ML21300A135
| ML21300A135 | |
| Person / Time | |
|---|---|
| Site: | 07007003, 07007004 |
| Issue date: | 10/26/2021 |
| From: | Karen Fitch American Centrifuge Operating, Centrus Energy Corp |
| To: | Office of Administration |
| References | |
| 86FR52926 00001, ACO 21-0060, NRC-2021-0170, NUREG-2159 | |
| Download: ML21300A135 (7) | |
Text
10/26/21, 4:17 PM blob:https://www.fdms.gov/48a9e3c2-c9f1-4fad-8d32-3540507c04a9 SUNI Review Complete As of: 10/26/21 4:16 PM Template=ADM-013 Received: October 26, 2021 PUBLIC SUBMISSION E-RIDS=ADM-03 ADD: Tom Pham, Status: Pending_Post Tracking No. kv8-57i9-v8p7 Mary Neely Comment (1)
Comments Due: November 22, 2021 Publication Date: Submission Type: Web 9/23/2021 Citation: 86 FR 52926 Docket: NRC-2021-0170 Acceptable Standard Format and Content for the Fundamental Nuclear Material Control Plan Required for Special Nuclear Material of Moderate Strategic Significance Comment On: NRC-2021-0170-0001 Acceptable Standard Format and Content for the Fundamental Nuclear Material Control Plan Required for Special Nuclear Material of Moderate Strategic Significance Document: NRC-2021-0170-DRAFT-0002 Comment on FR Doc # 2021-20631 Submitter Information Email: fischelsra@centrusenergy.com Organization: Centrus Energy General Comment See attached file(s)
Attachments ACO 21-0060 signed letter no bcc blob:https://www.fdms.gov/48a9e3c2-c9f1-4fad-8d32-3540507c04a9 1/1
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- of Nuclear Power October 26, 2021 ACO 21-0060 ATTN: Program Management, Announcements and Editing Staff Office of Administration Mail Stop: TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 American Centrifuge Lead Cascade Facility and American Centrifuge Plant Docket Numbers 70-7003 and 70-7004; License Numbers SNM-7003 and SNM-2011 Comments on draft NUREG-2159, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control Plan Required for Special Nuclear Material of Moderate Strategic Significance, Docket ID NRC-2021-0170 To whom it may concern:
American Centrifuge Operating, LLC (ACO) appreciates the opportunity to provide the comments in Enclosure 1 to the draft NUREG-2159, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control Plan Required for Special Nuclear Material of Moderate Strategic Significance.
If you have any questions regarding this matter, please contact me at (740) 897-3859.
Sincerely, l~Y4U Kelly L. Fitch Regulatory Manager cc: Y. Paraz, NRC HQ American Centrifuge Operating, LLC 3930 U.S. Route 23 South - P.O. Box 628 Piketon, OH 45661
Enclosure 1 to ACO 21-0060 Comments on draft NUREG-2159, Acceptable Standard Format and Content for the Fundamental Nuclear Material Control Plan Required for Special Nuclear Material of Moderate Strategic Significance Information Contained Within Does Not Contain Export Controlled Information Reviewing Official: #1014, ACO Date: 10/25/2021
Enclosure 1 ACO 21-0060 Page 1 of 4 Number NUREG Page Text Comment Proposed Resolution Section 1 Section 2 6 lines 8- The MC&A program The proposed guidance far exceeds Remove the noted text entirely.
Item 4 18 needs to protect against a the requirements found in Subpart single insider, providing D 74.41 (c) as well as the similar Replace with a paragraph stating: Where the that requirements found in Subpart E organizational structure is such that a position individual does not have for SSNM and is not a credible having responsibility within the 10 CFR Part 74 authority within the concern. MC&A program also has responsibility within the physical protection system 10 CFR Part 73, Physical Protection of Plants and that would permit him or 74.43(b) (1) A management Materials, system, the plan will address roles and her to participate in a structure shall be established, responsibilities to ensure the MC&A program is not conspiracy aimed at documented, and maintained that subject to compromise by the actions of a single defeating the safeguards assures: insider filling the position. A safeguards manager system. If an MC&A could be an example of such a position.
individual does have (i) Clear overall responsibility for authority within the material control and accounting physical protection (MC&A) functions.
system, the MC&A program is required to protect against the (ii) Independence from production coverup of a collusion of and manufacturing responsibilities; that individual with any and other individual having MC&A authority. To (iii) Separation of key address collusion responsibilities.
concerns, the licensee or applicant would need to This provides sufficient protect an MC&A independence of activities.
function performed by a worker without physical For most licensees, such a position protection system would require access to SGI and as authority against a single such the individual would be insider.
granted access to SGI in This approach should accordance with 73.22(b) which allow licensees or includes a background check to applicants to provide determine the individual is adequate without trustworthy and reliable, and for requiring a totally some licensees such a position redundant system while still maintaining the
Enclosure 1 ACO 21-0060 Page 2 of 4 Number NUREG Page Text Comment Proposed Resolution Section ability of the MC&A would require either an L or Q program to clearance.
provide an extra level of independent protection and an added measure of assurance that the safeguards system as a whole has not been compromised.
