ML20211M942

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Partially Withheld Response to Noncompliance Noted in Insp Rept 70-1113/86-09 (Ref 10CFR2.790(d)).Corrective Actions: Similiar Models Rechecked to Assure Correctness & Computation Model Revised
ML20211M942
Person / Time
Site: 07001113
Issue date: 07/01/1986
From: Winslow T
GENERAL ELECTRIC CO.
To: Barr K
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20211M455 List:
References
FOIA-86-704 NUDOCS 8612180087
Download: ML20211M942 (3)


Text

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GENERALh ELECTRIC NUCLEAR FUEL & COMPONENTS MANUFACTURING i

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GENEQA; ELECirbC COWANY

  • P o box 780. W1L%NG10N NOQTH CADOUNA 28402 July 1, 1986 S$

$3 Mr.

K.

P.

Barr, Chief 1

_q Nuclear Materials Safety & Safeguards Branch T,

Division of Radiation Safety and Safeguards 3

U. S. Nuclear Regulatory Commission, RII co

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P.O. Box 2203 h

Atlanta, Georgia 30301 cm

Dear Mr. Barr:

References:

(1) NRC License SNM-1097, Docket 70-1113 (2) NRC Inspection Report 70-1113/86-09 dated 6/5/86 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 April 28-May 2, 1986.

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.

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 item in your letter and in our related reply, if necessary, for further clarification of this item.

Pursuant to 10 CFR 2.90(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.

Very truly yours, GENERAL ELECTRIC COMPANY 8612180087 861205 NER

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T. Preston Winslow, Manager Licensing & Nuclear Materials Management M/C J88

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GENERAL h ELECTRIC N

Mr. Kenneth P. Barr July 1, 1986 Attachment - Page 1 ATTACHMENT The information given below refers to item 86-09-02 in Enclosure 1, " Notice of Violation", in the NRC Inspection Report 70-1113/86-09, dated 6/5/86.

10 CFR 70.51(a) and (e)(4)(i) require the licensee to calculate the limit of error, which is a 95 percent confidence interval, associated with the inventory dif ference for each material balance interval.

Contrary to the above, for the August 13, 1984 -

August 5, 1985 material balance interval, the limit of error associated with the uranium inventory difference was incorrectly calculated in that it was overstated by approximately 179 kilograms of uranium.

This is a Severity Level V violation (Supplement III).

General Electric admits the violation occurred.

The measurement system of concern is gravimetric analysis.

The method determines the oxygen to uranium (0/U) ratio in the sample which is subsequently converted to a uranium factor (grams uranium per gram sample) af ter taking into consideration the concentration of non-volatile metal oxide impurities.

The analytical results from the measurement of standards used to control the measurement system and to make estimates of the systematic error and bias are reported in units of O/U ratios.

The certified values of the standards are also listed as oxygen to uranium ratios since this serves as a mechanism of comparisons when measuring standards.

During the material nee eriod t In the process of th s conversion, the transformation of the a n ard's variance from O/U units to uranium factor units was inadvertently

GENERAL $ ELECTRIC f

m Mr. Kenneth P.

Barr July 1, 1986 Attachment Page 2 omitted.

This oversight resulted in an overstatement in the magnitude of the measurement system's systematic variance.

As a retiult of this violation, all similar models were rechecked to assure correctness a d ion model was rev' which will avoid further violations of this type for these variances in the future.

t The oxygen to uranium ratio conversion model is now in full compliance.

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%.....*j AUG 1 1986 Docket No. 70-1113 License No. SNM-1097 General Electric Company ATTN:

Mr. Eugene A. Lees, General Manager Nuclear Fuel and Component Manufacturing P. O. Box 780 Wilmington, NC 28402 Gentlemen:

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 70-1113/86-15)

This refers to the Nuclear Regulatory Com.ission (NRC) inspection conducted by S. Q. Ninh on July 14-18, 1986.

The inspection included a review of activities authorized for your General Electric Company facility. At the conclusion of the inspection, the' findings were discussed with those members of your staff!

identified in the enclosed inspection report.

Areas examined during the inspection are identified in the report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observation of activities in progress.

The inspection findings indicate that certain activities appeared to violate NRC requirements. The violation, references to pertinent requirements, and elements to be included in your response are described in the enclosed Notice of.

Violation.

Your attention is invited to an unresolved item identified in the inspection report.

These matters will be pursued during future inspections.

In accordance with 10 CFR 2.790(d) and 10 CFR 73.21, safeguards activities and security measures are exempt from public disclosure; therefore, the enclosure to this letter, with the exception of the report cover page which presents a nonexempt summary, will not be:placed in the NRC Public Document Room.

The responses directed by this letter and its enclosure are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511.

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AUG 1 1986 General Electric Company 2

Should you have any questions concerning this letter, please contact us.

Sincere y, J

Kenneth P. Barr, ief Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards

Enclosures:

1.

Notice of Violation (Exempt from Disclosure) 2.

NRC Inspection Report (Exempt from Disclosure) cc w/encis:

T. Preston Winslow, Manager Licensing and Nuclear Materials Management c

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