ML20005D610
| ML20005D610 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 06/07/1984 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML19327A915 | List: |
| References | |
| FOIA-87-88 NUDOCS 8910200053 | |
| Download: ML20005D610 (5) | |
Text
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(919) 343-5,656 June 7, 1984 Mr. J. Philip Stobr, Director Division of Emergency Properedness &
Materials Safety Programa U. 8. Nuclear Regulatory Commission, RII Post Office Box 2203
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Atlanta, Georgia-30301 Dear Mr. Stohr References (1) NRC Licence SNM-1097, Docket. 70-1113 (2) NRC Inspection Report 70-1113/84-06 l
dated'5/9/84 I
Thank ou very much for your letter re rtin$ricationplantby the results of the inspec ion conducted at our licensed f 1 fa Mr. B. L. Richards of your office on April 2-6,.1984.
i Pertaining to the items of apparent noncompliance with NRC requirements in your letter, the replies to these items are given in the attachment to this letter.
We appreciate your inspector's comments and suggestions related to our safeguards programs.
These comments and-suggestions are helpful to us'in our constant efforts to maintain and, where
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necessary, improve these programs and to ensure: the continuation of a successful' safeguards effort at our~ plant.
We also, welcome. further. discussion with your staff on the items in your letter - and in our related replies, 'if. necessary, for-further clarification.
Pursuant to 10 CFR 2.790(d), letter' be withheld from publicGeneral Electric Company requests
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that the' attachment to this j
disclosure since this attachment identifies details of General Electric's control and-accounting procedures for safeguarding o-licensed special nuclear material.
Very truly yours, GENERAL ELECTRIC COMP JW QG Sy C
t'W Charles M. Vaughan, Manager Licensing & Nuclear Materials Management M/C J26 CMV:cd SGD-I Attachment i
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GENERAL $ ELECTRIC Mr. J. Philip Stohr June 7, 1984 4
ATTACEMENT The information given below refers to the items in Enclosure 1 -
l Notice of Violation, in the NRC Inspection Report 70-1113/84-06, dated 5/9/84.
- 1. License Condition 2.t_of Safeguards i
Amendment No. MPP-3 to, Special _ Nuclear Materials License No. SNM-1097 requiree the licensee to follow the current revision of I
his Fu @ ental Nuclear Material Control' Plan. Qection 8.2.3.1 of.that' plan differenc(es to be reported to the Manager, requires jignificant shipper-receiver j
j Licensing d Nuclear Materials Management.
_l Contrary to the above, significant shipper-receiver dif ferences ~( for both" the individual cylinders and the shipment totals) on a shipment of uranium hexafluodde received; December 6, 1983, were not@eported to the Manage Licensing j
and Nuclear Materials Management This is a Severity Level V violation 1 j
(Supplement III).
l General Electric admits the violation as stated above.
The specific shipper-receiver differences (SRDs) report cited in this violation represented situations that were:similar to other SRDs
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i that had been observed and the appropriate corrective-actions were plied to this one as they were in the - past.
Unfortunately, the l
anager;. Licensing and Nuclear Materials Managemen (LENMM) was-l not immediately available to review the information and. the form' i
was set aside and subsequently overlooked.
i Th Manager, L&NMM has since reviewed this particular incident and 1
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de Irmined that tNY SRDs -were correctly handled end has signed-of f
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on the form.
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GENERAL $ ELECTRIC Mr. J. Philip Stohr June 7, 1984 Attachment - Page 2 In order to prevent this type of situation from reoccurring, the Manager, LENMM will instruct the responsible individuals,. in writing, that they at to follow the proceduros with particular!
emphgis on obtaining review and a signature ' from the Manager, L&Ngwhen required.
Full compliance will be achieved for this item by June 30, 1984.
- 2. License Conditon 2.1.of Safeguards r
. Amendment No. MPP-3 to Special Nuclear Materials License No. SNM-1097 requires the licensee to follow the current revision of his. Fungmental Nuclear Material-Control Plan. Qection 6.6 of~that plan requires the licensee to prepare and-distribute DOE /NRC-741 nuclear material transaction
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reports in accordance with the published-instruction, for the reoort]) The published instructions, NUREG/BR-0006,: require the licensee to enter. limits of ' error (954-confidence-interval) on. DOM /NRC-741 forms.
1 Contrary to the : above, the licensee. f ailed to correctly calculate limits sof. error; which were entered on DOE /NRC-741 form' ZQM-YLJ 273 for a shipment of1 uranyl nitrate solution received February 20, i
1984.
The licensee applied incorrect.
parameters to the limit of errot-
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calculations which. resulted in.limias of error being reported that were not determined at the' 954 confidence level.
A similar violation was disclosed -during an-inspection' conducted July 25-29, 1983,-and reported in Inspection Report No. 70-1113/
83-21.. The licensee's corrective actions for this violation were not adequately i
i implemented to-prevent recurrence.
This' is a repe.t violation.
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l GENERAL $ ELECTRIC J
l Mr. $. Philip Stohr June 7, 1984
,j Attachment - Page 3 i-j-
General Electric admits the violation as stated above.- The reason this violation occurred was that the analysts responsible inc
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inputting the data did not follow the newly revised internal i
procedure.
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i The responsible analysts have viewed and f amiliarized themselves j
with the existing procedure.
A new statement has been added to J
the computer program that ask the user ~if he/she has verified.
that the information in the sample /rnalysis. matrix file used by the computer to calculate LE. values is correct.
If a "no" response is entered,. analytical results cannot be input to the program and the user is required to ' correct tLa. condition before continuing}
General Electric is currently in compliance and no 'further action is planned.
I It should be noted that.the final LE which resulted - from the I
calculation in question and in the prior cited example was a ecnservative value.
Notwithstanding theisignificanco;of the deviation from the procedure, it is difficult in: routine practice to err such that non-conservative LE. values are~ generated by the failure mode observed in this instance.
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- 3. 10 CPR 70.58(g)(1) requires the licensee to
.1) follow procedures for assuring accurate identification and measurements of the l
quantities of special nuclear material received.
I contrary to the above, e licensee failed j
to. follow procedu No
.1.1.18 whi h required (PgOD '
10.96), revision 4
. sample request fo a to mpleted and submitted specifyin uplicat nalysis on samples
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taken from uranyl n rate receipts.
The sample request.fo
'was in rectly L
completed in tha uplicat nalyses.were ~ 4--
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i not requested as equired, and a a result eachsamplewasonlyanalyzedonetim]e for a shipment of f uranyl nitrate received i
February 20,-1984.
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This is a Severity Level V Violation
.(Supplement III).
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GENERAL $ ELECTRIC e
Mr. J. Ph Stohr June 7,-1 Attachments-Page 4 i
i General Electric admits the violation as stated above..The reason this violation occurred was due to an operator misint pr ing the instruction included n the OD.
The operator took hree samples t
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but did not request duplicat analysis.
I All operators who are c ently invQ.;.ved with obtaining UNH.
l samples and filling out ample formghave been instructed by l
supervision as to the i ont of the procedure and the appropriate method to be used.
Additionally, review of this PROD will be scheduled for inclusion in supervision to employee discussions (Roundtable Meetings) and' this particular sampling method will be highlighted in WMD's j
sampling training program.
j Full compliance will be acheived t:. July 2,.1984.
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