ML20214H046
| ML20214H046 | |
| Person / Time | |
|---|---|
| Site: | 07000687 |
| Issue date: | 04/24/1987 |
| From: | Mcgovern J CINTICHEM, INC. |
| To: | Rolonda Jackson NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| 28190, NUDOCS 8705270257 | |
| Download: ML20214H046 (4) | |
Text
{{#Wiki_filter:. s., PDR: LTR. OMI,Y CINTICHEM, INC. a wholly owned subsidiary of Medi-Physics, Inc. e.o. sox e,s. Tuxeoo. NEW YORK 109e7 [914] 351-2131 47/ April 24, 1 7 te U.S. Nuclear Regulatory. Commission /s 'S Director, Office of Nuclear Material Safety and Safeguards jh h Fuel Facility Safeguards Licensing Branct f g 16 Dg y, ! Washington, D.C. 20555 l j. Attention: Mr. R. L. Jackson k M'h ' 3
Dear Mr. Jackson:
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SUBJECT:
Docket 70-687 License SNM 639, Request for a Change to the Fundamental Nuclear Material Control Procram The subject FNMC Plan for the Cintichem facility in Tuxedo, N.Y. requires that certain audits be conducted. These requirements appear in five places throughout the plan. The bases for these audits are those required per 10CFR Parts 70.57(b)(2) and 70.58(c)(2). Compliance with the Regulatory audit requirements has been complicated because of the difficulty of correlating the audit requirements of the FNMC Plan with those of the regu-ulation. We propose the foilowing changes to the FNMC Plan to make the audit requirements per the plan consistent with the requirements per 10CFR Part 70. A summary of the current audit requirements of the FNMC Plan is as foilows: ~- ci el Para- [ g; Audltor araoh Purpose Oualifications iG 1.2.5 Audit of material control No quaTifications spect-and accounting and the f;Jpd measurement program g ch 4.1.3 Review the management of Reviewer not directly the measurement quality involved in area being g 3 S ssurance program to deter-reviewed. Reviewer shall a Ine that effectiveness of be neither the accounta-e
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, 4-l ) U.S. Nucler Regulatory Commission 4-24-87 e,- Para- . Auditor araoh Purpose Qualifications 4.1.4 -Audit the Measurement Q.A. Auditor shall be compe-procedures tent technically and shall not be involved directly in area being audited. There will be no cross-auditing of functions. 6.3 Management-review of the Auditor will be_inde-material control and pendent'of the nuclear accounting procedures material control and records management, measure-ment or utilization. 8.2.1 Essentially the same as requirement in 6.3 A similar summary of the current requirements per 10CFR Part 70 is as follows: Auditor Part Purpose Qualifications 70.57(b)(2) Management review to assess Trained Individuals inoe-adequacy of Measurement QA pendent of direct respon-program and applicability sibility for receipt, of current procedures and custody, utilization, to verify conformance with measurement quality and the program, shipment of SNM. 70.58(c)(2) Audit of material control Individuals independent I -{ and accounting procedures of management and direct and practices and of responsibility for records. receipt, custody, utl-lization, measurement, measurement QA and ship-ment of SNM. l t
aj U.S. Nuclear Regulatory Commission 4-24-87 The provisions of the FNMC Plan had been developed over a span of several years as the regulations regarding safeguards and measurement quellty assurance developed. Hence, we have redun-dancy and some discontinuity in the audit requirements that were included in the various sections of the plan as they were devel-oped. Examining the various audit requirements in the current plan we conclude that the audits required under Sections 4.1.3 and 4.l.4 of the plan are based on the Regulatory requirements in Part 70.57(b)(2) and those under Sections 1.2.5, 6.3 and 8.2.1 of the plan are based on 70.58(c)(2). The discrepancies between the plan requirements anu the regulations, particularly regarding auditor qualifications, have led to deficiencies noted in com-pliance inspections. We believe that, if the audit requirements of the plan were consolidated and revised to comply with the regulations, these deficiencies would be avoided. The proposed changes are as follows: Sections 1.2.5 and 6.3 are consolidated and changed to reflect the audit requirements per 100FR 70.58(c)(2). Sections 4.1.3 and 4.1.4 are consolidated and changed to re-flect the requirements per 10CFR 70.57(b)(2). Section 8.2.1 is changed to refer to the audits required under 1.2.5 and 4.1.3. Revised pages inco porating these proposed changes are enclosed for your convenience and approval. Occasionally, we have encountered difficulty in obtaining an auditor who is qualified in respect to both the technical knowl-edge and the Independence from management of and direct involve-ment with SNM within the laboratory staff as prescribed in 10CFR 70.58(c)(2). We request that approval be given to allow personnel from the Engineering staff at the laboratory to fill this function if the Independent auditor (currently'the Sr. Scientist Consultant) is not available. I have enclosed an organization chart which shows the current titles of'the FNMC plan organization. It can be seen here that the Engineering group is Independent of all other functional groups who directly control or measure SNM on site and this group reports directly to the Plant Manager as do the Sr. Scientist Consultant and the Nuclear Safeguards Committee. 6 LE
-:j . :L U.S. Nuclear Regulatory Commission 4-24-87 .~ We submit thet these changes will not compromise the account-s ability and. control of SNM and we request your approval. The application fee of $150.00 prescribed by 10CFR170 is enclosed. Very truly yours, t 1 J J. Govern Plant Manager Enclosures 1 4 3 9 4 5$ l I}}