ML20211M521
| ML20211M521 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 07/26/1985 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20211M455 | List:
|
| References | |
| FOIA-86-704 NUDOCS 8612170325 | |
| Download: ML20211M521 (4) | |
Text
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.c NUCLE AR FUEL MANUF ACTURING DEPARTMENT erkrant torcinic couPA=v - P. o aos too - wnum0 Tom. monta camouw asso c
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Dr. J. Nelson Grace, Regional Administrator
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3 U. S. Nuclear Regulatory Commission, RII a
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P. O. Box 2203 IC Atlanta, Georgia 30301 f
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Dear Dr. Grace:
References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/85-01 (3) Letter, CM Vaughan to JP Stohr, 3/22/85 (4) Letter, CM Vaughan to JP Stohr, 4/22/85 (5) Letter, JN Grace to EA Lees, 6/04/85 As required in Reference 5, General Electric Company Nuclear Fuel Manufacturing Department hereby submits a supplemental response to the item of apparent noncompliance identified during NRC Inspection 85-01.
In your 6/4/85 letter, you indicated that the NRC's position was originally communica'ted in an attachment to a letter dated 11/17/77.
This document was transmitted to GE identified as a
" draft" and, even~after a recent review, we find that it provides no detail with regard to delegation of authority as it relates to I
the current issue.
Notwithstanding this fact, the telephone 7
conversations and current written communications have been sufficient to define the NRC's position.
We also appreciate your review of the severity level classification of the subject violation.
We continue to feel that Severity Level V is more appropriate for this limited situation of minor significance.
We currently have no intention of pursuing the matter further since, at this time, the severity level has no bearing on our compliance with the regulatory requirements.
Should the severity level become important in assessing our overall compliance in the future, additional attention to this matter would be warranted.
Pursuant to 10 CFR 2.790(d), General Electric requests that the attachment to this letter be withheld from public disclosure since 861217032'5 861205 R
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GENERAL h ELECTRIC
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l Dr. J. Nelson Grace July 26, 1985 Page 2-this attachment identifies details of GE control and accounting procedures for safeguarding licensed special nuclear material.
If you have any questions regarding this matter, please contact me.
GENERAL ELECTRIC COMPANY ca.lYV '$.
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Charles M. Vaughan, Manager Regulatory Compliance M/C J26 CMV:bsd Attachment NSD-I
<Q GENERAL h ELECTRIC Dr. J. Nelson Grace July 26, 1985 ATTACHMENT In NRC Inspection 85-01, the following apparent violation (85-01-01) was identified:
Failure to establish and follow a management system which provides for review and approval of nuclear material control and accounting procedures by the individual assigned the responsibility for the nuclear material control and accounting function.
In the NRC response of June 4, 1985, the NRC indicated that GE had not identified corrective action nor a date for full compliance which addressed the subject violation.
In our March 22, 1985 letter, the NRC was advised that the condition related to Revisions 25 and 26 to QCOR 3.1.1 was a limited incident, that this apparent violation was corrected by Revision 27 and that GE was at that time in full compliance.
General Electric continues to maintain this position related to 85-01-01.
Beginning at a meeting in Atlanta on March 13, 1985, and in continuing communications (both written and oral involving principally E. J. McAlpine of Region II, C. N. Smith of NMSS and C. M. Vaughan of GE), discyssions have been held on the subject of whether the person with ovarall responsibility for specified items
[ reference 70.57(b), 70.58(b), 70.58(c) and 70.58(d)(3)] can delegate to other individuals the authority for signature to demonstrate compliance with the regulatory requirements.
Notwithstanding our collective inability to understand precisely what the regulatory requirement is or how it is to be implemented, GE's policy for all material control and accounting procedures covered by the Fundamental Nuclear Material Control Plan and MC&A license conditions is as follows:
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GENER AL @ ELECTRIC N
Dr. J. Nelson Grace July 26, 1985 Attachment - Page 2 (1)
The position (individual) with ov res nsibi r the (2) he ure of the is used emonstrate comp lance or a proce reviewed and approved by L&NMM.
(3)
When the is away from his normally assigned work loca ton e Witmington, N. C. plant site) for any officially recognized reason and a GE-authorized Delegation of Authority letter (not delegation of responsibility) is properly issued, the person granted authority may approve such procedures to demonstrate compliance to regulatory requirements.
Th_is policy was adjusted on July 8, 1985 to eliminate delegation _s of authority (not responsibility) in A ct up until that time f,or f.J revisions.to PRODS (M$s/QCOR57 Eiid ' Temporary Operating
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-2 Instructions (TOIs).
Therefore, since 7/10/85 any such action is
- 4 in accord with the regulatory requirements including the verbal g/6 discussions regarding implementation of the requirements.
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C. M. Vaughan
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NUCLEAR REGULATORY COMMISS vN O
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ATLANTA.GloAGI A 30323 5, v /
SEP 0 51985 Om General Electric Company ATTN:
Mr. Eugene A. Lees, General Manager Nuclear Fuel Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:
SUBJECT:
rep 0RT NO. 70-1113/85-12 On June 15, 1984, an NRC staff member conducted an on site review of your followup of certain allegations from one of your employees.
At the conclusion of that review, the scope of the review was discussed with those members of your staff identified in the enclosed inspection report.
In reexamining our files, we found that this on site activity had not been documented in an inspection report. Therefore, to complete the docketed record, we are now issuing the findings of that review in the subject inspection report.
I Areas examined during the review are identified in the report. Within these areas, the review consisted of selective examinations of documents and an interview of one individual.
Within the scope of the review, no violations or deviations were identified.
In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, safeguards activities and security measures are exempt from public disclosure; therefore, the enclosures I
to this letter, with the exception of the report cover page which presents a non-exempt summary, will m be placed in NRC's public Document Rocm.
i Should you have any questions concerning this letter, please contact us.
J Sincerely, hilip<
o 1 rector Division of Radiation Safety and Safeguards
Enclosure:
Inspection Report No. 70-1113/85-12 cc w/ encl:
C. M. Vaughan, Manager Regulatory Compliance n g :., s.. y,ct -
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