ML20134A724

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Sanitized Insp Rept 70-1113/85-06 on 850422-25.Major Areas Inspected:Technical Review of Allegations & Records & Repts
ML20134A724
Person / Time
Site: 07001113
Issue date: 05/23/1985
From: Mcalpine E, Todd G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134A567 List:
References
FOIA-85-598 70-1113-85-06, 70-1113-85-6, NUDOCS 8511070560
Download: ML20134A724 (5)
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JUN 12 885 Report No. 70-1113/85-06 Docket No. 70-1113 License No. SNM-1097 Safeguards Group No. III Licensee: General Electric Co.

Wilmington, NC 28402 DateofInspection[ April 22 - 25, 1985 Type of Inspecti n: Unannounced Material Control and Accountability Inspector: . . ,

G. y Tod ( Sa(e g Auditor Dite S(gned Approved by: Ph *C E. J. McAlpTne, Chief, haterial Control and 5/za/rs Date Signed Accountability Section, Nuclear Materials Safety and Safeguards Branch, Division of Radiation Safety and Safeguards

SUMMARY

Scope: This routine, unannounced inspection entailed 36 inspector hours by one NRC inspector in the areas of technical review of allegations and records and reports.

Results: No violations or deviations were identified.

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a gen-- Sopies This Document la not to be g reproduced without specirlo approval of IE:II Report No. 70-1113/85-06

1. Key Persons Contacted
  • W. W. McMahon, Manager, Quality Assurance
  • C M. Vaughan, Manager, Regulatory Compliance
  • L. A. Sheely, Manager, Fuel Quality
  • C. W. Doyle, Manager, Quality Audits and Customer Service
  • R. H. Foleck, Senior Specialist, Licensing Engineering The inspector also_ interviewed several other licensee employees.
  • Denotes those present at the exit interview
2. Exit Interview The inspection scope and findings were summarized on April 25, 1985, with those persons indicated in Paragraph 1 above.
3. Licensee Action on Previous Enforcement Matters This subject was not addressed during this inspection.
4. Technical Review of Employee Concerns It was alleged by a former General Electric Nuclear Fuels Manufacturing Department employee that coded computer passwords used by laboratory technicians were accessible by passers-by.
a. Allegation -

Specifically, it was. alleged that coded passwords and employee pay numbers illuminated on the computer r.creen of the densification measurement system in the Chemet Laboratory at the General Electric nuclear fuel facility. The illumination of these technicians' computer passwords allowed access to those passwords by casual observation of the screen by other plant employees.

b. Discussion To determine the validity of the stated allegation and the extent of l concern .among laboratory technicians the inspector interviewed the l laboratory manager, two laboratory supervisors and four laboratory technicians on the normal and off shifts. The interviews were i

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conducted in private with each individual with one exception. One laboratory supervisor was interviewed in the presence of a Licensing and Nuclear Materials Management staff member. The inspector also witnessed a requested demonstration of the densitometer and its associated computer interface.

The results of the interviews and equipment demonstration confirmed the alleged illumination of technician passwords and employee pay numbers on the densitometer computer screen.

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L Y a The inspector's interview with the laboratory manager disclosed that he was not aware of the described condition nor was he aware of any concerns associated with password control and access.

The inspector's interview with two laboratory shift supervisors disclosed that they had been apprised of the described condition by a laboratory technician on or about April 10, 1985. Their perception of the stated concern was that as a result of password control issues in the past the technicians in the laboratory wanted a more stringent password control system such that at no time would their passwords be visible to co-workers or other individuals with access to the l aboratory. As a result of this concern one of the supervisors investigated the condition and reported it at that time to lfiCS computer maintenance personnel of the licensee's Automation Technology organization for evaluation and resolution. Within the same general time frame the supervisor of the concerned technician stated that he

.- informed the technician of the actions he had taken to resolve the concern.

The inspector determined through additional management interviews that in fact this concern has been communicated to the Automation Technology group during this time frame and the evaluation and resolution was earmarked on an action tracking system. It was determined by this group that the software for this system was vendor (INTEL) designed which warranted an evaluation prior to a recommendation for modifica-tion. This evaluation was in progress at the time of the inspection.

