Text

Forwards Proprietary Rev 3 to FNMCP, Incorporating Louisiana Energy Services (LES) Responses to NRC Comments in Encls 1 & 2 of NRC to LES for Consistency W/ Discussions Held W/Nrc on 930818.Rev 3 of FNMCP Withheld
	ML20058P383
Person / Time
Site:	Claiborne
Issue date:	10/07/1993
From:	Leroy P; LOUISIANA ENERGY SERVICES
To:	Jim Hickey; NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
Shared Package
ML19311B125	List: ML20058P383;
References
	NUDOCS 9310250020
	Download: ML20058P383 (26)
	v • d • e

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J go-300 LOUISANA 1

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{Q Charlotte, NC 28201-1004 October 7,1993 Mr. John W. N. Hickey, Chief Enrichment Branch -

l Division of Fuel Cycle Safety

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and Safeguards, NMSS U.S. Nuclear Regulatory Commission

- Washington, D.C. 20555

Subject:

Docket No.: 70-3070 i

Louisiana Energy Services Claiborne Enrichment Center Fundamental Nuclear Material Control Plan, Revision 3 File: 6046-00-2001.01

Dear. Mr. Hickey:

'i Enclosed are five copies of the Claiborne Enrichment Center (CEC) Fundamental Nuclear Material Control (FNMC) Plan, revision 3. This revision incorporates LES' responses to your comments contained in Enclosures 1 and 2 of your letter to LES dated May 7,1993. These responses have been developed to be consistent with the discussions held with your staff on August 18,1993. The specific comments and their responses are provided as Attachment A to this letter.

This FNMC Plan contains proprietary information as defined by 10 CFR Part

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2.790(d)(1). Therefore, please withhold this FNMC Plan from public inspection.

1 Chapter 9 of this FNMC Plan has been determined to contain classified information.

Chapter 9 and responses to your requests for additionalinformation for chapter 9 were submitted under separate cover by letter dated September 8,1993.

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If there are any questions concerning this submittal, please do not hesitate to call me at (704) 382-2834.

Sincerely, f

Peter G. LeRoy Licensing Manager i

HAH /LNRC93.008 Enclosures 220010 hI@

1 l-9310250020 931007

$2]

PDR ADOCK 07003070-C.

PDR.

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October 7,1993 Mr. John W. N. Hickey, Chief Page 2 xc:

(w/ one copy of enclosures)

Mr. Morton B. Margulies, Esq., Chairman Administrative Judge Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 (w/ cover letter only)

Ms. Diane Curran, Esquire Harmon, Curran, Gallagher, & Spielberg 2001 S Street, NW, Suite 430 Washington, DC 20009-1125 Mr. R. Wascom Office of Air Quality and Radiation Protection Louisiana Department of Environmental Quality PO Box 82135 Baton Rouge, Louisiana 70884-2135 Ms. Nathalie Walker Sierra Club Legal Defense Fund 400 Magazine Street Suite 401 New Orleans, LA 70130 ee-

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.c ATTACHMENT A Page 1 of 21 i

ENCLOSURE 1 i

Succested Chances to FNMC Plan That Are of Minor Sienificance

l. Page I-1 -- in the sixth line of the second paragraph, change the phrase "shall be the condition" to "shall be a condition." '

Revised as requested.

2. Page 1-1 -- in the third line of the last paragraph on the page, change the word "six" to "nine."

Revised as requested.

3. Page I-2 -- in the third indented (bold lettering) affirmation statement, modify the first line to read "... and detect the unauthorized (undeclared) production of."

Revised as requested.

4. Page 1-2 -- add the following phrase at the end of the first sentence of the last paragraph:

"and of unauthorized production of enriched uranium enriched to 5.00 weight percent or less in the U-235 isotope."

Revised as requested.

5. Page I-3, Paragraph at top of page -- The affirmation (at the bottom of page I-2) that "LES will resolve indications of missing uranium" will not be satisfied by the Clandestine Enrichment Prevention Program (CEPP). The purpose of the CEPP is to detect and prevent unauthorized enrichment. Hence, revision of this paragraph should be considered.

Deleted reference to the CEPP.

6. Page 1-2, Section 1.2.4 -- Since the Health Physics Manager (who has no direct MC&A related responsibilities) is identified in Sub-section 1.2.4.1 as reporting to the Technical Support Superintendent, it would be appropriate to also identify the Chemistry Manager (who i

does have MC&A responsibilities) in a new Sub-section 1.2.4 7 i

Added as requested.

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9 ATTACHMENT A Page 2 of 21

7. Page 1-2, Section 1.2.4.1 was revised, as requested, to clarify that the Health Physics Manager has no MC&A responsibilities. However, the 3rd page of Table 1.31 still shows the HP Manager as being responsible for MC&A related NDA measurements, and thus Table 1.3-1 needs to be modified also.

Revised to Chemistry Manager.

