ML20127E759
| ML20127E759 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/28/1985 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20127E724 | List: |
| References | |
| NUDOCS 8505200194 | |
| Download: ML20127E759 (3) | |
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%lMPGg,gTH CAROUNA 28402 GENERAL ELECTRIC COMPANY P February 28, 1985 Mr. J. Philip Stohr Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 2900 Atlanta, Georgia. 30303
Dear Mr. Stohr:
Reference:
(1) NRC License SNM-1097, Docket i 70-1113 (2) NRC Inspection Report 70-1113/84-18 dated 1/31/85, received 2/5/85 Thank you very much for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr.
T.
R.
Decker of your ot?fice on December 17-21, 1984.
Pertaining.to the one item of apparent noncompliance with NRC requirements in your letter, the reply to this item is given in the attachment to this-letter.
We appreciate your inspector's comments and suggestions related to our emergency preparedness and fire protection programs.
These comments and suggestions are helpful to us in our constant efforts to improve these programs, and ensure our compliance with NRC regulations and license conditions.
We also welcome further discussion with your staff on the items in your letter and in our related reply, if necessary, for further clarification of this item.
Your inspection report referred to above does not contain information which we believe to be proprietary.
Sincerely, GENERAL ELECTRIC CO P NY 8505200194 850416 ADOCK0700ggg3 PDR C
Regulatory Compliance
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-O GENERAL $ ELECTRIC Mr. J.
Philip Stohr February 28, 1985
-Page 1 of 2 ATTACHMENT The following is the General Electric Company response to NRC Inspection Report 84-18, Notice of Violation - Enclosure 1.
10 CFR 70.22(h)(1) states, in part, that Emergency Plans shall contain the elements that are listed in Section IV, " Content of Emergency Plans", of Appendix E to 10 CFR 50.
10 CPR 50, Appendix E IV(D)(1) states, in part,.that administrative and physical means for notifying local, State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described.
Contrary to the above, though the Emergency Director is required by the Radiological Contingency and Emergency Plan to provide projected dose information and recommendations to off-site organizations for implementing effective emergency action, neither the Plan or Implementing Procedures were adequately prescriptive to assure prompt notification and protective action recommendations to off-site authorities.
This is-a Severity Level IV violation (Supplement VIII).
General Electric Company admits the violation as stated above.
The reason the violation occurred was due to the omission of the subject notification and action requirements in the Emergency Director's procedures.
However, these requirements were and are identified in the Nuclear Safety Advisor's procedures.
It is each advisor's responsibility to assess the potential hazard associated
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Mr. J. Philip Stohr February 28, 1985 ATTACHMENT - Page 2 of 2
. with their. area of responsibility (i.e.,
industrial safety, radiological safety, and' environmental issues) and to make appropriate recommendations for protective actions to the Emergency Director.
On a' temporary basis, a hand written instruction that identifies immediate notification with protective action recommendations to off-site authorities has been included in the Emergency Director's manual which is located in the Emergency Control-Center.
The Emergency Director's emergency procedures will be updated to include immediate notification and recommended actions, as appropriate, to the local off-site authorities.
Full compliance on -this item will be achieved by August 15, 1985.
As a result of NRC inspection 82-01, a Notice of Violation was issued to NFMD which addressed the assessment of the magnitude lof releases, evaluation of the need for. notification and the
. protective actions to be taken off site.
As, described in the NFMD response to this violation _ dated 5/5/82, procedures describing these activities were written and the objectives were accomplished through-the recommendations of competent NFMD technical advisors to the Emergency Director.
Therefore, the requirements in the form of decision criteria and action guides were technically implemented as a result of closing this item.
The current violation indicates a perceived procedural deficiency to. provide a double check for an existing requirement which is already covered in the advisor's procedure.
While we agree that the double check is desirable in this situation, the significance of its absence appears minor in nature.
In-view of the corrective actions taken in regard to violation 82-01-A, General Electric Company requests that the NRC consider reclassification of item 84-18-01 pursuant to the guidelines of 10 CFR 2, Appendix C, as Severity Level V.
CM Vaughan
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