ML20211P268

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

ML20211P268
Person / Time
Site:	07001113
Issue date:	02/14/1985
From:	David Jones, Mcalpine E, Todd G 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 70-1113-85-01-0, 70-1113-85-1, NUDOCS 8612190029
Download: ML20211P268 (5)

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NUCLEAR REGULATORY COMMISSION REGION 11

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% , , , , , ** ATLANTA. GEORGIA 30323 Re: ort No. 70-1113/85-01 0::ket No. 70-1113 License No. SNM-1097 Safeguards Group No. III L':ensee: General Electric Company Wilmington, NC Da:e of Inspecti n: January 14 - 17, 1985 spectors: (d$6 w 3l/3 lVC D.V.Jfes, Statistician Date Signed mi /VfS$

A.,Tpdd A / ate' Signed A proved by: 1[N /2 S E. J. McAlpihe, Chief, Mhterial Control and Date Signed Accountability Section, Nuclear Materials Safety and Safeguards Branch, Division of Radiation Safety and Safeguards

SUMMARY

5: ope: This routine, unannounced inspection entailed 49 inspector-hours during r:rmal duty hours inspecting: facility operations and internal centrols; and f a:ility organization and management controls.

Results: One violation was identified - Failure to establish and follow a tamagement system which provides for review and approval of nuclear material l

c:ntrol and accounting procedures by the individual assigned the responsibility for the nuclear material control and accounting functions.

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REPORT DETAILS T N Re;or$ No., 70-1113/85-01 ,

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1. Key Persons Contacted n

• R. C. Hawk, Manager, Operational Planning

• G. R. Hallett, Senior Engineer, Measurements and Statistics

' *W. W. McMahon, Manager, Quality Assurance 4 *R. G. Patterson, Manager, Fuel Fabrication Operation

• H. Stern, Consulti,ng Engineer, Manufacturing Technology '

• C. M. Vaughn, Manager, Regulatory Compliance The inspectors also interviewed several other licensee employees.

" Denotes those present at the exit interview

2. Exit Interview The inspection scope iand findings were summarized on January 16, 1985, with those persons indicated in Paragraph 1 above. The following issue was discussed in detail with the Regulatory Compliance Manager on January 17, 1985. failure to, establish and follow a managemeni, rystem which provides for the review and approval of nuclear material contrci and accounting I procedures by the

• individual assigned the responsibility for the nuclear i material control and accounting functions (para. 5). The licensee acknowledged the inspection findings and took no exceptions.

1 i g 3. Licensee Action On Previous Enforcement Matters This subject was not addressed during this inspection.

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I 4. Facility Operations and Storage and Internal Controls (85205)

I t A review of the licensee's internal accountability and control system w&s

{ t s performed to determine operational compliance with applicable 10 CFR Part 70 l \ Regulations, the licensee's approved Fundamental Nuclear material Control i Plan and related procedures.

' The inspector evaluated the licensee's program for maintaining current knowledge of disi; rete items or containers of special nuclear material (SNM)

I and their associated records.

The licensee maintains and monitors their program to provide the current knowledge of item identities, quantities and locations within the plant utilizing an internally maintaineo cornputer system referred to as the l M, .. . . m. 1. .a ".I se . .* -

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'i To verify the accuracy of the he MICS data base s are audited by th a ly basis Th dit veri scation throu sical inventory o The audit i reports are documentec and distributed by Manu acturing ystem Operations personnel to responsible station area representatives. Summaries f h audits and their findin e di uted to plant management on basis coinciding with a racking system. -

The inspector reviewed the MICS audit repo maries for calendar year 1984. The overall facility accuracy was percent cumulative for calendar year 1984. A total of six repeat a indings were disclosed by the licMsee during the audit year. These items were identified to area managers and promptly corrected. An examination of the nature of these audit findings . and actions taken to correct them disclosed that the ,

identified items' locations had not been updated and in one case the items' gross weight was erroneously recorded by ten grams. The licensee updated the location designations for the identified items and clarified the I ght differences to reflect the l This guidance w - exclude or messeges on items with a weight descrepancy of less thar The corrective actions were deemed timely and appropriate and demonstratec the licensee's commitment to an effective program of material control and accountability.

The inspector verified that the licensee had established and maintained a

system for scrap control such that no item of scrap with a measurement uncertainty of greater than 210 percent remains on inventory longer than 12 months as specified in 10 CFR Part 70.58(i)(2).