8. Page 1-13, Section 1.4.1 -- The summary for procedure MCP-105 states that the periodic MC&A program assessment will be conducted by selected consultants, while Chapter 8.0 states that at least half of the assessment team are selected from outside the facility staff. The procedure description in Section 1.4.1 should be generalized to facility personnel and/or consultants.

Generalized as requested.

9. Table 1.3-1 -- (1) The responsibility for implementing the assessment program (Chapter 8.0 of FNMC Plan) should be added to the table. (2) The MC&A Recordkeeping Specialist would be a more appropriate " responsible individual" for " source data control," rather than the Production Schedule Manager, as currently shown.

The assessment program responsibility has been added as requested. The MC&A Recordkeeping Specialist function has been left as primary reviewer of source data.

control. Actual position assignments will be adjusted as necessary closer to start up, consistent with specified responsibilities and requirements for independence.

10. Page 2-2, Section 2.1.1,4th paragraph on page -- To be consistent with the definitions for

" empty cylinder" and " emptied cylinder" as given in Appendix C, the word " empty" should be changed to " emptied" in (1) the 2nd and last word of line one, (2) the last word of line four, and (3) the 7th word of line six. Additionally, the first part of the third sentence could be better clarified by modifying it to read; "The mass of the UF heel remaining...."

Revised as requested.

11. Page 2-2, Section 2.1.2 -- Assuming that the first paragraph of this section is addressing product cylinders with heels (as opposed to filled product cylinders), the word " emptied" should be inserted in the first line of this section before the term "UF."

6 The word "any" has been inserted to clarify this applies to any product cylinder.

s 94 ATTACHMENT A Page 3 of 21

12. Pages 2-5 & 2-6, Section 2.1.4.5 -- It is our understanding that residual holdup in piping and equipment does not reach an equilibrium, but rather increases rapidly when UF is first 6

introduced, then increases asymptotically with time. Inleakage will increase the rate of solids buildup at a rate dependent on the level of inleakage. Once uranium is deposited in the pipes.

it does not enter into equilibrium conditions with the gaseous UF. Hence, this section may 6

need modification.

i Modified in accordance with comments.

13. Page 2-18. Section 2.3.3.2 -- The phrase " analyzing samples" (1st and 2nd line of section) should be modified to read " analyzing UF samples" so as to avoid the impression that all 6

samples are measured by the Davies and Gray method.

Revised as requested.

14. Pages 2-23 & 2-24, Section 2.5.6 -- The comment # 12, above, also pertains to this section.

Modified in accordance with comments.

15. Pages 2-25 & 2-26, Sections 2.5.9 & 2.5.10 -- Section 2.5.9 states that UF is absorbed in 6

the alumina traps of the Feed Purification System, and Section 2.5.10 then states that 100 percent of the weight gain in an activated alumina trap is HF. Should not the chemical trap in Section 2.5.10 be an activated carbon trap?

Several corrections have been made to adsorption ratios and quantitles.

16. Table 2.1 Both Tables 2.1-1 and 2.1-2 state that gas sampling is performed at the l

Purification Takeoff Station. Should not this gas sampling point be listed in Table 2.1-3?

The references to gas sampling at the Purification Takeoff Station have been corrected 3

to indicate Feed Autoclave sampling results are used for determining the assay in the i

feed purification cylinders.

17. Table 2.2-2 -- Should not the Purification Takeoff Station gas sample point be listed in the table?

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See response to #16.

18. Table 2.3-1 -- In the tenth row of the " Application" column, "UF " should also be added.

6 Added as requested.

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4 ATTACHMENT A Page 4 of 21

19. Figure 2.2-1 -- The Purification Takeoff Station gas sample points are not identified on the figure.

See response to #16.

20. Page 3-7, Section 3.3 -- The last two lines on the page should be modified to read as follows:

" item, which is known to produce a bias effect on the measurement will be present to the same degree in the control standards to the extent practicable. To ensure this, LES will"-

Modified as requested.

21. Page 3-10, Section 3.3.5 -- In addition to titration, the first paragraph should also identify the spectrophotometric and the alpha-spectrometry measurement systems as being used in conjunction with reversed-phase chromatography.

The reversed-phase partition chromatography will be used, for MC&A purposes, only as preparation for visible spectrophotometry. The text has been revised accordingly.

22. Page 4-11, Section 4.3 -- In the last line of the second paragraph, the phrase " Figure D-1" should read " Table D-1."

Corrected as requested.

23. Page 4-15, Section 4.6 -- The text states that " typical ID Situation ranges are shown on Figure D-1." Presumably you meant Table D-1, but in any event the ranges mentioned are not shown. Ei her Table D-1 should be expanded to show " Typical ID Situation Range," or t

the reference to 'he table in Section 4.6 should be deleted.

To clarify, the word " Range" has been revised to " limits."

24. Figures 4.4-1 and 4.4-2 -- The numerical scale on the y-axis for SEID Limit is incorrectly shown as being 0.25 percent of active inventory. It is twice the total measurement i

uncertainty that is limited to 0.25 percent of AI. Thus, the limit for SEID, when assuming a 1:1 ratio of measurement to non-measurement uncertainty, is 0.177 percent of AI.

