ML20005D609

Sanitized Insp Rept 70-1113/84-05 on 840326-09.No Noncompliance Noted.Major Areas Inspected:Measurements & Internal Controls

ML20005D609
Person / Time
Site:	07001113
Issue date:	05/09/1984
From:	Bates J, Mcalpine E, Todd G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19327A915	List: ML19327A914 ML20005D605 ML20005D606 ML20005D607 ML20005D608 ML20005D609 ML20005D610
References
FOIA-87-88 70-1113-84-05-0, 70-1113-84-5, NUDOCS 8910200051
Download: ML20005D609 (5)

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e Report No. 70-1113/84-05 Docket No. 70-1113 License No. $NM-1097 Safeguards Group No. III Licensee: General Electric Company Wilmington, NC 28401 Date of Inspecti

March 26-29, 1984 Type of Inspect on:

Special Unannounced Material Control and Accountability Inspectors- [ ~

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E. J. McAlpine. Chi diAE II Control and Date Signed Accountability S ction. S*feguards Branch Division of Radiatiois %fet and Safeguards-Inspection Summary Areas Inspected: Measurements and Internal Controls The inspection involved 54 inspector hours on site-by two NRC inspectors'and was begun during the regular hours.

Results:.The licensee was found to be in compliance;with NRC requirements in the two areas examined during the inspection.

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l REPORT DETAILS l

Report No. 70-1113/84-05 1.

Key Persons Contacted W. J. Hendry,. Manager, Regulatory Compliance

• C. M. Vaughan, Manager,- Licensing and SNM

• R. H. D. Foleck, Licensing Specialist R. I. Parnell, Supervisor,- Chemical Laboratory

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T. P. Winslow, Manager, Chemical Laboratory R. C. Church, Manager, Manufacturing System Operations The_ inspectors also interviewed several other licensee employees.

• Denotes those present at the exit interview 1

2.

Review of Concerns Regarding Measurements and Internal Controls

.l During the initial meeting with licensee management to discuss the. scope of-the review relative' to the receipt by NRC of allegations pertaining to the GE facility, the inspectors were apprised that GE management was also in receipt of certain alleged improprieties from one of their employees.. Since the allegations received by NRC'and the allegations' received by GE were in j

similar areas, the inspectors incorporated the stated concerns 'from both

-i sources into their review.

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MC 85206 Measurements It was asserted by a General Electric Wilmington Manufacturing Depart-

'I ment employee, that on -two different. occasions calibrations /verifica -

tions were not performed on enrichment. analyzers following a detector -

change.

Enrichment - analyzers are. used a toJ determine i the percent uranium-235 in a wide variety of' low' enriched UO2' powder and pellet -

i samples in which the sample is converted tos urano uranic oxide, i

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chemically treated, and a portion.of the. sample _ transferred to' a countin.g tube ~ for analysis.

4 The written procedure for this measurement entitled Isotopic U-Count j

Limit Change Criteria No. C01411, Revision 3, dated February 9,1983, cifies-that~ at the beginning of. a detector _ calibratio llowing a s

hour burn-off, a' calibration will be performed using sta rd l

that span th_e range of. operation followed by a verification of r

1 sample standardsL that also span the range of : operation.

If the count:

rate remains - in spect fied. limilsi the ' laboratory technician may then -

begin measuring a maximum of QQunknown production = samples. ~Each-l Ec7/,"o? o!setosuu:

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series of% production samples must be followed by either remeasure-ment of the alibration or verification standards to ;obtain an aggregate of high standard values that are used for the calculation of uranium count and the minimum uranium count limit.

The concerned employee asserted-that the measurement offs 1]x calibration standards was not being - performed according to procefufe.

It was-determined that 'the understanding of_ the employee concerntnc the' won _isur ceT. ermined through'

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- 4s verii n.euon or counting data records that combinations of calibrations and verifications were measured durtng the period when isotopic analyses of production' samples were performed.

These measurem nts of calibration / verification standards were performed a total of six times as specified by the licensee's procedure.

That production counting _

logs did not contain calibration data, indicated to the employee that calibrations had not been performed. This-lack of data in the counti.ng.

logs ~ was evident only in instances where calibrations were 'being-l performed and~ production samples were not being analyzed. This appears to have given the concerned worker the misconception that calibrations /

verifications were not being properly performed.

Through inquiry of laboratory managers, it was' determined.that-the subject calibration log book entries, are categorized as ; working documents that are generated during' production sample : analyses ;'as. a readily available summary of ' counting, data to be - used inn analyzing system stability and trouble shooting-during periods when. minimum uranium limits are exceeded.

The log-was not: intended to record all H

calibration and verification standards data as _ recorded by the printed 1

Laboratory Measurement Control-System (LMCS)' tape.

' it was determined through independent review of the calibration recording tape that during periods when the calibration log pages ware blank, the Laboratory Measurement Control ' Program ~was recording - the calibration data as performed.

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MC 85210 Internal Control 1

Computer Access Controls 1

a It was asserted by an employee of - the General' Electric Wilmington 1

i Manufacturing Department that-data stored in the computer from isotopic' I

analyses performed in the chemical laboratory are accessible and could.be altered. Specifically it was asserted that transactionicodes assigned j

to laboratory superviscrs that allow changes to analytical data associated with uranium samples were being used; by laboratory technicians and that this practice was condoned ~ by; supervisors.

