ML19269E142
| ML19269E142 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 05/24/1979 |
| From: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Zeff D BABCOCK & WILCOX CO. |
| References | |
| NUDOCS 7906260572 | |
| Download: ML19269E142 (3) | |
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SGiL:HB 70-1201 Babcock & Wilcox Company Power Generation Division ATTN: Mr. D. W. Zeff, Manager Nuclear Materials Control P.O. Box 1260 Lynchburg, Virginia 24505 Gentlemen:
This is in response to Attachment 2 of your letter dated September 6,1978 and your letter dated April 27, 1979 both of which transmitted changes to your Fundamental Nuclear Material Control Plan under 10 CFR 70.32(c).
Our review has identified a number of items which are not adequately addressed or need clarification. The enclosures to this letter describe those items which must be addressed in order to complete our review. is general in nature and expounds on the philosophy of the regulations for physical inventory. Attachment 2 is specific to Chapters 5, 6, 7 and 8.
It has been established that the enclosures to your letters dated September 6, 1978 and April 27, 1978, and the enclosures to. this letter 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.
Sincerely, L
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Jam ( s G. Partlow, Chief Material Control & Accountability Licensing Branch Division of Safeguards Attachments:
As stated 2133 354 79082eo r7 2 C
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Physical Inventory 10 CFR 70.51(f) specifies requirements for a physical inventory of SNM.
Part 1(1) states:
" Establish physical inventory procedures to assure that: the quantity of special nuclear material associated with each item on inventory is a measured value."
Chapter 5 of your Fundamental Nuclear Material Control Plan describes B&W procedures for the physical inventory verification. Item 5.8 "Use of Factors" and Item 5.9 " Prior Measurements on Nontamper-safed Items" states these values are accepted if verified at the 95% confidence level. These are examples of procedures that must be clarified to determine if they are acceptable under the regulation. The primary problem is that the FNMC Plan lacks necessary detail as indicated in 10 CFR 70.51(f)(3) - in-process items; and 10 CFR 70.51(f)(4)(ii) - process line cleanout.
Statistical sampling of nontamper-safed items may be acceptable when administrative controls are provided to prevent crossover of lots by segre-gation of material and storage time for such items is restricted.
Chapter 5 should be rewritten'to indicate where sampling plans are used - by category of material; in-process material measurement - including holdup in equipment; and, inventory of in-process storage. As a minimum, all open items of SNM must be weighed.
S
5.0 PHYSICAL INVENTORY 1.
5.5 First Sentence "NMC personnel bring current and reconcile all NMC ledgers and journals." What does this mean?
2.
5.8 First two words
" uranium capability", please clarify.
3.
5.9 Nontamper-safed items should have 100% weight check not 95% confidence l evel.
Check to see if sampling plan is acceptable.
4.
5.10 Is there a 100% cleanout between enrichments?
5.
5.11 " steps are taken to consolidate similar categories of SNM specified in 5.10".
Explain.
6.
5.11.1 Sampling and analysis plans used for determining uranium and isotope factors are described in Chapter 3."
Explain using specific categories.
SNM items not tamper-sealed may be sampled on a statistical basis for inventory measurements as long as enrichment, lot, and material type identity is maintained." Explain how this is done at B&W.
7.
5.13 Each plant ID and LEID determination shall be verified by an individual not involved in the original calculation.
6.0 MATERIAL ACCOUNTING SYSTEM 1.
6.3 Audits "and general plant conformance to regulations and license conditions."
7.0 INTERNAL CONTROL 1.
7.1.3 In those cases where the shipper limit of error is not available DOE has agreed to supply data. This item should be deleted.
NRC should be contacted if data is not available.
8.0 MANAGEMENT 1.
8.2.1 Management Audit The annual audit described in Section 6.3 includes comparison of basic operating practices with specific license conditions and the regulations.
2.
8.2.5 Refer to 10 CFR 70.52 which requires notification of missing items to the NRC.
2133 356
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