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l The inspector's interview with the laboratory technicians confirmed the l events and time frame of communications that were described by the  ;

laboratory supervisor. Each technician expressed a generic concern- l l

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is one technician reported his concern to his supervisors.

k technician who reported his concerns regarding password controls to his supervisor stated that his concerns were based on knowledge of other password control issues in the laboratory and felt that illumination of his password on the screen presented the possibility of it being obtained by an unauthorized individual. He stated that he did not feel that any passwords had been compromised nor did he have any infor-mation related to the potential to utilize another technicians password to falsify data or make unauthorized changes to data,

c. Inspector Findings and Conclusions g

The inspector discussed the findinne nf the inspection with licensee management on April 25, 1985. [

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violation or deviation from regulatory requirements. The licensee acknowledged the inspectors findings and further explained that the internal communications and evaluations of this condition at the laboratory supervisor level was responsive to the technicians concern and the normal method of conducting business to resolve problems when they are identified. The licensee management committed to further research to correct the condition within a benchmark schedule of completion.

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The licensee's response to this concern was determined by the inspector

, to be prompt and effective. It should be noted, however, that the licensee's exercise of control of passwords for the identified equipment was solely for the protection of information and processes that are company proprietary in nature. The described equipment and its associated password control system is not an NRC required system to establish current knowledge requirements for special nuclear material (SNM) nor is it used to generate data for physical inventory which is periodically tested to detect diversion of SNM. Accordingly, the inspector concluded that no violations or deviations from regulatory requirements had occurred.

This matter is closed.

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5. Records and Reports (85215)

Examination of the licensee's accounting procedures disclosed a system of records had been established and was sufficient to close the material balance. An independent reconciliation of the licensee's reported inventory for the period ending December 31, 1984, was performed by Martin Marietta Energy Systems, Inc., an NRC contractor. This reconciliation dated March 1, 1985, indicated that the licensee's SNM reported inventories reconciled with the nuclear material transaction report balance generated by the Nuclear Materials Management and Safeguards System.

The licensee's Material Balance Report and Physical Inventory Listing was submitted for the October 1 through December 31, 1984, in accordance with the Protocol of the US/IAEA Safeguards Agreement.

No violations or deviations were identified.

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General Electric Company auu 2 s85 ATTN: Mr. Eugene A. Lees, General Manager Nuclear Fuel Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:

SUBJECT:

REPORT NO. 70-1113/85-08 On June 10 - 14, 1985, NRC inspected activities authorized by NRC License No. SNM-1097 for your Wilmington Manufacturing Department facility. At the conclusion of the inspection, the findings were discussed with those members of your staff identified in the enclosed inspection report.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.

Within the scope of the inspection, no violations or deviations were identified.

Your attention is invited to one unreso'lved item in the report. This matter will be pursued during a future inspection.

In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, safeguards activi'.ies and security measures are exempt from public disclosure; therefore, the enc'iosures to this letter, with the exception of the report cover page which prosents a nonexempt sumary, will not be placed in NRC's Public Document Ror:a.

Should you have any questions concerning this letter, please contact us.

Since ely,

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Kenneth P. Barr, Chief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards

Enclosure:

Inspection Report No. 70-1113/85-08 cc w/ encl:

C. M. Vaughan, Manag'er Regulator C-]

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\....*/ JUL 121985 Report No. 70-1113/85-08 Docket No. 70-1113 License No. SNM-1097 Safeguards Group No. III Licensee: General Electric Company P. O. Box 780 Wilmington, NC 28401 Date of Inspection: June 10 - 14, 1985 Inspector: M 'OhE.) '

  • 7[(2[fS E. L. Clay \ \ Date Signed Approved by: _ ' G 0 m' m E. J. McAlpinb, Chief, Material Control and Viz/rs_

Date Signed Accountability Section, Nuclear Materials Safety and Safeguards Branch, Division of Radiation Safety and Safeguards -

SUMMARY

Scope: This routine inspection entailed 41 inspector-hours in the areas of measurement systems, inspector followup items and facility organization and management controls.

Results: No violations or deviations were identified.

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4. Copies go, This Doomment te not to be reproduced sithout spectifta spyroval of IE:II REPORT DETAILS Report No. 70-1113/85-08
1. Key Persons Contacted "W. W. McMahan, Manager, Quality Assurance
  • C. M. Vaughan, Manager, Regulatory Compliance "A. F. Schillmoller, Manager, Production Planning and Control
  • B. F. Bentley, Manager, Fuel Chemical Operations

. "A. G. Dada, Manager, Chemical and Ceramic Engineering

  • R. A. Petelinkar, Manager, Site Operations and Material Systems
  • W. C. Peters, Manager, Nuclear Safety Engineering
  • R. L. Torres, Manager, Radiation Protection
  • G. W. McKensie, Acting Manager, Manufacturing Technology and Engineering Operations
  • R. G. Patterson, Acting Manager, Manufacturing
  • R. J. Keenan, Nuclear Safety Engineer -

"G. R. Mallett, Senior Engineer, Measurements and Statistics

  • R. O. Foleck, Senior Specialist, Licensing Engineering R. E. Strine, Fuels Quality Control Engineer R. P. Armstrong, Quality Control Engineer R. L. Bruce, Analyst, Licensing and Nuclear Materials Control The inspectors also interviewed several other licensee employees.

