ML20058P316
| ML20058P316 | |
| Person / Time | |
|---|---|
| Site: | Framatome ANP Richland |
| Issue date: | 10/06/1993 |
| From: | Noss D SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER |
| To: | Milstein R NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML19310E907 | List: |
| References | |
| NUDOCS 9310220209 | |
| Download: ML20058P316 (7) | |
Text
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% />S 7 SIEMENS October 6,1993
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U.S. Nuclear Regulatory Commission Attn: Mr. Richard Milstein Division of Fuel Cycle Safety & Safeguards Licensing Branch Washington, DC 20555
Dear Mr. Milstein:
Ref: Milstein to Noss, June 23,1993, Safeguards Plan Revison With regard to your letter to me dated June 23,1993, the following revisions have been made to my original Safeguard Plan Revision submitted to you March 26,1993. Revised FNMC plan pages are attached. I have addressed each questions or comment raised by you in your June 23rd letter as follows:
- 1. As suggested, a " List of Effective Pages" is found in Attachment 1. The Attachment includes current approved revisions only.
- 2. Sectica 1,1,1,1, paragraph 1
- a. Second sentence What has the President delegated?
Words added as underlined: "He has delegated that responsibility to the Senior Vice President and General Manager, Nuclear Division."
Shouldn't the wording be changed to " Senior Vice President and General Manager Nuclear Division?
See pr2vious comment.
- b. Third sentence Change "The Soaior Vice President and Manager" to "The Senior Vice President and General Manager Nuclear Division" Words added as underlined:"The Senior Vice President and General Manager, Nuclear Division has in turn delegated major safeguards responsibilities applicable to the Fuel Fabrication Plants to the Vice President of M nuf turing th Irect r. Finance and the Vice President of Enalneerina.
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Page 2 October 6,1993 The Vice President of Manufacturina has deleasied safeauards responsibilities to the Plant Manaaer."
Change " delegated major safeguards elements" to " major safeguards responsibilities".
See previous comment.
Change "who in turn delegates to the Plant Manager" to "who in turn delegates these responsibilities to the Plant Manager".
See previous comment.
- 3. Section 1.1.1.1, paragraph 2 Change "The Manager of Materials Research of Engineering" to "The Manager of Materials Research, Engineering Division" Changes to the second paragraph are as underlined: "There are two other custodians: the Manager of Product Development and Testina of th_e Engineering Department and the Manager of Materials and Scheduling of the Manufacturing Department who have responsibilities for SNM under their control."
- 4. Section 1.1.1.1, Page 1-2, item 2 The Manager of Fuels Research was not identified earlier (page 1-1, Section 1.1.1.1, paragraph 2) as a custodiam, The Manager of Materials Research was. Figurc 1.1 shows a " Materials Research" organization unit, but not a " Fuels Research" unit. Please make oppropriate changes to insure consistency.
Changes to the second paragraph are as underlined: 'The other material custodians, The manager of Product Development and Testina and the Manager of Materials and Scheduling, have similar safeguards responsibilities for SNM under their control."
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- 5. Section 1.1.1.1, Page 1-3, item 4
" Plant Engineering" doesn't appear on figures 1.1 or 1.2. Please add to figures or j
describe where this organization is located within the Siemens organizational structure.
Figures 1.1 and 1.2 modified to include Plant Engineering.
- 6. General Who is the custodian of the SNM in the laboratory? Who is responsible for the inventory in this area?
All of section 2 describes Material Control areas. Since the laboratory is
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located in the UO2 and SF buildings, they are a part of NMCA-2 as described in a
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d Page 3 October 6,1993 the section. The Manager of Plant Operations-Richland is the custodian of NMCA-2.7.
Section 1.1.1.2, Page 1-3, paragraph 3
- Manager, Fuels Research" doesn't appear on the organizational charts. Do you mean
" Manager, Materials Research?" If so, please correct.
The wording has been changed as follows: "Vice President, Manufacturing, has delegated the responsibility for selecting Nuclear Material Control Area (NMCA) custodians to the Plant Manager, Manager, Materials and Scheduling, and Manager, Product Development and Testina."
