ML20056G006
| ML20056G006 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 08/30/1993 |
| From: | Pierson R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Winslow T GENERAL ELECTRIC CO. |
| Shared Package | |
| ML19310D661 | List: |
| References | |
| NUDOCS 9309010145 | |
| Download: ML20056G006 (2) | |
Text
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/t Proprietary Information j
, /"%g (2.790 Information) c j, 1! E UN.TED STATES NUCLEAR REGULATORY COMMISSION
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i Docket 70-1113 License SNM-1097 Mr. T. Preston Winslow, Manager Licensing and Nuclear Materials Management, M/C J88 Nuclear Fuel and Components Manufacturing General Electric Company i
P.O. Box 780 i
Wilmington, North Carolina 28402
Dear Mr. Winslow:
i i
SUBJECT:
ADEQUACY OF CRITICAL MC&A PROCEDURES j
As a result of previous material control and accounting (MC&A) inspections at your facility, those internal procedures designated as " critical. MC&A procedures" were reviewed and in many instances judged to be inadequate with respect to meeting regulatory intent.
In particular, inspection reports 70-1113/92-201, 70-1113/92-202, and 70-1113/93-201 all identified weaknesses relative to your critical pr:.cedures.
Inspector Follow-up Item 92-201-01 i
resulted in the review of your entire set of 17 critical MCLA procedures, and such review concluded that many of these procedures were in need of strengthening by providing some additional information relative to the basic methodologies utilized to implement the MC&A program.
It was determined by the Nuclear Regulatory Commission that the resolution of this issue was more of a licensing function than an inspection responsibility. Hence, the Licensing Branch undertook an in-depth review of your entire set of critical MC&A procedures. That review has been completed, and it is our conclusion that:
(1) the overall set of critical procedures, and the majority of the individual procedures fail to satisfy the acceptance criteria and the regulatory intent for the contents of critical MC&A procedures; and (2) each individual procedure is in need of strengthening and/or clarificat son.
The basis for our conclusion is that 10 CFR 74.31 is a performance based regulation that contains very few specific requirements and allows l'icensees the flexibility to design and define specific methodologies for achieving the performance objectives and system capabilities stated in 5 74.31. Thus, the combination of a licensee's Fundamental Nuclear Material Control (FNMC) plan Document Transmitted Proprietary Information When separated from -
IIerewith contains (2.790 Information)
Enclosure this j
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Mr. T. P. Winslow 2
and its critical MC&A procedures must provide sufficient details and commitments to allow the NRC to assess whether a licensee has a defined program that can (with high assurance) achieve the regulatory performance l
objectives.
l Our review found that the majority of your critical procedures merely l
identified basic activities and organizational units having responsibility for each activity, but provided no description of how the activities were to be accomplished.
Accordingly, we are requesting that General Electric initiate a program to l
upgrade its critical MC&A procedures so that they contain sufficient information to allow a reader (in particular an NRC inspector or licensing reviewer) to have a basic understanding of what methodologies are involved with respect to the identified activities.
Such a program should be completed by March 31, 1994, at which time a revised set of procedures, acceptable tn the NRC, will have been implemented.
In addition, by May 31, 1994 you should submit any necessary revisions to your FNMC Plan to make it totally consistent with your upgraded set of critical MC&A procedures.
The enclosure to this letter contains specific comments and guidance to assist you in initiating this procedure upgrading project. However, the enclosed comments for the most part only address obvious areas of needed clarification with respect to current procedure content.
Based on the level of detail contained in the attached comments and guidance, you should evaluate your critical procedures for further upgrading (in addition to that suggested by our comments) which may be necessary.
If you have any questions regarding this matter, please contact Mr. Donald Joy of my staff on (301) 504-2352.
We have determined that the enclosure to this letter contains information of the type specified in 10 CFR 2.790(d). Accordingly, pursuant to Section 2.790(d)(1), such information is deemed to be commercial or financial informa-tion within the meaning of 10 CFR 9.17(a)(4) and shall be withheld from public disclosure unless subject to the provisions of 10 CFR 9.23.
Sincerely, Robert C. Pierson, Chief Licensing Branch Division of Fuel Cycle Safety
Enclosure:
As stated and Safeguards, NMSS DISTRIBUTION:
Docket 70-1113 PDR 4NRC file Centerr Region II EKeegan NMSS r/f FCSS r/f FCLB r/f FCLS1 r/f ETenEyck
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g DATE 8/23/93 8/N93 8/c/93 8/ W 93 8/7a/93 C = COVER E = COVER & ENCLOSURE N = NO COPY OFFICIAL RECORD COPY Decontrolled