ML20212D005
| ML20212D005 | |
| Person / Time | |
|---|---|
| Issue date: | 10/06/1986 |
| From: | Stello V NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML19310D971 | List: |
| References | |
| FRN-51FR37578, RULE-PR-70, RULE-PR-74 AB26-1-03, AB26-1-3, PR-861006, NUDOCS 8612310257 | |
| Download: ML20212D005 (20) | |
Text
i
[7590-01]
NUCl. EAR REGULATORY COMMISSION f
10 CFR Parts 70 and 74 Reporting of Special Nuclear Material Physical Inventory Summary Results AGENCY: Nuclear Regulatory Commission.
ACTION:
Proposed rule.
SUMMARY
The Nuclear Regulatory Commission (NRC) is proposing amendments to its regulations on special nuclear material control and accounting to require the reporting of summary results of physical inventories of special nuclear material.
The affected licensees have been providing this information on a voluntary basis since 1975.
The objective of these amendments is to provide a regulatory basis for the reporting of special nuclear material physical inventory data by licensees t:, provide information for the NRC inspection program and to provide inventory difference information to the public.
Incorporating special nuclear material inventory reporting into the NRC regulations is the most cost-effective way to obtain the necessary information.
DATES:
Submit comments by Comments received after this date will be considered if it is practical to do so, but assurance of consideration cannot be given except as to comments received on or before this date.
861229 37578 J
i ADDRESSES:
Send comments to:
Secretary, U.S. Nuclear Regulatory Commis-sion, Washington, DC 20555, ATTN:
Docketing and Service Branch.
Hand deliver comments to:
Room 1121, 1717 H Street NW., Washington, DC, between 8:15 a.m. and 5:00 p.m.
Copies of the regulatory analysis, OMB Clearance Supporting-Statement, and comments received may be examined at:
The NRC Public Document Room (PDR), 1717 H Street NY., Washington, DC.
Copies of NUREG-0430 are also available for inspection or copying for a fee in the PDR.
Copies of this report may be purchased from the U.S. Government Printing Office (GPO) by calling 202-275-2060 or by writing the GPO, P.O. Box 37082, Washington, D.C.
20013-7082. They may also be purcnased from the National Technical Information Service, U.S. Department of Commerce, 5285 Port Royal Road, Springfield, VA 22161.
FOR FURTHER INFORMATION CONTACT:
Darrell A. Huff, Office of Inspection and Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone (301) 492-7077.
SUPPLEMENTARY INFORMATION:
BACKGROUND The current material control and accounting (MC&A) regulations for fuel facilities require the performance of physical inventories of special nuclear material (SNM) on a periodic basis by licensees.
However, the regulations do not require licensees to report physical inventory results l
to the NRC unless certain thresholds prescribed in 10 CFR Part 74 are l
exceeded. The NRC needs this information to assess the material accounting performance of licensees and to monitor and assess licensee investigatory activities in response to inventory data which exceed specified limits.
l _
i In 1975 the Office of Inspection and Enforcement (IE) instituted a voluntary reporting system known as the Safeguards Status Report System (SSRS) whereby licensees were requested to report to the NRC physical inventory results in a prescribed format.
Currently,12 affected licensees make a voluntary commitment as part of their operating plan to report physical inventory results to the appropriate NRC regional office.
The information provided by these voluntary reports is also used as input by the NRC for NUREG-0430, " Licensed Fuel Facility Status Report / Inventory Differnce Data," which was initiated by the Director of IE in 1977 in response to congressional and public concerns.
NUREG-0430 reports
~
licensed fuel facilities physical inventory difference data following agency review of the information and completion of any related investigations.
Recognizing the need for the reporting of physical inventory results, IE requested an explicit regulatory basis for this physical inventory reporting system.
On August 23, 1976 (41 FR 35537), the NRC published in the Federal Register proposed amendments to 10 CFR Part 70 that would have required the reporting of the results of each ending physical inventory and any associated material accounting and measurement error data.
The proposed amendments were published for a 60-day public comment period.
Comments were received from seven respondents.
Final action on the reporting requirements was postponed, pending initiation of a separate but related rulemaking effort (the MC&A reform amendments).
