ML19284B972

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Forwards Revised Amend MPP-2 to License SNM-777,revising Decommissioning Fundamental Nuclear Matl Control Plan,In Response to 801027 Request.New License Condition 3.2 Requires Representative Enrichment Measurements
ML19284B972
Person / Time
Site: Wood River Junction
Issue date: 12/04/1980
From: Partlow J
NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
To: Amy G
UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.)
References
NUDOCS 8101060924
Download: ML19284B972 (5)


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United fluclear Corporation Recovery Systems Division ATTil:

Mr. Glenn Amy

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d One Narragansett Trail Wood River Junction, Rhode Island 02894 Gentlemen:

This is in response to your letter dated October 27, 1980 which transmitted the revisions to your Decomissioning Fundamental Nuclear Material Control Plan required by License Conditions 3.2 and 3.3.

The letter also transmitted a Plan revision involving measurement of contaminated equipment that was implemented and reported under the orovisions of 10 CFR 70.32(c). We have determined that the commitments involving the bulk measurement of acid rinse solutions and the measurement of contarinated equipment are acce? table.

However, in connection with the enrichment measurements, we find your cocnitment unacceptable. Consequently, we are adding a new License Conditicn 3.2 that requires representative enrichment measurements be performed.

In order to incorporate thi: Candition and the revisions citea abovet we are revising Amencment MPP-2 to your License No. SNM-777, effective immediately, as snown in the enclosure.

We have determined that the enclosure to your letter dated October 27, 1980 contains infomation of a type specified in 10 CFR 2.790(d).

Accordingly, pursuant to Section 2.790(d)(1), such infomation is deeneo to be conmercial or financial information within the meaning of 10 CF'l 9.5(a)(4) and shall be subject to disclosure only in accordance with the provisions of 10 CFR 9.12.

Sincerely, ll James lG Partlow, Chief

Mater, Control and Accountability Licensing Branch

Enclosure:

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Enclosure Revision of Sections 1.0 Through 3.0 In Their Entirety ta Materials and Plant Protection Amendment MPP-2 to License No. SNM-777 Effective 9/19/80 1.0 FACILITY ORGANIZATION 1.1 Notwithstanding the requirements of 10 CFR 70.57(b)(2) to perform reviews and audits of the measurement control program, the licensee is exempt from such reviews and audits during the deconmissioning of the Plant.

1.2 Notwithstanding the requirements of 10 CFR 70.57(b)(3) to perform reviews and audits of a contractor's measurement control program at intervals not to exceed every 12 months, the licensee is exempt from this requirement.

1.3 Notwithstanding the requirements of 10 CFR 70.58(c)(2) to perform reviews and audits of the nuclear materiel control program at least every 12 months, the licensee is exempt from this requirement.

2.0 FACILITY OPERATION 12/3/80) 2.1 The licensee shall follow the Fundamental Nuclear Material Control Plan, except Section 3.6, paragrach one, and Sectica 7.1, trans-mitted with correspondence dated August 29 and September 8, 1980 and as revised October 24, 1980 and in accordance with the provisions of 10 CFR 70.32(c).

2.2 No statement in the licensee's Plan identified in Condition 2.1 shall relieve the licensee of a requirement of 10 CFR Part 70 unless granted in a specific exenption or exception set forth as a condition of this license.

2.3 Operations involving special nuclear material wnich are not described in the Plan identified in Condition 2.1 shall not be initiate

. 3.0 MEASUREMENTS 3.1 The licensee or his designated snall measure except as specified in 10 CFR 70.58(e) and Conditicn 3.2, the uranium and uranium-235 content of all special nuclear material shipments, waste discards, internal transfers from MBAs and material on inventory.

2/3/80) 3.2 The uranium content of materials neasured by nondestructive assay may be calculated based on enrichment provided it can be dencnstrated that the enrichment value is representative.

Representative is defined as traceable to the source of the SNM.

