IR 05000930/2010004: Difference between revisions

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{{Adams
{{Adams
| number = ML20151N626
| number = ML20198J075
| issue date = 12/24/1985
| issue date = 11/25/1985
| title = Notice of Violation from Insp on 850930-1004
| title = Matl Control & Accounting Insp Rept 70-0371/85-14 on 850930-1004.No Noncompliance Noted.Major Areas Inspected: Measurement Control & Statistics
| author name =  
| author name = Jones D, Keimig R
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =  
| addressee name =  
| addressee affiliation =  
| addressee affiliation =  
| docket = 05000298
| docket = 07000371
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-298-85-26, NUDOCS 8601030036
| document report number = 70-0371-85-14, 70-371-85-14, NUDOCS 8605300650
| package number = ML20151N623
| package number = ML20198J068
| document type = NOTICE OF VIOLATION OF A REGULATION, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = INSPECTION REPORT, MANUFACTURER/VENDOR/ENGINEER, INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 2
| page count = 4
}}
}}


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=Text=
=Text=
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  .
  .
APPENDIX A
'
  .     NOTICE OF VIOLATION L
- s.n usce,  W TEDSTATES o,  NUCLEAR REGULATORY COMMISSION
'
#"  'd Ri!GtCN IQ j*
Nebraska-Public Power District    Docket: 50-298/85-26 j Cooper Nuclear Station    License: DPR-46
  *
M. ,
  'r 101 M AplETTA STREE'f, NW, ATLANTA, GEORGI A N*C3
  #
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: Report No.: 7C 371/85-14      ,
Docket No.: 70-371      i
,
License No.: 5NM-368
'
SAFEGUARDS GROUP: 1      ;
        ,
  ,
Licensee UNC Naval Products i
Division of UNC Resources. In ,
67 Sandy Desert Road Uncasville, Cor.necticut 06382 Facility Name: UNC Naval Products      '
Inspection At: Uncasville, CT
.
.
  ~
  '
; During an NRC inspection con'ucted d  on September 30 through October 4, 1985, -
I Inspection Conducted: September 30 - October 4, 1985   ,
i three violations of NRC requirements were identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR
!
Date of Last Material Control and Account 1 reg Inspection: June .10-14, 1935
        #
Inspector:      $S
,
D. Jones [iRegion[istician
_
    '
    .
    /) 7htzu _ /d/
Date Signed'
Approved by:
R. dl. Keimig,
_ief, fn :I" eguards
__ Section,. _ _
      // g@M Date Signed
,  Division of tation afety and Safeguards  '
        .
Inspection Summary: Routine, Announced Material Control and Accountino Inspection on September 30 - October 4,1985, Repo'ri.[Nofl70-D1/85!14).
 
Areas Inspected: Measurement control and stat.istics. The inspection involved 32 inspector hours by one NRC inspecto i Results: The licensee was in compliance in the areas exanir:ed during thic
,
inspection.


-
,         i
  . Part 2, Appendix C (1985), the violations are listed below:
        <
;
.
, Waste Gas Radioactivity Monitor Calibrations
l
~
}
Environmental Technical Specification 3.4.3.a.8 requires that "All waste
{  . gas monitors shall be calibrated at least quarterly by means of a known
:  radioactive source."


i-        '
l
i Contrary to the above:
.         \
'
l
The following gaseous radiation monitors were not calibrated on a    ,
-
. quarterly frequency:
[ Radwaste building ventilation monitor was not calibrated with a known radioactive source between the period January 7 through
!  ~ July 10, 1985.


j The elevated release point (ERP) ventilation monitor was not
'
;  calibrated with a known radioactive source between the periods i  February 22 through July 26, 1984, and January 8 through July 9, 198 . Turbine building ventilation monitor was not calibrated with a known
l
.
radioactive source between the period May 4 through October 16, 198 :- Reactor building ventilation monitor (primary containment) was not-calibrated with a known radioactive source in 1984 prior to
,
July 27, 1984, and between th'e period October 17, 1984, through    i April 9, 198 '


       , The ERP-GE "A"-and "B"' monitors'were not calibrated wit'h.a known radioactive source between1the period October 3, 1984,'through
8605300650 851202 PDR      l ADOCK 07000371      :
}  March 18, 1985.
C  PDR    l l
       ._. _ _ . . . .- !


