ML20057E887
| ML20057E887 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 10/07/1993 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML18100B296 | List: |
| References | |
| NUDOCS 9310130322 | |
| Download: ML20057E887 (5) | |
Text
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UNITED STATES u
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j NUCLEAR REGULATORY COMMISSION
'C WASHINGTON, D.C. 20555-0001
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OCT 0 71993 DOCKET:
70-734 LICENSEE: Generai Atomics San Diego, California
SUBJECT:
SAFEGUARDS EVALUATION REPORT: AMENDMENT APPLICATION DATED OCTOBER 1, 1993, REQUEST FOR ONE-TIME EXTENSION TO RECONCILE PHYSICAL INVENTORY Backaround In a letter dated October 1,1993, General Atomics (GA) requested a two-week delay (from October 13th to October 26, 1993) for completing all activities required by 10 CFR 70.51(e)(4). The delay is needed because of operational problems with a furnace that had to be utilized for converting filter hold-up l
material to a form suitable for accountability measurement.
Despite the furnace problem, GA may still be able to complete its reconciliation activities for the physical inventory in question by October 13th (the 30-day deadline), if isotopic analyses (to be performed by an off-site contractor laboratory) are completed and reported under optimum timing. However, as a prudent measure, GA is asking for a two-week delay to allow for possible less than optimum timing.
It should be noted that GA is the only active Category II licensee (authorized 1
to possess and use SNM of moderate strategic significance) and thus is the only major fuel cycle facility subject to a 30-day time limit for completing all the activities associated with closing and reconciling a physical inventory, as specified in E 70.51(e)(4). That is, GA is subject to the material control and accounting (MC&A) requirements of Part 70, while all other major fuel cycle facilities are subject to the newer MC&A requirements contained in Part 74.
In Part 74, Category I facilities are allowed 45 days to reconcile a physical inventory, and Category III licensees are allowed 60 days.
Discussion Extending the reconciliation period for this particular physical inventory from 30 days to 43 days will not compromise the desired level of safeguards control and is warranted because of the following:
1)
The furnace malfunction that necessitated a delay in closing this material balance was unexpected and beyond GA's control; i
I 2)
Current regulatory criteria, as reflected in 10 CFR Part 74, allows 45 days for reconciling Category I (strategic SNM) physical inventories.
If a Part 74 Category II MC&A rule had been promulgated (as had been originally intended when there were several Category II licensees), it is safe to assume that the inventory reconciliation period would have been at least 45 days; and r
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Based on an October 4, 1993 telephone conversation with Chester Wisham (GA's Accountability Manager), there is no reason to suspect or expect an excessive inventory difference value.
Cateaorical Exclusion Based on the information submitted by GA, the staff has determined that granting the requested amendment will not adversely affect the public health and safety, the common defense and security, or the environment, and is otherwise in the public interest. The staff notes that the provisions in 10 CFR 51.22(c)(12) cites an exclusion for safeguards plans and materials accountability. Therefore, neither an Environmental Assessment nor an Environmental Impact Statement is necessary for this proposed action.
Conclusion / Recommendation The staff concludes that the requested one-time exception to the requirement of 10 CFR 70.51(e)(4) is warranted, and that granting such request should have no adverse effect on the common defense and security nor the public health and safety, and is otherwise in the public interest.
Principal Contributor Donald R. Joy
1 License Conditions that are Obsolete and which have been' Deleted from License SNM-696 j
FACILITY OPERATIONS j
During the HEU shutdown period for HTGR fuel manufacturing (Plant I), production of LEU fuel (having a maximum U-234 enrichment of 19.99%) for the North Warning-System project may be conducted in accordance with the Material Control Plan submitted as an attachment to the Licensee's letter dated-September 16, 1985 (ref. #696-8014), and in accordance.with.the Licensee's letter of April-16,1987 (ref. #696-1058), provided such production is limited to processing activities within the SVA and SVB buildings and that the quantity of LEU materials does not exceed Category III limit, as defined i
by 10 CFR 73.2(y)(2), within the non-vault area of each of the two said buildings, except as noted in Condition'SG-2.4.1.
l During rod processing campaigns associated with the North Warning System project, as l
much as 22 kilograms U-235 contained in low enriched uranium may be on the production floor (i.e., within the processing areas, but excluding the vaults) of the SVA building, provided all the requirements specified in 10 CFR~ 73.67(d)(1) through (d)(11) and the controls and procedures specified in Attachment 1 of the licensee's
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letter 696-8066, dated February 12, 1986, are in effect-whenever such U-235. quantity i
exceeds 10 kilograms.