" Denotes those present at the exit interview

2. Exit Interview (30703)

The inspection scope and findings were summarized on June 14, 1985, with those persons indicated in paragraph 1 above. The following issue was discussed in detail: unresolved ** item associated with reporting details of biannual management audits of the measurements control program (para. 6).

The licensee acknowledged the inspection findings and took no exceptions.

3. Licensee Action On Previous Enforcement Matters (92702) l No previous enforcement matters, in the area of nondestructive analyses, were pending at the time of this inspection.
4. Unresolved Items One new unresolved item identified during this inspection is discussed in paragraph 6.
    • An Unresolved Item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation.

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5. Measurement Systems - Fat Albert U02 Rod Scanning (85207)

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The General Electric Company, Wilmington Manufacturing Department (WMD),

. Wilmington, North Carolina uses two NDA measurement systems to perform and accountabilit measurements of UO2 fuel rods. Af~' l 4,] physical ~ ~

measurement system is used to perform measure-

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-ments on ( fuel rods. A delayed gamma detection measurement

. system (Fat Albert) is used to perform measurements on[, ,1U02 fuel rods. f This inspection was devoted to evaluating the accountability measurements performed by the Fat Albert NDA measurement system.

a. System Description

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j Inspection Report Nos. 70-1113/83-10, 70-1113/82-08 and 70-1113/80-02.

b. Standard Calibrations, Fabrications and Traceability the time (,f this inspection, the licensee was using h 6U /  !

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. These calibration and verification techniques were reported

! in Inspection Report No. 70-1113/83-10. The inspectors examination of current operating data indicated that calibration and verification measurements were performed in accordance with approved procedures.

The inspector determined that, all standard rods were fabricated from 002 powder characterized through multiple sample analysis, over a long period of time, by the facility Chemet, Teledyne and Ledoux laboratories. Traceability to a National Measurement System was achieved through analytical techniques employed by the analyzing laboratories. Support data for establishing analytical values of each standard fuel rod used by the Fat Albert measurement system was documented.

c. Measurement Techniques l

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d. System Requalification The inspector's examination of an approved test plan, resulting test plan data and observations of Fat Albert operations indicated that the system had been requalified in accordance with approved procedures.

Techniques employed to requalify the system was reported in Inspection.

Report Nos. 70-1113/83-10 and 70-1113/82-08. The latest system requalification was performed in February 1984 following a system source change. The results of this requalification indicated that the system met all qualification criteria and was declared qualified to measure all types of U02 fuel rods. The results of this requalifica-tion test was documented and were reported to plant management as required.

e. Measurement Bias In 1979, the licensee determined that Fat Albert measurements of UO2 fuel rods were biased. In 1980, the licensee began _ testing the system to identify the root cause and to resolve the bias. The results of previous bias tests were reported in Inspection Report Nos. 70-1113/83-10 and 70-1113/82-08.

As part of their continuing program to identify the source of this bias, and to reduce it to a manageable level, the licensee is fabricating and testing two new fuel rods from each of the four basic g enrichm measured. Along with eight previously (ghgigated fuel g[ .L i rods to identify the level of bias at the time the tests are performed. t-o n s owing each i

test, the resulting value of the bias is applied to Fat Albert measure-ments during the succeeding evaluation period. The inspector's examination of historical test data indicated that this measurement bias is fluctuating in magnitude and is presently considerably smaller than when the tests were begun.

f. FNMC Plan Review ._

A reyiew of the facility FNMC Plan applicable to NDA measurements by

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the 7NDA measurement system was conducted during this inspection.

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4 Sections 1.0 Organization, 3.0 Measurements, 4.0 Measurement Control Program, 8.0 Management and Appendix C-3, Specifically Accepted Safeguards Systems, provide descriptions and methods used to determine the U-235 content of SNM measured by NDA techniques at the facility.

To the extent examined, this review indicated that the licensee was following his current FNMC Plan for performing accountability measure-ments by the Fat Albert NDA measurement system,

g. License Conditions Review Docket 70-1113 Licensed Conditions to Materials and Plant Protection Amendment MPP-3 revised and amended May 31, 1985 for License No.

