ML20154J411
| ML20154J411 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 12/03/1984 |
| From: | Vaughan C GENERAL ELECTRIC CO. |
| To: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20154J343 | List: |
| References | |
| FOIA-85-158 NUDOCS 8603100592 | |
| Download: ML20154J411 (8) | |
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GENER AL O ELECTRIC V
wiU4NGTON MANUFACTUIUNG DEPARTMENT GENERAL ELECTDC COMPAW
- PO BOX 780.WlOWNGTON, NORTH CAROUNA 96409 December 3, 1984 Mr. J. Philip Stohr, Director Division of Radiation Safety & Safeguards U. S. Nuclear Regulatory Commission, RII P. O. Box 2203 Atlanta, Georgia 30301
Dear Mr. Stohr:
References:
(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/84-14 dated 11/06/84 Thank you very much for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr. D. W. Jones of your office on October 1-5, 1984.
Pertaining to the four items of apparent noncompliance with NRC requirements in your letter, the replies to these items are given in the attachment to this letter.
We appreciate your inspector's comments and suggestions related to our safeguards programs.
These comments and suggestions are helpful to us in our constant efforts to maintain and, where necessary, improve these programs and to ensure the continuation of a successful safeguards effort at our plant.
We also welcome further discussion with your staff on the items in your letter and in our related reply, if necessary, for further clarification of these items.
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 General Electric's control and accounting procedures for safeguarding licensed special nuclear material.
GENERAL ELECTRIC COMPANY h,(', k h g31 2 060124 RATNER 85-150 PDR Charles M. Vaughan, Acting Manager Regulatory Compliance M/C J26 CMV:bsd SGD-I Uo x
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D C OSURE Mc. J. Philip Stohr December 3, 1984 Attachment - Page 1 ATTACHMENT The information given below refers to the four items in Enclosure 1,
" Notice of Violation," in the NRC Inr.poetion Report 70-1113/84-14, dated 11/06/84.
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 his Fundamental Nuclear Material Control Plan.
Section 4.2.4 of that plan reouires the licensee to determine measurement biases from data obtained from measurements of standards.
Section 4.2.1.2 of that plan also requires the licensee to base the assigned value for standards prepared from process materials on measurements performed by at least two different methods or laboratories which verify each other.
Contrary to the above, for the uranium dioxide powder shipped by the licensee to Japan Nuclear Fuel during August 9, 1983 through May 11, 1384, the 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 cnalytical me t hod.
This is a Severity Level V violation (Supplement III).
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General Electric admits the violation occurred.
In the specific incident identified in this violation, GE has in essence replaced NFMD measurements with those of Ledoux & Company.
Ledoux is a laboratory qualified for performing this type of measurement and the use of their values is acceptable for
,' compliance.
General Electric did not consider this type of change
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in measurement basis as a bias adjustment.
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N Mr. J. Philip Stohr December 3, 1984 Attachment - Page 2 The mechanism used to handle this replacement of measurement basis was similar to making a bias adjustment in that total quantitier of material transferred were adjusted and only reported via the DOE /NRC-742 form (individual DOE /NRC-741 forms were not changed).
General Electric selected this mechanism because it involved less paperwork.
Changes to the DOE /NRC-741 form were not felt to be necessary as JNF is a foreign licensee and does not recognize the U.
S.
form.
Additionally, the terms of the commerical contract do not require reporting of this information since there are no provisions for consideration of measurement differences in quantity of material.
The contract is based on JNF values verifying that material specifications and quantity are met.
(3)M Genar_aL Electric plans no corrective action Apacifice1]v related
_to item 84-14-01, however, since it is directly related to item gg 84-14-02, the _onao ing_corre_c_t ive_ac.t ionJiis cu s S ed _be low W.ij l eliminate any future occurrences of this type of action.__
2.
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 his Fundamental Nuclear Material Control Plan.