The delay in implementing the MC&A reform amendments caused IE to request, in a memo dated June 2, 1982, that the Office of Nuclear Regulatory Research (RES) publish an amendment to 10 CFR Part 70 requiring reporting of physical inventories of SNM.
However, due to the unavailability of resources within RES, completion of this rulemaking was referred back to IE by the EDO j
in a memo dated May 21, 1986.,
o Ir 1983, a decision was made to create a new Part 74 which would pertain solely to MC&A safeguards requirements.
When 10 CFR Part 74 was published on February 28, 1985 (50 FR 7575), it contained the MC&A regulatory requirements for licensees authorized to possess and use more than one effective kilogram of special nuclear material of low strategic significance.
Certain safeguards-related recordkeeping and reporting requirements, formerly found in Part 70, were also moved to new Part 74 in order to separate them from safety reporting requirements.
Therefore, the reporting requirement for SNM physical inventory results is also being included in Part 74.
Because of the time lapse since the reporting requirements were published as a proposed rule, the NRC is republishing the requirements in proposed form.
The newly proposed amendments reflect comments and suggestions received when the amendments were first proposed in 1976 as well as comments and suggestions that were solicited from the NRC regional offices in 1983 and 1984.
These proposed amendments would require each licensee sifoject to the physical inventory require-ments of 10 CFR 70.51(e) and 74.31 to report the results of these inventories to the appropriate NRC regional office.
The impact of the reporting requirements on the affected licensees should be minimal because they have been reporting the information requested on a voluntary basis since 1975.
The requirements for performing the physical inventories and keeping appropriate records of those inventories have been in place since 1973.
Although the completion of the reporting form (NRC-327) will require an estimated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of effort per licensee per report, this will not be an additional effort since the affected licensees have been reporting volun-tarily.
The alternative to the licensees reporting the data is sending NRC inspectors out to collect it, which would have an adverse impact on the inspec-tion and enforcement program in terms of increased costs and staff time..
ENVIRONMENTAL IMPACT:
CATEGORICAL EXCLUSION The NRC has determined that the proposed rule is the type of action described in categorical exclusion 10 CFR 51.22(c)(3). Therefore, neither an environmental impact statement nor an environmental assessment has been prepared for this proposed rule.
PAPERWORK REDUCTION ACT STATEM5NT This proposed rule amends information collection requirements that are subject to the Paperwork Reduction Act of 1980 (44 U.S.C. 3501 et seq.).
This rule has been submitted to the Office of Management and Budget for review and approval of the paperwork requirements.
REGULATORY ANALYSIS The Commission has prepared a draft regulatory analysis on this proposed reguiation. The analysis examines the costs and benefits of the alternatives considered by the Commission.
The draft analysis is available for inspection in the NRC Public Document Room, 1717 H Street, NW, Washington, DC.
Single copies of the analysis may be obtained from Darrell A. Huff, Office of Inspection and l
Enforcement, U.S. Nuclear Regulatory Commission, Washington, DC 20555, telephone I
(301) 492-7077.
i
REGULATORY FLEXIBILITY CERTIFICATION As required by the Regulatory Flexibility Act of 1980, 5 U.S.C. 605(b),
the Commission certifies that this rule, if adopted, will not have a signi-ficant economic impact upon a substantial number of small entities.
Currently, 12 licensees, who are composed of low enriched uranium and high enriched uranium fuel manufacturing facilities, will be affected by these amendments.
The proposed rule codifies a reporting procedure that has been a licensee practice since 1975.
Accordingly, there is no new, significant economic impact on these licensees, nor are the licensees within the definition of small businesses set forth in section 3 of the Small Business Act, 15 U.S.C. 632, or within the Small Business Size Standards set forth in 13 CFR Part 121.
LIST OF SUBJECTS IN PARTS 70 AND 74 Part 70--Hazardous materials-transportation, Material Control and Accounting, Nuclear materials, Packaging and containers, Penalty, Radiation protection, Reporting and recordkeeping requirements, Scientific equipment, Security measures, Special nuclear material.
Part 74--Accounting, Material control and accounting, Nuclear mate-rials, Penalty, Reporting and recordkeeping requirements, Special nuclear material.
