ML20137D910
| ML20137D910 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 11/15/1984 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20137D194 | List:
|
| References | |
| FOIA-85-554 NUDOCS 8511270164 | |
| Download: ML20137D910 (5) | |
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November 15, 1984 Mr. James P. O' Reilly, Regional. Administrator U.S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 2900 Atlanta, Georgia 30323
Dear Mr. O' Reilly :
Re f erence s :
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/84-11 dated 10/18/8 nank you very much for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr.
B.
L.
Richards of your of fice on July 30 - August 2, 1984.
Pertaining to the itecs of apparent noncompliance witn NRC regoirements in your letter, the replies to these items are given the attachment to this letter.
We appreciate your inspector's comments and gug.gestions related to our safeguards programs.
These comments and suggestions are helpf to us in our constant efforts to maintain and, where necessary, improve these programs and to ensure the continuation of a successf ul sa feguards ef fort at our plant.
We also welcome further discussion with your staff on the items in your letter and in our related replies, if necessary, for fu.rther clarification.
I Pursuant to 10 CFR 2.790(d), General Electric Company requests tha the attachment to this letter be withheld from public disclosure since this attachment identifies details of General Electric's control and accounting procedures for safeguarding licensed specia nuclear material.
Very truly yours, GENERAL ELECTRIC COMPANY f
kN-ylW Charles M.
Vaughan, Manager I
Licensing 6 Nuclear Materials Management M/C J-26
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3 GEN ER AL O iticTRic CONTAINS 10 CFR 2.790(d) INFORMATION Mr. J.
P. O' Reilly November 15, 1984 ATTACHMENT The information given below refers to the items in Enclosure 1 1
Notice of violation, in the NRC Inspection Report 70-1113/84-11, l dated 10/18/84.
1.
License Condition 2.1 of Safeguards Amendment No.
MPP-3 to Special Nuclear Materials License No.
SNM-1097 requires the licensee to follow the current revision of % g(L Fundamental Nuclear Naterial
, Control Plan. ;i I
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Contrary to the above,,the licenses failed to correctly calculate limits of error which were entered on DOE /NRC-741 forms for shipments of uranium dioxide pellets.
The licensee applied incorrect parameters to the limit of error calculations which resulted in limits of error being reported that were not determined at the 95%
confidence level.
Similir violations were disclosed during inspections conducted July 25-29, 198 3 (reported in Inspection Re po r t No. 70-1113/83-21), and April 2-6, 1984
( reported i,n Inspection Report No. 70- 1113/84-06).
The licensee's corrective actions for these violations were not adequately implemented to prevent recurrence.
This is a repeat violation.
This is a Severity Level V violation (Supplement III).
General Electric Company concurs with the above finding.
The incorrect Limit of Error (LE) occurred as a result of inacco sampling and measurement quantities used in the calculations.
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4 GENER AL O iticiaic CONTAINS 10 CFR 2.790( d ) 'INFORMATION Mr. J.
P. O' Reilly November 15, 1984 AttacNnent - Page 2 As we discussed at our September 6, 1984 meeting, GE's design philosophy for LE. calculations was one of(automating the work and integrating it into the near real time accoantability system)
The use of. automation) typically eliminates the human error compone that is responsible for inaccuracies in manual systems.
At the ti the original system and procedures were established, the shipping and receiving measurement plans were well defined and consistent time af ter time.
We were successful in removing the human influer in the system design, however, in retrospect our degree of removal appears to have been too great.
T.e first two instances of LE inaccuracies were associated with receipts of materials.
At that time we reviewed the entire progra and identified what was the most probable root cause and took reasonable steps to correct it.
The second situation was created a sequence of human errors including a single individual who indicated they were not adequately aware of the procedural change which corrected potential problems associated with LE calculations on receipts of material.
sometime af ter the initial violation in the sequence, changes were made in the type and sampling methodology oY shipments of material This change invalidated one of the original principles of control philosophy applied to LE calculations and this fact was not recognized by our routine change control program.
This resulted :
an error creati'ng the third violation.
In order to prevent this type of incident from reoccuring, each category of receipts and shipments has been reviewed to determine other similar conditions exist.
Provisions have been made to forward all documentation (such as (certification and blend plans)of shipments) that identifies the number of samples and analyses involved to the function responsib) for performing the LE calculations.
This will assure that the information is obtained from source data and thereby reduce the likelihood of error.
The individuals involved with the subject calculations have been instructe'd by training sessions and by written documentation on how to check for and how to account for 1 O
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...g GENERAL $ ELECTRIC CONTAINS 10 CFR 2.790(d) INFORMATION Mr. J. P. O'Re1'11y November 15, 1984 Attachment - Page 3 correct number of samples and analyses.
Also, the internal procedure utilized in preparation of LE calculations for nuclear material shipments (L&NMMP 202) has been revised to incorporate these new controls.
Full compliance was achieved on October 24, 1984.
2.
10 CFR 70.57( b) ( 12) requires the licensee to establish a record system which allows for the efficient retrieval of program data.
The licensee was notified by NMSS on May 14, 1984, that efficient retrieval meant retrieval within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for all measarex.ent control data generated during the last 12 months.
Contrary to the above, as of August 10, 1984, the licensee could not retrieve measurement control data associated with the ran' dom analytical (isotopic) error calculation for uranium dioxide pellet shipments which was requested by the inspector on August 1, 1984.
The data requested was generated by an agent of the licensee within the last 12 months.
This is a Severity Level y violation (Supplement III).
General Electric Company concurs with the above finding.
The measurement control records that were requested by the inspec could not be located because the datum involved was a new varianc and documentation had not been established per the controlling internal procedure (P/P 140-5, Section 4.2.4.7) prior to its init use.
Typicalry a formal record, such as a Quality Notice (QN), i issued to establish documentation of new methods and variances, this case, however, the procedure was not followed due to an oversight and the customary historic record did not exist.
The w papers whidh would have also supported the values in use had been recently used and apparently misplaced or lost.
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GENERAL h ELECTRIC CONTAINS 10 CFR 2.790(d) INFORMATION Mr. J.
P. O'Reilly November 15, 1984 Attachment - Page 4
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1 The variance involved has been recalculated and documentation of results are currently maintained in our files as work papers.
The function responsible for doctanenting variance calculations ha reviewed the applicable procedure with their management to assure that this type of situation does not reoccur.
A formal record (in this case a QN) documenting the subject varia -
will be issued no later than 12/31/84.
Full compliance will be achieved by December 31, 1984.
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