ML20137E108
| ML20137E108 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 03/08/1985 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20137D194 | List:
|
| References | |
| FOIA-85-554 NUDOCS 8511270204 | |
| Download: ML20137E108 (6) | |
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I GENERAL $ ELECT 1 tlc i
wu.emmcumensee oemsnen GBERM Sf05C COMmHV + PO sox 780.WILMNGION, NOHH CAaOtte 96409 March 8, 1985 di -
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g Mr. J. Philip Stohr, Director
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Division of Radiation Safety t Safeguards U.S. Nuclear Regulatory Commission, RII P.O. Box 2203 23 Atlanta, Georgia 30301
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Dear Mr. Stohr:
References (1) NRC License SNM-1097, Docket, 9 70-1113 (2) NRC Inspection Report 70-1113/84-14 dated 11/06/84 (3) Letter, CM Vaughan to JP Stohr, 12/3/84-it (4) Letter, JP Stohr to EA Lees, 2/1/85 (5) Letter, CM Vaughan to JP O'Reilly, 2/6/85-6 (6) Letter, CM Vaughan to JP Stohr, 2/15/85 - to On December 3, 1984, General Electric Company Nuclear Fuel Manufacturing Department responded to,the inspect fon" conducted at our licensed fuel fabrication plant by Mr. D.
W. Jones of your office on October 1-5, 1984.
On February 6, 1985, GE-NFMD submitted further information related to this inspection which concerned bias correctic ns.
On February 1, 1985, the NRC formally accepted the GE-NFMD response to the tourth violation in Inspection Report 84-14 and requested further response to the first three apparent violations.
This information is given in the attachment to this letter.
l Pursuant to 10 CFR 2.790(d), General Electric Company requests that the attachment to this letter be withheld from public disclosure since this attachment identifies details of the General Electric control and accounting procedures for safeguarding licensed spc ial i
- nuclear material.
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General Electric personnel would be pleased to discuss this matter further with you and your staff as deemed necessary.
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Sincerely, 8511270204 851119 G
ERAL LECTRIC PAN [Y PDR FOIA g
f/g/ o g RATNERB5-554 PDR y
Regulatory Compliance
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GENERAL h ELECTRIC
- ll EXEMPT FROM DISCLOSURE 10 CPR 2.790 INFORMATION Mr. J. Philip Stohr Attachment - Page 1 March 8, 1985 ATTACHMENT The information given below refers to the first three items.of concern regarding NRC Inspection Report 70-1113/84-14, dated 11/06/84, as described in JP Stobr's letter to EA Lees dated 2/1/85.
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License Condition 2.1 of Safeguards Amendment j
No. MPP-3 to Special Nuclear Materials License g
No. SNM-1097 requires the licensee to follow Material Control Plan. g Fundamental Nuclear the current revision of
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J, Contrary to the above, for the uragium dioxide powder shipped by the licensee to(~
during August 9, 1983 through May 11, 1984, the
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licensee determined the bias associated with enrichment measurements from data obtained by measuring 'a series of process material samples, the assigned values of which had been determined by one contractor laboratory using a single analytical method.
This is a Severity Level V violation (Supplement III).
In the GE-NFMD response on 12/3/84 to the subject NRC inspection, General Electric stated that the correction made was not a bias correction (in accord with bias correction definitions in MC&A requirements).
GE still contents that this is the case.
General Electric also stated that corrections were made to NFMD accounting records and were not made to the DOE /NRC-741 forms.
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GENERAL h ELECTRIC EXEMPT FROM DISCLOSURE 10 CPR 2.790 INPORMATION
. M r. J. 'P h il ip' S tohr Attachment - Page 2 March 8, 1985 The limit of error calculations for the ID of the August 1984 inventory did not assume that a bias correction was made.
The records reviewed by the inspector which referenced the
-corrections as biases did not intend to use the word " bias" in the context,of SNM measurements, but rather mean,ing a comparison betweeni The observation that Ledoux is not listed in Table 3-1 for tee analysis of routine process samples is correct.