These figures provide no new information and have been deleted.

ATTACHMENT A Page 5 of 21

25. Page 5-7, Section 5.2.1 -- The Running Book In-Process Inventory (RBIPI) is applicable only to the bimonthly dynamic inventory (i.e., only material code 89 -- uranium in cascades).

That is, the RBIPI would be part of a total plant Running Book Inventory (RBI) that would.

l include all applicable material codes.

RBIPI has been revised to RBI.

26. Page 5-12, Section 5.3.1.1 - In the first line of this section, insert the phrase "of the cascade system" after the word " inventory."

Revised as requested.

27. Page 5-18, Section 5.3.2.1 -- In the second sentence, change the phrase "All nuclear material" to read "All source and special nuclear material." That is, by-product material and other radioactive materials that do not qualify as either SM or SNM need not be included in the physical inventory.

Revised as requested.

28. Page 5-22, Section 5.3.2.1.25 -- The term "RBIPI" should be changed to "RBI."

Revised as requested.

29. Page 5-23, Section 5.3.2.3.1 -- The second sentence of second bullet is incomplete. The sentence of the fourth bullet is also incomplete.

These sentences have been corrected.

30. Page 5-26, Section 5.3.2.4 -- (1) In the first sentence, the term "RBIPI" should be "RBI."

(2) With respect to the second set of bullets,it is not clear if UF tails are to be treated as 6

removals from inventory (i.e., as shipments), part of inventory (as stored material), or both.

RBIPI has been revised to RBI. The word "may" has been added to the introduction to the second set of bullets, since tails could be either inventory or shipments.

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ATTACHMENT A Page 6 of 21 j

31. Page 9-6, Section 9.2.2.2 -- Rather than state that the listed process monitors are adequate to meet the design criteria of Section 9.2.1 and provide effective barriers to unauthorized production or diversion of SNM, it would be more appropriate to say that the listed process monitors form a major detection element, but they would not in themselves alone meet the criteria.

t Please refer to LES letter dated 9/8/93 for responses to NRC comments regarding i

Chapter 9.

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32. Page 10-2, Section 10.1.1.1 -- The last bullet should include allegations made by any l

member of the public.

i Added as requested.

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33. Page 10-3, Section 10.2.1 -- In the 2nd and 3rd lines of the second paragraph, the phrase "whether unauthorized production has occurred or is underway" should be changed to "whether any source material or special nuclear material is actually missing."

Revised as requested.

34. Page 10-4, Section 10.2.2 -- The first sentence of the last paragraph of this section should i

be modified to read:

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.. LES will determine within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months whether the indicator is true or false, and if true, report such finding to the NRC pursuant to 10 CFR 74.11....

l Modified as requested.

35. Page 10-4, Section 10.2.3 -- In the 6th line of the first paragraph, the phrase "Since unauthorized enrichment cannot normally be detected...." should be changed to read "Since unauthorized enrichment might not be detected...."

1 Revised as requested.

}

36. Page 10-5, Section 10.2.3 -- The 2nd paragraph on this page discusses loss or theft of l

uranium. It does not belong in Section 10.2.3 (Investigation and Resolution of Indicators of the Production of Uranium Enriched to more than 5 WT%) but rather Section 10.2.1 l

(Investigation and Resolution of Indicators of Missing Material).

1 This paragraph has been merged into Section 10.2.1.

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ATTACHMENT A Page 7 of 21

37. Page 10-5, Section 10.2.3 -- The 3rd paragraph on page 10-5 discusses unauthorized i

production of uranium enriched to less than 5 percent. It does not belong in Section 10.2.3 but rather Section 10.2.2.

t This paragraph is redundant with the information in Section 10.2.2, and thus has been deleted.

38. Page 10-9, Section 10.4 -- The last sentence on page 10-9 should be removed. It is the same as the first sentence in Section 10.4.

Sentence has been deleted.

39. Page C-3, Definition for " Abrupt Loss" -- This term, as defined in 10 CFR 74.4, only applies to strategic special nuclear material. and is defined differently than the LES definition.

We suggest that you delete this term from the definitions given in Appendix C of your FNMC Plan.

Deleted as suggested.

40. Page C-3, Definition for "Beginning Inventory" -- The word "in-process" should be deleted from your definition.

Deleted as requested.

41. Page C-5, Definition for " Procedural Error" -- The second sentence of the definition needs to be completed.

This term is not used uniquely and thus has been deleted.

42. Page C-6, Definition for " Standard Error of Inventory Difference" -- Although your definition is consistent with that given in 10 CFR 74.4, to be consistent with your commitments in Section 4.4 (and its sub-sections), you may want to modify your definition to include non-measurement uncertainty (as permitted by the guidance given in NUREG/CR-5734).

This definition has been corrected.