For the reasons set out in the preamble and under the authority of the Atomic Energy Act of 1954, as amended, the Energy Reorganization Act of 1974, as amended, and 5 U.S.C. 553, the NRC is proposing to adopt the following amendments to 10 CFR Parts 70 and 74. __-
PART 70--DOMESTIC LICENSING 0F SPECIAL NUCLEAR MATERIAL 1.
The authority citation for Part 70 continues to read as follows:
Authority:
Sec. 161, as amended (42 U.S.C. 2201); sec. 201, as amended (42 U.S.C. 5481).
2.
In S 70.53, paragraph (b) is amended to read as follows:
S 70.53 Material status reports.
n n
n n
n (b) Each licensee subject to the requirements of S 70.51(e) shall follow the requirements set out in SS 74.13(b) and 74.17(b) of this chapter.
n n
n n
n i
PART 74--MATERIAL CONTROL AND ACCOUNTING OF SPECIAL NUCLEAR MATERIAL 3.
The authority citation for Part 74 is revised to read as follows:
Authority:
Secs. 53, 57, 161, 182, 183, 68 Stat. 930, 932, 948, 953, 954,'as amended, sec. 234, 83 Stat. 444, as amended (42 U.S.C. 2073, 2077, 2201, 2232, 2233, 2282); secs. 201, as amended, 202, 206, 88 Stat. 1242, as amended, 1244, 1246 (42 U.S.C. 5841, 5842, 5846).
For the purposes of sec. 223, 68 Stat. 958, as amended (42 U.S.C.
2273); SS 74.17, 74.31, 74.81, and 74.82 are issued under secs. 151b and 1611, 68 Stat. 948, 949, as amended (42 U.S.C. 2201(b) and 2201(i)); and SS 74.11, 74.13, 74.15 and 74.17 are issued under sec. 1610, 68 Stat. 950, as amended (42 U.S.C. 2201(o)). _-
4.
In Subpart B $74.17 is added to read as follows:
Subpart B -- General Reporting S 74.17 Special Nuclear Material Physical Inventory Summary Report.
(a) Each licensee subject to the requirements of S 74.31 shall submit a completed Special Nuclear Material Physical Inventory Summary Report on NRC Form 327 not later than 60 calendar days from the start of the physical inventory required by S 74.31(c)(5).
The licensee shall report the inventory results by plant and total facility to the appropriate NRC regional office listed in Appendix A of Part 73 of this chapter.
(b) Each licensee subject to the requirements of 6 70.51(e) of this chapter shall submit a completed Special Nuclear Material Physical Inventory Summary Report on NRC Form 327 not later than 30 calendar days from the start of the physical inventory required by S 70.51(e)(3) of this chapter.
The licensee shall report the inventory results by plant and total facility to the appropriate NRC regional office listed in Appendix A of Part 73 of this chapter.
2 Dated at Bethesda, Maryland, this day of
, 1986.
For the Nuclear Regulatory Commission.
f g
Victor Stello, Jr.
Executive Director for Operations. J
OMB SUPPORTING STATEMENT FOR NRC FORM 327:
SNM PHYSICAL INVENTORY SUf#iARY REPORTS A.
JUSTIFICATION
_ev 1.
Need For The Information Collection.
Special Nuclear Material (SNM) is required to be controlled and accounted for because of the govern-ment's national security obligation to prevent or detect loss, diver-sion or theft, or even the appearance of loss, diversion or theft of quantities of SNM that could be used for clandestine nuclear devices.
To meet this obligation, the NRC's current safeguards matarial control and accounting regulations for fuel facilities require the conduct of physical inventories of SNM on a periodic basis by licensees. However, unless certain thresholds prescribed in 10 CFR Part 74 are exceeded, in which case some limited inventory results must be reported, the current regulations do not require licensees to report physical inventory results to the NRC.
Licensees have been voluntarily providing this information since 1975. Without voluntary responses, the NRC could obtain the information by sending inspectors to the licensed facilities, but this would have an adverse impact on the inspection program in terms of increased costs and staff time.
Nevertheless, the NRC would have to conduct inspections if licensees, for whatever reason, chose not to voluntarily supply the data.
There-fore, the NRC is proposing a rule that would require the reporting of physical inventory results on NRC Form 327 each time that a physical inventory is conducted by a fuel facility.
2.
Agency Use of Information.
