ML20029E195
| ML20029E195 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 05/06/1994 |
| From: | Winslow T GENERAL ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9405170170 | |
| Download: ML20029E195 (4) | |
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.I GE Nuclear Energy
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May G 1994 j
U.S. Nuclear Regulatory Commission Document Control Desk Washington, D.C. 20555
Subject:
REPLY TO NOTICE OF VIOIATION
References:
1)
NRC License SNM-lO97, Docket 70-1113 2)
NRC Inspection Report 70-1113/94-201 Dated 4/08/94 Thank you for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr. C. S. Light and Mr. R. F. Cassano of your office during March 14-18, 1994.
The inspection report comments and suggestions are helpful to us in our continuing efforts to improve our programs and ensure our compliance with NRC regulations and license conditions.
Pertaining to the items of apparent noncompliance with NRC requirements in the referenced report, our reply is provided in Attachment 1 to this letter.
Pursuant to 10 CFR 2.790(d), GE requests that the attachment to this letter be withheld from public disclosure since the attachment identifies details of GE's measurement control and accounting program for safeguarding licensed special nuclear material.
GE respectfully requests that the NRC consider this proposed Severity V Violation as a non-cited violation in accordance with 10 CFR 2 Appendix C VII D 1(a)-(c). We believe the proposed violation meets these criteria as follows:
(a)
This violation has not been cited in a previous inspection over the past two years, and therefore no corrective action resulting from a prior inspection could have prevented this violation.
(b)
This violation was corrected prior to the completion of the NRC inspecuan. Internal procedure " Key '4easurement Systems" (MC&AP 119) was revised to prevent recurrence of this incident.
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Do'cument Control Desk May 6,1994 Page 2 (c)
At the time, we believed the method we were using to be correct.
We had no prior indication nor opportunity for prior indication of our misunderstanding of the requirement. We immediately took corrective actions once it was identified. It is GE's intention to always be in compliance with our Fundamental Nuclear Material Control plan requirements.
Please contact me on (910) 675-5461 if you have any questions or would.
like to discuss this matter further.
Sincerely.
GE NUCLEAR ENERGY l
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T. Preston Winslow. Manager Emergency Preparedness, Security, Material Control & Accounting
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TIMV-94-050 G. L. Troup - Region II l
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EXEMPT FROM PUBLIC DISCLOSURE 10 CFR 2.700 INFORMATION U.S. Nuclear Regulatory Commission Document Control Desk May 6,1994 Page 1 of 2 L
KITACHMENT 1 i
l The infornmtion given below refers to the items in Enclosure 3, " Notice of Violation" in the NRC Inspection Report 70-1113/94-201 dated April 8, l
1994.
Violation No. 94-201-03 Section 4.2.1, " Key Measurement Systems", of the Plan states that the set of key measurement systems shall account for at least 90 percent of the total U-235 measurement variance contribution to the standard error of measurement for any given material balance period, and willinclude any measurement system that is normally used to measure a totallow enriched uranium (LEU) quantity, during an inventory period, in excess of 25 percent of the active inventory quantity.
Contrary to the above, the licensee failed to identify mass spectrometry measurements performed by their contractor, Ledoux and Company, as a key measurement system. This measurement system measured in excess of 25 percent of the active inventory quantity.
This is a Severity Level V violation (Supplement III).
GE Response to Violation GE agrees that due to a misinterpretation of the requirement, our method of determining key measurement systems did not identify Ledoux & Company as a key measurement system in accordance with Section 4.2.1 of the FNMC Plan.
Once the process of evaluating measurement systems relative to the active inventory criteria was understood, we re-performed our key measurement determination using the clarifled method accepted by the NRC inspector performing the audit. These actions were completed on March 18,1994, and the NRC inspector concurred with the results. Our internal procedure tided " Key Measurement Systems" (MC&AP 119) was revised on April 29, 1994, to document the revised method for identifying key measurement systems. Implementation of this procedure change will provide controls to prevent any recurrence of this incident.
EXEMPT FROM PUBLIC DISCLOSURE 10 CFR 2.700 INFORMATION U.S. Nuclear Regulatory Commission Document Control Desk May 6,1994 Page 2 of 2 NITACHMENT 1 Ledoux and Company conforms with applicable requirements of 10 CFR 74.31, and biennial audits are performed by GE personnel for verification of acceptable measurement controls and confonnance to federal regulations.
Micrefore, no tangible consequences occurred as a result of omitting Ixdoux and Company from the list of key measurement systems, Based on these completed actions, full compliance has been achieved.
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