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b A'ITACIIMENT A Page 8 of 21 ENCLOSURE 2 Succested Chances to FNMC Plan That Must be Addressed

1. Pages 2-1 & 2-2, Section 2.1.1,2nd,3rd,4th, and 5th paragraphs -

(a) The 2nd paragraph states that the mass for both uranium element and U-235 are calculated using the " verified" shipper's assay or 0.711 percent. This paragraph should be

.i modified so as to clarify that it is just U-235 mass that is being addressed at this point, because the LES receipt determination of uranium mass, as described in the 5th para-graph, can be established after weighing the cylinder (within 3 days of receipt). It is not entirely clear as to what is meant by " verified shipper's assay or 0.711%." If LES' U-235 assay measurement for a given feed cylinder (prior to feeding to the enrichment system) is conducted within 30 days of receipt, that measurement (rather than the shipper's assay or an assumed 0.711 percent value) should be utilized for shipper-receiver evaluation purposes.. If such U-235 assay is conducted more than 30 days following cyli'ider receipt, the rationale and criteria for using the 0.711 percent value instead of the shipper's assay should be provided. Additionally, there needs to be a commitment that LES' U-235 assay (by gas-ionizationmass spectrometry) will always be conducted within 30 days of receipt whenever LES' enrichment meter measurement does not agree with the shipper's U-235 assay within plus or minus 0.10 weight percent U-235.

Section 2.1.1 has been modified in accordance with the above comments. The option to use 0.711% instead of the shipper's assay has been deleted.

(b) Based on the discussion in these paragraphs, it appears that LES will initially book shipper's values (for total U and total U-235) at the time of each cylinder receipt; make an adjustment to the book values after weighing a cylinder within 3 days of receipt; and then make a 2nd (final) book adjustment after LES' mass spectrometer U-235 assay is conducted. No specific time period limit has been specified for the elapsed time between cylinder receipt and the final U-235 receipt assay. It would be undesirable to go more than 90 days without making a final U-235 receipt assay, and it would be preferable if all receipt measurements were performed within 30 days of receipt. In those cases where all receipt measurements are completed within 30 days following receipt, the intermediate adjustment to a book value is not necessary.

A commitment to use the " oldest" cylinders first has been added to minimize the time

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between receipt of a feed cylinder and completion ofits assay measurement. In most

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cases this may prevent exceeding 90 days without having completed a final US assay measurement. Taking samples from feed cylinders outside the autoclaves is not practiced. A strict 90-day limit cannot from a practical standpoint be guaranteed, especially during the early phase of plant commissioning.

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ATTACHMENT A Page 9 of 21 (c) These four paragraphs of Section 2.1.1 need to be expanded to clarify the issues discussed above.

Expanded, as explained in a & b above.

2. Page 2-5, Section 2.1.4.1 & Page 2-22, Section 2.5.3 -- The statement that "the U-235 assay used for material collected by the Feed Purification System and collected in the Feed Purification Station Take-Off Station is always assumed to be 0.711 percent U-235" should be modified to state that the U-235 isotopic quandty and/or concentration of such material will be based on accounting values associated with the feed cylinders in question.

Modified as requested.

)

3. Page 2-10, Section 2.1.8 -- The fourth and fifth sentences of the last paragraph should be revised so as to provide better clarification. The following wording is suggested:

"A nominal U-235 enrichment, based on the type of waste and the area of generation, is assumed. The mass of uranium is determined by dividing the U-235 mass (as determined by gamma-ray assay measurement) by the nominal U-235 enrichment (expressed as a weight fraction)."

Modilled in accordance with suggested wording.

4. Page 2-18, Section 2.3.3.3 -- The reversed-phase panition chromatography method (as described) is not a measurement system in itself, but rather the first portion (or sample pretreatment step) of a " volumetric, colorimetric, or a-spectrometry" measurement. Hence, this section needs to be expanded to address the volumetric, colorimetric, and a-spectrometry methodologies. If the volumetric measurement is a Davies and Gray titration, a reference to Section 2.3.2.3 (with a notation that the sample is not subject to the hydrolyzation pretreatment step that UF. samples undergo) would suffice. Alternatively, it would be preferable to have three separate sections for the three measurement techniques, with all three identifying the reversed-phase partitioning as part of the overall measurement system.

The reversed-phase partition chromatography will be used, for MC&A purposes,'only as preparation for visible spectrophotometry. The text has been revised accordingly.

5. Page 2-21, Section 2.3.4.2 - The last sentence of the section states that the measurement in question is for weight percent U-235 (i.e., for U-235 enrichment) which contradicts the rest of the section. Hence, the last sentence should be revised to state the calibration range in terms of total grams U-235 within a waste container.

I Modified as requested.

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ATTACIBfENT A Page 10 of 21

6. Page 2-22, Section 2.5.3 -- This section should be expanded to identify the circumstances under which the 0.711% U-235 isotopic constant may be assumed. The existing statement that the U-235 isotopic concentration "is always assumed to be 0.711 percent U-235" is not acceptable if this measurement is used in any way for accountability purposes. That is, the enrichment level should be either (1) based on the U-235 isotopic concentration (as derived from the accounting records) of the UF fed into the Feed Purification System, or (2) based 6

on measurements of UF gas (or liquid) samples taken from the FPS.

