ML20203F086

Partially Withheld (Ref 10CFR2.790) Matl Control,Accounting & Physical Security Insp Rept 70-1100/86-02 on 860127-31. Violation Noted:Failure to Notify Commission of Changes Made to Physical Security Plan

ML20203F086
Person / Time
Site:	07001100
Issue date:	03/05/1986
From:	Della Ratta A, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20203F078	List: ML20203F072 ML20203F083 ML20203F086
References
70-1100-86-02, 70-1100-86-2, NUDOCS 8604250016
Download: ML20203F086 (5)

Text

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- 3 U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-1100/86-02 Docket No. 70-1100 License No. SNM-1067 Safeguards Group: III Licensee: Combustion Engineering, Inc.

p.0. Box 500 Windsor, Connecticut 06095 Facility Name: Combustion Engineering - Nuclear Fuel Manufacturing Inspection At: Windsor, Connecticut Inspection Conducted: January 27-31, 1986 Date of last Material Control and Accounting Inspection: December 9-13, 1985 Date of Last Physical Security Inspection: July 2, 1985 Type of Inspection: Routine, Unannounced Material Control, Accounting, and physical Security Inspection Inspector: . A= !w _ f. S 3C date

/A. Della R ta, S ds Auditor Approved by: .

_e $:$p _5 # 84

. Keimigf Chie M afeguards Section, date R[ Nuclear MtterialVSafety and Safeguards Branch Inspection Summary: Inspection on January 27-31, 1986 (Report Number 70-1100/86-02)

Areas Inspected: Nuclear material control, accounting, and physical security, including: facility organization and management controls; facility operations and internal controls; records and reports; and physical protec-tion measures for special nuclear material of low strategic significance.

Results: One violation was identified: Failure to notify the Commission within two months of changes made to the NRC-approved physical security plan, as required by 10 CFR 70.32(e) (Paragraph 7),

i 8604250016 860417 "~

PDH ADOCK 07001100 C PDR

e DETAILS

1. Key Persons Contacted

• 0. Parks, Manager, Nuclear Materials and Security R. Sheeran, Manager, Licensing, Safety, Security and Accountability G. Kersteen, Manager of Production H. Cohen, Supervisor, Nuclear Material Accountability P.-Rosenthal, Manager, Radiological Protection Services J. Limbert, Radiation Safety Engineer B. Ayers, Commander, Site Security J. Esso, Captain, Site Security The inspector also interviewed other licensee employees involved with nuclear material. controls, production and physical security.

• present at exit interview

2. 30703 - Exit Interview

The inspector met with Mr. D. Parks at the conclusion of the inspection on January 31, 1986, and summarized the scope and findings of the inspection.

At no time during this inspection was written material provided to the licensee by the inspector.

3. 92701 - Licensee Action on Previously Identified Items (Closed) Inspector Follow-up Item (70-1100/83-05-01): Samples taken for physical inventory verification were analyzed by the licensee's laboratory and New Brunswick Laboratory. The inspector compared the laboratories' results and no statistically significant differences were noted.

(Closed) Inspector Follow-up Item (70-1100/85-04-02): Samples taken for physical inventory verification were analyzed by the licensee's laboratory and New Brunswick Laboratory. The inspector compared the laboratories'.'

results and determined that two uranium assay results, out of ten, hadj statistically significant differences. One difference amounted to 0.6w uranium and the other difference amounted to 1.2% uranium. These differ-ences could have been the results of a sampling error, but additional samples were obtained for analysis during inspection 85-06 in an attempt l to resolve these differences. This matter is being tracked under IFI l 85-06-01.

4. 85203 - Facility Organization and Management Controls l

l The inspector discussed with management, and reviewed, the licensee's 1 i NRC-approved Fundamental Nuclear Material Control Plan (FNMCP). The cur-rent organizational structure and qualifications of the material control  ;

! management and support staff were in accordance with the FNMCP. The l I

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. 3 ll licensee was in the process of revising its FNMCP to comply with the re-quirements of 10 CFR 74.31 " Nuclear Material Control and Accounting for SNM of Low Strategic Significance."

