ML20133K414
| ML20133K414 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 09/20/1985 |
| From: | Wolf R GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| To: | Brown W, Crow W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 25825, 696-8017, NUDOCS 8510210273 | |
| Download: ML20133K414 (5) | |
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l In Reply GA Technologies Inc.
Refer To: 696-8017 e
20 September 1985 f
RETURN TO 396-SS t
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Mr. William T. Crow l
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SEP30kbC{/y{g b
f Office of Nuclear Material Q
N Safety & Safeguards
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,V U.S. Nuclear Regulatory Commission A
% d8.Nucang D-Washington, D.C. 20555 4
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Dr. Willard B. Brown, Chief
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SEP 3 01985 5 L
U ggyg Fuel Facility Safeguards y
Licensing Branch g
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i Division of Safeguards, NMSS T
U.S. Nuclear Regulatory Commission Washington, D.C. 20555 G*
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Subject:
Docket 70-734: SNM-696: Clarification of Proposed Reorganiza-tion Reporting Relationships.
References:
(a) Docket 70-734: SNM.696; GA ltr 696-7088 dtd 8/7/85, Notice of Reorganizational Change.
(b) Docket 70-734: SNM-696; GA ltr 696-8005 dtd 8/30/85,
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Additional Information Regarding sRoorganization.
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Dear Sirs:
j My letter (ref, b) of August 30, 1985, included as Attachment 1 a two page description of the organizational change GA Technologies Inc. wishes to make with respect to our operations under License. No. SNM-696.
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i It has been brought to our attention that the first paragraph on the
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second page of that Attachment 1 was not so clear as. it might have been i
about the resulting reporting relationships. We have rewritten the para-graph to clarify its language and our intent.
Enclosed is a replacement Attachment 1 which includes the rewritten para-
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graph at the top of page two.
Please substitute the enclosed Attachment i
1 for. the earlier version transmitted with our August 30th letter.
I It has also been noted that the information provided in our letters of
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. August 7 (ref, a) and August 30,1985 (ref b) did not address the sub-ject of annual reviews / audits of our security program or our nuclear material accountability and control program.
Heretofore two separate audit teams have been appointed each year to conduct each of those annual j
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W. T. Crow /W. B. Brown 696-8017 management reviews and audits.
For the future, GA will establish two standing committees, one for each audit, with staggered terms of appoint-ment for the respective members to provide the benefits of continuity and experience carryover from one audit to the next, and to avoid delays some-times caused by the need for additional security clearances. The members of each committee will be appointed by the company's Executive Committee and will be independent of the management or supervision of the function to be audited.
As indicated in my letter of August 30th, it is important that we stab-ilize the situation which has developed from the retirement of four de-partment heads as quickly as possible. Because of the several concerns expressed by NRC representatives following our letters of August 7 and August 30, we have not implemented the proposed reorganization. We hope our discussions with Mr. D. R. Joy on September 23, 24 and 25 will re-solve all of the NRC points of concern of which we are aware.
If there are any others, please inform me of them as soon as possible. My phone i.tuter is (619) 455-2033 Sincerely, f\\
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Robe t A. Wolf Secretary RAW:KEA:he :
Description of Organizational Change, cc:
John B. Martin, NRC, Region V.
l ATTACHMENT 1
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Description of Organizational Change I
f The reorganization will eliminate the Quality Assurance and Compli-ance Division, and reassign its components to other organizations of the company. The office of the corporation's Secretary will assume responsi-j bility for assuring compliance with applicable license requirements and i
will control the radiological and nuclear safety and safeguards of licen-
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sed material.
This organization will establish the necessary policies of operation, cause them to be published in company wide guides and manuals,
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and coordinate related activities with operating groups to assure compli-ance with related policies, procedures, regulations and license condi-tions.
The Secretary will have the authority specified in the license and plans previously vested in the director of QACD.
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The Nuclear Material Management organization, which included a nuc-lear accountability function and a waste yard operation, is being elim-
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inated. Nuclear Material Accountability will be responsible for the nuc-lear material accountability function and for assuring compliance with l
SNM custody and control regulations and license conditions.'
r The Waste Yard Operation has been reassigned to the Fuel Operations
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Division under the Vice President, Reactor Programs.
This operation is responsible for the collection, processing and/or packaging of waste i
prior to its shipment for disposal.
This move is in keeping 5dth the regulatory intent and our general license commitments to place signifi-cant material handling operations in operating groups separate from the f
material control functions specified in Section 3.2.2 of the subject lic-ense specification. This places responsibility on the Fuel Operations Division, a major contributor to the waste volume, to properly classify l
and package the material in preparation for its shipment.
Licensing Ad-ministration, Nuclear Material Accountability and Health Physics will l
continue to review procedures and activities of waste yard operations as I
well as control the individual shipments therefrom. Nuclear Material Accountability will have primary control responsibility over the ship-I ments to assure that appropriate material accounting documents, releases, certifications, shipping orders, etc., are completed prior to dispatching the shipment.
f Another benefit of the new organization is to remove the SNM Measure-t ment Control function from the Fuel Operations Division and elevate it at
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a level equal to other company material control functions. The elevated function will be independent of the fuel processing organizations, their quality control organization and the company SNM material accounting func-tion. This is made possible by combining it with the company's Nuclear Safety function. Both functions necessarily have strong background in nuclear interactions, statistics and calculational techniques as well as require intimate knowledge of material flows through the processes.
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Revised Sept. 20, 1985 I
L The Nuclear Safety and SNM Heasurement Control, License Administra-
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i tion, and Nuclear Material Accountability functions will report to the i
Office of the Secretary. The Security and Health Physics functions will i
report to the Director of Human Resources (previously Director of Em-ployee Relations). However, matters regarding the establishment and the l
implementation of company policies and procedures to ensure conformance f
with governmental requirements as stipulated in regulations, permits and l
licenses which involve Security and Ikalth Physics will also be subject j
to coordination with, and review and approval by,(and,in urgent situa-tions, if necessary, direction by) the Secretary. The managers of each of the above functions will be responsible for. reporting to the Secretary I
all matters important to the company's effectiveness in fulfilling its
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license commitments, and the Secretary is vested with the responsibility
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and the authority to coordinate and act as the focal point of the com-pany's management with respect to-all' such matters. Thus, each of the j
managers of these functions will have direct access to the highest level I
of authority in reporting such matters to the Secretary; the Secretary j
reports directly to the office'of.the President.
I Thus, the reorganization will result in no' adverse. changes to the working relationships of the various. functional organizations nor in their effectiveness in discharging their responsibilities to implement I
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license conditions either singularly or in concert.
For example, con-i sistent with established procedures, all Work Authorizations and appro-
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priate safety related information shall be approved in writing by Health i
Physics, Nuclear Safety, Nuclear Material Accountability, and Licensing
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q Administration.
In addition,_ all such requests shall continue to be sent to Security Administration and/or the Criticality and Radiation. Safety Committee for approval when appropriat'e (a's specified in the license).
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Furthermore Licensing Administra51on, as the designee of the Secre-j tary,1will continue to approve all Supporting Plans" described in Section
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8 of the subject license to ensure conformance with UA policies and gov-ernmental requirements as-stipulated 'in regulations, permits and licen-ses.
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