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The assumption of 0.711% no longer applies. Enrichment levels are based on accounting values.

7. Table 2.1-1 -- In the fifth (i.e., last, far right) column blocks of the table, the wording in -

1st,3rd, and 4th rows should be modified to read something like the following:

1st ow:

. the feed material isotopic assay as determined by mass spectrometer analysis 3rd row:

the tails material isotopic assay as determined by mass spectrometer analysis 4th row:

. the feed material isotopic assay as determined by mass spectrometer analysis Revised as requested.

8. Table 2.2-2 -- All rows, except the last, in the " Measured Characteristic" column, should list i

only "U-235" (rather than "U, U-235").

Revised as requested.

9. Page 3-6, Section 3.2.5.1 -- It is not clear as to how 2S sample cylinders can be used to calibrate an NDA enrichment measurement on large UF cylinders. Also, this section 6

mentions "three standards... for each material type," which contradicts the statement that

" enrichment meter measurements. will only be performed on UF contained in ANSI N14.1 6

UF cylinders." A more conventional method of calibrating an enrichment meter (for UF 6

6 cylinders) would be to correlate enrichment meter count-rate results (after attenuation-correction for cylinder wall thickness) with mass spectrometer enrichment measurements on gas samples taken from the same cylinders.

This paragraph has been re-written to incorporate these comments. Table 3.3-3 has also been revised accordingly.

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<e ATTACHMENT A Page 11 of 21

10. Pages 3-8 & 3-9, Section 3.3.1 -- The list of weight control standards should include empty (or emptied) 48X/48Y cylinders.

An emptied 453X cylinder has been added to the list.

I1. Page 312, Section 3.4 -- The bullet at the very top of the page should be revised to read:

" Equal to at least 15 during an inventory period when the number of MC&A measurements is between 15 and 333." The next bullet should also be modified to read:

" Equal to at least 50 when the number of MC&A measurements exceeds 333 during an inventory period."

Revised as requested.

12. Table 3.3-2 -- Weight control standards should be established and utilized for weights of new (unloaded) chemical traps and empty 48" cylinders. A weight control standard for new chemical trap beds is identified in Section 3.3.1.

These standards have been added as requested.

13. Table 3.3-5 -- (1) Replicate measurements need to be performed for the load cell systems if the bi-monthly inventory measurement uncertainty is based on these measurements.

(2) If all accountability weight values from load cell systems are derived from an average of two weighings (with a cylinder being rotated 180 degrees between weighings), a replicate measurement should consist of an averaging of two additional weighings. Additionally, it should be noted that for replicate measurements to be meaningful, the second measurement should be separated. time-wise, from the first measurement by at least 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . It is also desirable to have tne replicate measurement performed by a different operator if two or more operators are utilized for conducting load cell weighings.

(1) Replicate measurements will be performed to estimate autoclave load cell random error by use of a control standard, as now described in Sections 3.3.2 and 3.4, and l

Tables 3.3-1 and 3.3-5.

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(2) The text in Section 3.4 has been revised to require two additional weighings where production measurements are normally based on the average of two weighings.

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Accountability weight values from load cell systems will not be based on two weighings.

because the cylinders (for the dynamic inventory) are weighed during the continuous process of being filled or emptied.

14. Page 4-2, Section 4.1.1.1 - This section equates random error and bias, and makes no association between random error and replicate measurements. Hence. the first sentence of the section needs to be revised as follows:

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e ATTACHMENT A Page 12 of 21 "The random error for each weighing system is determined for each inventory period by using control standard measurement data (that is also used to estimate system bias) as replicate measurement data. Tnus, the random error is quantified and controlled."

i Revised as requested.

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15. Page 4-3, Section 4.1.1.2 -- Similar comment as for # 14, above. Hence, the fhst sentence of the section needs to be revised as follows:

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"The random error for each mass spectrometer is determined for each inventory period by measurement of replicate samples. Thus, the combined analytic plus sampling random error is quantified and controlled."

i Revised as requested.

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16. Page 4-3, Section 4.1.1.3 -- Similar comment as for # 14 and 15. above. Hence, the first j

sentence of the section needs to be revised as follows:

"The random error for the titrimetry system is determined for each inventory period by the measurement of replicate samples. Thus, the combined analytic plus sampling random error is quantified and controlled."

Revised as requested.

17. Page 4-3, Section 4.1.1.4 - Inasmuch as the reversed-phase partition chromatography method is not a complete measurement system in itself, it is not necessary to determine its i

separate random error contribution as long as it is included as part of the total random error determinations for each of three systems identified as:

(a) sampling plus reversed-phase partition plus volumetric, (b) sampling plus reversed-phase partition plus colorimetric, and (c) sampling plus reversed-phase partition plus a.-spectrometry.

t Tha %e Neds to be a FNMC Plan commitment for the measurement of replicate samples

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foi cah of trw three systems listed above. [ NOTE: Also see comment #4 of this enclosure.]