! Steam jet air ejector radiation monitor was not calibrated with a known radioactive source between the period August 28, 1984, through July 23, 198 . The control room ventilation monitors RMV-1A, 1B, and 1C were not calibrated with a known radioactive source between the period
. . . - .    - . . __ _ _ _ _ _ _ _ _ _ _
:
.-
November 29, 1984, through March 25, 198 This is a Severity Level IV violation (Supplement IV)(298/8526-01).
.
REPORT DETAILS
:
, Persons Contacted
'
Licensee Employees
*T. Collopy, Manager, Nuclear Material Control
*N. Grenon, Supervisor, Nuclear Material Control
* Kelly, Statistical Specialist The inspector also interviewed other licensee personnel involved in the control and accounting of special nuclear material (SNM) and chemistr * Attended exit interview Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on October 4,1985, and summarized the scope and findings of the inspection. At no time during this inspection was written material provided to the licensee by the inspecto . Followup on Inspector Identified Items and Unresolved Items (92701)
(Closed) Inspector Followup Item (85-08-01): Procedures not numbered or date During the inspection conducted on June 10-14, 1985 it was found that the licensee's written statistical procedures were not numbered or dated. During this inspection the procedures were reviewed and found to have been assigned numbers and dated. This item is close (0 pen) Inspector Followup Item (85-08-02): Data base for fuel vendors measurement uncertainties. As was indicated in inspection report 70-371/85-08, the licensee books his fuel vendor's measured valves for fuel receipts and therefore uses the fuel vendors measurement uncertainties in limit of error calculations. However, the uncertainties supplied to the licensee by the vendor were determined from data generated over three material balance periods rather than from one period. The vendor has agreed to supply the licensee with uncertainties determined from data generated during a single material balance period. The licensee indicated that as of the date of this inspection, no fuel, and, therefore, no error data had 'been received since the June 10-14, 1985 inspection. This item will remain open pending inspection of the error data supplied for the next fuel receip (0 pen) Inspector Followup Item (85-08-03): Updating of volume measurement uncertainties. During the inspection on June 10-14, 1985 it was noted that the licensee's FNMC Plan contained no commitment to update the error estimates associated with the volume measurements used to account for the SNM contained in element sections. NMSS has been requested to review this
        ,
matter. This item will remain open pending resolution by NMS l
    -
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!
B601030036 851224 PDR ADOCK 05000298 0  pm i
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  '
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        . . _ _ _ _ - _ - - _
          -


  .
  (Closed) Unresolved Item (85-08-04): Calculation of systematic error associ-ated with NDA measurements. During the inspection conducted on June 10-14, 1985, an attempt was made to verify the licensee's computer program used for calculating the systematic error associated with NDA measurements. The licensee was requested to enter the data from an example contained in a reference text. Since the results obtained by the licensee did not totally agree with the results delineated in the reference text, this issue was deemed unresolved pending demonstration by the licensee that appropriate statistical methods were being used. The licensee's followup actions were reviewed during this inspectio Further inspection revealed that the licensee's routine method of determining NDA systematic errors consisted of two phases. A regression analysis was first performed on the NDA systems measur: ment control data to obtain intermediite results. The intermediate results were then input to a computer to obtain the error estimate Documentation was reviewed which demonstrated that when the appropriate intermediate results, obtained by a regression analysis of the example raw data, were entered into the computer, the correct error estimates were produced. This item is close . Measurement Control and Statistics (85209) The licensee's calculations of the inventory difference (ID) and its associated limit of error (LEID) for the May 17 - July 19, 1985 material balance period were inspected. The inspection consisted of an audit of the material balance summary, a review of the written proce-dures for calculating the LEID, a review of the mathematical model of the LEID, and an examination of the coefficients used in the model to propagate measurement errors through the material balance statemen The material quantities of beginning inventory, receipts, shipments, ending inventory and their adjustments, as reported in the material balance summary, were compared to the licensee's official accounta-bility records and were substantiate The reported quantities of additions to material in process and removals from material in process appeared to have been overstated by approximately 13 %. This issue has been deemed an inspector followup item (85-14-01) and will remain open until an agreement is reached among the licensee, Region I and NMSS on the optimum method for computing these quantitie A review of the licensee's written procedure revealed that it contained a narrative description of the statistical calculation rather than the mathematical model and the equations used for calculating the LEI However, the actual calculations were being performed by use of a compute The licensee's calculations of the coefficients, i.e., the material quantities, used to propagate the measurement errors associated with fuel receipts, feed material, charges, sectioned elements and sludge were examined. The coefficient used for propagating the weighing error associated with fuel receipts was found to have been overstated by
, .
 
