NRC-2021-0170, Comment (6) of C.D. Manning on Behalf of Framatome, Inc. on Nrc'S Draft NUREG-2159, Acceptable Standard Format and Content for the Material Control and Accounting Plan Required for Special Nuclear Material of Moderate Strategic Signifi
| ML22119A007 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 11/22/2021 |
| From: | Manning C Framatome |
| To: | Office of Administration |
| References | |
| 86FR61795 00006, CDM:21:017, NRC-2021-0170 | |
| Download: ML22119A007 (6) | |
Text
SUNI Review Complete framatome Template=ADM-013 E-RIDS=ADM-03 ADD: Tom Pham, Mary Neely November 22 , 2021 Comment (6)
CDM :21 :017 Publication Date: 11//08/2021 Citation: 86 FR 61795 Office of Administration Mail Stop : TWFN-7-A60M U.S. Nuclear Regulatory Commission Washington , DC 20555-0001 ATTN : Program Management, Announcements and Editing Staff
Reference:
- 1) Federal Register, September 23, 2021 (86 FR 52926)
- 2) SNM , 1257, Docket 70-1257
Subject:
Framatome's Comments on Draft NUREG-2159, Docket ID NRC-2021-0170.
Dear Madam or Sir:
Framatome Inc. appreciates the opportunity to comment on NRC's draft NUREG-2159 "Acceptable Standard Format and Content for the Material Control and Accounting Plan Required for Special Nuclear Material of Moderate Strategic Significance: (Reference 1).
Draft NUREG-2159 is intended to provide guidance to facilitate compliance with applicable provisions in Subpart D of 10 CFR Part 74. Framatome is providing comments to clarify , and risk inform sections in the draft NUREG.
Attached are Framatome's specific comments regarding daft NUREG-2159 .
If you have any information concerning this information , please contact me at 509 375 8237 .
Sincerely,
~ IY?n..,HW7' C D. Manning, Manager Licensing and Compliance CDM/rd Cc: R. Jervey, USNRC NMSS Framatome Inc.
2101 Horn Rapids Road Rich land, WA 99354 Tel: (509) 375-8100 www.framatome.com 22709WA-6 (01 112/2018)
fram atom e be: T J Tate E Calvo-Tone 22709WA-8 {01/1 2/2018 )
fra ma tome Attach ment Numb er NURE G Comm ent Section Propo sed Resolu tion 1 Section 2, The propos ed guidan ce far exceed s the require ments found in Subpa rt D Remov e the noted text entirely .
Item 4; 6 Pg 74.41 (c) as well as the similar require ments found in Subpa rt E for SSNM 6, lines 8- 18 and is not a credible concern .
Replac e with a paragraph stating : "Where the organiz ational structure is such that a 74.43(b) (1) A manag ement structure shall be established , docum ented , position having responsibility within the 1O and maintained that assures:
CFR Part 74 MC&A progra m also has responsibility within the 10 CFR Part 73, (i) Clear overall responsibility for material control and accoun ting (MC&A ) "Physical Protection of Plants and functio ns .
Materials, " system, the plan will addres s roles and responsibilities to ensure the (ii) Indepe ndence from production and manufa cturing respon sibilities; and MC&A progra m is not subjec t to compr omise by the actions of a single (iii) Separa tion of key responsibilities.
insider filling the position . A safegu ards manag er could be an examp le of such a This provides sufficient indepe ndence of activities .
position ."
For most licensees , such a position would require access to SGI and as such the individual would be granted access to SGI in accord ance with 73.22(b) which includes a backgr ound check to determ ine the individual is trustwo rthy and reliable, and for some licensees such a positio n would require either an L or Q clearance.
2 Section 3.3 Section 3.3 "MC&A Organi zation" states:
Replac e this wordin g with similar guidan ce used in NURE G-152 0, Section "An organizational chart and position-by-position description of the entire 2.4.2(8)(3) to read:
MC&A organization should be provided. A license e should design ate an individual as the overall manag er of the MC&A program, and the MC&A "In the organiz ational hierarchy, the MC&A plan must demon strate the assura nce of indepe ndence of action and organization(s) is indepe ndent of the objectivity of decisio n for the MC&A manag er. Two options for meetin g the operat ions organization(s) , allowing it to organiz ational indepe ndence are: (1) report directly to the plant Framatom e Inc.
or site provide objecti ve MC&A audit, review , or 2101 Horn Rapids Road Richland, WA 99354 Tel: (509) 375 .. 9100 www.fram atome.co m 22709WA-8 (01/12/2018)
framatome manager, or (2) report to an individual who reports to the plant or site control activities. "Independent" means that manager through a management chain with no production respon sibilities." neither organization reports to the other in This guidance is not performance based . Other options can easily meet the an administrative sense . (However, both objectives of the regulation . It is unnecessarily to restrict organiz ation may report to a common manager. ) Lines of structures and independent reporting options . This could be particu larly responsibility and authority are clearly problematic as advanced reactors look to limit the number of onsite drawn. "
personnel.