NRC uses the information tor' Determine whether SNM is lost, diverted, or stolen; Assess the material control and accounting performance and compliance of SNM licensees; Make safeguards regulatory decisions; Fulfill the Commission's commitment to report to the public in NUREG-0430 (sample copy attached) differences between licensees' book and physical inventories.
3.
Reduction of Burden Through Information Technology.
Respondents report classified information and thus must adhere to security regulations.
Information technology is not immediately applicable to this relatively small amount of classified data.
4.
Effort to Identify Duplication.
The respondents' data are unique and are required only by the NRC regulations.
5.
Effort to Use Similar Information.
The physical inventory data required on NRC Form 327 are not presently available in any other NRC data collection system.
The NRC requires periodic SNM material status
4 reports from all SNM licensees (DOE /NRC Forms 742 and 742C), but that information'is based on licensees' book records and is not necessarily-the immediate results of a physical inventory.
Besides, there are-
. quantities required on NRC Form 327 that are not: included on the DOE /
NRC forms.
/
6.
Effort to Reduce Small Business Burden.
Not applicable.
7.
Consequences of Less Frequert Collection. The reporting period cor-responds to the inventory frequencies required by the NRC regulations.
The frequency depends essentially on the strategic significance of the SNM covered by a particular license.
Six existing strategic SNM licensees are required by 10 CFR 70.51 (e)(3) to inventory every two i
months.
Thus, these six licensees would submit a total of thirty-six reports per year.
~
1 Two licensees have LEU of moderate strategic significance, which i
must be inventoried every six months. Thus, there are four reports l
per year in this category.
Seven licensees have LEU of low strategic significance, which presently must be inventoried annually.
Thus, there are seven reports per i
year in this category.
Hence, there would be a total of forty-seven inventory reports
{
required per year.
Less frequent reporting would result in unaccept-able delays in determining whether SNM is lost, diverted, or stolen.
8.
Circumstances That Justify Variation From OM8 Guidelines.
Not applicable.
I 9.
Consultations Outside the NRC.
As yet, there have been tions outside the NRC; however, the requirement to repo no consulta-rt inventory results is being submitted as a proposed rule. Affected NRC licensees will have the opportunity to review the new form during the comment period for this rule.
10.
Confidentiality of Information.
The respondents' data for high enriched uranium (HEU) is classified and low enriched uranium (LEU) data is usually treated as proprietary.
Thus, the information is I
confidential.
The only exception is the periodic publication of j
inventory difference data (see item 2. above) in NUREG-0430, which requires the Commission's approval before the information is released.
11.
Justification for Sensitive Question.
The respondents' data is sensi-tive because it is related to national security, proprietary operations, or both.
12.
Estimated Annualized Cost to the Federal Government.
The collection i
of information will require an average of two hours of NRC staff time per report to review and evaluate licensees' physical inventory results.
i Thus, the annual labor costs for this activity will be $5,640 per year j
(47 reports /yr x 2 hrs / report x $60/hr).
In addition, the compilation, printing, and distribution of inventory difference information in :
NUREG-0430 is estimated to cost $1,360 per year ($600 for compilation,
$340 for printing, and $420 for distribution).
Therefore, the total annual cost to the Federal government will be approximately $7,000 per year.
13.
Estimate of Burden.
a.
Estimated Hours Required to Respond to the Collection:
The completion of the SNM Physical Inventory Summary Report will require approximately 4 staff hours of effort per licensee per report.
Therefore, the effort will be about 4 x 47 = 188 hours0.00218 days <br />0.0522 hours <br />3.108466e-4 weeks <br />7.1534e-5 months <br /> annually.
b.
Estimated Cost Required to Respond to the Collection:
The total costs for all respondents, at $60 per hour of staff time, is about 188 hours0.00218 days <br />0.0522 hours <br />3.108466e-4 weeks <br />7.1534e-5 months <br /> x $60/ hour = $11,280.
c.
Source of Burden Data and Method for Estimating Burden:
The burden data in terms of required staff hours is based on NRC's experience and bes,t judgment.
The effort required is for transcribing the data, checking the data, signing the form, and forwarding the report to the NRC.
It is not expected that the estimated staff hour burden will vary much from licensee to licensee.
d.
