ML20211M856

Partially Withheld Insp Rept 70-1113/86-09 on 860428-0502 (Ref 10CFR2.790(d) & 73.21).Violation Noted:Failure to Correctly Calculate Limit of Error Associated W/Inventory Difference

ML20211M856
Person / Time
Site:	07001113
Issue date:	06/03/1986
From:	David Jones, Mcalpine E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211M455	List: IA-86-704, Partially Withheld Insp Rept 70-1113/85-01 on 850114-17 (Ref 10CFR2.790(d) & 73.21).Violation Noted:Failure to Establish Mgt Sys Which Provides for Review & Approval of Nuclear Matl Control & Accounting Procedures ML20211M449 ML20211M480 ML20211M498 ML20211M505 ML20211M521 ML20211M560 ML20211M571 ML20211M585 ML20211M593 ML20211M606 ML20211M722 ML20211M756 ML20211M791 ML20211M829 ML20211M856 ML20211M906 ML20211M942 ML20211M964 ML20211M984 ML20211N006 ML20211N043 ML20211N060 ML20211N869 ML20211P265 ML20211P268
References
FOIA-86-704 70-1113-86-09-0, 70-1113-86-9, NUDOCS 8612180066
Download: ML20211M856 (5)

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'.....# JUN 0 5 G86 c.e: ort No.: 70-1113/86-09 L':ensee: General Electric Company l Wilmington, NC 28401

ket No.: 70-1113 License No.: SNM-1097 Fa:ility Name: General Electric Company Iaspection Conducted: April 28 - May 2, 1986 l-spector: C '

- ou2 6/3 7 66-D. W. Jortes, Statistician Date Signed A: proved by: FD* h E. J. McAlpTne, Chief, %terial Control and 6/3/e 6 Date Signed Accountability Section, Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards

SUMMARY

S: ope: Areas examined curing this routine, unannounced inspection included licensee action on previous enforcement matters and inspector followup items, and r easurement control and statistics.

te sults: One violation was identified - Failure to correctly calculate the limit c' error associated with inventory dif ference.

8612180066 861205 PDR FOIA RATNERB6-704 PDR

REPORT DETAILS 1

Re;:rt No. 70-1113/86-09

1. Key Persons Contacted

'J. H. Bradberry, Acting Manager, Re;ulatory Compliance *

• B. S. Dunn, Specialist, Licensing Surport

• R. H. D. Foleck, Senior Specialist, Licensing Engineering

• G. R. Hallett, Acting Manager, L&NMM "G. W. McKenzie, Acting Manager, Technology and Automation

• G. R. Pearson, Acting Manager, Fuel Production

• W. C. Peters, Acting Manager, Fuel Manufacturing C. M. Vaughan, Manager, Regulatory Compliance The inspector also interviewed several other licensee employees.

• Denotes those present at exit interview.

2. Exit Interview The inspection scope and findings were summarized on May 2, 1986, with those persons indicated in paragraph 1 above. The following issues were discussed in detail: a violation - failure to correctly calculate the limit of error associated with inventory dif ference (paragraph 5) and an unresolved item"

- lack of detail in audit reports (paragraph 4). The licensee acknowledged the inspection findings and took no exceptions.

3. Licensee Action on Previous Enforcement Matters (92702)

(Closed) Violation (85-01-01) Failure to establish and maintain a management system which provides for review and approval of nuclear material control and accounting procedures by the individual with the overall responsibility for the nuclear material control and accounting functions. During the inspection conducted on January 14-17, 1985, it was found that the individual with the overall re bili for the nuclear material and accounti tions, i.e.

had delegat authority for procedure approva to s nate pe nnel.

During this inspection, it was found that the authorization for those -

subordinates to approve procedures had been rescinded via an internal memorandum dated July 8,1985. Three randomly selected procedures, which had been revised aftje the randum were examined and found tohavebeenapprpfdbyth "An unresolved item is a matter about which more information is required to determine whether it is acceptable or may involve a violation or deviation.

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4. Followup on Inspector Identified Items (92701)  ;

(Closed) Inspector Followup Item (85-01-02) Review of biennial nuclear material control system audit. During the inspection conducted on  :

January 14-17, 1985, the licensee indicated that the most recent audit had been performed during November 1984, but as of the date of that inspection the results of the audit had not been reported to the facility management.

During this inspection, the results .of that audit were reviewed. The results of the audit were documented in report number 58401 dated January 24, 1985. The audit was performed by individuals who were independent of the facility.