The delegation of material control and accounting (MC&A) responsibilities and authorities was documented in writing and the overall planning, coor-dination, and administration of the MC&A functions for special nuclear material were vested in a single individual who was at an organizational level sufficient to assure independence of action and objectiveness of decisbns.

The inspector also reviewed the latest audit report of SNM control and accounting procedures / practices, dated May 20, 1985. The audit team found no discrepancies in the SNM control and accounting practices. The inspec-tor found that the audit was timely and performed as required by the cor-porate internal audit staff.

5. 85205 - Facility Operations and Internal Controls The ' inspector observed that the authorized possession and use of special nuclear material were as specified in the facility license.

The inspector reviewed the licensee's storage and internal control prac-tices applicable to the two material balance areas (MBA's) and the two item control areas (ICA's) and determined that the licensee properly pre-pared and maintained control of SNM transfer documents. All of the MBA 2 and MBA 3 internal transfer documents issued during the physical inventory period of March 19, 1985 - September 17, 1985 were reviewed by the inspec-tor.for signature, measured quantities, location and timeliness. No dis-crepancies were identified.

6. 85215 - Records and Reports The inspector audited the nuclear material control records and reports for the low enriched uranium physical inventory material balance period March 19, 1985 - September 17, 1985. All line items on the SNM inventory report were traced to source documents and compared to the records main-tained by the licensee and to the DOE-NMMSS computer tabulations. The licensee's ledgers were also verified for accuracy. Nuclear Material Transaction Reports (00E/NRC Form-741), that documented receipts, ship-ments, and measured discards, were reviewed for timeliness, format, and accuracy of content. No discrepancies were identified.

Material Status Reports (DOE /NRC Form-742), submitted for the material balance period ending September 17, 1985, were also reviewed for the same i attributes. No discrepancies were identified.

l The inspector determined that the licensee's control and subsidiary records for the period under review were adjusted to the results of the physical inventory, as required by NRC regulation.  ;

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7. 81485 - General Requirements for the Protection of Special Nuclear Material of Low Strategic Significance The licensee was protecting special nuclear material of low strategic significance in conformance with the NRC-approved physical security plan for the facility. The inspector confirmed this by examining barriers and access controls, procedures, and by observations of a licensee test of alarm system features. Implementation of the physical security plan meets the general performance requirements and objectives of the governing reg-ulations except as follows: The inspector's review of the licensee's NRC-approved physical security plan determined that the licensee had made several changes in August, 1983, and February,1984, but had not submitted these changes to the Commission within two months after the changes were made, as required by 10 CFR 70.32(e). Examples of the changes made are as follows:

THIS PARAGRAPH CONTAINS 2.790(d)

INFORMATION !.TJ IS NOT FOR PUBLIC DISCLOSURE. IT IS I INTENTIONALLY LEFI BLANX.

Failure to submit these changes to the Commission within the allotted two months was identified as a violation (70-1100/86-02-01).

The inspector also noted that the licensee could only provide, for review, security patrol records for the preceding 30 days. The physical security plan requires that certain security patrols be conducted, but the plan does not specifically require retention of records.

The Radiological Safety Officer stated that it was his decision to retain the records for only 30 days and destroy the older records after review.

The absence of record retention requirements for NRC required activities, such as, security patrols, appears to be an oversight in the conditions w_

- 5 of this license. This matter was discussed by the inspector with Mr. R.

Jackson, NRC-NMSS during a telephone conversation on February 4, 1986.

Mr. Jackson-will pursue this matter with the appropriate group in NRC Headquarters and advise Region I and the licensee of the results. This is an unresolved item (86-02-02). An unresolved item is one about which more information is required in order to ascertain whether it is acceptable or is a violation of NRC requirements.

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