Aoditionally, it was asserted that individual-technician's password a

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e that allow transaction entry into the Laboratory Heasurement Control-System (LMCS) were being used by fellow laboratory technicians to create false data or to release data created by other technicians.-

Through inquiry of laboratory management and selected laboratory technicians together with a review of pay ~ number, ~ password, and transaction controls, the inspectors. were ' able to determine-the following:

(1) The Chpet Laboratory Measurement Control System (LMCS). incorpo-rates (two transaction codes that allow the identified user to change data associated with analytical measurements of -uranium

_l sampleC These transaction codes are referred to as LMCS.902/903 transactions entitled " Update of the Sample and Test. Records," the instructions for which are dated August 4, 1983, and July 14, 1983, respec ively..The transaction codes identified above allow the user to correct' data input errors associated with production samples t ut cannot be ' used to change measurement results_ for.

L standardQ Additionally, modifica ions of results of. production samples were restricted to use _by laboratory supervisors only, i

It was acknowledged by laboratory management that 902/903;trans-actions were used.by laboratory technicians. in ' the absensec of their supervisor]but that the. authority to: do so-had {been gran3 to them through a verbal' delegation. This' delegation was.normally-granted during Lweekends, _ a in the laboratory. [' Interviews of: several-time when pervi sor[ would ' not.

L normally be present labor tory pe sonnel substantiated the use 'of verbali delegations by upervisors regarding the 'use of 902/903-transacti_ons. ~When apprised of fact that the use of, these transactions did not l-provide traceability for determining who_ actually corrected the I

data - or_ why the changes _were made, the licensee modified his operational procedures regarding: _ restricted'; access to these.

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transaction codes.

In a laboratory policy memorandum ~ dated January 19, '.1984, the licensee restated that the identified transaction-codes couldL not be used to change ' results ofi standards; re-emphasized; to super-visors the need for restricting access.to,the codes; indicated L

that supervisors - have been instructed _ to not divulge their-pa uwords for any reason; andsspecified that at anytime, a j

i supervisor feels his password has:become known to change it; and t

in the event of suspected ; password use,; he/she shall investigate-the condition immediately.

This measure and its timely implementation. was ' deemed : by inspectors to be appropriate and acceptable for improved-

.r trative controls over laboratory measurements.

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80 cry 2$$NQ (2) When

-use of the HP988hcomputer was initiated in November

1982, he password o the technician performing the sample solut on weighing _ was.used as the password associated-.with the identity of the persons performing the key process steps for'each sample.

This password _was also used as the sample identifier on the LMCS results' reporp - Since the ~ sample measurement process usually spanned beyond-a- single work shif t :the individual who actually released-the sample results would-not normally be the same' individual who had actually prepared.the sample-or performed the measurement.

It is pssib that a-shift technician who transacts data from the(HP988 to CS could innocently allow incorrect data to be transmitted.

he LMCS results report would ~

then show the incorrect data and t e password-of' the technician who weighed the sample ~ and.not the password of th technician who-entered the data incorrectly) by Because ~ of ' this sof tware limita -

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tion), the = indiscriminate use technicians ~ o each other's psf 7ords. was necenary to promptly_ release sample meas'urement -

deta. from the Hp988Jto LMCS.

r/f licensee modified his procedure for ' password control on Jangry 2L '1984, and. modified the transmitting icentifier within theljp988Z] computer on January 17, 1984. These referenced modifi-cations will restrict the issuance and changing of passwords -

_ts a E ngle auth rized individual. Also transactions between the-

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[HP9887 and th LMCS 1 record the password of the technician J

releaTing' the results.

The inspectors-detected ! no J evidence of:

intentional creation false. data within LMCS. ' The modifications as implemented by the licensee were _ deemed by the inspector's to:

g be an appropriate system ; improvement to the- --administ ra tive -

controls and appear to be consistent with the generally accepted

( intent of the principles of computer surety.-

I The evaluation of the results of these modifications and related laboratory

systems, will be' performed during subsequent 1

inspections (84-05-01).

j 3.

Exit Interview h

The inspection scope and findings were summarized on March 29, 1984, with those^ persons indicated in paragraph I above.

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JUN 18 g General Electric Company ATTN: Mr. J. A. Long, General Manager I

Wilmington Manufacturing Department l

P. O. Box 780-Wilmington, NC 28402 Gentlemen:

I SUILIECT: REPORT NO. 70-1113/84-06 Thank you for your response of June 7,1984, to our Notice of Violation issued on May 9,1984, concerning activities conducted at your Wilmington facility. We have evaluated your responses and found that it meets. the requirements of 10 CFR 2.201.

We will examine the implementation of your corrective-actions during future inspections.

We appreciate your cooperation in this matter.-

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1 Sincerely, 1-v J. Philip Stohr, Director Division of Radiation Safety and Safeguards cc:

C. M. Vaughan, Manager J-Licensing and Nuclear Materials Management Unit bec: Document Control. Desk

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Safeguards and Majorial Program i-i Branch, EW-359

-l Fuel Facility Safeguards Licensing Branch, 881-SS J

License Fee Management Branch State of North Carolina i

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