2 Section 20 lines All contractor or offsite This is an arbitrary time frame not Reword to remove the 30 days and state Findings 55.1.3 36-39 laboratory assessment specified in the regulations. and recommendations are to be addressed consistent findings and with the licensees QA and Corrective Action recommendations should Program.
be documented and submitted to both the measurement control program manager and the overall MC&A manager within 30 days of completion of the review.
3 Section 21 lines FNMCP plan should Sentence is a recommendation, Reword sentence to state FNMCP should address 5.2 6-7 describe. must with an embedded requirement, the following applicable attributes:
include as appropriate then a caveat is applied.
4 6.2 37 lines Licensees should also Normal technical review by one Reword to state licensees should commit to 28-31 commit to having at least other qualified individual is the independently verify the accuracy of the ID and two individuals nuclear industry normal practice. SEID calculations for each total plant material independently verify the To invoke two additional balance.
accuracy of the ID and verifications for such a highly SEID calculations for specialized function is an extreme Also, although provided elsewhere, the formula for each total plant material burden on the licensee with no SEID should be provided in this section.
balance. If the SEID value clear regulatory basis. Also, the is calculated by a SEID does not directly affect the computer, the verification accounting records; it is calculated by two or more persons to determine if you are in control.
involves a checking for correctness of the input data used by the computer to calculate SEID.
Enclosure 1 ACO 21-0060 Page 3 of 4 Number NUREG Page Text Comment Proposed Resolution Section 5 6.3 38 lines unless the effect of a Provide basis as to what is meant Reword or remove unusually large or state the 29-30 single significant bias or by unusually large. NRC following: The bias correction is only applied if it the net sum of all acceptance criteria does not is significant with 95% confidence and exceeds the significant biases is normally call for applying bias rounding error.
unusually large. corrections to either the accounting records or as an adjustment.
6 6.3 38 line Provide basis as this appears to be Reword: if such bias is statistically significant at 44 the bias is greater than a new criterion being introduced. the 95 percent confidence level, and exceeds the 0.01 percent relative rounding error of the affected items. The bias correction is intended to correct the ID. Its impact on the SEID should also be propagated, resulting in an adjustment to the SEID.
7 6.4, 4th 39 line 74.43 (c) (8) (iii) Correct citation may be (i) versus Confirm and correct as needed.
Bullet 36 (iii) 8 7.5 44 lines Dynamic Inventory There is no direct regulatory basis Suggest rewording to remove the 3 months and 13-14 periodicity of 3 months for the 3 months stated. state at a frequency that takes onto account the potential for loss or diversion from the operation 9 7.6 47 lines Warning-level ID: Provide regulatory / technical basis Provide basis for suggested warning ID levels and 28-38 Plutonium, U-235, or U- for these suggested warning ID address 10 kg vs 9 kg value or just remove.
233 ID 1.7 (SEID) or levels.
uranium ID 1.7 (SEID) and 10 kg U Also, if keeping the 10kg should Significant ID problem: be changed to 9 kg Plutonium, U-235, or U-233 ID 3(SEID) and 300 grams of U-235 in HEU or 200 grams of plutonium or U-233 or 9,000 grams of U-235 in LEU 10 7.7 49 lines This is unnecessary and basis for Remove text 48-50) will result in a 90-percent 0.4% is unclear.
(or better) probability of detecting a discrepancy equal to or greater than 0.4 percent of the active inventory
Enclosure 1 ACO 21-0060 Page 4 of 4 Number NUREG Page Text Comment Proposed Resolution Section 11 8.2 51 lines The following items that Include common exemption for Also include the guidance from the previous draft 29-39 can be exempt from item samples. regarding the exemption for laboratory samples and control program reference standards maintained in the laboratory coverage in accordance material management system and containing with 10 CFR uranium enriched to less than 20 percent in the 74.43(c)(6): uranium-235 isotope.
- items whose time of existence is less than 14 calendar days
- any licensee-identified items each containing less than 200 grams of plutonium or uranium-233 or 300 grams or more of uranium-235 up to a cumulative total of one formula kilogram of strategic SNM or 17 kilograms of uranium-235 contained in uranium enriched to 10.00 percent or more but less than 20.00 percent in the uranium-235 isotope 12 9.5 59 line Each shipping container is 74.43(b)(7) does not contain this 3 Reword to be more consistent with 74.15 (a) which 21 inspected within 3 day requirement requires updated information to be generated within working days 10 days.
13 16 91 lines NUREG/BR-0096, Date in draft NUREG is October Update in all locations to correct date.
6-7 revision date 1992. ADAMS version has January 1992.