This laboratory is used extensively for certification of standards and is qualified to meet the same measurement and measurement control requirements as GE-NFMD.
NFMD currently plans to continue to use the measurement system as defined in Table 3-1 of the Fundamental Nuclear Material Control Plan.
Should changes be desired, the appropriate change in documentation will be filed with the NRC.
The corrective step NFMD has taken in response to this violation is to remove this correction from the SNM accounting records associated with the proper material balance.
The subject of future violations is discussed in the consideration of the second alleged violation.
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A revised inventory report was submitted to the NRC on March 1,
1985.
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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 revisi g.of his Fundamental Nuclear Material Control 2
Plan.)
Contrary to the above, the licensee's enrichment measurements performed af ter May 11, 1984, were adjusted based on data obtained by measuring a
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series of process material samples, the assigned a
S
s GENER AL h ELECTRIC
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EXEMPT FROM DISCLOSURE 10 CFR 2.790 INFORMATION Mr. J. Philip Stohr Attachment - Page 3 March 8, 1985 values of which had been determined by one contractor laboratory using a single analytical method.
This is a Severity Level V violation (Supplement III).
As stated previously in this attachment, GE-NFMD admitted that the correction made was not a bias correction (within the MC& A definition).
GE-NFMD also admits that the value used was backed by data from one laboratory, not the two that is required for estimating biases.
These actions were directed toward reporting the best quality information regarding MC&A performance and were not intended to resolve any cause of the apparent bias.
GE-NFMD conducted an internal review in an attempt to determine the root cause of the apparent bias.
The following causes were identified and a corrective action program to address them has been implemented:
o Insufficient gain stabilization o
Chance coincidence sumning o
Material age effects o
Analyzer window inaccuracies-As an interim corrective action, on 5/11/84 a Quality Notice (ON' F-G-1307) was issued to establish a procedure to correct measurements made since May 11, 1984.
This QN was a part of the measurement method until superceded by the issuance of Quality Section Administrative Routine (QASAR) 320-70.10 on February 13, 1985, which con pletes the documentation and implementation of an upgraded system.
The QASAR requires data from two qualified laboratories to substantiate a bias (correction.
In the NFMD inventory reports to the NRC dated 9/10/84 and 10/15/84, the bias adjustment made included a bias correction for measurements made since 5/11/84 for the me thod under question.
The corrective action taken for the first violation will remove the concern stated by this violation.
However, the ID restatement made in the first violation will also be e.f fected by including a bias for the entire material balance pericd.
As stated previously, the inventory report was resubmitted on
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March 1, 1985.
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GENERAL h ELECTRIC EXEMPT FROM DISCLOSURE 10 CPR 2.790 INFORMATION Mr. J. Philip Stohr Attachment - Page 4 March 8, 1985 3.
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 revis of his Fundamental Nuclear Material Control I
Plan I f
GE-NFMD confirms that it did not fully conform to the bias correction techniques detailed in the FSMCP.
implementationoff 10 CFR 70.57, the topic of bias Since the corrections has been under\\ discussion with the NRC.
These discussions began with the' subject of calibration ranges, but it was soon learned that when discussing ranges, the type of calibration (i.e.,
point or linear) and the o ocedure for correcting biases also becomes pertinant.
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On February 6, 1985, GE-NFMD submitted a description of the actions taken regardino GE-NFMD procedures for perforning bias a
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GENERAL $ ELECTRIC EXEMPT FROM DISCLOSURE 10 CFR 2.790 INFORMATION Mr. J.
Philip Stohr Attachment - Page 5 March 8, 1985
' corrections.
With these changes, NFMD contents that we have taken and completed the necessary corrective actions to resolve concerns for this violation.
We have not received an answer to our 2/6/85 4
letter.
As a result of these actions, GE-NFMD anticipates that Region II will determine that our operations are in full compliance and no further action is required.
O e
4 CM Vaughan
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