ML20053C509
| ML20053C509 | |
| Person / Time | |
|---|---|
| Site: | 07000371 |
| Issue date: | 04/15/1982 |
| From: | Evans L NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Kirk W UNITED NUCLEAR CORP. (SUBS. OF UNC, INC.) |
| References | |
| NUDOCS 8206020255 | |
| Download: ML20053C509 (6) | |
Text
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" Return to NMSS/SGFF, Mail Stop 881-SS" DISTRIBUTION:
PDR Docket file 70-371 Case file NMSS r/f SGFF r/f s/f apq g q g CRONO
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CNSmith CWEmeigh DWeiss WBrown, IE FC United Nuclear Corporation AT o Naval Products co t~
ATTN: Mr. W. F. Kirk, Manager g
Nuclear and Industrial g
Safety Services
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67 Sandy Desert Road Nh Uncasville, Connecticut 06382 S
to to 2
CP 2
-JJ bC Gentlemen:
y This is in response to your letter dated March 18,1982 in wh (h; uregi$s '*
exemptions from requirements of the regulations related to receipt [ rdopt and limits of error on shipments. An additional exemption related w measurements, which was discussed with Mr. C. Emeigh of nty staff on April 5 and documented in an April 7 telecopy, is also addressed.
We have determined that granting the referenced exemptions will not adversely i
affect the common defense and security nor the public health and safety and are otherwise in the public interest. Accordingly, in order to incorporate j
the required exemption, we are modifying Amendment MPP-1 to your License No.
l SPM-368 by revising existing License Condition 3.1 and adding new License l
Conditions 3.3, 3.4, 4.8 and 6.6, effective insediately, as reflected in the enclosure.
In connection with our approval of your request to use composite samples fo:-
isotopic determinations, we understand from conversations with T. Collopy of your staff, that the size of the composites will be limited to a maximum of five samples. We find such a limitation appropriate in order to provide assurance that unexpected discrepancies will not go undetected.
I We note that your letter dated March 18, 1982 contains Confidential-Restricted Data and it will be protected accordingly.
Sincerely, I
t L. J. Evans, Jr., Chief Fuel Facility Safeguarde cendng Branch 8206020255 820415 PDR ADOCK 05000371 Division of Safeguards, NMSS C
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4/.. /,82, NRC FORM 318 (10 80) NRCM 0240 (UYf?[jsh @ ( @ [( M @ 7
p-l 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 imediately upon identification and corrective actions initiated, A sumary 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 review / audit, a schedule shall be developed for corrective actions.
2.0 FACILITY DESCRIPTION 2.1 The licensee shall follow the UNC, Naval Products Fundamental Nuclear Mater :al Control Plan, Revision l', 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; January 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 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.
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 4/14/82 3.1 The licensee or his designated agent shall measure, except as specified -
in 10 CFR 70.58(e) and in License Conditions 3.2, 3.3, 3.4 and 5.1, the -
uranium and uranium-235 content of all special nuclear material receipts, shipments, waste discards and material inventoried.
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e-Amendment No. MPP-1 Page 2 of 5 Docket No.70-371 License No. SNM-368 the requirements of 70.58(e) and (g)(1) to measure
.4/14/82 3.2 Notwit t
the r
' uranium-235 content of encapsulated fuel element pack
.fsite for additional. processing and subsequently rett icensee may ship and ' receive such items on the basis of,
.aeasurements provided the cladding remains intact.
4/14/82 3.3 Not..thstanding the requirement of 10 CFR 70.58(e) to measure the uranium and uranium-235 content of Government Retainer Samples received from off-site, the licensee may accept shipper's values for acccountability without verification provided the samples are received in tamper-safe condition and seal integrity is maintained.
4/ 14/82 3.4 Notwithstanding the requirement of 10 CFR 70.58(e) to measure the uranium-235 content of the one-in-four intermediate product sample received from off-site, the licensee may assign the isotopic assay determined from the fabricability sample composites provided the intermediate product sample is represented in at least one of the fabricability samples.
4.0 MEASUREMENT CONTROL
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4.1 The licensee shall perform appropriate process and engineering tests j
to establish the validity of sampling whenever:
l (a) a change in process parameter affects the physical properties j
of the material, and (b) the sampling technique or the sampling equipment 'is changed.
4.2 The licenses shall assure that all measurements, including those performed to establish correction factors applied due to (1) non-l representativeness between reference standards and process materials l
and (2) variability in measurement conditions, are traceable to national standards or nationally accepted measurement systems.
I l
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 determine 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 perform 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 Plan ident,ified in License Condition 2.1.
4.4 Notwithstanding the requirements of 10 CFR 70.57(b)(4) to determine systemati,c sampling error and to conduct engineering tests on all material types, the licensee shall follow Section 4.3 of the Plan identified in
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License Condition 2.1.
6.
s' Amendment No. MPP-1 Page 3 of 5 Docket No.70-371 License No. SNM-368 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 covarianc'e 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.
4/14/82 4.8 Notwithstanding the requirement of 10 CFR 70.57(b)(8)(ii) to provide current data for the determination of random sampling and analytical error for the fabricability and one-in-four intermediate product samples, the licensee may utilize the random sampling and analytical error data obtained from fuel lot analyses for purposes of computing the limit of error associated with receipt measurements.
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 projected 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.
o.
Amendment No. MPP-1 Page 4 of 5 Docket No.70-371 License No. SNM-368 6.3.3 Shipper-receiver differences are not statistically 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.
6.4.2 The licensee shall clearly certify on Form NRC-741 that shippers' values are accepted on the basis of independent measurement verificatio.n.
6.5 Notwithstanding the requirements of 10 CFR 70.53(a)(1) to complete a Material Balance Report (DOE /NRC Form 742) in accordance with the printed instructions for that particular form, the licensee may utilize the computer report generated by NMMSS as described in Section 6.2.1.2 of the Plan identi~fied in Condition 2.1.
4/14/82 6.6 Notwithstanding the requirements of 10 CFR 70.54 and 70.58(e) to include limit of error data on DOE /NRC Form-741 for waste ship-ments to burial, the licensee is exempt from including such data for all burial shipments.
7.0 INTERNAL CONTROL 7.1 At least two individuals shall attest to the contents of containers, 4
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 form 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 (il 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)
j s.
3 Amendment No. MPP-1 Docket No.70-371 Page 5 of 5 l
License No. SNM-368 l
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.
7.3 Notwithstanding the requirbment of 10 CFR 70.58(i)(2) that all scrap measured with an uncertainty greater than + 10 percent be pro. cessed and recovered within six months, the licensee j
may accumulate up to two (2) kilograms of such scrap for a period not to exceed twelve (12) months..
8.0 MANAGEMENT
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. Currently there are no license conditions in this section.
The necessary information has been incorporated into an-approved plan.
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