ML20148A583
| ML20148A583 | |
| Person / Time | |
|---|---|
| Site: | 07000734 |
| Issue date: | 10/18/1978 |
| From: | Partlow J NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Mowry W GENERAL ATOMICS (FORMERLY GA TECHNOLOGIES, INC./GENER |
| References | |
| SGMC:CWE, NUDOCS 7810300205 | |
| Download: ML20148A583 (4) | |
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o UNITED STATES y'
NUCLEAR REGULATORY COMMISSION
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WASHINGTON, D. C. 20555 OCT 181978 SGMC:CWE 70-734 General Atomic Company ATTN:
Mr. William Mowry Licensing Administrator P. O. Box 81608 San Diego, California 92138 Gentlemen:
i We have reviewed your letters dated September 28, 1978 and October 12, 1978 both concerning material control and accounting program modifications associated with your planned campaign to produce low enriched uranium fuel for research evaluation and testing.
We have determined that the proposed permanent increase in the scope of a Plant V campaign, as reflected in revised Section 2.1.2.1 of your Fundamental Nuclear Material Control Plan will not decrease the effect-iveness of your fundamental material controls. Accordingly, we are revising License Conditions 2.1, 4.2, and 4.3, effective imediately, as reflected in Enclosure I to this letter. The revision of License Conditions 4.2 and 4.3 take into account the campaign proce..;ing in Plant V.
With respect to the additional program modifications, we have determined that an acceptable level of safeguards control will be achieved if all commitments are satisfied. Therefore, we are requiring that the commitments be carried out by adding a new License Condition 2.4 to Amendment MPP-1, effective immediately, as reflected in the enclosure to this letter.
General Atomic should also review all chapters of the FNMC Plan and Amendment MPP-1, Sections 1.0 through 8.0, to assure that i
all other commitments and requirements are satisfied.
In view of the large number of inter-plant and inter-MBA transfers, particular attention should be given to the measurement requirements of 10 CFR 70.58(e) and License Condition 3.1.
Sufficient measurements must be made to sub-stantiate the quantities of element and isotope for all special nuclear material received, produced, transferred between MBAs, transfers from MSAs to ICAs, on inventory, shipped, discarded or otherwise removed from inventory.
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2 We have determined that your letters dated September 28, 1978-
. (w/ attachment) and October 12, 1978, contain information of a type specified in 10 CFR 2.790(d). Accordingly, pursuant to Section 2.790(d)(1), such information is deemed to be commercial or financial within.the meaning of 10 CFR 9.5(a)(4) and shall be subject to disclosure-only in accordance with the provisions of 10 CFR 9.12.
Sincerel
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N Ja >es artlow, Chief Mat erial Control Licensing Branch Di\\ ision of-Safeguards
Enclosure:
As stated t
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b Revision of Sections 1.0 through 8.0 In Their
. Entirety To Materials and Plant Protection Amendment MPP-1 To License No. SNM-696 1.0 FACILITY ORGANIZATION 2.0 FACILITY OPERATION 2.1 The licensee shall-follow the " Fundamental Nuclear Material Control Plan", GA-A-13248, Revision 2, dated February 1976, as amended March 24, 1976, November 10, 1976, and September 26, 1977, and August 14, 1978 and as revised September 27, 1978 and in accordance with the provisions of 10 CFR 70.32(c).
2.2 No statement in the licensee's Plan identified in Condition 2.1 shall relieve the licensee of a requirement of 10 CFR Part 70 unless granted in a specific exemption or exception set forth as a condition of this license.
2.3 Operations involving special nuclear materials which are not described in the Plan identified in Condition 2.1 shall not be initiated until an appropriate safeguards plan has been approved by the Nuclear Regulatory Com.mi s si on.
e 2.4 For the low enriched uranium production campaign described in the September 28, 1978 letter, the licensee shall follow the material control and accounting program modifications described in the September 28 and October 12, 1978 letters.
3.0 MEASUREMENTS 3.1 A system shall be established, maintained and followed for the measure-
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ment of special nuclear material received, produced, transferred between MBAs, transfers from MBAs to ICAs, on inventory or shipped, discarded, or otherwise removed from inventory and for the determination of the limit of error associated with each such measured quantity except as specified in Conditions 3.1.1 -and 3.1.2.
The system shall provide for sufficient measurements to substantiate the quantities of element and isotope measured and the associated limits of error.
3.1.1 Measurements are not required on PuSe sources, samples which have been determined by other means to contain less than 10 grams U-235, U-233 or Pu each; reactor-irradiated fuels involved in research, development, and evaluation' programs, and encapsulated SNM sources which are used unopened for research and development or calibration activities.
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Amendment No. MPP-1 Page 2 of 4 Docket No.70-734 License No. SNM-696 3.1. 2' Notwithstanding the requirements of 10 CFR 70.51(f)(2)(iii),
(f)(3)(ii) and 10 CFR 70.58(e), drums of waste materials awaiting incineration in the waste incinertor material balance area of Plant I may be inventoried on the basis of prior measurements without the use of tamper-indicating devices.
Waste materials in Plant III destined for ultimate disposal may be inventoried or shipped on the basis of prior measure-ments without the use of tamper-indicating devices.
3.1.3 For those materials measured by nondestructive assay, the licensee may calculate the elemental content based on isotopic abundance measurements which can be demonstrated to be representative of the material.
3.2 In accordance with the provisions of 10 CFR 70.51(e)(6), the licensee shall establish and maintain a system of material control and accounting such that the LEMUF values for the HTGR Fuel Fabrication Operations (Plant I) shall not exceed 1200 grams uranium and 1100 grams uranium-235 for each material balance period during the period of October 1, 1978 through September 30, 1979.
4.0 MEASUREMENT CONTROL 4.1 All identifiable covariance effects shall be taken into account in the calculation of LEMUF.
4.2 LEMUF calculations are not required for material b? lances associated with Plants III, IV and V except as noted in Section 2.1.2.1 of the Plan identified in License Condition 2.1.
4.3 Material unaccounted for in Plants III, IV and Y shall not exceed 300 grams uranium or uranium-235 contained in high enriched uranium.
4.4 The assigned value for working calibration and test materials prepared from process materials shall be based on measurement by two different methods or laboratories which shall verify each other. Verification shall be determined as described in Section 4.2.1.2 of the Plan identified in License Condition 2.1 The assigned value and associated uncertainty shall be determined by data pooling on a weighted basis.
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