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= _  . . . . . .-_  . ., .. - ..- -  ..
. ,   2
          ,
.
          ,
Y Maintenance and Test Procedure Compliance
>
.
Technical Specification 6.3.3 requires that maintenance and test procedures be provided to satisfy routine inspection, preventative maintenance programs, and operating license requirements. Station instrument and control (I&C) Procedure 7.5.2.6, Section VI.C requires that health physics be contacted prior to performing work in the Traversing Incore Probe (TIP) enclosur Contrary to the above, on. August 28, 1985, two individuals from the I&C
  ,
  ,
department' entered the TIP enclosure to perform work without contacting health physic This is a Severity Level IV violation (Supplement IV)(298/8526-02). Radiation Protection Procedure Compliance Technical Specification 6.3.4 requires that radiation control procedures
  *          .
  >
  -
be maintained consistent with the requirements of 10 CFR Part 20. Statio Health Physics Procedure 9.1.1.4 requires a raecial work permit for all jobs which may involve work in the presence of high radiation, in areas in which high levels of radioactive contamination exists, in areas of hazardous airborne radioactivity concentrations, or work involving industrial safety hazard Contrary to the above, on August 28, 1985, two individuals entered the TIP enclosure and performrd work in a.high radiation area and in high airborne radioactivity concentrations without the issuance of~a special work permi This is a Severity Level IV violation (Supplement IV)(298/8526-03).
.           ,
. .
          '
i


Pursuant to the provisions of 10 CFR 2.201, Nebraska Public Power District is hereby required to submit to this office within 30 days of the date of the .
          *
letter-transmitting this Notice, a written statement or explanation in reply, including for each violation: (1) the reason for the violations if admitted, (2) the corrective steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and
i
  -
          ,
  (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
          ,
approximately 27 kgs. (U). The coefficient used for propagating the    -
weighing error associated with the charge scale was overstated by    !
approximately 62 kgs. (U). The coefficient used for propagating the    '
weighing error associated with the fuel material scafie was goderstated    '
. by approximately 62 kgs. (U). In that the coefficients were overstated    .
for one of the scales and understated for another scale by a sfnitar    ,
4  amount, and given that the magnitudes of the weighing errors are
,  minimal, these discrepancies would have had a negligible impact on the     .
reported LEI Therefore this matter has been deemed .an inspector    '
followup item (85-14-02).        .
J The licensee's statistical control program for monf,toring the quality    .
:  of special nuclear material control and accounting measurements was
!
"
also inspected. The inspection consisted of an eraninstion of the .
          '
licensee's written procedure for establishing .and maintaining control    ,
          '
charts, the data base used to determine control chart 11mits, and the
; statistical methods applied in the evaluation af the data base, The performance of the program during the period July-Aagust, 1995, was
,
inspected. The program data used to monitor the quality of the     i following types of measurements were f r/Spected: uranium cor. centration    ,
and enrichment measurements cf fuel material .and nondestructive assay    '
of sludge.


A review of the li;censee's written procedure for calculating control    ,
chart limits reveale:: that it contained parrative descriptions of the statistical calculations eather than the mathematical models and the equations used for evaluating the statistical parameters. .The mathe-
  'matical expressians of the control chart limf ts were delineated in
          ,
          .
section 4.5.1 of the FNMC Plan. For those systems inspected, the    ~!
calculations of the control chart limits for the period under review-    i were verified to be accurate and in accordance with the FNMC Plan. The data base used in those ca~1culations hi.d al so been generated in accordance with the FNMC Pla It was,however, noted that the licensee had not submitted a revision to his FRMC Plan to incorporate NMSS policy regarding response to indications that a measurentent system is    !
out of contro The licensee indicated that a revision to the plan    ;
incorporating the necessary changes would be s'ubmitted to the Region'I office no later than February 1,1986. This matter has been deemed an inspector followup item (85 .14-03)
          ;
          ~
,
,
Dated at Arlington, Texas, this 24th day of December , 198 s
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      .
,          .
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}}
}}

Latest revision as of 12:39, 21 November 2020

Matl Control & Accounting Insp Rept 70-0371/85-14 on 850930-1004.No Noncompliance Noted.Major Areas Inspected: Measurement Control & Statistics
ML20198J075
Person / Time
Site: 07000371, 05000930
Issue date: 11/25/1985
From: David Jones, Keimig R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198J068 List:
References
70-0371-85-14, 70-371-85-14, NUDOCS 8605300650
Download: ML20198J075 (4)


Text

_ _ .. . .. . . .

