ML20041G081
| ML20041G081 | |
| Person / Time | |
|---|---|
| Site: | 07000371, 07100371 |
| Issue date: | 01/28/1982 |
| From: | Evans L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kirk W UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 8203190190 | |
| Download: ML20041G081 (6) | |
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" Return to HMSS/FFSL, Mail Stop 881-SS" DISTRIBUTION:
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WBrown, IE ATTN: Mr. W. F. Kirk Manager D.T[g, Nuclear and Industrial Safety RPage, FC 67 Sandy Desert Road ATCody, RI Uncasville, Connecticut 06382 Gentlemen :
This is in response to your letter dated January 12, 1982 which transmitted minor revisions to Chapters 3.0 and 6.0 of your Fundamental Nuclear Material Control Plan.
We have determined that the proposed revisions will not adversely affect the common defense and security nor the public health and safety and are otherwise in the public interest. We have further determined that an exemption from the regulations in 10 CFR 70.53(a)(1) is appropriate for your proposed change in format for materul status reports. Accordingly, in order to incorporate the proposed revisions and the referenced exemption, we are revising License Condition 2.1 and adding a new License Condition 6.5 to Amendment MPP-1 to your License No. SNM-368, as reflected in the enclosure, effective immediately.
We have determined that the enclosure to your letter dated January 12, 1982 contains 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. J. Evans, Jr., Chief Fuel Facility Sa feguards Licensing Branch Division of Safeguards, NHSS
Enclosure:
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s Sections 1.0 Through 8.0 of Materials and Plant Protection Amendment MPP-1 to License No. SNM-368 1.0 FACILITY ORGANIZATION 1.1 Review / audit results shall be documented and communicated to management in accordance with the following criteria:
Deficiencies which seriously weaken the material control system shall be reported to management immediately upon identification and corrective actions initiated, A summary of review / audit results and ~ recommendations shall be verbally communicated to management at the conclusion of the activity but in no case more than ten (10) working days after completion of the review / audit,
- Within thirty (30) working days after completion of the revi.ew/ audit, a schedule shall be developed for corrective actions.
2.0 FACILITY DESCRIPTION
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1/28/82 2.1 The ifcensee shall follow the UNC Naval Products Fundamental Nuclear Material Control Plan, Revision 1, dated September 1,1980; as revised September 4, October 3 and December 2,1980; February 18, March 6, except for the first and fourth sentences in Section 4.5.1, August 19, and September 1, except for the next to last paragraph of Section 2.1.1; Janua ry 12, 1982; 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 i
relieve the licensee of a requirement of 10 CFR Part 70 unless granted in a specific exemption or exception set forth as a condition of this license.
l 2.3 Operations involving special nuclear material which are not described in the Plan identified in Condition 2.1 shall not be initiated until an appropriate safeguards plan has been approved by the Nuclear Regulatory Commission.
3.0 MEASUREMENTS 3.1 The licensee or his designated agent shall measure, except as specified in 70.58(e) and in License Conditions 3.2 and 5.1, the uranium and uranium-235 content of all special nuclear material receipts, shipments, waste discards and material inventoried.
Anendment No. MPP-1 Page 2 of 5 Docket No.70-371 License No. SNM-368 3.2 Notwithstanding the requirements of 70.58(e) and (g)(1) to measure the uranium and uranium-235 content of encapsulated fuel element packs shipped offsite for additional processing and subsequently returned, the licensee may ship and receive such items on the basis of previous measurements provided the claddino remains intact.
4.0 MEASUREMENT CONTROL 4.1 The licensee shall perform appropriate process and engineering tests to establish the validity of sampling whenever:
(a) a change in process parameter affects the physical properties of the material, and (b) the sampling technique or the sampling equipment is changed.
4.2 The licensee shall assure that all measurements, including those performed to establish correction factors applied due to (1) non-representativeness between reference standards and process materials and (2) variability in measurement conditions, are traceable to national standards or nationally accepted measurement systems.
4.3 Notwithstanding the requirements of 10 CFR 70.57(b)(8) to measure standards and replicates for volume systems, to not provide de minimis quantities for bias calculations, bias corrections and systematic errors, to detennine separate random errors for sampling and analytical,-
to generate random errors for bulk and NDA from replicate measurements of process materials, to perform replicate isotopic analyses and to parform replicate sampling and replicate analyses of liquid and stack discards, the licensee shall follow Sections 4.2.2, 4.2.4, and 4.4 of the Plaa identified in License Condition 2.1.
