ML20211M505
| ML20211M505 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 04/22/1985 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20211M455 | List:
|
| References | |
| FOIA-86-704 NUDOCS 8612170313 | |
| Download: ML20211M505 (3) | |
Text
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A GENERAL de ELECTRIC s
WILMINGTON MANUFACTUltNG DCPAJtTMENT GENEllAL ELECTibC COMPANY PO BOX 780 WI M.NG10N. NORTH CAJKXINA 98409 April 22, 1985 Yh r
Mr. J.
Philip Stohr, Director Division of Radiation Safety & Safeguards j$
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S.
Nuclear Regulatory Commission, RII gg
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Box 2203 b.,
Atlanta, Georgia 30301 y,
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Dear Mr. Stohr:
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References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/85-01 dated 2/21/85, received 2/26/85 (3) Letter, CM Vaughan to JP Stohr, 3/22/85 Attached is.a supplement to the General Electric Company response to the report of the inspection conducted at our licensed fuel fabrication plant by Mr.
D.
W.
Jones of your of fice on January 14-17, 1985.
The attachment to this letter deals with a description and clarification of the phrase "provides a mechanism" for the Manager of L&NMM to review and approve procedures, and also addresses the subject of delegation of safeguards-related activities which is independent of the Notice of Violation but surfaced during discussions related to our response.
We welcome further discussion with your staff on these items as necessary.
Pursuant to 10 CPR 2.790(d), General Electric Company requests that the attachment to this letter be withheld from public disclosure since this attachment identifies details of General Electric's control and accounting procedures for safeguarding licensed special nuclear material.
Very truly yours, GENERAL ELECTRIC COMPANY 8612170313 861205 PDR FOIA RATNER 86-704
- PDR, Charles M.
Vaughan, Manager Regulatory Compliance CMV:bsd SGD-I b
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A GENERAL h ELECTRIC M
Mr. J. Philip Stohr April 22, 1985 Attachment - Page 1 ATTACHMENT i
The information given below refers to the item in Enclosure 1,
" Notice of Violation," in the NRC Inspection Report 70-1113/85-01 dated 2/21/85.
This violation dealt with failure to properly approve certain internal MC&A procedures under the requirements of 10 CFR 70.58(c)(1) with specific reference to procedures generated under the guidance of General Electric procedure P/P 80-6.
General Electric responded to this notice on March 22, 1985.
In the second paragraph of Page 4 of the Attachment, the phrase i
"provides a mechanism" was used.
It is our understanding that clarification of this phrase is required.
As used, "provides a mechanism" means as follows:
1 The management structure and system including assignment of responsibility and authority, the definition of organizational relationships and the procedural system necessary to implement regulatory requirements which, in this case, involves procedural approval of MC&A procedures.
Federal Regulations currently applicable to fuel fabrication facilities in a few cases identify specific responsibility and authority issues which must be defined by licensees (i.e.,
70.57(b), 70.58(b), 70.58(c) and 70.58(d)(3)).
The commitment to implementation of these requirements is defined in the Fundamental Nuclear Material Control Plan (FNMCP) and license conditions as approved and issued by the NRC.
GE's commitment to implementation is defined in FNMCP Sections 1.2, 1.4, 1.9, 4.1.1 and 8.1.
It was GE's intent to comply with these commitments in the cases pointed out in the Notice of Violation.
General Electric's implementation of the licensed commitments is accomplished through procedural systems and management directives (job descriptions, etc.).
The overall Wilmington site operates in accordance with a procedural system called Practices & Procedures.
This system is structured in P/P 10-3 and includes specific (hlPT
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GENERAL h ELECTRIC h
Mr.
J.
Philip Stohr April 22, 1985 Attachment - Page 2 directives to comply with P/P 140-4, " Change Control of Safeguards Prog ram" ( reference P/P 10-3, Sections 4.4.2, 4.11 and 4.16.2 ).
P/P 80-6, which is the authori ument o
the COR
~instru tion, requires the j
or for the QCOR.
T NRC has raised 4
~f unction and manager means the same thing. questions as to whether
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1 P/P 10-3, responsibilities, by componentSection 4.4.2.2, " Responsibilities - A brief su i
or by
'or contributor for rformi work tas ro i
i i
In summary, P/P 80-6, Revision 6, assigns the re nsibi y for approval of its procedural documents to th demonstrat ed most clearly in Exhibits 2 an 3.
General Electric as af firms this commitment and the commitment to comply with Sections 1.2, 1.4, 1.9, 4.1.1 and 8.1 of the currently approved FNMCP.
In subsequent discussions related to responsibility for procedural l
approval, the question of delegation of certain activities within the charge of responsibility has surfaced.
Neither the regulation nor the license specifically require that 1
the person with overall assigned responsibility exists on eacha written signatur; document.
Provisions for written approval by that required in the regulation and license.
person are General Electric Company policy provides for the delegation of certain activities and responsibilities and requires these delegations to be in writing.
The GE-Wilmington FNMCP also addresses delegation most specifically in Sections 1.9 and 4.1.1.
Delegation is necessary to conduct effective business activities and in no way relieves the manager (s) of any assigned responsibility.
The discussions with NRC regional personnel and with NRC Licensing l
personnel indicate that, in certain circumstances, delegations are acceptable.
There is an indication that in other circumstances, i
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a GENERAL $ ELECTRIC
.m Mr. J. Philip Stohr April 22, 1985 Attachment Page 3 delegations are not appropriate.
The subject, therefore, remains unclear except to the extent that it is covered in the facility FNMCP.
General Electric plans to document this concern to NRC Licensing for further clarification and will abide by any such directives issued by that function.
Until such time that this happens, GE plans to comply with the applicable regulations and the approved PNMCP.
We feel that we are in compliance with approval requirements even though written delegations have existed in the past and will continue to exist in the future.
I CM Vaughan
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