. _ , . , ,_

.

'

- s.n usce, W TEDSTATES o, NUCLEAR REGULATORY COMMISSION

  1. " 'd Ri!GtCN IQ j*

M. ,

'r 101 M AplETTA STREE'f, NW, ATLANTA, GEORGI A N*C3

ef .M....$ ,

l i

Report No.: 7C 371/85-14 ,

Docket No.: 70-371 i

,

License No.: 5NM-368

'

SAFEGUARDS GROUP: 1  ;

,

,

Licensee UNC Naval Products i

Division of UNC Resources. In ,

67 Sandy Desert Road Uncasville, Cor.necticut 06382 Facility Name: UNC Naval Products '

Inspection At: Uncasville, CT

.

'

I Inspection Conducted: September 30 - October 4, 1985 ,

!

Date of Last Material Control and Account 1 reg Inspection: June .10-14, 1935

Inspector: $S

,

D. Jones [iRegion[istician

_

'

.

/) 7htzu _ /d/

Date Signed'

Approved by:

R. dl. Keimig,

_ief, fn :I" eguards

__ Section,. _ _

// g@M Date Signed

, Division of tation afety and Safeguards '

.

Inspection Summary: Routine, Announced Material Control and Accountino Inspection on September 30 - October 4,1985, Repo'ri.[Nofl70-D1/85!14).

Areas Inspected: Measurement control and stat.istics. The inspection involved 32 inspector hours by one NRC inspecto i Results: The licensee was in compliance in the areas exanir:ed during thic

,

inspection.

, i

<

.

l

l

. \

l

-

'

l

8605300650 851202 PDR l ADOCK 07000371  :

C PDR l l

._. _ _ . . . .- !

. . . - . - . . __ _ _ _ _ _ _ _ _ _ _

.-

.

REPORT DETAILS

, Persons Contacted

'

Licensee Employees

  • T. Collopy, Manager, Nuclear Material Control
  • N. Grenon, Supervisor, Nuclear Material Control
  • Kelly, Statistical Specialist The inspector also interviewed other licensee personnel involved in the control and accounting of special nuclear material (SNM) and chemistr * Attended exit interview Exit Interview The inspector met with the licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on October 4,1985, and summarized the scope and findings of the inspection. At no time during this inspection was written material provided to the licensee by the inspecto . Followup on Inspector Identified Items and Unresolved Items (92701)

(Closed) Inspector Followup Item (85-08-01): Procedures not numbered or date During the inspection conducted on June 10-14, 1985 it was found that the licensee's written statistical procedures were not numbered or dated. During this inspection the procedures were reviewed and found to have been assigned numbers and dated. This item is close (0 pen) Inspector Followup Item (85-08-02): Data base for fuel vendors measurement uncertainties. As was indicated in inspection report 70-371/85-08, the licensee books his fuel vendor's measured valves for fuel receipts and therefore uses the fuel vendors measurement uncertainties in limit of error calculations. However, the uncertainties supplied to the licensee by the vendor were determined from data generated over three material balance periods rather than from one period. The vendor has agreed to supply the licensee with uncertainties determined from data generated during a single material balance period. The licensee indicated that as of the date of this inspection, no fuel, and, therefore, no error data had 'been received since the June 10-14, 1985 inspection. This item will remain open pending inspection of the error data supplied for the next fuel receip (0 pen) Inspector Followup Item (85-08-03): Updating of volume measurement uncertainties. During the inspection on June 10-14, 1985 it was noted that the licensee's FNMC Plan contained no commitment to update the error estimates associated with the volume measurements used to account for the SNM contained in element sections. NMSS has been requested to review this

,

matter. This item will remain open pending resolution by NMS l

-

l l

t

, , , -- - - , , . , . . - .-.

'

...

