ML20045G147
| ML20045G147 | |
| Person / Time | |
|---|---|
| Site: | 07001201 |
| Issue date: | 07/07/1993 |
| From: | Carr C BABCOCK & WILCOX CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9307120161 | |
| Download: ML20045G147 (3) | |
Text
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(?)B&WFUEL COMPANY 05 s
8, NQd kn American Company with Worldwide Resources P.O. Box 11646 Lynchbum, VA 24506-1646 Telephone: 604-522-6000 July 7, 1993 U.S.
Nuclear Regulatory Commission ATTN:
Document Control Desk Washington D.C.
20555
REFERENCE:
NRC Inspection Report No. 70-1201/93-201-02, Reply to a Notice of Violation.
Gentlemen:
This letter provides the written explanation and corrective action taken for the violation that resulted from Inspection No.
70-1201/93-201.
Attachment I addresses the violation in detail.
If questions should arise during your review, please feel free to contact either Kathryn Knapp (804-522-6202), John Anderson (804-522-6067) or myself.
Sincerely, B&W FUEL COMPANY C
W.
Carr, Manager Commercial Nuclear Fuel Plant cc:
Stewart D.
Ebneter Regional Administrator, Region II USNRC 101 Marietta Street, N.W.
Atlanta, Georgia 30323
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ATTACHMENT I 1.
VIOLATION #93-201-02:
Title 10 CFR 74.31(c) (7) requires the resolution of shipper / receiver differences (SRD) that exceed both twice the combined measurement standard error and 500 grams of U-235.
Section 6.2 of the licensee's approved Fundamental Nuclear Materials Control (FNMC) Plan requires signifi-cant SRD to be promptly investigated and resolved.
Section 3.0 of Critical Procedure NM-1614 (Shipper-Receiver Difference Evaluation) requires the staff to take appropriate and corrective action to reconcile an SRD that exceeds both twice the combined measurement standard error for the shipment and 500 grams of U-235.
Section 6.3.3 of the licensee's approved FNMC Plan and Critical Procedure NM-1614 (Shipper-Receiver Difference Evaluation) provide instruction for combining the U-235 error for the shipper and receiver.
Contrary to all of the above requirements:
(a) the licensee failed to investigate and resolve a significant SRD (Nuclear Material Transaction Reports YUD-YNJ 00067) and (b) the licensee improperly combined the shipper's measurement error and the receiver's measurement error for the evaluation of the SRD.
Admission or Denial of the Alleoed Violation We acknowledge the validity of the facts contained in the notice of violation.
Reason for Violation (a)
Investigation of the computer program used to calculate the Shipper / Receiver measurement error, revealed that the program compares the total U-235 SRD against 500 grams and indicates a "YES" or "NO" depending upon whether the difference is greater or less than 500 grams.
A loss (negative number) regardless of size would always be less than 500 and the program would indicate the word "NO".
In checking for significant difference, the pro-gram looks at the above check and compares the SRD to the combined measurement error and if both were
E i.
exceeded, indicates a "YES".
Due to the 500 gram limit never being exceeded if negative values were used, the check would never indicate the SRD to be statistically significant.
In addition, a visual check of the SRD against the l
combined measurement error was not properly con-ducted.
i (b)
The formula used prior to the audit for de--
termining the Receiver's measurement error was:
1.96 x
sum of the variances x
0.707 The result of this calculation was being statistically combined with the shipper's reported limit of error.
In conversations between statisticians at NNFD and CNFP and in conversation with the NRC inspector, it has been determined that the above calculation does not result in limit of error.
Corrective Steps that have been Taken and Results i
Achieved l
(a)
- )
The computerized program has been changed-to reflect positive values regardless of whether the difference is a loss or a gain.
2)
Personnel preparing and checking the limit of' error calculation have been instructed to visually compare the SRD against the combined limit of error to assure that it is not grea-ter than 500 grams and it does not exceed the combined LE.
(b)
The formula has been changed to:
1.96x[__sumofthevariances g
By removing the 0.707 factor, the calculation becomes the limit of error and will be compatible with the shipper's reported measurement error.
3 This change has been made to the computerized
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formula used in computation of the licensee's measurement of error and such error will be iden-tified as limit of error, or LE, on future docu-f mentation.
The Date of Full Comoliance l
The noted corrective actions are complete and we are in compliance at this time.
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