INVENTORY In accordance with the provisions of 10 CFR 70.51(e)(6), the licensee shall maintain a system of material control and accounting such that.neither the uranium element not the U-235 LEID (or LEMUF) value for the HTGR Fuel Fabrications Operations (Plant I) shall exceed 1100 grams for any physical inventory taken between November 1,1984 and October 31, 1985.
Notwithstanding the requirement of 10 CFR 70.51(f)(2)(ii) to verify the integrity of tamper-safing devices at the time of inventory, the licensee may follow Section 5.12-2 of the Plan identified in Condition SG-2.1 with respect to HTGR-fuel blocks.
PHYSICAL PROTECTION RE0VIREMENTS FOR FORMULA OUANTITIES OF STRATEGIC SPECIAL NUCLEAR MATERIAL Notwithstanding the requirement of 10 CFR 11.15(a)(1) to submit application on or
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before January 6,1986, for special nuclear material access authorization for l
affected individuals employed on October 28, 1985, the licensee shall follow the i
schedule of submittals as outlined in his letter (ref. #696-8047) dated December 2, 1985.
TEMPORARY OR ONE TIME CONDITIONS Notwithstanding the requirement of 10 CFR 70.58(e) and Section 3.1 of the licensee's
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i Fundamental Nuclear Material Control Plan to measure all SNM received, the licensee is authorized to receive at shipper's values (being the same values under which the material was initially shipped to Babcock & Wilcox from General Atomics) the historical samples and/or dormant SSNM described in the letter from K. E. Asmussen to D. J. Kasun dated August 15, 1990, provided the material is maintained under tamper-safe conditions while stored at Babcock & Wilcox.
Notwithstanding the requirements of 10 CFR 70.51(e)(4) that activities associated with the physical inventory completed within 30 calendar days of the ending inventory, the licensee is granted a 10-day extension (from October 16,1990, to October 26,1990) for closing the Plant II (TRIGA Fabrication) physical inventory.
Notwithstanding the requirements of 10 CFR 70.51(e)(4) to complete calculations
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associated with the inventory difference and to reconcile the results within thirty days, the licensee is granted a ten-day extension to the time requirement and is authorized to report the results of the March 3,1991, Plant V physical inventory no later than April 13, 1991.
l Notwithstanding the requirement of 10 CFR 70.58(e) and Section 3.1 and 7.1.1 of the l
Licensee' Fundamental Nuclear Material Control Plan concerning measurement of SNM l
received from external sources, the licensee may account for the quantity of material l
in the TRIGA fuel elements described in the letter from K. E. Asmussen to T. S. Sherr dated June 19, 1991, as follows:
1)
Shipping packages and tamper safe seals will be inspected immediately upon l
receipt and promptly opened.
2)
Upon opening of the shipping packages, GA fuel element identifications will be verified and each element will be gamma-scanned to confirm the presence of U-235.
3)
Any discrepancies will be resolved before decladding commences.
4)
The values which were assigned to the completed elements and used when they l
were originally shipped to Martin Marietta for storage will be used for receipt 1
purposes.
5)
Once decladding, processing operations and blending with depleted uranium are
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complete, the element and isotope content of the downgraded material will be measured. The measured value of the downgraded material will be compared with the calculated value and significant differences will be investigated and resolved.
Notwithstanding the requirements of 10 CFR 70.51(e)(4) and Section 6.2.1.1 of the Licensee's Fundamental Nuclear Material Control Plan that activities associated with the physical inventory be completed within thirty (30) calendar days of the ending j
inventory, the licensee is granted a nine (9) day extension (from October 13, 1992 to 1
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October 22, 1992) for closing the Plant II (TRIGA Fabrication) physical inventory.
This temporary license condition shall automatically terminate with the closing of the Plant Il physical inventory or October 22, 1992, whichever occurs first.
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