(Closed) Unresolved Item (85-08-04): Calculation of systematic error associ-ated with NDA measurements. During the inspection conducted on June 10-14, 1985, an attempt was made to verify the licensee's computer program used for calculating the systematic error associated with NDA measurements. The licensee was requested to enter the data from an example contained in a reference text. Since the results obtained by the licensee did not totally agree with the results delineated in the reference text, this issue was deemed unresolved pending demonstration by the licensee that appropriate statistical methods were being used. The licensee's followup actions were reviewed during this inspectio Further inspection revealed that the licensee's routine method of determining NDA systematic errors consisted of two phases. A regression analysis was first performed on the NDA systems measur: ment control data to obtain intermediite results. The intermediate results were then input to a computer to obtain the error estimate Documentation was reviewed which demonstrated that when the appropriate intermediate results, obtained by a regression analysis of the example raw data, were entered into the computer, the correct error estimates were produced. This item is close . Measurement Control and Statistics (85209) The licensee's calculations of the inventory difference (ID) and its associated limit of error (LEID) for the May 17 - July 19, 1985 material balance period were inspected. The inspection consisted of an audit of the material balance summary, a review of the written proce-dures for calculating the LEID, a review of the mathematical model of the LEID, and an examination of the coefficients used in the model to propagate measurement errors through the material balance statemen The material quantities of beginning inventory, receipts, shipments, ending inventory and their adjustments, as reported in the material balance summary, were compared to the licensee's official accounta-bility records and were substantiate The reported quantities of additions to material in process and removals from material in process appeared to have been overstated by approximately 13 %. This issue has been deemed an inspector followup item (85-14-01) and will remain open until an agreement is reached among the licensee, Region I and NMSS on the optimum method for computing these quantitie A review of the licensee's written procedure revealed that it contained a narrative description of the statistical calculation rather than the mathematical model and the equations used for calculating the LEI However, the actual calculations were being performed by use of a compute The licensee's calculations of the coefficients, i.e., the material quantities, used to propagate the measurement errors associated with fuel receipts, feed material, charges, sectioned elements and sludge were examined. The coefficient used for propagating the weighing error associated with fuel receipts was found to have been overstated by

= _ . . . . . .-_ . ., .. - ..- - ..

,

,

>

,

  • .

-

. ,

. .

'

i

i

,

,

approximately 27 kgs. (U). The coefficient used for propagating the -

weighing error associated with the charge scale was overstated by  !

approximately 62 kgs. (U). The coefficient used for propagating the '

weighing error associated with the fuel material scafie was goderstated '

. by approximately 62 kgs. (U). In that the coefficients were overstated .

for one of the scales and understated for another scale by a sfnitar ,

4 amount, and given that the magnitudes of the weighing errors are

, minimal, these discrepancies would have had a negligible impact on the .

reported LEI Therefore this matter has been deemed .an inspector '

followup item (85-14-02). .

J The licensee's statistical control program for monf,toring the quality .

of special nuclear material control and accounting measurements was

!

"

also inspected. The inspection consisted of an eraninstion of the .

'

licensee's written procedure for establishing .and maintaining control ,

'

charts, the data base used to determine control chart 11mits, and the

statistical methods applied in the evaluation af the data base, The performance of the program during the period July-Aagust, 1995, was

,

inspected. The program data used to monitor the quality of the i following types of measurements were f r/Spected: uranium cor. centration ,

and enrichment measurements cf fuel material .and nondestructive assay '

of sludge.

A review of the li;censee's written procedure for calculating control ,

chart limits reveale:: that it contained parrative descriptions of the statistical calculations eather than the mathematical models and the equations used for evaluating the statistical parameters. .The mathe-

'matical expressians of the control chart limf ts were delineated in

,

.

section 4.5.1 of the FNMC Plan. For those systems inspected, the ~!

calculations of the control chart limits for the period under review- i were verified to be accurate and in accordance with the FNMC Plan. The data base used in those ca~1culations hi.d al so been generated in accordance with the FNMC Pla It was,however, noted that the licensee had not submitted a revision to his FRMC Plan to incorporate NMSS policy regarding response to indications that a measurentent system is  !

out of contro The licensee indicated that a revision to the plan  ;

incorporating the necessary changes would be s'ubmitted to the Region'I office no later than February 1,1986. This matter has been deemed an inspector followup item (85 .14-03)

~

,

t J

, .

J-1

. _ . . - , , , . - - . . _ _-,,,_-,-.. _ , , , . . . . - . . . . , , . . _ . , , , . . , _ . . - , . - . ,