Section 4.2.3.3 of that plan requires the licensee to use standards for calibrating SNM accountability measurement systems.
Section 4.2.1.2 of that plan also reauires the licensee to base the assigned value for standards prepared from process materials on measurements performed by at least two different methods or laboratories which verify each other.
Contrary to the above, the licensee's enrichment measurements performed af ter May 11, 1984, were adjusted based on data obtained by measuring a series of procecs material samples, the assigned values of which had been determined by one contractor laboratory using a single analytical method.
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GENERAL $ ELECTRIC 1
C Mr. J. Philip Stohr December 3, 1984 Attachment - Page 3 This is a Severity Level V, violation (Supplement III).
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General Electric admits the violation occurred.
Notwithstanding the requirements of License Condition 2.1 of Amendment MPP-3 to SNM-1097 (as they relate to measurements and measurement control), GE contends that there is a responsibility to the extent practicable to report accurate material balance statements.
While it is debatable as to whether General Electric's actions defined in items 84-14-01 and 84-14-02 do or do not constitute a bias correction as defined in 10 CFR 70.57 or the FNMCP, it does appear that our actions represent the best statement of material quantities.
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Beginning in 1982, there was some evidence that enrichment L
measurements were slightly low.
This was even implied in limited NRC tests on UO exparts.
NFMD has continued to monitor this 2
situation and in 1983/84 conducted engineering analyses and evaluations as identified in 10 CFR 70.57(b)(6).
The results of the initial phase of the program were reported 4/2/84 and resulted in the change in JNF UO values for the period 8/9/83 to 5/11/84 2
as well as a model correction for the enrichment analyzer as documented in Quality Notice F-G-1307 dated S/11/84.
The engineering evaluations also produced a number of other significant recommendations which have been incorporated into a program to upgrade enrichment analysis.
The engineering evaluations are continuing in parallel and will continue until such time that it appears that the measurements and routine measurement control program are producing unbiased results, At a recent meeting of the enrichment engineering evaluation team, (g 0#
the program was modified to include the use of two laboratories (gj t, (currently Ledoux and Teledyne Isotopes) for the determination of
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the model correction for the enrichment analyzer.
This change specifically addresses the NRC concerns of 84-14-01 and 84-14-02.
The changes are to be incorporated in a Quality Assurance Gection Administrative Routine (QASAR) to be issued by the end of January 1985 (before further model adjustments are made).
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Mr. J. Philip Stohr December 3, 1984 j
Attachment - Page 4 The overall enrichment measurement upgrade program is continuing and should be complete around mid-year 1985.
Following a qualification and evaluation period, we expect to find that the problem has been resolved and the model adjustment procedures can be discontinued.
Currently, reviews of the FNMCP are being conducted as well as work in identifying the structure and content of a new FNMCP to be reauired by 10 CFR 74.
Any changes which can be identified and which will, in turn, serve to clarify licensee actions related to these types of measurement problem situations, will be included.
No additional corrective actions are contemplated at this time and it is our belief that the correction of the NRC concerns will be (5) complete by January 31, 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 revision of his Fundamental Nuclear Material Control Plan.
Section 4.2.4.1 of that plan requires the licensee to make bias corrections for measurement methods which involve point or curve calibrations at the closing of each material balance period except for those methods where bias corrections are made as part of routine operations.
The curve bias correction is required to be determined by:
a.
Calculating calibration curve from standards data generated during the material balance
- period, b.
Calculating bias correction at the average value of the independent measurement variable or for each item measured.
c.
Applying this bias, together with the quantity of material measured with the associated measurement method, to calculate a proposed adjustment to be applied to the inventory difference if significant.
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.49/INFORMATION Mr. J. Philip Stohr December 3, 1984 Attachment - Page 5 Contrary to the above, for the material balance period August 9, 1983 through August 13, 1984, the licensee failed to determine bias corrections in accordance with the required technique.
This is a Severity Level V violation (Supplement III).