The reversed-phase partition chromatography will be used, for MC&A purposes, only as a

preparation for visible spectrophotometry. Thus, only one system will need to be addressed. Replicate sample requirements for this system have been added as requested.

b ATTACHMENT A Page 13 of 21

18. Page 4-4, Section 4.1.1.6 - It is not necessary to determine random sampling error i

separately. That is, determining the combined analytical plus sampling random error by measuring (analyzing) two or more samples from each of several process batches (or containers) is sufficient. However, if LES wants to determine random error separately, the following equation should be used:

0, = (0 - 0,2)"

2 Where a, is the total analytical plus sampling random standard deviation and o,is the analytical random standard deviation.

Thus, if LES wants to place a commitment in its FNMC Plan to determine both analytical and sampling random errors separately, thc third an'i fourth sentences should be revised as -

follows:

l "This is evaluated every inventory period by periodically performing two or more analyses on a single sample along with the taking of two or more samples from a single process item (with a single analysis of each), and comparing the "within sample" and "between sample" variations.

Commitments to determine random error separately have been removed from Section l

4.1.1.6.

19. Page 4-6, Section 4.1.2.1 -- (1) The correctness of the first sentence is questionable. We would expect that the potential for biases associated with analytical measurements of uranium element concentration and U-235 isotopic concentration to be as great or greater than that for UF mass determinations. Thus, the wording of the first sentence should be changed to:

6 "An important component of bias..."

(2) The following phrase should be inserted after the word " estimated" in the first line of the second paragraph:

from the periodic weighing of artifact cylinders (both full and empty)...."

Revised as requested.

20. Page 4-8, Section 4.1.2.4 - The statement in this section contradicts the information

-t presented in section 3.3.7, " Gamma-ray Assay System Control Standards Measurements."

f Thus, the wording should be changed to: " Gamma-ray detection system biases are determined by the analysis of control standards as described in Section 3.3.7."

Revised as requested.

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ATTACHMEhT A Page 14 of 21

21. Page 8, Section 4.1.2.5 -- The last sentence should be deleted since it is addressing random sampling error, rather than sampling bias.

I Section 4.1.2.5 has been revised to remove references to random sampling error determinations.

22. Page 4-10, Section 4.2 -- (1) The fourth sentence should be modified as follows:

"If the range between two measurements of a replicate pair, or the difference between the measurement response of a control standard and its assigned value is outside the 40 band (i.e.,

20, where o is based on previous measurement control data), there is a likelihood that such replicate pair difference, or control standard result, is an outlier."

(2) The fifth sentence should be modified to read as follows:

. 95.46% or all measurements will be within a 40 band (i.e., within 120 of the historical average replicate pair difference, or within 20 of the control standard's assigned value), and 99.74% of all measurements will be within a 60 band (i.e.,

30)."

(3) In the sixth sentence, change "6a range" to "6a band."

(4) The last sentence on page 4-10 needs to be revised so as not to contradict Section 3.5.1, y

and make it clear that the occurrence of any single outlier (in itself) will define a measurement system as being out-of-control (until shown otherwise), rather than the occurrence of outlier within each of two consecutive groups of measurements. That is, the second group of measurements (or merely a single repeat control measurement) would normally be part of a resolution process for an out-of-control situation, and if the second group contains no results outside the 20 control limit band, the system can be regarded as back in control.

Section 4.2 has been revised to incorporate these comments.

23. Page 4-12, Section 4.4.1 -- (1) Inasmuch as a bi-monthly inventory utilizes a different set of-measurement systems, and different material quantities than those for an annual total plant physical inventory, annual and bimonthly SEIDs must be calculated separately. Hence, the following sentence should be added after the first sentence in the second paragraph:

"The SEID for each bimonthly inventory is calculated separately from the SEID for the annual physical inventory since a different set of measurement systems, and different material quantities are involved."

(2) The third sentence in the second paragraph should be modified to read:

~

1 1

1 A'ITACIIMENT A Page 15 of 21 "The total combined measurement plus non-measurement uncenainty of the inventory difference is then found...."

(3) In the second line of the third paragraph, insert the word " total" before the word

" uncertainty."

These modifications have been incorporated as requested.

24. Page 4-13. Section 4.4.2 --- The "SEID" defined on page 4-12 includes both measurement and non-measurement uncertainties. Also the limit for the total measurement uncertainty contnbution to SEID is defined in terms of "twice the standard error." Therefore, the equations on page 4-13 should be changed to:

SELDU235 5 0.00177

IAU235 or SEIDU235 s 3,500 g U235 SEIDU s 0.00177

IAU or SEIDU s 70 Kg U Table D-1 should also be corrected to reflect the changes in the above equations. [Also see comment # 45.]