The licensee implements his scrap control program through procedure number l w,140-2 entitled, "Special Nuclear Material Scrap Control." This 1 l procedure inco rates e assignment of responsibilities and methodology for thel f scrap m rials, the monitoring of scrap '

inventorL by and the eventual scheduling for '

processing or s pment o scrap an waste containers.  ;

l The licensee maintains a perpetual scrap inventory b n a computerized tabulation referenced as RO ntitled " Materia gn Report." This report is routinely examined by Fuel Manufacturing personnel to identify respective ages of scrap items and to schedule their necessary disposition within the specified time constraint. i The inspector obtained a copy of Report No. R018 dated Januar 1985, and examined the assigned scrap codes and ages of the total listed containers. It was determined through this examination that a 1 containers coded as having been measured with an uncertainty of greater than 110 percent were listed on the report and that no item of this type had exceeded the prescribed 12 month regulatory constraint.

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It should be noted that two items he li wer tified by the inspector as having an inventory However, an investigation by the licensee and Suosequently vert the inspector, i disclosed a data in error related to the fill date on th ource documentation. The It should be further noted that the materials categorized as incinerator ash were not a part of this review. The licensee had received an exemption from e the further processing of these materials until December 31, 1986. This exemption was dated December 31,1 4 fro he Office of Nuclear Materials Safety and Safeguards and involved of incinerator ash that could not be processed by the licensee's o site scrap recovery contractor. This exemption will allow the licensee to process these materials themselves through their soon to be on-line scrap recovery system (Uranium Process Management Project).

No violations or deviations were identified.

5. Facility Organization and Management Controls (85203) i The licensee's organization structure for nuclear material control and accounting was inspected. The licensee's corporate and plant management structure, as it relates to nuclear material control and accounting, is described in the licensee's Fundamental Nuclear Material Control Plan (FNMCP). The FNMCP includes an organization chart depicting the functional relationships between the various management groups. Narrative descriptions of the material control and accounting functions and their relationship to other organizational units are also included in the FNMCP. Functional responsibilities and position qualification requirements are documented in Position Guides snd Position Data Sheets which are maintained in personnel files. Tne facility organization is structured to provide a separation of j functions such that the activities of one individual or organizational unit serve as controls over and checks of the activities of other individuals or organizational units. The overall responsibility for the planning, coordinating, and administering the nuclear material control a unting functions and the measurement conte )rogram is vested in th The position appears e at an organizationa evel cou;ensurate wit 1 the position responsibilities and authorities. The delegations of this and other material control and accounting functional responsibilities and authorities are documented through a system of management policy guides, manuals and procedures.

The licensee's management system for nuclear material control was also inspected. The licensee has established a management system to provide for the development, revision, implementation, and enforcement of nuclear ,

material control and accounting procedures. The management system, as '

described in Chapter 8 of the licensee's FNMC Plan, is. implemented through ,

the licensee's procedure system entitled " Practices and Procedures" (P/P). l The system includes provisions for approval of the nuclear m erial control and accounti ce and vision thereto, by The P/Ps do not require the  ;

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individual with overall r sibility for the material control and accounting function, i.e. to approve nuclear material control and accounting pro cures in accordan:e with 10 CFR 70.5S(c)(1).

Compliance with the P/Ps would not assure nce wit Section 1.4 of the FNMC Plan which also specifies that th approves nuclear material control and accounting procedures and their res sions. Randomly selected procedures for weighing, sampling, destructively analyzing and nondestructively analyzing SNM were reviewed by the inspector for having been approved as required by P/P system. It was found that " Quality Control Operator Requirement" (QCOR) Number 3.1.1, Revisions 25 anc 26, which includes instructions for perf accountability scale calibration checks, had not been approved b s required by P/P No. 80-6, Rev. 6 (85-01-01). Other procedures rev wed during the inspection were found to have been approved in accordance with appropriate P/Ps.

The management system also provides for a review of the nuclear material control system at intervals not to exceed 24 months as specified by License Condition 8.1. The licensee indicated that the most recent audit had been oerformed on November 26 - 30, 1984, but as of the date of this inspection the results of the audit had not been reported to facility management. The documented results of the audit will be reviewed during a subsequent inspection (85-01-02).

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i ATLANT A, GEORGI A 3o323

% . .'.'. . **e SEP 23 985 General Electric Company ATTN: Mr. Eugene A. Lees, General Manager Nuclear Fuel Manufacturing Department P. O. Box 780 Wilmington, NC 28402 Gentlemen:

SUBJECT:

rep 0RT NO. 70-1113/85-14 On August 12-16, 1985, NRC inspected activities authorized by NRC License No. SNM-1097 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 enclosures to this letter, with the exception of the report cover page which presents a nonexempt summary, will not be placed in NRC's Public Document Room.

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

Sincerely, a-KubC  %

enneth P. Barr, Chief Nuclear Materials Safety and Safeguards Branch .

Division of Radiation Safety and Safeguards

Enclosure:

Inspection Report No. 70-1113/85-14 (Exempt from Disclosure) cc w/ encl:

l C. M. Vaughan, Manager Regulatory Compliance

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