ML20212D778

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Comment Supporting Proposed Rules 10CFR50 & 10CFR72 Re Reporting Requirements for Nuclear Power Reactors
ML20212D778
Person / Time
Site: Portsmouth Gaseous Diffusion Plant, Paducah Gaseous Diffusion Plant
Issue date: 09/20/1999
From: Toelle S
UNITED STATES ENRICHMENT CORP. (USEC)
To:
NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-64FR36291, RULE-PR-50, RULE-PR-72 64FR36291-00011, GDP-99-0163, NUDOCS 9909240072
Download: ML20212D778 (2)


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GDP 99-0163 Secretary, U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 ATTN: Rulemakings and Adjudications Staff Paducah Gaseous Diffusion Plant (PGDP)

Portsmouth Gaseous Diffusion Plant (PORTS)

Docket Nos. 70-7001 & 70-7002 USEC Comments on NRC's Proposed Rule, " Reporting Requirements for Nuclear Power Reactors," (64 FR 36291)

Dear Madam:

The United States Enrichment Corporation (USEC) is pleased to submit the following comments on the NRC's Proposed Rule, " Reporting Requirements for Nuclear Power Reactors."

USEC agrees with the Commission and the industry that the change to the reporting requirements of 10 CFR 50.73 allowing 60 days to submit a follow-up written event report is appropriate. However, USEC believes that the Commission's decision to currently limit the applicability of this change to Part 50 licensees is too narrowly focused. USEC understands that the NRC is considering the feasibility of expanding the applicability of this change to other categories oflicensees in the future. Written reports required by 10 CFR 76.120 are similar in nature to Licensee Event Reports required by Part 50.73, in that they also require a root cause analysis and corrective action plan g 'E development USEC, therefore, requests that 10 CFR 76.120(d)(2) be similarly amended F

to allow the submittal of written event reports within 60 days of discovery in order to f,

allow time to complete root cause analyses and corrective action plans.

N USEC agrees with the Commission that this longer time allowance would reduce the

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h number of event reports that require revision to update information resulting in resource g

savings with little or no reduction in safety.

In keeping with the spirit of the rd g

Commission's proposed change, USEC would continue to make every effort to complete EE and submit reports on a time scalegmmensurate with the significance of the issue.

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6h03 Rockledge Drive, Ilethesda, MD 20817-1818 Telephone 301-564-3200 Fax 301-564-3201 http://www.usec.com Offices in Livermore, CA Paducah, KY Portsmouth, OH Washington, DC

Secretary, U. S. Nuclear Regulatory Commission September 20,1999 GDP 99-0163, Page 2 Thank you for the opportunity to provide our comments. We would be pleased to discuss these comments with you. Please contact Ms. Lisamarie Jarriel at USEC HQ (301) 564-3247, Mr. Mike Boren at PGDP (270) 441-6777, or Mr. Scott Scholl at PORTS (740) 897-2373.

Sincerely, Nab d a Steven A.Toelle Nuclear Regulatory Assurance and Policy Manager cc: Robert Pierson, NRC HQ Patrick Hiland, NRC Region III Office Kenneth O'Brien, NRC Resident Inspector - PGDP David Hartland, NRC Resident Inspector - PORTS

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