ML20207T018
| ML20207T018 | |
| Person / Time | |
|---|---|
| Site: | 07001113 |
| Issue date: | 02/08/1985 |
| From: | Rolonda Jackson NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| To: | Brown W NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS) |
| Shared Package | |
| ML20207S990 | List: |
| References | |
| FOIA-87-88 NUDOCS 8703230061 | |
| Download: ML20207T018 (9) | |
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PLEASE RETURN TO NMSS/SGFF, MS-881-SS DISTRIBUTION:(W/ Encl.)
Docket File 1113 "
FEB 0 81985 Caja File "
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SGFF:RLJ SGFF s/f 70-1113 LICobs, IE " "
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MEMORANDlN FOR: Willard B. Brown, Chief SGFF r/f Fuel Facility SG Licensing Branch THRU: C. N. Smith, Section Chief Nuclear Material Control Licensing Section, SGFF FRCM: Raynond L. Jackson Nuclear Material Control Licensing Section, SGFF
SUBJECT:
TRIP REPORT - GE (WILMINGTON, NC)
JANUARY 29 - 30, 1985 Purpose To tour GE's newly conjLtru te and discuss their proposed relateg .C procedures as well as other RCIA licensing J,7[O matters. "-
Licensee Contacts I H. Vaughan -
Manager, Regulatory Canpliance and Acting itanager, Licensing & Nuclear Materials Management B. S. Dunn ( - Licensirg Admin. Clerk R. H. D. Foleck )- Licensing Engineer P. N. Denison -
IMSS & SS Rep. (Records & Reports)
G. R. Hallett -
Sr. Engineer, Measurements & Statistics -
R. L. Bruce -
Analyst, IN Control W. W. McNahon -
Manager, Quality Assurance i
a M. L. Faris
- 0. J. Kemppain S. W. Dale ,
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- 0. W. Brown 7
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FEB 0 81985 10 tTR 23WSI" F ,l f.,1 i
The firs morning was spent in a pre-tour meeting with the aforementioned J 'g6 timenamed {a brief overview of the purpose of the unit was presented.ma I in turn stated my reason for being there, i.e., to ensure ourselves that the required MC&A procedures had been, or would be, incorporated in the actual operational mode of the unit and that GE's Fundamental Nuclear Material Control (FNMC) Plan reflected as much.
Ae purpose of thef f.
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ontaminated solids will be packaged for shTpnent to licensed off ite burial facilities.
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F09F '7-7 FEB 0 E 1985 e -Willard B. trewn 10 CmUSG!dsM
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The implementation of the ill significantly reduce the quantities of V measured discards record the GE-NFMD accounting systen. L/ '
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TTndicated to the meeting attendees that I foresaw no problems' i_n granting MC&A approval, but would know better after I had reviewed GE's FNMC Plan submittal with GE-MC&A personnel that afternoon.
At the conclusion of the meeting a 3-hour tour, with appropriate discus-sions took place. It is evident that a considerable amount of planning 1..p#and into quiteeffortan(equating impressiveg to % _.]considerable monetary expenditure) has gone The afternoon was devoted in the main to discussing, with- GE-MC&A person-nel, their FNMC Plan s i tal dated 11/8/84 to incorporate the 'necessary l'q0 revisions to cover the As a result of this discussion and review of the FHMC Plan revisions a d rqy receipt and reviet of additional back-up infonnation that I requested, I told GE-MC&A penonnel that I foresaw no
. problems in approving their 11/8/84 submittal and that a letter revising the appropriate License Condition 2.1 would be forthcoming.
Non( licensino Matters o Resolution of statistically significant S/R Differences (10 CFR i 70.58(g)(3) - Reference our generic letters of August 16, 1983 and October 15,1984: ,
l In a letter dated Hoventer 19 , 1984, GE contends that certain portions I of our October 15, 1984 letter are in conflict with our letter dated August 16, 1983, and as a result requested a letter of clarification from us.