3 Section 3.5 Section 3.5 states one of the roles to be an "overall MC&A progra m Revise the first bullet to read :
management (note that this individual should have no major respon sibilities not related to MC&A) ."
"overall MC&A program management (note that overall MC&A program management This guidance is not performance based . Other options can easily meet the should be vested to a single individual at an objectives of the regulation . Given the industry need to reduce overhead organizational level sufficient to assure cost, there should be an allowance for MC&A management to have other independence of action and objectiveness duties not specifically related to MC&A.
of decisions). "
4 Section 5.1.3; This Section states that:
Pg 20 , lines Reword to remove the 30 days and state "All contractor or offsite laboratory assessment findings and "Findings and recommendations are to be 36-39 recommendations should be documented and submitted to both addressed consistent with the licensees QA the measurement control program manager and the overall MC&A and Corrective Action Program. "
manager within 30 days of completion of the review ."
This time frame is not specified in the regulations and does not appear to be risk informed .
5 Section 5.2; This Section states that:
Pg 21 , lines Reword sentence to state "FNMCP should 6-7 address the following applicable "The FNMC plan should describe the replicate sampling progra m , which attributes: ... "
must include 6 the following , as appropriate" The language of this sentence mixes requirements , recommendatio ns and provides a conditional out. .
22709WA-8 (01112/2018)
framatome 6 Section 6.2; This Section states that:
Reword to state "licensees should Pg 37 , lines "Licensees should also commit to having at least two individuals commit to independently verify the 28-31 independently verify the accuracy of the ID and SEID calculations for each accuracy of the ID and SEID total plant material balance ." calculations for each total plant material balance. "
This recommendation is not performance based . To invoke two addition al verifications for such a highly specialized function is an extreme burden on the licensee with no clear requlatorv basis or safety benefit.
7 Section 6.3 ; This Section states that:
Reword or remove "unusually large" or Pg 38 , lines 29-30 state the following : "The bias correction is
" .. .the NRC acceptance criteria do not normally call for applying bias only applied if it is significant with 95%
corrections to either the accounting records or as an adjustment to ID confidence and exceeds the rounding unless the effect of a single significant bias or the net sum of all significa nt error. "
biases is unusually large."
"unusually large" is an ambiguous term . NRC acceptance criteria does not normally call for applying bias corrections to either the accounting records or as an adjustment.
8 Section 6.3 ; This Section states that:
Pg 38 , line 44 Reword : "if such bias is statistically "the bias is greater than 0.01 percent relative " significant at the 95 percent confidence level , and exceeds the rounding error of the affected items. The bias correction is This appears to be a new criterion being introduced without a clear tie to intended to correct the ID . It's impact on regulation .
the SEID should also be propagated ,
resulting in 9
an adjustment to the SEID ."
Section 7.5; This Section states that:
Pg 44 , lines Suggest removing the 3 months and state
" ... physical inventories are performed so as to confirm that a loss or " ... at a frequency that takes onto account 13-14 diversion of a sign ificant quantity of SNM has not occurred : dynamic (i.e., the potential for loss or diversion from the in-process) materials , which is performed on a frequency not to exceed 3 operation" calendar months ... "
This requirement is not performance based and there is no direct regulato ry basis for the 3 months stated.
2270ff'NA-8 (01112/2018)
fram atome 10 Section 8.2; This section provides examples of items that may be exempt from item Also include the guidance from the previous Pg 51 , lines control program coverage . This list should expand to include sample
- s. draft regarding the exemption for laboratory 29-39 samples and reference standa rds maintained in the laboratory material management system and containing uranium enriched to less than 20 percent in 11 the uranium-235 isotope .
Section 9.5 Section 9.5, "Resolution of Significant Shipper-Receiver Differe nces - Recommend that this section be reworded Commitments and Acceptance Criteria" states:
to be more consistent with 74 .15(a) which requires updated information to be "Each shipping container is inspected within 3 working days after receipt for generated within 10 days.
loss or damage to the container or T/Ds to determine whether SNM could have been removed . If the integrity of a container is questionable, the presence of all items that were that were packaged in the shippin g container will be confirmed within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovering the questionable integrity."
10 CFR 74.43(b)(7) contains neither a 3 working day nor a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> requirement appea rs to be overly restrict ive and depending on the type of package and the number of items in the package in some cases may not be achievable.
22709\NA-8 (01/12/2018)