4.0 MEASUREMENT CONTRCL 4.1 The responsibility for planning, developing, coordinating, and administering the measurement control program shall te assigned to an individual in accordanca uith tne criteria specified in 70.57(b)(1).

4.2 The assigned value for working calibration and test material s prepared from process materials sncil be based on measurement by two different methods or laboratories.

For NDA standards, this requirement applies to tnc characterization of the SNM ased to prepare the standard.

4.3 In lieu of the requirement in 10 CFR 70.57(b)(11) to establish control chart limits of the 0.001 level of significance, the licensee shall follow Section 4.4.1.2 of the Plan identified in License Condition 2.1.

4.4 All instruments used for material control and accounting purcosas shall be calibrated over the range of operation, and results outside the range shall not be used.

4.5 Notwithstanding the requirements of 10 CFR 70.57(b)(ll) to estaclish control limits at the 0.05 leal of significance, the licensee may establish the control limit fcc scales and balances it a value

..hich is equal to the readao:lity of the device.

4.o The licensee snall assure that 311 measurements, including those perforT.1ed to establish correcting f actors applied due to (i) ncn-representativeness between ref arence standards and precess materi3ls, and (2) variability in measurewnt conditions, 3re traceable ta national standards or nationally accepted neasurement systens.

4.7 All nondestructive assay systers snall te calibrated aith a t aimun of four standards, one of which may be 0.0 grams J-235.

Eacn standard shall be counted a mim.num of three times.

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4.3 Mondestructive assay stancarcs sr.all ce representative of the material to be measured.

Consideration shall oe given to uatrix, isotcpic ratios and geometrical distribution.

4.9 Control of measurement systems shall incluce the measurement of standards over the range of operation.

4.10 For determining systematic error variances, the licensee shall use the uncertainty on the bias or the uncertainty on the original calibration, as appropriate, plus the uncertainty on the standards.

4.11 Notwithstanding the requirement of 10 CFR 70.57(b)(8) to run standards and replicates for volune systems, to perform replicate sampling and repi1cate analysis for environmental releases, to perform replicate isotopic analysis, to generate random errors for bulk measurement systems from replicate measurements of process materials, and to require separate random errors for sampling and analytical on all sampling systeas, the licensee shall follow the Plan identified in License Condition 2.1.

4.12 The licensee shall detennine the magnituce of bias correcticns frca the standards program.

The bias corrections need not be applied in the accountirg records provided *.he bias is less than its associated limit of error.

5.0 PHYSICAL INVENTORY 5.1 Notwithstanding ne requirement of 10 CFR 70.51(e)(4;r,i) ta calculate a limit of error associated with an Inventory Difference determinat:cn, the licensee need not calculate a limit of arrar during tne facility ceccmaissioning.

t RECORDS AND REPORTS 6.1 The licensee shall report on a montnly basis all intentional discards and material unaccounted for.

The MUF shall be that ahich has been determined during the acnth as a result of completing a.naterial balance around a single operation, a number of operations, or the entire plant. This report shall be made within fifteen (15) days af ter the end of the acnth in which the discard was made or the material unaccounted for was detenained.

Reports shall be sent to the Regional Of fice of the Nuclear Regulatory Commission.

i.2 The licensee shall establish 2 separate account for accumulaticn of all material gains resulting fraa the f acility deccamissicning.

4 7.0 INTERNAL CONTROL

'1 Accurate records shall be estaolished and maintained which provide on a daily basis knowledge of the identity,1ccation, and quantity of all S3NH within each plant in discrete itens ana containers.

7.2 Two individuals shall attest to the contents of containers or vaults prior to tamper-safing.

8.0 MANAGEMENT 3.1 Any apparent loss of a discrete item or container which cannot be resolved by an imnediate investigation shall be reported to the Manager of Quality Assurance who shall immediately notify the Region Office of the Nuclear Regulatory Commission and shall conduct an investigation of the loss.

The Man:ger of Quality Assurance shall document the results of his investigation and maintain the record for five years.