Reasonableness of Burden Estimates:
Because the effort required to complete the report takes place only after the effort of collecting inventory data has been completed, there should be minimal additional effort on the part of the licensee.
The estimate of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per report is probably conservative, allowing more time than is actually necessary.
14.
Reasons for Change in Burden.
Because licensees are now voluntarily reporting summary inventory data results, there is no increase in burden.
15.
Publication for Statistical Use.
NRC publishes semi-annual summaries of the inventory difference information included on NRC Form 327 in NUREG-0430, " Licensed Fuel Facility Status Report / Inventory Difference Data." These summaries are normally published in January and July t
of each year.
Due to declassification constraints, a six month delay is reflected in the information that is published.
B.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS Statistical methods are not used in the collection of information.
NRC Form 327 is only used to transcribe data already being calculated by the affected licensees as required by the current regulations. - -.
NRC Fare 327 Pcge 1 5
SNM PHYSICAL INVENTORY
SUMMARY
REPORT Licensee name:
Facility location:
Docket number:
License number:
Reporting peri.
From:
To:
Special Nuclear Material (SNM) categcry (HEU, Pu, U-233, LEU):
Licensee's Certifying Official:
Date:
Grams Element Grams Isotope (U or Pu)
(U-233,U-235, or Pu-239+Pu-241)
Beginning inventory.
Receipts.
+
Shipments.
Measured discards.
Ending inventory.
Net sum of biases
+
+
pertaining to but not included -
in the above quantities (circle the appropriate sign).
- Prior period adjustments
+
+
i (circle the appropriate sign). **
i
+
+
Inventory Difference (ID) (The algebraic sum of the above values.)
Grams Element Grams Isotope Limit of Error of the ID (LEID).
l LEID limit.
ID limit.
If the net sum of all biases is positive, circle the " " sign; if the net sum of all biases is negative, circle the "+" sign.
- If the sum of prior period adjustments increases the ID, circle the " " sign, if the sum of prior period adjustments decreases the ID, circle the "+" sign.
Attach explanations or comments to this form on corporation letterhead.
NRC Form 327 Pag: 2 DEFINITIONS OF QUANTITIES REPORTED BEGINNING INVENTORY: The quantity of SNM present at the facility as of the beginning of business on the first day of the period covered by the report.
This quantity must agree with the ending inventory value (element and isotope) on the last report submitted.
RECEIPTS:
The quantity of SNM received at the facility and other increases resulting from the introduction of additional SNM into the inventory during the reporting period.
SHIPMENTS:
The quantity of SNM that was shipped from the facility during the reporting period.
This includes any samples shipped for off-site analysis and parts of SNM receipts that were returned to the shipper.
Measured discards are not to be included, even if shipped during the reporting period for disposal.
MEASURED DISCARDS:
The quantity of SNM in the forms of gaseous, liquid and solid waste that has been discarded from the plant during the reporting period.
This quantity includes the amounts of discarded SNM that have been transferred to an official holding account, released to the environment under license conditions or methods approved pursuant to 10 CFR 20, or shipped to an authorized recipient for disposal.
ENDING INVENTORY:
The quantity of SNM that is indicated to be present at the facility as the result of the physical inventory.
BIAS:
A fixed error which remains constant over replicated measurements. (Refer to the license conditions for specific operational procedures for calculating bias.)
PRIOR PERIOD ADJUSTMENTS:
The quantity of SNM, increment or decrement, by which the centralized record system was adjusted during the current reporting period for verifiable corrections that were applicable to prior reporting periods.
Typically, this quantity will involve corrections of shipments and receipts to reconcile shipper-receiver differences, or corrections of errors associated with the beginning inventory that were detected after the previous report was submit-ted.
Any bias adjustments associated with these corrections should be included.
LIMIT OF ERROR OF THE INVENTORY DIFFERENCE (LEID):
The measurement uncertainty component used in constructing a 95 percent confidence interval associated with the ID after bias has been eliminated or its effects accounted for (this uncertainty component is twice the standard error of the estimated measurement uncertainty associated with the ID).
LEID LIMIT:
The applicable quantity in 10 CFR 70.51(e)(5), 10 CFR 74.31(c)(4) or another quantity assigned to the licensee by the NRC.
