ML19261C654
| ML19261C654 | |
| Person / Time | |
|---|---|
| Site: | Wood River Junction |
| Issue date: | 03/20/1979 |
| From: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Bowers C UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 7903280057 | |
| Download: ML19261C654 (2) | |
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9 UNITED STATES b
NUCLEAR REGULATORY COMMisslON
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M c 01979 SGMC:GEG 70-820 United Nuclear Corporation Recovery Operations ATTN:
Mr. C. E. Bowers General Manager Wood River Junction, Rhode Island 02894 Gentlemen:
The purpose of this letter is to document the position of the Material Control and Accountability Licensing Branch relative to the implementation and reporting of changes and modifications to approved Fundamental Nuclear Material Control Plans.
Three major amendments to upgrade material control and accounting for safeguards have been incorporated in 10 CFR Part 70 durine the past five years. These are 10 CFR 70.51, 70.57, and 70.58.
With each change, licensees have been required to submit detailed plans which describe the site specific program they will implement to ensure compliance with the new regulations. These plans were based on the operating conditions at the time they were written and for the foreseeable future. However, changes in facility operation inevitably occur which necessitate revision of these plans.
The fact that the plans are expected to be dynamic documents is recognized in the provisions of 10 CFR 70.32(c).
In accordance with the provisions of this paragraph, a change or modification may be implemented without prior NRC approval when the effectiveness of the material control and accounting program is not decreased. The change or modification must subsequently be reported to NRC Licensing and the appropriate Region Office within two or six months depending on the category of special nuclear material involved. Conversely, if a change or modification is necessary that would decrease the effectiveness of the program, NRC Licensing approval is required prior to implementation.
While the intent of paragraph 70.32(c) is clear, i.e., to provide a vehicle for plan modification, there are no requirements or guidance relative to assessing the impact of a proposed change on the material control and accounting program.
In view of the potential consequences of an incorrect decision, the importance of an adequate assessment is clear. A change implemented without prior approval which is questionable in the mind of a safeguards inspector may be cited as an unresolved item and referred to Licensing for evaluation.
In a case where there is a significant potential for an adverse effect on the public health and safety or the commen defense or security, an item of noncompliance with appropriate enforcement action could result. With the importance of making the correct decision in mind, the following guidance is provided.
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- It is desirable that each licensee e All licensee personnel affected by a propos a.
opportunity to have input in the d
overall responsibility for the m t
A plan change which has been judged by effectiveness of the program should be su b.
and Accountability Licensing Branch as so allows two or six months for not earlier submittal is in the best in An early review provides added assurance The change should be submitted in the lF pages to the Fundamental N been made.
t f acilitates easy incorporation in the plan, When a licensee deems it nec c.
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must be submitted to Material Contr with sufficient lead time to permit a thoroug this should be at least thirty (30) days in a As before, the chan desired implementation date.as dated supporting information should be included With respect to the license fee program (P
) is tions), the submission described in paragra However, if the Material Control and Acco with the licensee's interpretatio) category (administrative, minor or major further review commences. described in pa If you have any comments or questions o to hear from you.
Sincer bW J4mes G. Part Mjterial Cont?
Licensing B Division of S m -