ML19269D468

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Revises Amend SG-4 to License SNM-1107 to Require That Licensee Will Adhere to Fundamental Nuclear Matl Control Plan.Request for Addl Time to Implement Program May Not Be Granted W/O Proper Justification.License Condition Encl
ML19269D468
Person / Time
Site: Westinghouse
Issue date: 04/30/1979
From: Partlow J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Dipiazza R
WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
References
NUDOCS 7906040115
Download: ML19269D468 (4)


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4 UNITED STATES 7

NUCLEAR REGULATORY COMMISSION i kA)_ j WASHINGTON, D. C. 20555

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\\; %'#f APR 3 0 1979 SGML:CWE 70-1151 Westinghouse Electric Corporation Power Systems ATTN:

Mr. Ronald P. DiPiazze, Manager NES License Administration P.O. Box 355 Pittsburgh, Pennsylvania 15230 Gentlemen :

We have reviewed and accepted your revised Measurement Control Plan dated April 6,1979, which was submitted pursuant to 10 CFR 70.57(c) and to our request dated November 17, 1977.

In order to assure complete compliance with the requirements of 10 CFR 70.57, we have found it necessary to equire that your Material Control and Accounting program be strengthened in certain respects.

Accordingly, we are revising Section 4.0 of Amendment SG-4 to Special Nuclear Material License No.1107 as set forth in Enclosure 1.

The new License Conditions being added to Section 4.0 were discussed with Messrs. W. Goodwin, J. Chinault, C. Vogel and H.' Foster of the Westinghouse Nuclear Fuels Division during an April 16, 1979 meeting at this office, and consensual agreement concerning their acceptability and wording was reached.

'With respect to the timing of implementation, we note that in your transmittal letter you requested add:+1onal time to implement certain aspects of your Measurement Control program. A decision on your request cannot be rendered until appropriate justification is provided.

We have determined that the degree of standards verification (power of the test) is not adequately addressed in Section 4.2.l(.c) of your Plan.

The values assigned to the reference standards associated with your various measurement systems should be verified to an extent that minimizes the potential undetected bias associated with the Inventory Difference (ID) quantity.

Therefore, we request that you submit, within six months of the date of this letter, an assessment of the potential magnitude of ID bias due to the degree of verification that you currently perform on each reference standard.

Please feel free to contact us if additional assistance cr guidance is necessary.

7906040115

We have determined that your initial and revised Measurement Control Plans of November 7,1975, May 1,1978, February 15, 1979 and April 6,1979 contain information of a type specified in 10 CFR 2.790(d). Accordingly, pursuant to Section 2.790(d)(1), such information is deemed. to be commercial or financial information within the meaning of 10 CFR 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12.

Sincerel

' n d's G. Partlow, Chief Jam rial Control & Accountability Mat Ltcensing Branch Division of Safeguards 2258 296

~New License Conditions For Materials And Plant Protection Amendment SG-4 to License No. SNM-1107 2.0 FACILITY OPERATION 2.1 The licensee shall follow the material control and accounting plan entitled, " Fundamental Nuclear Material Control Plan - Columbia Plant" dated January 24, 1975, as amended June 10, September 23, October 14, 1975, and April 6, 1979, with the exception of Section 1.3, and as revised in accordance with the provisions of 10 CFR 70.32(c).

4.0 MEASUREMENT CONTROL 4.1 The licensee shall assure that all measurements, including those performed to estabiish correction factors due to:

(1) the non-representativeness between reference standards and process materials, and (2) variability in measurement conditions are traceable to national standards, nationally accepted measurement systems.

4.2 For those material types for which the data does not already exist, studies concerning mixing, sampling, subsampling and sample integrity of SNM, as required by 10 CFR 70.57(b)(4), shall be completed within 12 months following approval of the Plan identified in License Condition 2.1.

Those material types with the most significant impact on the inventory difference quantity shall be completed first.

Results of the studies for all sampling systems and previous data generated to demonstrate representative sampling shall be submitted to NRC for review.

4.3 Notwithstanding the commitments in paragraph 4.2.3(g) of the Plan identified in License Condition 2.1, the licensee shall either perform overcheck measurements on volumetric glassware to verify the accuracy of calibration markings or use glassware that is individually certified and serializ;.. Overcheck measurements shall be traceable to the national measurement system or physical constants and performed before the glassware is used for material control and accounting measurements.

4.4 Notwithstanding the wording of paragraphs 4.2.l(d) and the second paragraph of Section 4.2.3 of the Plan identified in License Condition 2.1, the licensee shall use representative standards that span the range of operation for the calibration and control of the Nuclear Chicago Gas Proportional Counters used to measure liquid effluents.

22158 297 i egewee me eM e s ees ee

4.5 Reference standards used in the calibration of nondestructive assay systems shall be representative of the material to be measured:

consideration shall be given to matrix composition, SNM geometrical distribution, quantity and isotopic content. The licensee may use generic standards for items to be measured which are nonroutine and which do not have a significant impact on the ID and the LEID.

4.6 Notwithstanding the requirements of 10 CFR 70.57(b)(3) to perform audits and reviews of the measurement control programs of contractor facilities, the licensee shall follow Section 4.1.5 of the Plan identified in License Condition 2.1.

4.7 Notwithstanding the requirements of 10 CFR 70.57(b)(8) to measure standards and replicates for volume systems, to not provide de minimis quantities for bias significance, bias corrections and systematic error significance, to determine separate random errors for sampling and analytical, and ta generate random errors for bulk and NDA from replicate measurements of process materials, the licensee shall follow Sections 4.2.2, 4.2.4 and 4.4 of the Plan identified in License Condition 2.1.

4.8 Notwithstanding the requirements of 10 CFR 70.57(b)(4) to determine systematic sampling error and to conduct process and engineering tests on sampling systems for all material types, the licensee shall follow Section 4.3 of the Plan identified in License Condition 2.1.

4.9 -Except as specified in License Condition 4.7, limit of error calcula-tions shall include consideration of both random and systematic errors in all components of measurement. All identifiable covariance effects shall be taken into account in the calculation of LEliUF.

4.10 The frequency and the quality of the material transfer and inventory measurements of the DCFB material balance area shall be designed so that the LEMUFs associated with uranium and U-235, during any required material balance period, do not exceed 0.5% of the additions to or removals from material in process, whichever is greater.

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