SNM-1097 were reviewed during this inspection. The licensee was determined to be following the three license conditions applicable to SNM measurements by the Fat Albert i0A measurement system.

h. Standard Operating Procedures (SOP) Review The licensee uses a variety of approved procedures to perform routine ,

Fat Albert measurement and control functions. A review of several SOPS associated with Fat Albert measurements was conducted during this inspection. To the extent of these reviews, the licensee was judged to be following the requirements of the following procedures.

(1) Product / Process Quality _. Plan (P/ POP) No. 4 413, Revision 18, U02 g g Rod Scanning with thel~ 'l dated September 21, 1984. Y (2) P/PQP No. 4.4.10, Revision 7, Fuel Rod Scanning, dated July 12, ~

1983.

(3) P/PQP No. 4.4.12, Revision 6, Rod Scanning Records, dated August 22, 1983.

(4) Procedures and Practices (P&P) No. 70-32, Revision 9, Qualifica-tion of QC Inspection, Examination and Test Personnel, dated February 9, 1983.

(5) P&P No. 140-09, Revision 3, SNMC Measurement Training and Qualification, dated .lanuary 10. 1985.

(6) Quality Notice (QN) 1 -Q-1539, Revision 0, Test Report - Active Scanner Qualification, dated February 27, 1984.

(7) QN-F-Q-1554, Revision 0, Qualification Test Report - New Gap Model, Active Scanner, dated May 11, 1984.

(8) QN-F-Q-1612, Revision 0, Zone Length Qualification Test - Active Scanner, dated April 16, 1985.

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(9) QN-F-Q-1337, Revision 0, Demonstration Test Report for Getter Check - Active Scanner, dated August 30, 1984.

(10) QN-F-Q-1367, Revision 0, Second Half 1984 - Active Scanner Accountability Verification Test Report, dated January 11, 1985.

(11) Quality Control Inspector Instruction (QCII) No. 9.2.2, Revision 17, UO2 Fuel Rod Scanning - Active Scanner, dated April 15, 1985.

(12) Process Requirements and Operator Document (PROD) No. 80.56, Elephant Gun, dated December 17, 1985.

(13) Quality Assurance Section Administrative Routine (QASAR) No.

320-170.30, Revision 5, Replicate Scanning Program for Fuel Rods, dated November 2, 1984.

(14) QASAR No. 320-80.1, Revision 4, Certification of Site Inspection Specialist, dated March 29, 1984. .

i. Operator Training and Requalifications The licensee's operator training, qualification and requalification program was implemented as required by paragraph 4.7 of the licensee's FNMC Plan. The inspector's examination of qualifying procedures and data, indicated that the licensee had qualified measurement operators in accordance with approved procedures. Qualifying techniques and required performances criteria were found to be as indicated in Inspection Report No. 70-1113/83-10. At the time of this inspection, seven operators were qualified to perform measurements of UO2 fuel rods on the Fat Albert measurement system.
j. Reproducibility Test A test of the Fat Albert UO2 fuel rod measurement system's ability to

',, perform acceptable accou'ntability measurements for SNM content was performed during this inspection. The test consisted of remeasuring fifty U02 fuel rods previously measured by the Fat Albert measurement system. The selected test rods encompassed ten rods of five different enrichments. Calibration of the Fat Albert system was checked and verified before and af ter the measurement of each set of fuel rods.

Each set of A e test rods were measured in two different measurement positions. l g'b -

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the measurement capability of the- system, the data indicates that the RDFT m

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6 Fat Albert measurement system performed acceptable measurements on these UO2 fuel rods.
6. Facility Organization and Management Controls (85203)

The licensee's management organization provides a system of checks and balances for accountability measurements. The facility operations, measurements and accounting groups have different reporting avenues to responsible management. The custody, measurements and accounting functions for SNM control do not report directly through the same supervisory line.

The Licensing and Nuclear Materials Management (L&NMM) group coordinates the overall functions for accounting for SNM at the site. At the time of this inspection, the following plant groups were responsible for the operations, maintenance and control of the Fat Albert measurement system.

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The inspector determined that the licensee was meeting the requirements of paragraphs 1.8.1, 4.1.3, and 8.2.1 of their approved FNMC Plan and License

, Condigjga 8.1 by conducting management audits of their measurements program E)(, .l. na .The detai s and findings of the December 1982 manage-i ment Wdit was incTEBed in Inspection Report No. 70-1113/83-10.

4 The latest management audit was completed in December 1984 and included an evaluatica of all facility measurement systems. This audit was performed by corporate auditors of the Nuclear Energy Product and Quality Assurance Operation (NEP and QAO) department. This audit assessed the adequacy of compliance with regulations and determined the effectiveness of the program to detect covert diversion of SNM.

