ML19269E076
| ML19269E076 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 05/16/1979 |
| From: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Lichtenberger H ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| Shared Package | |
| ML19269E077 | List: |
| References | |
| NUDOCS 7906250001 | |
| Download: ML19269E076 (5) | |
Text
.
PbR
,,/
Ijo,,
UNITED STATES y;
g NUCLEAR REGULATORY COMMISSION g
E WASHINGTON, D. C. 20555 un e
.%;..v /
AiAY 16 L979 SGML:EJM 70-1100 Combustion Engineering, Inc.
Power Systems ATTN: Mr. H. V. Lichtenberger Vice President - Manufacturing 1000 Prospect Hill Road Windsor, Connecticut 06095 Gentlemen:
We have reviewed and accepted the revised measurement control plan subm, ticd with your letter dated February 15, 1979 which was submitted purstant to 10 CFR 70.57(c) and to our request dated November 17, 1977.
In order to ensure complete compliance with the requirements of 10 CFR 70.57, we have found it necessary to require that your material control and accounting program be strengthened in certain respects. Accordingly, the new conditions listed in Enclosure 1 are being added to your license.
These new conditions were discussed with Messrs. T. Bowie and G. Kersteen on May 15 and 16,1979 and consensual agreement concerning their acceptability and wording was reached on all except Condition 4.15.
Pursuant to the NRC's Rules of Practice as set forth in 10 CFR 2.204, you may request a hearing within 20 days of the date of this letter with respect to Condition 4.15.
In order to consolidate these conditions with outstanding letter amendments to your safeguards amendment, and to withdraw obsolete amendments, Special Nuclear Material License No. SNM-1067 is hereby amended to incorporate Material and Plant Protection Amendment MPP-4 (Enclosure 2), to be implemented '.birty (30) days after the date of this letter.
When this amendment is implemented it will supersede in its entirety Amendment MPP-3 which was previously issued to this license.
We have determined that the degree of standards verification (power of the test) is not adequately described in Section 4.2.1.2 of your Plan.
The values assigned to reference standards involved in your measurement systems should be verified to an extent that minimizes the potential undetected bias associated with the material unaccounted for (MUF) quan ti ty.
Therefore, we request that you submit, within two months of the date of this letter, an assessment of the potential magnitude of MUF bias due to the degree of verification that you currently perform on each reference standard.
Please feel free to contact us if additional assistance or guidance is necessary.
2199 320 7906250031
You will notice that a large number of license conditions were necessary to strengthen your reasurement control program.
We sincerely hope that as time becomes available your staff will appropriately revise the measurement control chapter so that as many of these license conditions as possible can be deleted.
We have determined that your initial and revised measurement control plans of November 10,1975, April 14,1978, December 5,1978 and February 12, 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 connercial or financial information within the meaning of 10 CFR 9.5(a)(4) and shall be subject to disclciure only in accordance with the provisions of 10 CFR 9.12.
Si ncerely, d-h ames Partlow, Chief
/
Material Control & Accountability Licensing Branch Division of Safeguards
Enclosures:
1.
New Conditions 2.
Sections 1.0 thru 8.0 to SNM-1067 cc: Mr. T. Bowie Combust ion Engineering, Inc.
Windsu, Connecticut 06095 4
2199 321
New License Conditions For Materials And Plant Protection Amendment MPP-4 to License No. SNM-1067 2.)
The licensee shall follow the Fundamental Nuclear Material Control Plan dated January 1975, as revised July 1975 and December 1977 with the exception of Chapter 5.0, as amended February 12, 1979; and as revised in accordance with the provisions of 10 CFR 70.32(c).
2.3 The Plan identified in Condition 2.1 is applicable only to low enriched uranium.
Prior to the receipt and processing of highly enriched uranium in unsealed form, a plan for that material shall be submitted by the licensee and be approved by the NRC.
4.1 The licensee shall assure that delegations of measurement control responsibilities by the Nuclear Materials Manager are consistent with the separation of functions in 10 CFR 70.57(b)(1), and that such delegations do not detract from his responsibility for planning, developing, coordinating, and administering the program.
4.2 The reviews and audits required by 10 CFR 70.57(b)(2) and (3) shall be performed at intervals not to exceed 12 months.
