ML19259C814
| ML19259C814 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 06/04/1979 |
| From: | Lichtenberger H ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Mccormick R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| References | |
| NUDOCS 7908150221 | |
| Download: ML19259C814 (5) | |
Text
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- **i ~ C-E Power Systems Tel 203/688-1911 1
Combushon Engineenng inc Telex. 99297 L
1000 Prospect Hal Road Windsor. Connecucut C6095
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June 4,1979 RECEIVm G
2 U. S. Nuclear Regulatory Ccmmission JUN 1 i 1979 >
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Silver Spring, MD 20910 Aiitention:
Mr. Richard G. McCornick b
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Assistant Director o
I O' Division of Material Safeguards
Subject:
License Conditions 4.3 and 4.5 of Amendment MPP-3 to License SNM-33 Gentlemen:
The new license conditicns listed in MPP-3 have been received and have been discussed with members of your staff.
We have not offered consensual agree-ment on license conditions a.3 and 4.5.
It was our understanding that Mr. Partlow's letter of November 17, 1977 re-questing a resubmittal of our Measurement Control Program description provided for an " effort-benefit" approach to determining the level of control required for each measurement system.
Discussions between our staffs revealed that there were two areas of disagreement concerning the technique and level of con-trol provided by current measurement systems. One of these areas of disagree-ment concerns the standard used in the nondestructive assay of wastes; the other area of concern involves the traceability to NBS Standards of volumetric glassware used in the analytic laboratory.
In order to place our position in perspective, an ' effort-benefit' discus.sion was submitted with the revised sub-mittal of the Hematite Plan.
It is our contention that the standard currently used for ti.e NDA System is perfectly adequate and correctly assures that the system is in control at a level of assurance that is commensur ce with tne quantity and type of material being measured. The cost of compliance uith license condition a.3 is not war-ranted in light of the marginal bene to be gained.
The attachment to this letter describes in detail the effort and benefits associated with this require-ment.
Our second contention is that we fulfill the requirement for traceability of standards and measurement systems even in the analytic laboratory where volu-metric glassware is purchased and used according to the requirements of Class A, NSS Circular 602.
The analytic measurement systens in questicn are " trace-able" by the continuous use of NSS certified uranium standards that assure the control of the measurement systems.
Further discussion of the minimal benefits that are to be gained by ccmpliance with condition 4.5 is included in the attach-ment.
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While we already have submitted ' effort-benefit' analyses. they have been rejected by means of the license conditions. Never have we been provided a formal or satisfying explanation for the denial of our effort-benefit approach.
It is therefcre requested that your staff objectively reconsider the subject conditions and the attached effort-benefit arguments. This re-quest for reconsideration is submitted in lieu of a request for a public hearing at this time.
However, we would like to reserve the option to re-quest a public hearing at a later date. Therefore, it is requested that the 20-day period for requesting a hearing be extended to JJne 30, 1979 or such later date consistent with the review requested of your staff.
Very truly yours, H. V. Lichtenberger Vice President-Nuclear Fuel.
Nuclear Power Systems-Manufacturing HVL/GCX/ssb Enclosure cc:
Mr. James Partlow
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EFFORT-BENEFIT ATTACHMENT
Reference:
Amendment MPP-3 to License No. SNM-33 Condition 4.3 Condition 4.3 relates to our gamma counter and requires geometry and matrix specific control standards for the on-going stability verification of the instrument.
The condition and associated cost is not warranted in that:
The counter was calibrated by methods consistent with Regulatory Guide 5.53, Qualification, Calibration, and Error Estimation Methods for Nondestructive Assay. This guide specifically acknowledge. the impractica-bility of using calibration standards as working standards for monitoring long term stability.
The license condition goes beyond that.
The counter is used for the low grade materials only and primarily as a "go, no-go" measurement to decide between recovery and burial of those materials that are not amenable to sampling.
Burials amou;.t to less than.02% of the plant shipments.
In the three year period ending with the January 1979 inventory a total of 34 Kg U was buried; during this same period, 432,700 Kg U was shipped as product.
A burial shipment this month contains about 1 Kg U in a truck load of bulk.
Of material on hand at inventory only about 2-3% is represented by gamma count assay.
In. terms of LEMUF, the gamma counter contributes 1-5 grams U-235 in a plant total of 2300 to 3900 grams U-235.
The direct cost of compliance is estimated at $3000-54000.
Additionally, there is the continuing administration cost for control and handling of the standards. This is unnecessary and certainly not cost effective.
Condition 4.5 This ccndition requires the scecific 1C05 calibration of analytical glass-ware - pipettes, burettes, volume flasks, etc. with traceability to the National Measurement System.
This goes beyond the requirements of the regulation.
The Measurement Control Program submittal ccmmits us to use "SS certified uranium assay standards to calibrate and control our assays.
Adding the requirement to specifically calibrate the glassware with traceability to NBS is redundant and will not increase the accuracy and control of the
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. Condition 4.5 (Cont'd) measurement or significantly effect LEMUF.
The regulation defines:
Calibration "The process of determining the numerical relationship between the observed output of a measurement system and the value, based upon reference standards, of the characteristics being measured."
Traceability "The a.iility to relate individual measurement results to national standards er nationally accepted measurement systems through an unbroken chtin of comparisons."
We use glassware guaranteed by the manufacturer as meeting calibration requirements of Class A, NBS Circular 602.
The NRC concern is that the manufacturer verifies calibration on a statistical sampling plan and therefore it is possible to have a piece that is not accurate. The chance of such occurrence is remote and should it occur, our NBS certified stan-dard will identify the problem.
The requirement for " Traceability" is fulfilled by use of the NBS certified uranit, assay standards.
Further, no significant benefit is gained sinca the particular analytic techniques are used only for:
Filtrate assay The filtrate now regularly is less than.01 gran U per liter, most are.005 grams U per liter or less.
Significant improvement hr.s been achieved in the process to the extent that the total uranium discarded in filtrates was 510 grams V (for the
.6 months inventory period ending January 1979) and less than 250 grams U since January 1979.
Contaminated scrap assay The glassware is used in the Davies-Grey (British assay) assay procedure.
The test was qualified and is controlled based on routine use of NBS certified U 0.
Sampling error of the material is more significant than 38 the procedure error.
Should a piece of glassware be significantly out of calibration - the NBS standard will identify the problem.
The ' British" assay's contribution to the LEMUF is less than
.57..
Conclusion It is evident that the requirements of license conditions 4.3 and 4.5 go beyond the scope and definitions found in 10CFR70.57.
Further, it is clear that the benefit to be gained by the imposition of these license conditions does not justify the cost of their implementation.
Finally, the net effect of such 650360 n'....,
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, implementation on th'e level of measurenent control (as reflected by the LEMUF) would be nearly insignificant.
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