4.4 Notwithstanding the requirements of 10 CFR 70.57(b)(4) to detennine systematic sampling error and to conduct engineering tests 'on all material types, the licensee shall follow Section 4.3 of the Plan identified in License Condition 2.1.
4.5 Notwithstanding the requirements of 10 CFR 70.57(b)(11) to use control charts to monitor the quality of each program measurement, for control of scales and balances, the licensee shall follow Section 4.5.1.1 of the Plan identified in License Condition 2.1.
4.6 All identifiable covariance affects shall be taken into account in the calculation of LEID.
4.7 All measurement systems utilized for material control and accounting purposes shall be included in the comprehensive measurement control program.
..c Amendment No. MPP-1 Page 3 of 5 Docket No.70-371 License No. SNM-368 5.0 PHYSICAL INVENTORY 5.1 Notwithstanding the requirement of 10 CFR 70.58(e) to measure the special nuclear material on inventory in standpipes, the licensee shall follow Section 5.5 of the Plan identified in License Condition 2.1 for the SSNM holdup in the standpipes in MBA-5. The SSNM shall be cleaned out every other inventory, measured and the quantity reconciled with that prcjected to be present.
5.2 Each plant ID and LEID determination shall be verified by any individual not involved in the original calculations.
6.0 RECORDS AND REPORTS 6.1 Deleted 6.2 Deleted 6.3 Shippers' values may be posted in the accounting records provided:
6.3.1 Shippers' limit of error values on grams uranium and uranium-235 are less than 0.5% for each material type in each shipment.
6.3.2 Independent receiver measurements shall be made for the total element and isotope content with limit of error values less than 0.5% for each material type in each shipment.
Shipper-receiver ' ifferences are not statistically d
6.3.3 significant at the 95% confidence level for each line item and for the total shipment.
6.3.4 Shippers' values are posted as a standard procedure subject to Conditions 6.3.1, 6.3.2 and 6.3.3.
6.4 If the licensee posts shippers' values in his accounting record pursuant to Condition 6.4, the following procedures shall be followed in completing the Form NRC-741:
6.4.1 The results of the receiver's measurements made pursuant to Condition 6.4.2 shall be recorded on Form NRC-741 in accordance with Condition 6.3.
Amendment No. MPP-1 Page 4 of 5 Docket No.70-371 License No. SNM-368 6.4.2 The licensee shall clearly certify on Form NRC-741 that shippers' values are accepted on the basis of independent measurement verification.
1/28/82 6.5 Notwithstanding the requirements of 10 CFR 70.53(a)(1) to complete a Material Balance Report (00E/NRC Form 742) in accordance with the printed instructions for that particular fonn, the licensee may utilize the computer report generated by NMMSS as described in Section 6.2.1.2 of the Plan identified in Condition 2.1.
7.0 INTERNAL CONTROL 7.1 At least two individuals shall attest to the contents of containers, equipment, and vaults at the time of tamper-safing. The " attesting to" declarations shall be documented and shall pertain to as many of the characteristics listed below as possible:
(a) container and/or seal numbers (b) material type or form (c) nothing other than the stated material type or fonn placed in the container (i.e., no foreign material or shielding added) during loading (d) nothing added or removed from container since loading or since previous seal broken (e) gross weight (f) net weight (g) inner item (s) integrity still valid when replacing broken seal on outer container (h) materal not concealed and/or shielded within equipment to avoid detection (i) quantity of material added or removed from a vault or container (when re-sealing a vault door or container)
(j) correctness of current vault record (i.e., listing) 7.2 Accurate records shall be established and maintained which provide on a daily basis knowledge of the identity, location, and quantity of all SNM within each plant in discrete items and containers.
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Amendment No. MPP-1 Docket No.70-371 Page 5 of 5 License No. SNM-368 7.3 Notwithstanding the requirement of 10 CFR 70.58(1)(2) that all scrap measured with an uncertainty greater than + 10 percent be processed and recovered within six months, the licensee may accumulate up to two (2) kilograms of such scrap for a period not to exceed twelve (12) months.
8.0 MANAGEMENT Currently there are no license conditions in this section.
The necessary information has been incorporated into an approved plan.
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