The results of the audit were reported to corporate and plant management and included recommendations for improvements. The management response to those recommendations appeared to be appropriate and timely. The report stated that the scope of the audit included all aspects of the nuclear material safeguards and physical protection system at the facility. However, it is a continuing concern of the NRC that the specific elements of the audit could not be discerned by a review of the audit report. Therefore the lack of detail in the audit report has been deemed an unresolved item pending review of this issue by the NRC Office of Nuclear Material Safety and Safeguards (86-09-01). The matter of NRC review of the 1984 audit report is closed.

5. Measurement Control and Statistics (85209)

The licensee's statistical program for the evaluation of the biases and uncertainties associated with special nuclear material control and accounting measurements was inspected. This inspection was a continuation of the inspection activities initiated during March 17-21, 1986 (reference Inspection Report 70-1113/86-06). The inspection consisted of an examination of the licensee's statistical methods used to evaluate measurement biases and uncertainties, and the databases used in those evaluations. The licensee's written procedure for performing the statistical calculations was reviewed during the previous insp6ction.

The performance of the program during the August 13, 1984 through August 5, 1985 material balance period was inspected. The program data for the following statistical parameters was inspected: the bias, systematic error l variance and randem error variance associated with full uranium hexafluoride cylinder weight measurements, elemental and isotopic analysis of uranium hexafluoride, elemental analysis of uranium dioxide pellets, and gamma spectrometric enrichment measurements.

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3 The strata selected for review and their relative contribution to the total

! variance of the U23' 10 are presented below.

Measurement Error -

% of Total i Strata Variance Component Variance (U23' 10)

LBBSY001 Systematic - UF. Cylinder Weight LBBMR001 Random - UF. Cylinder Weight LUUSY001 Systematic - UF. elemental analysis 1 l LUUMR001 Random - UF. elemental analysis  !

LEESY001 Systematic - UF. isotopic analysis LEEMR001 Random - UF. isotopic analysis i

GRUSY001 Systematic - U02 pellet elemental l

analysis GRUMR002 Random - U02 pellet elemental analysis i GRUSR002 Random - UO 2 pellet elemental sampling EAESY001 Systematic - Gamma Spectrometric isotope analysis l

EAEMR001 Random - Gamma Spectrometric isotope analysis EAESR008 Random - Gamma Spectrometric isotope sampling For these measurement systems the biases, systematic error variances and ,

' random weighting error variances were determined from measurements of  ;

standards. The random sampling and analytical error variances were determined from replicate measurements of process materials. The databases were sufficient for obtaining the parameter estimates. Appropriate mathematical models of the error structures were used to evaluate the databases in order to obtain the error variance estimates except for the systematic analytical error variances associated with the elemental and isotopic analyses of uranium hexafluoride. The systematic error variance should include the variance associated with the mean of the measurements of standards performed during the material balance period plus the variance '

associated with the uncertainty in the assigned value of the ndard used to control the measurement system. The licensee included the ather than the variance a soc ated with the mean of the measurements tandards. The licensee indicated that it l-L _ __

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is their policy to use the' hen the bias is o statistically significant at the con 3 e level. This appears to be inconsistent with regulato j policy and will be further investigated (86-09-M)f

• The systematic analytical error variance associated with the elemental analysis of uranium dioxide pellets (strata GRUSY001) was found to have been incorrectly calculated.

The systematic error variance consists of the measurement system variance

, determined from measurements of standards plus the variance associated with the uncertainty in the assigned value of the standard.

For this measurement system, the laboratories analytical results of measurements of standards are reported in units of oxygen to uranium ratio 4

(0/U) but those results must be converted to units of grams uranium per gram (or U-factor in the licensee's nomenclature) for SNM accounting purposes.

The variance associated with the standards measurements was converted from 0/0 units to U-factor units but the variance associated with the assigned value of the standard was not converted. This resulted in the limit of error associated with the uranium inventor difference reported for subject material balance period being overstated by approximate 1 kilograms of uranium (86-09-02). -

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JUN 17 $66 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:

SUELJECT: NRC INSPECTION REPORT NO. 70-1113/86-11 This refers to the Nuclear Regulatory Commission (NRC) inspection' conducted by J. W. Bates on June 2-6, 1986. The inspection included a review of activities authorized for your Wilmington 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.

Within the scope of the inspection, no violations or deviations were identified.

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.

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

Sincerely, v

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

Enclosure:

(See page 2)

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General Electric Company 2

Enclosure:

NRC Inspection Report l

(Safeguards Information) cc w/ enc 1:

T. Preston Winslow, Manager Licensing and Nuclear Materials Management 1

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