ML20010J346
| ML20010J346 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/18/1981 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19260J114 | List: |
| References | |
| NUDOCS 8109300347 | |
| Download: ML20010J346 (2) | |
Text
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' GEN ER AL h ELECTRIC NUCLEAR ENERGY jRC REGj{!
- PRODUCTS DIVISION i
WILMINGTON MANUFACTURING CASTLE H AYNE ROAD. P. O. BOX 780. WILMINGTON, N. C. 284 2 AM9y+3-k y gEPARTMENT May 18, 19fl Mr.
R.
C.
Lewis, Acting Director Division of Resident & Reactor Project Inspection U.S.
Nuclear Regulatory Commission, Region II 101 Marietta Street, NW - Suite 3100 Atlanta, Georgia 30303
Dear Mr. Lewis:
References:
(1) NRC License SNM-1097, Docket #70-1113 (2) GE Response to Inspection Report 70-1113/81-01, 4/14/81 (3) Telephone conversations between CM Vaughan (GE) and GP Coryell (NRC), 5/11/81 and 5/14/81 The purpose of this letter is to document General Electric's position regarding Inspection Report 70-1113/81-01.
General Electric responded to this Inspection Report on April 14, 1981 and General Electric believes that this response met all the requirements of 10 CFR 2.201.
Appendix A of the Inspection Report contains a requirement that l
General Electric's response be submitted under oath or affirmation i
(which, it is stated in the Inspection Report, stems from the l
general authtrity the Commission has under Section 182 of the l
Atomic Energy Act of 1954, as amended, to require statements to be l
made under oath or affirmation).
The origin of this requirement appears to be Proposed Appendix C to 10 CFR 2, which has been
(
published for comment but has not yet been finally adopted.
However, 10 CFR 2.201 contains no such requirement.
Until a rule incorporating this requirement is promulgated, notwithstanding the statement contained in 45 FR 66754 (October 7, 1980), that "the Proposed General Statement of Policy will be used as guidance to the NRC Staff in taking enforcement actions," General Electric believes that the imposition of this obligation is improper.
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81093OO347 ' 81090D l
PDR ADDCK 07001113 C
PDR L
I.
GENER AL $ ELECTRIC Mr.
R.
C. Lewis Page 2 May 18, 1981 In addition, in view of the complexity of~the open issue'and the fact that the finding has been resolved and the public health and safety was never jeopardized, General Electric requests that further action regarding the GE response to Inspection 70-1113/81-01 be deferred until June 30, 1981, contingent upon a meeting between GE management and the US Nuclear Regulatory Commission Office of Inspection & Enforcement.
Sincerely, GENERAL ELECTRIC COMPANY f
ht.) $
b"f' Charles M. Vaughan, Acting Manager Licensing & Compliance Audits
/sbm
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