Individuals shall not review their own or their reviewer's area of responsibility.
4.3 Reference standards prepared from process materials shall have assigned values and uncertainties which are based on measurements by either two independent laborat6 ries or two independent measurement methods which shall verify each other. The assigned values and uncertainties shall be determined by weighted pooling of data on the ba' sis of variance.
4.4 Standards.aed in the calibration and control of measurement systems shall be representative of all material to be measured.
Consideration shall be given to matrix composition, and SNM geometrical distribution, quantity and isotopic content when preparing nondestructive assay standards.
4.5 All non',ansumable tsference standards shall be stored in a manner which maintains their validity and integrity.
4.6 All consumable reference standards shall be recertified annually except those whose method of storage has been determined to be adequate.
Determinations of adequacy shall be based on measurements.
4.7 Notwithstanding Section 4.2.2.1 of the Plan identified in Condition 2.1, a standards program shall be maintained to provide a minimum of two measurements of standards per week for e'ach measurement system. Where measurements of samples are made on an intermittent basis, two measure-ments of standards shall be made during the weeks in which one or more samples are measured.
2199 322
4.8 The licensee shall assure that individuals measure both standards and process materials in such proportions that a bias introduced by the individual will be eliminated through the application of a bias correction.
4.9 Measurement systems shall be recalibrated whenever:
a.
an out-of-control condition is indicated by the measurement of a reference standard when the cause for such an out-of-control situation cannot be assigned to an error affecting that standard measurement alone, or b.
a change or modification is made to.the measurement system which could affect measurement results.
4.10 The licensee shall assure that all measurements, including those per-formed to establish correction factors applied due to (1) compositional differences between reference standards and process materials, and (2) variability in measurement conditions, are traceable to national standards or nationally accepted measurement systems.
4.11 Except as exempted in Conditions 4.17 and 4.18, limit of error cal-culations shall include considert. tion of both random and systematic errors in all components of measurement. Al' identifiable covariance effects shall be taken into account in the e.culations of LEMUF.
4.12 The licensee shall conduct the sampling, mixing, and sample integrity studies required by 10 CFR 70.57(b)(4) by May 9,1980. Those studies which have already been completed and for which the licensee has data to substantiata current sampling, mixing, and sample integrity procedures do not have to be repeated.
4.13 Volumetric calibrations of holding tanks shall include a minimum of four runs each of which shall have a minimum of six increments.
4.14 Notwithstanding Section 4.4.1 of the Plan identified in Condition 2.1, the licensee shall not reduce the analysis of replicates below the minimum specified therein unti.1 such reductions have been approved by the NRC.
~
4.15 The periodic statistical analysis of control data described in the third sentence of the second paragraph of Section 4.5.1 of the Plan identified in Conditien 2.1 shall be performed every two months.
4.16 Notwithstanding the requirements of 10 CFR 70.57(b)(ll) to use Contro. Charts to monitor the quality of each program measurement and to use the.001 level of significance for control of scales, the li.ensee shall follow Section 4.5.1 of the Plan identified in Condition 2.1.
4.17 Notwithstanding the requirements of 10 CFR 70.57(b)(4) to provide sampling systematic errors, the licensee shall follow Section 4.2.4.2 of the Plan identified in Condition 2.1.
2199 323
3-4.18 Notwithstanding the requirements of 10 CFR 70.57(b)(8) and (10) to not provide de minimis quantities for bias calculations, bias corrections, and systematic errors, the licensee shall follow Section 4.2.t of the Plan ider ified in Condition 2.1.
4.19 Notwithstanding the requirements of 10 CFR 70.57(b)(8), the licensee may 1) obtain random and systematic error data for volume from calibration data, 2) combine random analytical and random sampling errors, and 3) generate random error data for bulk and NDA from the measurement of standards.
6.5 The licensee shall assure that macerial balance records maintained pursuant to 10 CFR 70.58(k) are free from biases which have been determined to be statistically significant at the 0.05 level of significance prior to calculation of inventory difference. The effect on inventory difference of biases which are not statistically significant at the 0.05 level of significance shall be maintained pursuant to 10 CFR 70.51(e)(4)(iii) and reported to the NRC Region I Office within 30 days following the start of the physical inventory.
O O
2199 324
_