05000293/LER-1997-001, :on 970120,very Small Quantity of Unaccountable Special Nuclear Material Was Identifed Due to Less than Effective Methods for Control & Accounting of Devices. Procedures Revised

:on 970120,very Small Quantity of Unaccountable Special Nuclear Material Was Identifed Due to Less than Effective Methods for Control & Accounting of Devices. Procedures Revised

ML20134P939
Person / Time
Site:	Pilgrim
Issue date:	02/14/1997
From:	Boulette E, Ellis D BOSTON EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BECO-2.97.018, LER-97-001, LER-97-1, NUDOCS 9702260176
Download: ML20134P939 (8)

LER-1997-001, on 970120,very Small Quantity of Unaccountable Special Nuclear Material Was Identifed Due to Less than Effective Methods for Control & Accounting of Devices. Procedures Revised

Event date:
Report date:
2931997001R00 - NRC Website

text

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i 10 CFR 20.2201 4

,e so.um an.an Pilgrim Nuclear Power Staten Rocky Hill Rosd Plymouth, Massachusetts 02360 February 14, 1997 BECo Ltr. #2.97,018 j

E. T. Boulette, PhD Senior Vice President - Nuclear l

U.S. Nuclear Regulatory Commission Attn: Document Control Desk i

i Washington, D.C. 20555 1

).

Docket No. 50-293 License No. DPR-35 The enclosed Licensee Event Report (LER) 97-001-00, "Very Small Quantity of Unaccountable j

Special Nuclear Material,"is submitted in accordance with 10 CFR Part 20.2201.

This report contains no commitments.

Please do not hesitate to contact me if there are any questions regarding this report.

1 i

T, j

. T. Boulette, PhD.

DWE/dmc/9700100 cc:

Mr. Hubert J. Miller Regional Administrator, Region I i

. U.S. Nuclear Regulatory Commission i

475 Allendale Road l

King of Prussia, PA 19406 I

Sr. NRC Resident inspector - Pilgrim Station i

Standard BECo LER Distribution l

a I

9702260176 970214 n

C PDR ADOCK 05000293 S

4 PDR i

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NRC Form 386 U.S. NUCLEAR REGULATORY COMMISSION APPROVED BY OMB No. 31A194

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4 (4-e5)-

EXPIRES waties t

[

i

- LICENSEE EVENT REPORT (LER)

ES M ATE SURDEN PER RESPONSE TO COMPLY WITH THIS i

INFORMATION COLLECTION REQUEST: 50.0 HRS. REPORTED

'3 j

s LESSONS LEARNED ARE INCORPORATED INTO THE i

(See reverse for number of UCENSING PROCESS AND FED BACK TO INDUSTRY.

digits / characters for each block)

FORWARD COhadENTS REGARDING BURDEN ESTIMATE TO j

THE INFORMATION AND RECORDS MANAGEENT BRANCH (T-6 F33),

U.S.

NUCLEAR REGULATORY COhASSSION, f

i WASHINGTON, DC 20565-0001, AND TO THE PAPERWORK REDUCTION PROJECT (3150 0104) OFFICE OF MANAGEMNT l

AND SUDGET, WASHINGTON, DC 20503.

FACSJTY NAME (1)

DOCKET NUMBER (2)

PAGE(3).

f PILGRIM NUCLEAR POWER STATION

' 05000-293 Tm.E is)

Vzry Small Quantity of Unaccountable Special Nuclear Material l

[

EVENT DATE (5)

LER NUMSER (S)

REPORT DATE m oTHER FACIUTIES INVOLVED (B)

MONTH DAY

' YEAR

~ YEAR' R

MONTH DAY YEAR N/A 1^

FACluTV NAME DOCKET NUMBER j

01 20 97 97 001 00 02 14 97.

N/A OMM i

OPERATING TIGS REPORT IS SUBMITTED PURSUANT TO TDE REQUWtEMENTS OF 1S CFR: (Check one or more) (11) j MODE 19)

N x

20.2201 (b) 20.2203(sM2)(v) 50.73(a)(2MI) 50.73(aM2)(vHi)

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POWER 22.2203(aM1) 20.2203(a)(3MI) 50.73(a)(2Mii) 50.73(aM2Mx) f.'