ID LIMIT: The applicable quantity in 10 CFR 74.13(b)(1), 10 CFR 74.31(c)(5) or another quantity assigned to the licensee by the NRC.
If exceeded, this quantity of material would prompt an investigation and possibly the submittal of a subsequent special report to the NRC.
~k a
REGULATORY ANALYSIS 10 CFR Parts 70 and 74 Reporting of Special Nuclear Material (SNM) Physical Inventory Results 1.
STATEMENT OF THE PROBLEM The current material control and accounting (MC&A) regulations for fuel facilities require the performance of physical inwntories of special nuclear material (SNM) on a periodic basis by licensees.
Unless certain thresholds prescribed in 10 CFR Part 74 are exceeded, in which case the inventory results are reported to the NRC, the current regulations do not require licensees to report physical inventory results.
Since 1975, the licensees have been voluntarily providing this information which serves as the source of data for NUREG-0430,
" Licensed Fuel Facility Status Report / Inventory Difference Data."
It also enables the NRC to assess the material control and accounting performance of licensees.
Currently,12 licensees voluntarily provide the results of physical inventories to the appropriate NRC regional office.
If they did not do so, NRC would have to conduct additional inspections to acquire the needed information, i
Because the voluntary SNM physical inventory reporting was instituted in 1975 and therefore predates the Paperwork Reduction Act of 1980, the voluntary reporting has never been through the OMB clearance process required by the Act.
Without the OMB clearance, the reporting cannot continue.
This would require the NRC to dispatch an inspector to the facility to gather the necessary SNM physical inventory data.
Because of the importance of the SNM inventory data to the NRC, the staff believes that the reporting of SNM physical inventory data should have a regulatory basis.
Incorporating the SNM inventory reporting into the NRC regulations is the most cost effective way of obtaining the necessary information.
2.
OBJECTIVE i
The objective of this amendment is to provide a regulatory basis for reporting of SNM physical inventory data by licensees to provide information 4
s for the NRC licensing and inspection program and to provide inventory difference information to the public.
3.
ALTERNATIVES The alternatives considered for accomplishing this objective were as follows.
3.1 Maintaining the Status Quo The reporting of SNM physical inventory data has been a licensee practice on a voluntary basis since 1975.
By maintaining the status quo, the NRC would not be in compliance with the Paperwork Reduction Act of 1980.
3.2 Combining the SNM Physical Inventory Reporting With Other Material Accounting Reports In the past, consideration has been given to combining the information requested in the SNM Physical Inventory Summary Report with the material accounting information required on DOE /NRC Form 742, Material Balance Report, and DOE /NRC Form 742C, Physical Inventory Listing.
However, the reporting of physical inventories does not mesh with the current biannual requirement for reporting book inventories on Forms 742 and 742C.
3.3 Obtaining the Information through Inspection An alternative to reporting SNM physical inventory data is to obtain it by inspection.
If the NRC sends its inspectors out to obtain it, the increased costs in time and money incurred by the licensee and the NRC are significant.
One to six additional inspections per licensee, per year, depending on the
{
frequency of physical inventories, would be required.
Each inspection would be j
expected to take a minimum of six hours time to acquire the necessary information.
Licensees are billed on a per hour basis for inspections up to a negotiated l
maximum cost per year.
If the number of routine inspections is increased, this maximum can be renegotiated upward.
The fees that are collected by NRC are sent 4
to the U.S. Treasu:y and are not put into NRC's operating funds.
The NRC's costs O
for inspection include the inspector's salary, his actual expenses while on travel for the inspection, and the costs of his transportation to and from the site.
For example, costs for a single inspection at Nuclear Fuel Services, Inc.
(NFS) located in Erwin, Tennessee would be:
for NFS, 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> of inspection time at $56 per hour or $336.
for NRC, two days of an employee's time at $20 per hour, expenses 4
not to exceed $50 for two days, air fare of $235 and car rental at
$25 per day for a total of $705, 3.4 Codifying Current Licensee Practice Codifying the current voluntary practice of reporting SNM physical inven-tory results would have minimal impact on the licensees.
Completion of the report form would require an estimated 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of effort per licensee per report.
