ML20237G286
| ML20237G286 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/01/1987 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20237G255 | List: |
| References | |
| RTR-NUREG-BR-0006, RTR-NUREG-BR-6 5211-87-2083, NUDOCS 8709020182 | |
| Download: ML20237G286 (3) | |
Text
7 GPU Nuclear Corporation i
Gr,qu Nuclear
=,,omgreo l
Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Mter's Direct Dial NMen June 1, 1987 5211-87-2083 Mr. William T. Russell Region I, Regional Administrator U.S. Nuclear Regulatory Commission i
631 Park Avenue King of Prussia, PA 19406
Dear Mr. Russell:
Three Mile Island Nuclear Station, Unit 1 (TMI-1) l l
Operating License No. DPR-50 i
Docket No. 50-289 1
Submittal of DOE /NRC Form 741 On October 30, 1986, GPUN submitted the Semi-Annual Material Status Report for April 1,1986 to September 30, 1986 for TMI-1. As stated in our cover letter, we have evaluated the need to submit DOE /NRC Form 741 pursuant to 10 CFR 74.15.
10 CFR 74.13 requires the submission of DOE /NRC Form 742, Material Balance Report and DOE /NRC Form 742C, Physical Inventory Listing on a semi-annual basis for special nuclear material that is received, produced, possessed, transferred, consumed, disposed of, or lost.
10 CFR 74.15 requires the submission of DOE /NRC Form 741, Nuclear Material Transaction Report when special nuclear material is transferred or received. These forms are to be completed in accordance with printe'd instructions which are contained in NUREG/BR-0006.
In January 1980, NUREG/BR-0006 was revised to include a new " requirement" in the instructions for filing DOE /NRC Form 741. The NUREG required a DOE /NRC Form 741 for the reporting of special nuclear material-and source material inventory changes. This requires the reporting of a fictitious transfer from the licensee to the licensee each six months to calculate the material loss due to natural decay.
This had been calculated by Oak Ridge National Laboratory prior to 1980.
In late 1982, GPUN was made aware of the change and new reporting requirement via telephone calls from Oak Ridge.
In March 1985, NUREG/BR-0006 was again revised to specifically state that decay was to be reported as part of the nuclear material loss data.
The " apparent requirement" to report nuclear material losses due to decay resulted from changes to NUREG/BR-0006 and was not the result of more formal processes associated with Backfit Policy, OMB clearance requirements, and Paperwork Reduction Act reviews. GPUN therefore considers the NUREG instructions as guidance only.
It is our intent to submit DOE /NRC Form 741 on 8709020182 870825 PDR ADDCK 05000289 P
PDR GPU Nuclear Corporation is a subsidlary of the General Public Utilities Corporation L
~.
5211-87-2083 June 1, 1987 a semi-annual basis although identical information is provided on Form 742.
GPUN, however, will not accept a deviation or Notice of Violation for failing to complete 741 in accordance with NUREG/BR-0006 unless these instructions undergo the formal, procedural scrutiny and approval which valid requirements undergo.
Sincerely, b
RJ D. Hukill Vice President & Director, TMI-1 HDH/SM0/spb:0857A cc:
R. Conte, USNRC USNRC Document Control Desk l
i l
i 1
\\
/;
$O
- C#
gG ta0 e.3 g
},...
e 9
,