1986 Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Docketing and Service Branch
Subject:
ADDITIONAL COMMENTS REGARDING PROPOSED NRC RULE FOR CHANGES TO SAFEGUARDS REPORTING REQUIREMENTS
Reference:
Federal Register, Vol. 50, No. 166, Tuesday, August 27, 1985 On October 15, 1985, General Electric provided several comments on the proposed NRC actions.
Within the past few days General Electric i
I has learned of additional areas within the regulation which need improvement so as to remove an inherent vulnerability to the NRC and to the licensees.
is clearly in the bestWhile the public comment period has expired, it interest of the NRC and the public to consider these improvements at this time, i
10 CFR 70.52, " Reports of Accidental Criticality or Loss or Theft or Attempted Theft of Special Nuclear Material", and 10 CFR 74.11,
" Reports of Loss or Theft or Attempted Thef t of Special Nuclear Material",
to immediately report to the NRC. include a number of situations which require the criticality and thef t are clearly addressed.The subjects of accidental The subjects of
" attempted theft" and in particular " loss" or " accidental loss" adequately addressed so as to be universally clear as not are the NRC needs and what to what is required of the licensee.
General Electric provided recommendations in our for definitions of the terms " lost" 10/15/85 response and " unaccounted for" as they relate to transportation.
These are still clearly needed.
The NRC should also provide a definition of the phrases " attempted theft" and " unlawful diversion" so that this reporting is clearly understood by the NRC,the situation which requires the public.
the licensee and 8605280276 860428 PDR ADOCK 07001113 i
C PDR
GENERAL $ ELECTRIC Secretary of the Commission January 28, 1986 Page 2 The term " loss" as it relates to material control and accountability situations also needs definition.
There has been an attempt to 1
clarify the word by the exemption of measured discards and inventory difference.
We think that in the case of losses which involve the material control and accounting _ aspects of licensee programs, the term should be " accidental loss (es)" and should be defined as losses of material which are not measured ~ nor# accounted for by the MC& A system which is approved for the facility. '
With the above clarification of-the-term " loss", the NRC would be given immediate notification when tJua safeguard system does not function properly.
The NRC would then be ~in a position to quickly evaluate the licensee's corrective /kecovery actions to ensure that they are adequate.
Conversely,, megsured discards determined in accordance with approved licens'ee' criteria would not require special notification in addition topthe normal monthly reporting requirements (even if higher than normal).
As 10 CFR Part 20 already includes appropriate evaluation and reporting recuirements for conditions or. situations as they relate to radiological safety, the reporting requirements of Parts 70, 73, and 74 should be limited to safeguards considerations and significance so as to reduce the overall redundancy and confusion the composite regulatory structure c -
in General Electric hopes that these"domments will be useful to you in your ef forts to improve regulations.
If you have any questions or would like to discuss these comments further, please contact me.
4 Sincerely,._
GENERAL ELECTRIC COMPANY fp).
, Sa T. Preston Winslow, Manager Licensing & Nuclear Materials Management M/C J-26
/sbm cc:
Priscilla Dwyer Willard Brown
+
o DOCKET NO.
2d- ///
CONTROL NO.
M [n h 3 h OIb[ h[
DATE OF DOC.
/d
/8d>
OATE RCVD.
m
/
'f ren ecvF FCAF LPDR kN I6E REF.
smcuars /
een PC rC._
OTHER
- ;'gCR I t't IGN :
/
/
--,/
/
-4547,/s 1strm die 1
-\\n d
~
N WW V