(h X General Electric can neither admit nor deny the violation at this time and requests that the item remain open until such time as an NRC inspector can review additional information which we feel is pertinent.
GE does confirm that the inspector's statements are correct to the extent that the investigation was conducted.
The statement of the violation does not, however, consider the fact that Section 4.2.3 of the currently approved FNMCP identifies
(;dX certain items related to point and curve calibrations as being unresolved with the NRC.
This unresolved issue has a bearing on Table 4-3 which, in turn, has a direct influence on the application of Section 4.2.4.1.
Additionally, on December 9, 1983, NFMD sent revisions to Section 4.2.3 and Table 4-3 to the NRC for approval.
These changes were the result of discussions with the NRC during March 1983 and, once approved, they would eliminate the inspector's concern.
The problem stems from the lack of a completely acceptable definition of "inside the range" for point and curve calibrations (reference FNMCP Section 4.2.3) and the fact that the currently approved Table 4-3 was constructed to identify system calibration types ( point / curve) based on calibration verification procedures as opposed to actual calibration procedures.
Applying the requirements of Section 4.2.4.1 to the currently approved Table 4-3 results in a technically incorrect treatment of bias in some cases (i.e., gravimetric analysis for percent uranium and gross and tare weights by electronic scales).
General Electric has been advised that NRC Licensino is planning review of ourl12/9/83lsubmittal in the very near future.
They have verbally indi6atid~that their response will most likely be favorable.
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GENERAL $ ELECTRIC 10 C/Rh'FROM,DISpLOSVRE.p0 $0MkTION EXEMPT Mr. J.
Philip Stohr December 3, 1984 Attachment - Page 6 (f) y No other corrective action is anticipated at this time and full compliance should be clear once NRC approvals are documented.
GE h)y would, however, like to have this condition resolved with the inspector prior to the August 1985 uranium physical inventory so hb7 that these calculations are performed in an acceptable manner.
4.
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 his Fundamental Nuclear Material Control Plan.
Section 4.2.4.1 of that plan requires the licensee to make corrections for significant bias.
Contrary to the above, for the material balance period August 9, 1983 through August 13, 1984, the bias correction made by the licensee for uranium concentration measurements performed by the;qravimetric, analytical method was -1090 grams uranium-235 rather than
+1090 gram uranium-235 which is the correct value obtained when the measurement bias is applied to the quantity of material measured by that method.
This is a Severity Level V violation (Supplement III).
General Electric admits that the violation existed.
{ The error was apparently clerical in nature, was made during the initial calculations and was not detected in a subsequent, independent review. One might speculate that more emphasis was placed on the arithmetic to obtain the absolute quantity (which was correct) than on the complicated algebra associated with the material balance to obtain the sign. The error was corrected in a report to the NRC on October 15, f 1984, but not within the currently approved, 30-day maximum reconciliation period. f,s The error has been discussed with those responsible for the (H I original calculations and those performing the independent verification. We expect this to be ef fective in future work of this type. Additionally, 10 CFR 74 will allow a 60-day period for
GENERAL $ ELECTRIC EXEpPJ FBCM DI CLOSQRE tM9 0 I'N O Q 10 CER t 7 Mr. J. Philip Stohr December 3, 1984 Attachment - Page 7 the type of work currently required in 30 days. This increase in the alotted time is more commensurate with the complexity, volume and accuracy expected by the NRC. No further corrective action is anticipated at this time and (i) General Electric was in full compliance as of October 15, 1984, when the condition was reported. CM Vaughan sbsd k .r~c. -r,
fA $76& .. ?e gy GENERAL $ ELECTRIC WILMfMGTON DEPARTMENT GENERAL ELECTibC COMMNY + P .%LMPGlCH. H CAAOLINA 98409 February 28, 1985 Mr. J. Philip Stohr Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission, RII 101 Marietta Street, NW - Suite 2900 Atlanta, Georgia 30303
Dear Mr. Stohr:
Reference:
(1) NRC License SNM-1097, Docket # 70-1113 (2) NRC Inspection Report 70-1113/84-18 dated 1/31/85, received 2/5/85 Thank you very much for your letter reporting the results of the inspection conducted at our licensed fuel fabrication plant by Mr. T. R. Decker of your office on December 17-21, 1984. Pertaining to the one item of apparent noncompliance with NRC requirements in your letter, the reply to this item is given in the attachment to this letter. C We appreciate your inspector's comments and suggestions related to s our emergency preparedness and fire protection programs. These comments and suggestions are helpful to us in our constant efforts to improve these programs, and ensure our compliance with NRC regulations and license conditions. We also welcome further discussion with your staff on the items in your letter and in our related reply, if necessary, for further clarification of this item. Your inspection report referred to above does not contain information which we believe to be pronrietary. Sincerely, GENERAL ELECTRIC CO P NY fM a l n Charlec M. Vaughan, Manager Regulatory Compliance /sbm NSD-I fl y.Ol'If y gr cgA -
F-E: GENERAL $ ELECTRIC Mr. J. Philip Stohr February 28, 1985 Page 1 of 2 ATTACHMENT The following is the General Electric Company response to NRC Inspection Report 84-18, Notice of Violation - Enclosure 1. l 10 CFR 70.22(h)(1) states, in part, that Emergency Plans shall contain the elements that are listed in Section IV, " Content of Emergency Plans", of Appendix E to 10 CFR 50. 10 CFR 50, Appendix E IV(D)(1) states, in part, that administrative and physical means for notifying local, State, and Federal officials and agencies and agreements reached with these officials and agencies for the prompt notification of the public and for public evacuation or other protective measures, should they become necessary, shall be described. Contrary to the above, though the Emergency [ Director is required by the Radiological Contingency and Emergency' Plan to provide pecjected dose information and recommendations to off-site organizations for implementing affective emergency action, neither the Plan or Implementing Procedures were adequately prescriptive to assure prompt notification and protective action recommendations to off-site authorities. This is a Severity Level IV violation (Supplement VIII). General Electric C mpany admits the violation as stated above. The reason the violation occurred was due to the omission of the subject notification and action requirements in the Emergency Director's procedures. However, these requirements were and are identified in the Nuclear Safety Advisor's procedures. It is each advisor's responsibility to assess the potential hazard associated 9 o D e w a
7 Mr. J. Philip Stohr February 28, 1985 ATTACHMENT - Page 2 of 2 with their area of responsibility (i.e., industrial safety, radiological safety, and environmental issues) and to make appropriate recommendations for protective actions to the Emergency Director. On a temporary basis, a hand written instruction that identifies immediate notification with protective action recommendations to off-site authorities has been included in the Emergency Director's manual which is located in the Emergency Control Center. The Emergency Director's emergency procedures will be updated to include immediate notification and recommended actions, as appropriate, to the local off-site authorities. Full compliance on this item will be achieved by August 15, 1985. As a result of NRC inspection 82-01, a Notice of Violation was issued to NFMD which addressed the assessment of the magnitude of releases, evaluation of the need for notification and the protective actions to be taken off site. As described in the NFMD response to this violation dated 5/5/82, procedures describing these activities were written and the objectives were accomplished through the recommendations of competent NFMD technical advisors to the Emergency Director. Therefore, the requirements in the form of decision criteria and action guides were technically implemented as a result of closing this item. The current violation indicates a perceived procedural deficiency to provide a double check for an existing requirement which is already evvered in the advisor's procedure. While we agree that the double check is desirable s.: this situation, the significance of its absence appears minor its nature. In view of the corrective actions taken in regard to violation 82-01-A, General Electric Company requests that the NRC consider reclassification of item 84-18-01 pursuant to the guidelines of 10 CPR 2, Appendix C, as Severity Level V. CM Vaughan tbsd A s}}