- 8. Section 1.1.1.2 Page 1-4, paragraph 1 According to page 1-3, paragraph 3, the VP, Manufacturing has delegated responsibility for selecting custodians to "the Plant Manager, Manager, Materials and Scheduling, and Manager, Fuels Research." There is no mention that the Manager of Engineering has been delegated this responsibility. Furthermore, the Manager of Engineering does not appear on the organizational charts. Please correct these inconsistencies.
Page 1-3, paragraph har, been revised as noted in point 7. Paragraph 1, Page 1-4 has been revised as follows: "The LAanaaer of Product Development and Testina of Engineering has designated the Leader of Materials Research as the custodian of the Engineering Laboratory Operations (ELO) NMCA." The
" Manger of Engineering"is the Vice President of Engineering and does appear on the organization charts.
- 9. Section 1.1.1.2 Page 1-4 paragraph 2 The Manager, Piant Engineering and the Manager, Engineering do not appear on the organizational charts. Please add, if appropriate.
The last sentence in paragraph 2 has been modified as follows: " Technical support in the area of NDA measurements is provided through the Manager of Plant Engineering who reports to the Manager of Manufacturina Engineering."
Plant Engineering and Manufacturing Engineering have both been added to figure 1.1.
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- 10. Section 1.1.1.4 Page 1-4, paragraph 1 The text states that there are asterisks on Figure 1.1 that indicate which management and staff positions have position descriptions provided in this section. In Fact, there are no asterisks on Figure 1.1. -
The asterisks have been added.
- 11. Section 1.1.1.4 Page 1-5, paragraph 3
Page 4 October 6,1993 Why is there no statement on the qualifications for the Manager, Materials Research?
Please add.
The paragraph has been revised as to read as follows: "The Team Leader of Materials Research manages the ELO and, as such, is the custodian of SNM in that facility. He designates alternate custodians of the ELO NMCA. The minimum qualifications for the position shall be five years of experience in nuclear activities."
- 12. Section 1.1.2.2 Page 1-7, paragraph 2 The text refers to the "Vice President, Operations Division." The Operations D vision does not appear on the organizational charts. Please correct.
The paragraph has been changed as follows: "The Manger of Regulatory Compliance is audited periodically by an Ad Hoc Committee appointed by the Vice President, Manufacturina"
- 13. Section 1.3 Page 1-14, paragraph 2 The text refers to the " Manager, Plant Engineering." Where is this individual located in the organizational structure. Please add to figures 1.1 and/or 1.2.
Plant Engineering has been added to charts 1.1 and 1.2.
- 14. Table 1.2 The text refers to the " Manager, Equipment & Maintenance Engineering." I believe that the title has been changed to " Manager of Plant Engineering." Please Correct.
Table has been corrected.
- 15. Figure 1.1 and 1.2 These figures do not have the revision number, date, and page on them. Please add.
Revision number, date and page number have been added.
- 16. Section 4.5.1.2.2 Page 4-26, paragraph 1 Why are control charts no longer used to maintain control of the standard deviation?
The control charts were a manual chart used to visually depict the sigmas (standard deviations) of individual powder and pellet lot replicate samples. The chart visually compared the powdot and pellet lot sigma to the established 0.05 and 0.001 limits.
I Page 5 October 6,1993 in the last year we have developed a Lotus based PC system that calculates sigma for each lot and compares the result with the 0.05 and 0.001 limits. The program automatically flags any lots who's sigma is greater that the established limits. Since the comparison of sigma to the control limits is now done electronically, manually plotting the control chart is a redundant exercise and has been eliminated.
Please clarify the discussion of within-lot and between-lot standard deviations. Are controls on both maintained?
The discussion of within-lot and between-lot standard deviations applies to UO2 powder lots. Within-lot applies to powder lots in which more than one sample is taktn. Since SPC's practice is to take two replicate samples for each powder lot, the within-lot standard deviation applies. From these replicate samples we determine sigma (standard deviation) for each lot and control is maintained by comparing this value to the 0.05 and 0.001 limits.
The between-lot standard deviation refers to the standard deviation between powder lots if only one sample is taken per lot. SPC has approval under Section 3.4 Sampling Systems, paragraph 2, to take one sample from each powder lot. Even though we take two samples per lot, we still have the option under our plan to take only one, if only one sample were taken, control of standard deviation would be on between-lot standard deviation.
