ML19242A536
| ML19242A536 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 06/22/1979 |
| From: | Bartz H, Blaylock J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7908030093 | |
| Download: ML19242A536 (2) | |
Text
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NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555
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%, -.....f JUN 2 21979 SGML:DAH 70-1201 NOTE TO: Jim Partlow FROM:
Harry Bartz Jim Blaylock THRU:
Ron Brightsen
SUBJECT:
VISIT TO B&W COMMERCIAL JUNE 19, 1979 H. Bartz and J. Blaylock visited B&W to:
1.
review data required by license conditions on sampling and analytical chemistry bias for possible modifications.
2.
redw proposed revision of Chapter 5 (physical inventory) of FNMC plan.
3.
review implementation dates of measurement control plan.
B&W Commercial conducts a sampling program on incoming UO7 powder as required by License Condition 4.3, due to possible stratification of material.
J. Blaylock reviewed the data collected in response to this program.
The intent of the plan was to monitor sampling random error to assure represent-ative random samples.
The data indicated that the analytical random error did not vary significantly from replicate to replicate. Howei er, the sampling random error did vary significantly according to statist ical tests. The licensee performed tests on the data to test for pooling. No problems arose on the analytical random error, but liberties were taken with the sampling randem error data to allow pooling.
J. Blaylock stated that their handling of the sampling error data was incorrect and unacceptable.
To some extent the exercise may now be academic. B&W Apollo changed powder loading procedures to alleviate possible stratification of the UO material.
In addition, the effect on the last calculated LEID was examined.2 By assuming the worst possible random sampling error, the S&W Commercial LEID for the last inventory increased 100 grams.
The 70.57 Criteria allows the licensees to combir.e the analytical and sampling random errors if only one analysis per sample is run. This is acceptable provided the resulting contribution to the LEID is not significant.
In the B&W case, the data indicates non-representativeness of sampling (on material no longer leaded the same way), yet the results of this non-representativeness do not make much difference on LEID. Hence, J. Slaylock recomended that the sampling plan at B&W be reduced with the stipulation that if the combined analytical-sampling randcm error exceeds some defined amount, the sampling program should be reinstated.
To scme exten,t, this could be a neneric condition.
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' A discussion was held between H. Bartz and D. Zeff on questionr sent to
==au BY,1 in our letter dated May 24, 1979. Although B&W did not really DISTRIBUTIOM i express enthusiasm about tne NRC request for additional details on Docket File inventory verification, t. hey could not find a valid reason to object.
MCL r/f Their notes for this meeting did not show sufficient detail for an Case File acceptable revision. Specifically:
DCS JBlaylock 1.
Categorization of inventory types and forms - not complete.
HBartz 2.
Tables in present Chapter 3 showed rore than one sampling and RBrightsen assay method. Did not indicate crite:ia for choice between methods for each category of material.
i 3.
For material not tamper-safed, should require 100% weight verification.
h 4.
Present FNMC plan allows statistical sampling and assay for U and a
U-235. Asked for specific criceria for each type of SNM (oxide, I
scrap, recycle) etc. Asked for statement on administrative or physical basis for determining that material is not commingled at inventory time.
At the conclusion of discussion, Cartz asked Dave Zeff when revised Chapter 5 o
would be ",ert to NRC. Mr. Zeff promised to have revisions in the mail by June 29.
L Final item was discussion of B&W letter dated June 12, 1979 regarding F
implementation of FNC Plan. Additional time beyond original 30 day wasm requested for:
1.
Selection of Measurement Control Coordinator.
2.
Management audit of systems.
3.
Procedures for measurement methods.
c r
We advised B&W that it is our opinion that the measurement control coordinator 4
could be selected, indoctrinated and fuictioning within 60 days.
In the
. interim, or if further time is required, Dave Zeff, Pat Waters, or the QC senior man could fill in.
B&W had prior koowledge of tha need for this person. Mr. Zeff said' they had a previous choice turr, down the position and haJ an offer tendered ta a young lady and were w3iting for a resperae.
The management audit would be required within one year of the effective implementation date. No additional time is needed.
CT.I stated they had written procedures for all measurements wh1;h effect MUF & LEMUF.
It was not in bound form, i.e.. a manual. Althouah some changes may be required, we assured them that it was only necessary to have and use acceptable procedures. The NRC does 60t' require a bound volume.
We did ask them to review and update present procedures as a priority item.
Tile meeting closed at 2:45 p.m.
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