Until I have the opportunity to respond to GE's November 19 , 1984 letter, I told them to use the criteria stated in our August 16, 1983 letter and ignore our October 15, 1984 letter with the exception of that portion which states "70.58(g)(3) only applies to statistically significant SRDs associated with or within a given shipment. Hence, ,
there is no requirement to investigate (or resolve) significant SRDs l l
on a cumulative. basis." i o"'"d................. '
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10 CFR 2.190 Mnmitfoi ,
Willard B. Brown y FEB 0 8 G85 V f L
o Revisions to NUREG/BR-0006 " Instructions for Completing Nuclear Material Transaction Reports" (Revision 2 effective March 1,1985):
GE-MC&A personnel are concerned that the modifications are going to be extremely difficult and costly to implement. They were also per-plexed in that they had no opportunity to coment on the changes since they had seen no notice in the Federal Register. The first they were aware of the repor' ting instruction revis1oris for Forms 00E/NRC-741, 741A and 740M was via receipt of the referenced revised NUREG and the accompanying letter dated December 17, 1984, from T. S. Sherr, Chief, Material Transfer SG Licensing Branch, Division of Safeguards. I suggested that GE call June Robertson, SGMT, to express their concerns and then follow up with a letter to SGMT.
Upon my return, I took to Ms. Robertson GE marked-up copies of the 741, " Sample Letter to Correct Header Data" and GE-MC&A rough draft coments on the revised reporting instructions. Ms. Robertson advised me that she would look at GE's coments, but probably would do nothing until a formal letter from GE was forthcoming. The changes were not published in the Federal Register since it was "not a Rule change" and the changes were not cons:dered substantive nough to arrant the licensee's opportunity to coment. I called S. Dun GE and relayed to her Ms. Robertson's coments.
o Clarification of "in a timely manner" 10 CFR 70.57(b)(11):
In a generic letter dated May 14, 1984, we outlined our position for licensee compliance with that portion of 10 CFR 70.57(b)(11) which states, "Whenever control data exceed the 0.05 control limits, the licensee shall investigate the condition and take corrective action in a timely manner." Our letter concluded that if the licensee's FtNC Plan does not comit to our stated position, the licensee should
- make the appropriate revision and submit as a 70.32(c) change.
GE i nds to review their internal @CMM.i? ide ,w --
(Procedures)"andthens t revised FINC Plan chan tha g,,N correspond and relate to V (the referenced Section and page are dar,ed l 0/85).
~ GE's initial reaction is that they wish to apply our position only to the major ID contributors of their measurement control system.
- I made no comitment whether this was acceptable or not.
10 CFR 2.790 Wermatial
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10 CR 2.730 Ir.fonn 6cl Willard B. Brcwn -(,
FEB 0 81985 i o- IAEA- Y k
GE is currently preparing their Design Information Questionnaire (DIQ) for submittal, and our subsequent review, by February-12, 1985. GE was selected from the U.S. Eligibility List to come under the Protocol of the US/IAEA Safeguards Agreement. The completed ;
. DIQ is intended to provide a description of the licensee's current Sm operations and procedures.
GE-HC&A pers el asked my coinion as to whe r the' completed, g,d8but as still should be described in the DIQ. told then yes since the approval and consequent licensing of the unit was imminent. Otherwise, the DIQ would have to be revised perhaps in a couple of weeks after it had been sub-mitted. G. Sparks (SGMT) agreed with my F.scoupendation. I told GE make the DIQ writeup pertaining to the L _fas brief as possible, b140to The IAEA can tell them the amount / level o#d etail they need when the DIQ is verified on site by the IAEA and NRC Division of Safeguards personnel, i
o o The use of( )for determining certain[ [ inventory 3 quantities:
In a letter dated August 31, 1984, GE requested a one-time exemption i
"#e requirement (10 CFR 70.51(f)(1)(1), 70.58(j) and Section 7.2. 'of their FNMC Plan) that any factors utilized for establishing
, ve#;ory quantities be based on current measurements. The request pertained to six material categories and was necessitated by dis-crepancies between 1983 and 1984 factors used for these categories.
In a letter dated September 7,1984, we granted the exenption and also made the following comments:
"It should be noted that Section 7.2.3 of your FEC Plan is lacking in sufficient details relative to:
- 1. number of measurement values used to calculate an average factor (5 U) for a given material type, l 2. the method for updating factors, and
- 3. procedures or controls for detecting and investigating indica-tions of a change in factor values.