This would not be an additional effort since the licensees have been doing it volun-tarily. Having the licensees report physical inventory results is the most cost effective way for the NRC to obtain them.
t 4.
CONSEQUENCES The impact of codifying the reporting requirements should be minimal because the 12 affected licensees have been reporting the information on a voluntary basis i
since 1975.
The alternative to having the licensees report the data is to send NRC inspectors out to collect it, which would have an adverse impact on the inspection and enforcement program.
5.
DECISION RATIONALE i
1 1
i Since the information presently needed and required on Forms 742 and 742C for all major nuclear facilities differs significantly from the information that is needed for reporting the results of the physical inventories conducted by fuel facilities (see Form 327), the two reporting requirements are not compatible.
Codifying the SNM physical inventory reporting will enhance the inspection and 1
i l
1 3-i
,-.r
. _.. _ _, - _ ~.
_m.m-
.-_,.,,,,,,.-,-.,_-._,_,m._.,_
m
+
4 i
e enforcement program by providing a regulatory basis for this reporting without placing any additional burden on the NRC or licensee.
Other alternatives were rejected because they did not fully accomplish this objective.
4 i
i e
i j
i i
i i
i
(
i 1
4-2 i
t
.---4r-.,=+-..%....-
r_..
r--
_-m._
m,
,,,._,,_____,,._,_._._~,___,y.
,.,,m
._.,_m...,
6 DRAFT CONGRESSIONAL LETTER
Dear Mr. Chairman:
The NRC has sent to the Office of the Federal Register for publication the enclosed proposed amendments to the Commission's rules in 10 CFR Parts 70 and 74.
The amendments, if adopted, would require licensees to provide to the NRC the results of physical inventories of special nuclear material (SNM).
The current material control and accounting regulations which require physical inventories of SNM on a periodic basis do not require the licensees to report the results unless thresholds given in 10 CFR Part 74 are exceeded.
The NRC needs and uses the results of physical inventeries to monitor and assess the material control and accounting performance of licensees and to provide the data for NUREG-0430, " Licensed Fuel Facility Status Report / Inventory Difference Data."
Although this information is now provided to the NRC by the affected licensees on a voluntary basis, codifying the current procedure and requiring the licensee to provide it is preferable and cost-effective.
The Commission is issuing the proposed rule for 30-day public comment.
Sincerely, James M. Taylor, Director Office.of Inspection and Enforcement
Enclosure:
Federal Register Notice
g 9
Victor Stello, Jr.,
)istribution 1C5 SMPS reading D
DI reading l
OHuff, IE 4
SFratalli, MSS LCobb, IE RSpessard, IE I
H0enton, NRR 8 Hayes, O!
JOavis, ADM MSS
- PNorry, Warler, 0GC TMurley, RI JGrace, RII JKappler, RIII RMartin RIV JMartin,,RV CRGR members:
RBernero EJordan CHeltames W 5tarostocki.bh" 0FC :
}
- 5MPB IE
- 00:[
- 0:0 h '..
- D:0I w me
- D:hRR gemo : D:NM55 men,e
. 2,
......w.w... S em.. %.
......hbTo,m,,......e.........9: JPIsr NAME :D uff
- R5dessard ow
- BHayes
- HDenton
- JDsvis DATE$8/4p66sc is/21/86
$8/j/86 iB/)f/86 is/4/86 i8/15/86
$8/15/86 QFC : D: 0GC fmetw. :0:ADM wiemo : Region Irem:Re ion IIvww Re ion IIIsoeRegion IVtemRe ion VW.
-- - : 4-4 keg 6cc : O,-DL *--t-: -T' %$-:
9 UMuts.--: -
% :-W5-2 JK NAME :WParler
- PNorry 7: TMurley
- JGrace
- JKeppler
- RMartin
$JMartn g
DATE :8/6/86
- 8/8/86
- 8/5/86
- 8/7/86
- 8/7/86
- 8/18/86
- 7/30/86 4254 p t n
orG :E IE
- Af E
'NAMElJ lW rostechi VS lo,Ji.
i i
DATE $8 6 86 i8/1Af/86 i\\ C/ V /86 i i
~
'\\
- .e
- - - ~ ~
... - ~ ~ ~ -,. -..
L
l ATTACHMENT 2
EIRIEmule "f
,.o=
al um I museum ammene i
f.7 Documents l
i I
i i
t i
i
s.
