ML19242A548
| ML19242A548 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 06/21/1979 |
| From: | Rolonda Jackson NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7908030109 | |
| Download: ML19242A548 (2) | |
Text
DCS JUN 2 11979 w
t j
W1L:RLJ l0-1113 7'
l NOTE T0: Jim Partlow FROM:
Ray Jackson THRU:
Ron Brightsen
SUBJECT:
EVALUATIO:1 0F GE-WILMINGTON'S REQUEST T0 (1) DELAY IfiPLE!iE?iTING CERTAIi SECTI0flS OF THEIR 70.57 PLA t AND (2) REVISION OF CURRENT LICENSE C0tiDITION 2.1' i
I (1) The licensee in his letters dated May 29 and Jure 1,1979 requested that time extensions beyond the June 3,1979 implementation date of 6
the 70.57 Plan be granted for seven specific program requirements.
l These program requirements are as required by 10 CFR 70.57 and/or p
111 cense conditions issued as a result of our review identifying i
deficiencies in the Plan.
P" it is apparent, after our discussions with the licensees at the May 31, 1979 meeting hel d here and as a result of reviewing Attachments 1 and 2 of their May 29 and June 1,1979 submittals, that much of the procedures have already been implemented and the balance being worked on. The requested delay is a matter of allowing additicnal time for the procedures to be fully implemented.
sw -
This reviewer believes the licensee has been forthright in his attempt to effectuate his Material Measurement Control Plan and that the granting of the request will otI:t adversely effect the Safeguards progran at GE-Wilmington.
I urge approval of new License Condition 2.1.1 as found in the attached rough draft letter.
- 2) The GE-Wilmington letter of March 13, 1979 requests that License s
Condition 2.1 be revised to include specific reference to Appendix C of tneir FliMC Plan to ensure compliance with License Condition 2.2, i.e.,
"No statement in the licensee's Plan shall relieve the licensee of a requirement of 10 CFR Part 70 unless granted in a specific exemption or exception set forth as a condition of this license."
Appendix C contains previously reviewed and approved descriptions of alternative safeguards systems for meeting regulatory requirements.
tirneco enna<einn 9 a we 4,-s un onor+4vn n rio r +n m rnvicinn.
1ade as a rest it of the 70.L7 Plan review, read as foll ows:
- e~==>
ur= >
[cc axm m me mum ma b.....---,-..........-..-...
.f
...,7 -
- yc
..y wrgog,ogn
~
~
2=
"The licensee shall follow the Fundamental Nuclear Material Control Plan dated January 24, 1975 and as revised according l
to the schedule of pages dated May 19, 1978 attached to his i
letter dated June 9,1978; the pages dated Septerher 19, 1973 (Chapter 6.0) attached to his letter of September 25, 1978, with 8
the exception of those pages listed as Demonstration, and with the i
exceptio's noted below, and as amended in accordance with the provisions of 10 CFR 70.32(c).
}
a.
Chapter 4.0 b.
Appendices A, 8, and D."
This version implied that Appendix C was a valid - enforceable part of the FHMC.
No problem with the wort'ing existed until Dean James, GE Internal Auditor, felt the condition was in conflict with the previously stated License Condition 2.2 in that Appendix C was not specifically mentioned as containing acceptable alternative safeguards systems for meeting regulatory requirements.
i Revised license Condition 2.1, issued May 4,1979 as a result of incorporating r=_
I Chapter 4.0 (Measurement Control) into the FNMC, reads f s follows:
l "The licensee shall follow the Fundamental Nuclear Material Control Plan dated as specified on pages xix through xxvi dated April 25, 1979 except Appendix A; arid as revised in accordance with the provisions of 10 CFR 70.32(c)."
Again, no specific cention is made of Appendix C.
Dean James, GE Internal i
Auditor, brought the matter to the attention of GE personnel once again.
After a re-review and reanalysis, MCL staff menbers agreed there could be i
a conflict with existing License Condition 2.2.
Hence, the revision of License Condition 2.1 is as stated in the attached rough-draft letter.
7 I urge approval of the revised condition.
/s/
DISTRIBUTION:
Ray Jackson Docket File DCS Case File PCL r/f RLJackson RSrightsen f
m'a *
~
.u====>
.Rda.ck.srn:
dSrightsen.,
.fNU.9..
. 6/...R../.7.2.
ur= >
~~~
Nec Poned 3ts (3 74) Nac34 4244
- w.s. eeve=== sar e.anae on e.ca s s e ** s e e e s e
't -
e s
g 9a
.a.