Was the phrase "by comparison to past data" added to clarify Siemens procedure or does it represent a change in the procedure?
The statement was added to clarify SPC's procedure. The 0.05 and 0.001 limits are developed from powder and pellet lot results compiled prior to the most recent factor change.
Why is a " tabulation" used instead of a control chart for CUSUM?
The CUSUM control chart was a manual graph used to monitor the plant average percent uranium factor for powder and indicate when the factor should be changed. In our PC system, CUSUM is calculated for us in the same way as before. We visually monitor the CUSUM value with each entry and the system tells us when the CUSUM " tabulation" reaches the limit which would indicate a factor change should be made.
- 17. Section 4.5.1.2.2 Page 4-27 paragraph 1 Remove the word "on" from the first sentence Change mado
Page 6 October 6,1993 Please explain how the standard deviation is calculated for the 50 lots. Since the discussion is about controlling the standard deviation of replicate measurements, I assume that the standard deviation referred to here is some averaae standard deviation for 50 replicate measurements.
The wording for paragraph 1 should be a follows: "The control basis for the standard deviation is based on the standard deviation calculated from a minimum of 50 lots judged to be in control." This clarifies the basis for calculating the control basis for the standard deviation.
- 18. Section 4.5.2.1 Page 4-27, paragraph 2 What is the K-factor; how is it used?
Paragraph 2 has been revised as follows: "For the 0.00 limit, a K-Factor (for tolerance limits) of 90/95 is used and for the 0.001 limit, a K-Factor of 90/99.9 is used. These are multiplied by the observed standard deviation of the countina data."
- 19. Section 4.5.3.2 Page 4-31, paragraph 3 The original text discussed a "run of 10 points" in terms of a.40% change in the U-factor for powder and.04% for pellets and a "run of 20 points"in terms of a.20%
change in the U-factor for powder and.02% for pellets." The new language addresses the " absolute value" of the cumulative sum, a) Does this new approach represent a change in the limits for deciding when the U-factor should be changed? If so, how do these new limits compare to the original ones quoted above?
Since we do not ship any powder or pellets at the plant average factors except for occasional small quantitles of samples, realistically the plant average factors need only be modified when process changes warrant a factor adjustment or at physicalinventory time. This proposed method recognizes subtle increases or decreases in the factor, in that the trigger for changing the factor is based on when the summation of CUSUMS exceeds 1.0 for pellets and 10.0 for powder.
The average factor changed under the old method only if the average factor increased or decreased a certain amount over a set span of lots. Slow constant changes under the old method would not trigger a factor change until the factor was analyzed for the physical inventory. I have attached a work sheet that describes the application of this method.
The benefits of the new method are the recognition of subtle changes over a long period, and a reduction in the frequency of factor changes. While still recognizing rapid factor changes.
- 20. Section 5.1 page 5-3, paragraph 1
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Page 7 October 6,1993 8
According to the new language, " Filters and uranium solutions with concentrations less than 5 grams per liter in U-235 are exempt from tamper-safing. This is fine since the NRC does not require tamper-safing. However, the plan also states that "all previously measured items whose integrity has not been maintained by tamper-safing.
are subject to verification." This statement would also apply to the filters and uranium solutions.
Per our discussions, revised Sections 5.1,5.9 and 5.12.2 are attached.
Other changes that have been included in this revision are as follows:
Section 3.5 page 3-7, Paragraph 2 Change " potassium dichromate in sulfuric acid" to " ceric sulfate".
Table 3.2 pages 3-11 and 3-12
' Typical Error Parameter Values (UO2 Process)", updated with the latest values.
Section 4.2.3.3 page 4-14, paragraph 2 Change "(NBS U-010, U-015, etc)" to (NBS U-010, U-015, etc or equivalent). Change, "The factors are restimated on an annual basis. More frequent estimation is not required because biases in the mass spectrometer are controlled through the running of standards." to "The factors are restimated when control standard results show a recalibration is needed."
Table 5.2 " Verification Acceptance Limits", updated with the latest values.
Please let me know if you have any questions.
Yours Ve Truly, Q'\\ ) / (gy3/
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D. L. Noss, Safeguards Specialist DLN:pm j
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