The inspector's examination of the December 1984 audit report revealed that the report continues to be brief and presents findings by exception rather than -indicating the areas audited and specific findings of each area N '

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audited. Auditing and reporting techniques were reported in Inspection Report No. 70-1113/83-10.

The inspector determined that specific audit details which identify and present conclusions for each measurement system audited were not available at the WMD site. The licensee feels that it is not necessary to maintain detailed audit records on site and do not plan to change their biannual auditing and reporting techniques, since they feel that: (1) their technique for auditing and reporting the results of biannual audits meets all regulatory requirements and is in accordance with their approved FNMC Plan requirements; (2) their technique used in conducting audits and reporting audit results follows corporate policy for all other corporate facility audits; and (3) their presently used audit announcement letter and the resulting audit report have historically been used to meet all approved NRC regulatory requirements.

The inspector detemined that the licensee's presently used auditing and reporting techniques follow a literal interpretation of NRC regulatory and their approved FNMC Plan requirements. However, these techniques may not -

meet the intent of these requirements since the licensee's audit report contained insufficient data to permit the inspector to detemine whether all aspects of all measurement systems were included in the audit. The status of this item is considered unresolved pending further evaluation by NRC (85-08-01).

In conclusion, the inspector's review of the licensee's facility organiza-tion and management controls determined that: (1) the licensee had implemented an organization structure that is in accordance with their approved FNMC Plan and applicable license conditions, and (2) the licensee's management system includes provisions for the development, revision, implementation, enforcement, and periodic audit and review of the MCA program and for the training of measurement personnel as required.

, 7. Inspector Followup Items (92701) t

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- a. (Closed) Inspector Followup item 83-10-01: The 1982 annual review and management audit of the facility measurements control program failed to indicate the extent or degree of thoroughness of the subject audits performed. In addition, the audit report was brief and presented audit findings by exception rather that details of the areas audited. The inspector could not detemine whether all aspects of the measurement control program had been audited.

Current status of this item is discussed in paragraph 6. Followup Item

83-10-01 is considered administratively closed and is being reopened as an Unresolved Item in this inspection report (85-08-01).

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b. (Closed) Inspector Followup Item 83-18-02: On May 23, 1983, Safeguards Amcndment MPP-3 was revised to require the licensee to perfom manage-ment audits of the special nuclear material control and accounting program at two year intervals. The first of these two year audits was required to be completed prior to Jan ary 1,1985.

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The licensee conducted a management audit of the special nuclear material control and accounting program during the period of November 26, 1984 to December 2, 1984.

c. (Clossd) Inspector Followup Item 81-17-03: At the time of the subject inspection, measurement techniques employed by tile Elephant Gun measurement system failed to indicate licensee actions taken for cause and effect of operating changes made af ter the system's operating parameters had been exceeded. An examination of these measurement techniques during Inspection No. 70-1113/83-18, indicated that a requirements for recording threshold, window and high voltage operating parameters had been omitted from revised operating instructions.

An examination of presently used operating parameters indicated that techniques for establishing threshold, window and high voltage operating parameters are now included in operating instructions.

Process Requirements and Operator Document (PROD) No. 80-56, entitled Elephant Gun, was implemented on December 17, 1984. This latest revision to this operating instruction, includes instructions for performing equipment checks and establishing calibration parameters for, use in standard and unknown item measurements of 55 gallon drums and waste boxes.

d. (Closed) Inspector Followup Item 83-18-03: At the time of the subject inspection, the Elephant Gun NDA measureme stem contrgL11 pits were y,I beingboxprovided standardstoand theannually, measurement operatorg' or whenever a major cnange in the systemfor occurred, for 55 gallon drum standards. By the end of CY-83, the licensee agreed to provide the measurements operator with control limits for 55 gallon drum standards at the same frequency as waste box standards control limits were provided.

The inspector'.s examination of present operations irdicated that the number of containers measured is now considerably less than when first inspected and that the licensee was campaigning measurements of waste

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j=V i contained in 55 gallon drums. j I On the basis of the measurement effort req @ , the inspector cet. ermined that the licensee's' land k submittal of new control limits for 55 ga TE waste drum measurements was adequate.

8. In-Office Review The following item was evaluated by the Radiation Safety and Safeguards regional staff. Based on this review and the results of the latest and region based inspection activities in the affected functional area, the following item was determined to require no additional specific followup and is closed.

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83-10-02 Followup to assure continued compliance with requirements for l measurement of verification standards on the Fat Altert Rod Scanning System.

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