We are, therefore, requesting that you submit a FNMC Plan revision that clarifies the above points." GE did revise their Plan with a letter and page changes to Region II dated December 28, 1984.
Revised Page 7-3 now appears adequate.
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Willard 8. Brown 10 CR 2.730lefons 6ol FEB08 5
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Also in our response dated Septecber 7,1984, we requested that GE submit by December 31, 1984, a report to us which would discuss the investigation and resolution of the discrepancies between the 1983 and 1984 factors for the six material categories in question.
In a submittal dated December 28, 1984, GE didn't respond in a com-plately acceptable manner in that future procedures used to determine factors was described, but little of what caused the discrepancies between the 1983 and 1984 factors, i.e., did the measurement system go out of control, did the material actually change, etc., etc.?
In our discussion relating to this topic, GE-MC&A personnel responded dy of the situation is still going on as tiey A'1io are by taking saying thatoftheir a total material types) and is ' time consuming. I requested that #
report be submitted to us no later than June 23, 1985, which would fully document the investigation and resolution of the discrepancies between the 1983 and 1984 factors for the six material types in question.
, o Exenption Request from Requirements Regarding Transfer Doctanent LE Calculations:
In a letter dated October 12, 1984, GE requested an exemption from requirements of 10 CFR 70.58 specific ntsnber of samplesdan(e) analyses to use an average in the calculation rather of Lthanof E a for those cases where batches of the same material type are listed on the same Form DOE /NRC 741.
I had infonned GE via telecon that we needed additional inforraticn before we could proceed further in responding to their request. On January 8,1985. GE submitted additional infonnation. Based on this and conversations held with GE-MC&A personnel during my visit. I will now proceed to revise my rough draft evaluation memo and letter dated December 13, 1984, in which I proposed that the exenption be granted, but failed to include enough information to satisfy C. N.
Smith (Section Chief, if4CLS) and, therefore, the additional infonna-tion from GE was necessary.
l o License Condition 2.1:
Discussions related both to the updatin fd Region II approval of certain 70.32(c)changes g of theand condition the inco due to I of the date of theJNMC Plan Page changes describing C . .
] the{rpor 10 CFR 2.730Infennatics
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ij $f -Q" .; f~ jf Willard B. Brown 10 CFR 2390WmaW FEB 0 8 G85 LJ o ~ Delegation of Measurement Control Functions:
In a Region II Evaluation Memo dated Mg 11,1984, (S-F2:84-072 -
Inspection Reports Nos. 70-1113/83-28 and 70-1113/84-06) it was felt that GE's current delegation of measurement control functions may be contrary to accepted practices (Section 1.7.4 of GE's F)MC Plan and 70.58(a)(2) are cited). A copy of the referenced Evaluation Memo-randtsn is attached.
In our memo to Region II dated November 29, 1984, responding to four different Evaluation Memos concerning GE, we stated that "The licensee's procedures as described in the above referenced documents, as well as our MC&A Review Criteria, will be reviewed for consistency in regards to the intent of 10 CFR 70.58(b)(2)."
My conclusion, after talking with GE-MC&A personnel and reviewing certain GE internal procedures, is that GE's practices are acceptable.
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o close-Out Meeting:
The ttendance sheet I attached.
explained At the /request functionofs .W.McMahof l an .. Peter 11n g role 's MC&A Li g Reviewer. fur lained my purpose for the visit
- which was mainly to tour th nd discuss GE's rela d jroposed 4
J. M MC&A procedures and to disc various other unrelate licensing matters.
10 crR 2.790 bfermatid
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FEB 0 81985 L1 I expressed my appreciation for the extreme cooperation shown to me by GE personnel and stated that I foresaw no problens in our ap oval, in a timely manner, of GE's Fific Plan revision dealing with the ] s,7 ft I further stated that as a result of my discussions with GE M personnel, several S101-MC&A licensing matters had been resolved.
Raymond L. Jackson Nuclear Material Control Control Section, SGFF Attachments :
As stated 10 CFR 2.730lofarmatha 2,,,ci p SGFF SGF t l
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