A6%-1
-t T'
g** "'% 4 UNITED STATES k
NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SEP 2 01905 MEMORANDUM FOR:
Those on Attached List FROM:
Frank P. Gillespie, Director Division of Risk Analysis and Operations Office of Nuclear Regulatory Research
SUBJECT:
PROPOSED AMENDMENTS TO 10 CFR PARTS 51, 70 AND 74 'SPECIAL NUCLEAR MATERIAL (SNM) PHYSICAL INVENTORY
SUMMARY
REPORTS" Enclosed for your review and concurrence is the transmittal letter for the subject rulemaking. The transmittal letter includes a Federal Register notice and regulatory analysis as well as a draft of the letter notifying the appropriate congressional committees.
Comments on this proposed rulemaking which were received from IE, hMSS, ELD, ADM and the regional offices have been incorporated.
Your concurrence is requested by October 7, 1985.
Please contact Dr. Sandra Frattali (FTS-443-7890) if there are any questions, h
}hj!0 f.
t L
Frank P. Gillespie, Director Division of Risk Analysis and Operations Office of Nuclear Regulatory Research
Enclosure:
As stated j
l
ADDRESSEES John G. Davis, Director Office of Nuclear Materials Safety and Safeguards Harold R. Denton, Director Office of Nuclear Reactor Regulation James M. Taylor, Director Office of Inspection and Enforcement Guy H. Cunningham Executive Legal Director Ben B. Hayes, Director Office of Investigations Patricia G. Norry, Director Office of Administration Thomas E. Murley, Regional Administrator Region I J. Nelson Grace, Regional Administrator Region II James G. Keppler, Regional Administrator Region III Robert D. Martin, Regional Administrator Region IV John D. Martin, Regional Administrator Region V
DISTRIBUTION:
~
Circ Chron RMinogue Dross
- ,p,,, tg.3 FGillespie MErnst JNorberg PTing SFrattali SFrattali/rdg MEMORANDUM FOR
Those on Attached List JPSC/subj HFSG/rdg FROM:
Frank P. Gillespie, Director Division of Risk Analysis and Operations Office of Nuclear Regulatory Research
SUBJECT:
PROPOSED Ai!ENOMEtiTS TO 10 CFR PARTS 51, 70 AND 74 "SPECIAL NUCLEAR KATERIAL (SNM) PHYSICAL INVENTORY SUMt!ARY REPORTS" Enclosed for your review and concurrence is the transmittal letter for the subject rulemaking. The transmittal letter includes a Federal Register notice and regulatory analysis as well as a draft of the letter notifying the cppropriate congressional cocuittecs.
Coments on this proposed rulemaking which were received from IE, htiSS ELD, ADM and the regional offices have been incorporated.
Your concurrence is requested by October 7, 1985.
Please contact Dr. Sandra Frattali (FTS-443-7890) if there are any questions.
N Frank P. Gillespie, Director Division of Risk Analysis and Operations Office of Nuclear Regulatory Research
Enclosure:
As stated m
n HF{GB:DR40
-m.>
HFSGB:DRA0 F
DD DRA0:R S Dg:RES
~ [ih
.> Shallh'l'i:ce PT V rber
'MErst FGiTEspN 9/f/85 9/t$/55 9/d/85
'I'9 9/' d5
- w. >
N:c rone ne no soi Nacu ano OFFICI AL RECORD COPY-
~
ADDRESSEES John G. Devis, Director Office of Nuclear Materials 1
Safety and Safeguards Harold R. Denton, Director Office of Nuclear Reactor Regulation James M. Taylor, Director Office of Inspection and Enforcement Guy H. Cunningham Executive Legal Director Ben B. Hayes, Director Office of Investigations Patricia G. Norry, Director j
Office of Administration i
i Thamas E. Marley, Regional Adr.inistrator i
Region I J. Nelson Grace, Regional Administrator Region II i
James G. Keppler, Regional Administrator Region III j
Robert D. Martin, Regional Administrator Region IV l
John D, tiartin, Regional Adr.inistrator Region V l
I CUSN&Wih osn >
s:c recu n.. io.oi sacu e" OFFICIAL RECORD COPY J