The equations and Table D-1 have been corrected using the LEID concept.

i

25. Page 4-14, Section 4.5 -- The definition of the term "AU235" should read " additions to the enrichment process system, as Kg U-235," rather than " additions of U-235 to inventory."

1 Revised as requested.

26. Pages 4-15,4-16, & 4-17, Sections 4.6.1 & 4.6.2 - The warning-level ID situation occurs when either the U-235 or the U inventory difference exceed their respective limits, not when both exceed the limits. This also applies to the "significant ID problem" limits. Therefore, the following changes should be made:

(1) Page 4-15, Section 4.6.1 - The word "and" between the two equations should be~

changed to "or";

(2) Page 4-16, Section 4.6.1 -- The word "and" between the two equations at the top of the page should be changed to "or";

(3) Page 4-16, Section 4.6.2 - The word "and" between the second and third equations in Section 4.6.2 should be changed to "or"; and

e ATTACHMENT A Page 16 of 21 t

(4) Page 4-17, Section 4.6.2 -- The word "and" between the first two equations on Page 4-17 should be changed to "or."

Revised as requested.

27. Page 5-6, Section 5.2 -- In the paragraph following the four bullets, the fourth and fifth sentences need to be revised as follows:

".. is the total plant book inventory value for both uranium and U-235. The values are reported in grams U-235 and kilograms of uranium for soume material uranium (material codes 10 and 81) and in grams for both uranium and U-235 associated with SNM (codes 20 and 89) per NUREG/BR-0006..."

Revised as requested.

28. Pages 5-8 & 5-9, Sections 5.2.1.2 & 5.2.1.3 -- These sections need to be modified to clarify that LES will have intemal additions to and removals from inventory when changes in DOE /NRC material codes are involved (i.e., additions to, and removals from the cascade system). The following changes are suggested:

)

(1) Add an introductory phrase at the very beginning of Section 5.2.1.2 to read:

"Other than transfers of SM or SNM into and out of the cascade system (i.e., changes i

to or from material code 89),...."

j (2) At the very end of Section 5.2.1.2, add the following two sentences:

"When UF as natural uranium feed is introduced into the cascade system, such feed is treated as an addition to material code 89 (and as a removal from material code 81) and is documented with a DOE /NRC Form 741 transaction. Similarly, removals of tails or product from the cascade system are treated as additions to material codes 10 and 20, respectively (and removals from code 89)."

(3) In the first line of Section 5.21.3, insert the phrase "within a given material code," after "U-235."

(4) Delete the second sentence of Section 5.2.1.3.

(5) In the last sentence of Section 5.2.1.3, change the word " removals" to" shipments."

Changes made as suggested.

ATTACHMENT A Page 17 of 21

29. Page 5-14, Section 5.3.1.1.10 - The RBIPI includes additions and removals from the cascades; it does not include shipments, receipts, and measured discards. Change the first sentence in Section 5.3.1.1.10 to read:

"The RBIPI is the beginning inventory of the material in the cascades, plus all additions to the cascades, minus all removals from the cascades."

Revised as requested.

30. Page 5-28, Sections 5.4.1.1 & 5.4.1.2 -- AIDuns and AIDu are equal partners in determining a warning level ID and a significant ID problem. Both U and U-235 must be evaluated to provide detection of unauthorized production and accuracy of the material accounting system. Therefore, the following changes should be made on page 5-28:

(1) After the first equation, remove existing language and replace with the following:

"then AIDu is evaluated against the following equation. If":

(2) Replace the last sentence in Section 5.4.1.1 with the following:

"If the absolute value of AIDuns is greater than 500 g U-235 and if either of the remaining two conditions is not satisfied, then a Normal ID Situation has not occurred and the evaluation for a Waming-level ID Situation is performed.

(3) After the first equation in Section 5.4.1.2, remove existing language and replace with the following:

"then AIDu is evaluated against the following equation. If":

(4) Replace the last sentence on page 5-28 with the following:

"If either of these conditions is not met, then the evaluation for a Significant ID Situation is performed."

These sections have been revised as requested.

31. Pages 5-31 & 5-32, Sections 5.4.2.1 & 5.4.2.2 -- Similar comments as for item 30, above.

Thus, the following changes are suggested:

(1) After the second equation on Page 5-31, remove the existing language and replace with the following:

"then AIDu is evaluated against the following equation. If":

a

ATTACHMENT A Page 18 of 21 (2) Replace the last sentence in Section 5.4.2.1 with the following:

"If the absolute value of AIDuns is greater than 5.000 kg U-235 and if either of the remaining two conditions is not satisfied, then a Normal ID Situation has not occurred and the evaluation for a Warning-level ID Situation is performed."

(3) After the first equation in Section 5.4.2.2 (Page 5-32), remove the existing language and replace with the following:

"then AIDu is evaluated against the following equation. If":

(4) After the second equation in Section 5.4.2.2 (Page 5-32), replace the phrase "then a Normal ID Situation has occurred" with the phrase "then a Warning level ID situation has occurred."

l (5) Replace the last sentence in the seconi paragraph on Page 5-32 with the following:

"If either of these conditions are not met. then a Warning-level Situation has not occurred and the evaluation for a Significant ID Situation is performed."

I These sections have been revised as requested.

32. Figures 5.4.1 & 5.4.2 need to be revised to show the following:

(1) For bi-monthly inventories, a Normal ID Situation exists if:

(a) the U-235 AID is within the range of-499 grams to +499 grams, and/or (b) both the U and U-235 AIDS fall within the range of zero plus or minus two times SEID.

(2) For annual physical inventories, a Normal ID Situation exists if:

(a) the U-2325 AID is within the range of-4999 grams to +4999 grams, and/or (b) the U-235 AID is within zero (1.7 SEID + 500 g U-235), and the UAID is within zero (1.7 SEID + 10 kg U).

(3) A Warning Level ID Situation exists if:

(a) a Normal ID Situation is not satisfied; and (b) neither the U nor the U-235 AID has triggered a Significant or Major ID Situation.

(4) A Major ID Situation exists if the absolute value of the U-235 AID equals or exceeds the Detection Threshold (DT), regardless of the U AID value. Where:

(a) the annual inventory DT = DQ - 1.3 SEID, and (b) the bi-monthly inventory DT = DQ - 1.3 SEID - cumulative ID over the past ten months.

These figures have been revised as requested.

.l J

ATTACHMENT A Page 19 of 21

33. Table 5.3-1 -- The shading on this table implies that the ID will only be calculated for the total amount of U and U-235 present in all DOE /NRC material codes combined. In fact, the l

ids for each material code (i.e., depleted uranium, natural uranium, enriched uranium, and uranium within cascades) will also need to be calculated and reported separately. Thus, a total of five NRC 327 forms will have to be submitted for each annual physical inventory.

Additionally, the table should allow for the addition / removal of material to/from the cascades.

Table updated as requested. Also, formulas revised in Section 5.2.1 and 5.2.2 to be consistent.

34. Table 5.3-2 -- This table should allow for the addition / removal of material to/from the cascades. For bi-monthly dynamic inventories, only material code 89 (uranium within cascades) is being inventoried. Thus, it is not necessary to consider the other material codes for a Bi-Monthly Inventory Summary.

Table updated as requested.

t

35. Page 6-7, Section 6.4.1 -- The item monitoring program should also verify that all items at the facility are shown in the MC&A records. This is an important element in the detection of unauthorized production. Therefore, add a fourth bullet to Section 6.4.1 as follows:

. " Verify that items actually stored at the facility have been ide itified in the MC&A records."

Added as requested.

36. Page 6-8, Section 6.4.2 -- (1) To satisfy the acceptance criteria presented in NUREG/CR-5734, the item monitoring activities should be conducted at least monthly, rather than bi-monthly as currently stated in Section 6.4.2.

Frequencies revised as requested.

(2) The equation shown for determining the number of items to be verified also falls short of 10 CFR 74.33(c)(6) criteria which requires a capability to detect a 500-gram loss of U-235 from items. The following modification would be acceptable to the NRC:

(a) For item monitoring applied to tail cylinders, the "x/DQ" exponent can be allowed; (b) For feed cylinder item monitoring, change the exponent from "x/DQ" to"xn5 kg U-235";

and (c) For product cylinders item monitoring, change the exponent from "x/DQ" to "x/0.5 kg U-235," or merely commit to a 100 percent item verification.

i ATTACILMENT A Page 20 of 21 NOTE: For (a), (b), and (c), above, "x" is defined as the average mass of U-235 per item expressed in kilograms. Likewise, for (a), DQ is expressed in kilograms U-235.

Equations and commitments have been revised in accordance with these comments.

37. Page 8-2, Section 8.2 -- The team report should also include the soundness of the MC&A records and the effectiveness of the item control program. Therefore, add the following bullets to the list on Page 8-2:

" Soundness of the MC&A records"

= " Effectiveness of the Item Control Program" Added as requested.

38. Pages 9-3, 9-4, 9-27, & 9-28, Sections 9.2.2.1, 9.3.1.1.3, 9.3.1.1.4, & 9.3.1.1.5 --The inspection frequencies stated in items 3,5, and 5 of Section 9.2.2.1 disagree with those presented in Sections 9.3.1.1.3,9.3.1.1.4, and 9.3.1.1.5. To address unauthorized production concerns, the more frequent inspections are favored.

C Please refer to LES letter dated 9/8/93 for responses to NRC comments regarding Chapter 9.

39. Page 9-4, Section 9.2.2.1, Item 7 -- The frequency for inspection of cylinders to detect the presence of unauthorized cylinders should be conducted monthly (see comment # 36). We also note (from Chapter 6.0) that the inspection is performed as part of the item control program, and not as a part of the Bi-monthly Inventory Program (as stated in Section 9.2.2.1).