LEVEL (10) 97 20.2203(aM2MI) 20.m M3Mii) 50.73(aM2)(Ni) 73.71 l

e 20.2203 tam 2MN) 20.2203(aM4) 50.73(aM2Miv) oTHER l

l 20.2205aM2 MIN) 50.36(c)(1) 50.73(aM2)(v)

Specify in Abelrect below i

20.2203(sM2Xiv) 50.36(cM2) 50.73(a)(2Mvti) or in NRC Form 3sSA LICENSEE CONTACT FOR THIS LER (12)

.[

NAME TELEPHONE NUMBER (include Area Code)

I (508) 830-8160 l

Douglas W. Ellis - Regulatory Affairs Principal Engineer COMPLETE ODE LINE FOR EACH COMPOfENT FAILURE DESCRSED pl THIS REPORT (13)

REPORTA8LE TO REPO9 TABLE TO I

CAUSE

SYSTEM COhPONENT MANUFACTURER NPRDS

CAUSE

SYSTEM COhPONENT MANUFACTURER N8RDS l

l i

SUPPLEMENTAL REPORT EXPECTED (14)

EXPECTED MONTH lDW YEAR

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YES X

NO SUBMISSION l

(if yes, compiste EXPECTED SUBh4SSION DATE)

DATE(15) l' ABSTRACT (umn to 1400 spaces Le., appr_

15 n.-_

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On JInuary 20,1997, the NRC Operations Center was notified that a very small quantity of special nuclear

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mitIrlal (SNM) contained in sealed devices could not be accounted for. The discovery was the result of l,

reconciling a 1996 baseline inventory of portable devices containing SNM.

i L

Tha most probable cause was less than effective methods for control and accounting of devices containing less i

thin one gram of SNM in the 1975 - 1987 time frame. The previous (1987) baseline inventory of portable d: vices containing SNM relied on a review of documentation for items located in the spent fuel pool or installed '

L in tha reactor, and piece counts of portable devices located in other plant areas. The method used for the 1996 bis line inventory was a piece part count of portable devices containing SNM including the devices in the spent t

full pool.

i Corrective actions taken in 1987 included revision of the procedure goveming the control and accounting of SNM to include devices containing less than one gram of SNM. Corrective actions taken in 1996 included rsvision of the procedure govemirig the control and accounting of SNM including the transfer of SNM, revision of j

mIintenance procedures that involve SNM, training on SNM, and the establishment of a new baseline inventory i-of portable devices containing SNM.

I Tha devices containing the SNM that could not be accounted for were most probably shipped to a licensed disposal facility and pose or posed no threat to national defense or public health and safety.

. NRC FORM 308 (45) m.,

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_, ~

NRC Form.3(4A.

U.S. NUCLEAR REOULATORY COMMISSION (4-95)

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

SEoUENTIAL REVISloN YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATION 05000-293 2 of 7 97 001 00 TEXT (if more space is required, use additional copies of NRC Form 366A) (17)

BACKGROUND Special nuclear material (SNM) is defined in 10 CFR 70.4 as, "(1) plutonium, uranium 233, uranium enriched in th2 isotope 233 or in the isotope 235, and any other material which the Commission, pursuant to the provisions of section 51 of the act, determines to be special nuclear material, but does not include source material; or (2) cny material artificially enriched by any of the foregoing but does not include source material..."

At Pilgrim Station, the isotope uranium 235 (U-235) is contained in reactor fuel (fuel pins) and in sealed devices utiliz:d for the detection of neutrons. The neutron monitoring system source range monitors (SRMs),

int:rmediate range monitors (IRMs), and local power range monitors (LPRMs) utilize sealed detectors containing U-235. The circuitry associated with the SRMs, IRMs, and LPRMs provide trip functions to the reactor manual control system and reactor protection system during reactor startup, reactor power operation, reactor shut down, cnd refueling operations. Fuel loading chambers (FLCs) also contain sealed U-235 and function to detect n utrons during reactor fuelloading operations. The traversing incore probes (TIPS) also contain sealed U-235 and function to detect neutrons, and are used for calibration of the LPRMs. Installed or spent reactor fuel, instilled devices (SRMs, IRMs, LPRMs, and TIPS), and devices stored in the spent fuel pool are considered iniccessible.

In e I:tter submitted to the NRC on July 21,1995, Boston Edison Company replied to a notice of violation (VIO 95-09-03) pertaining to portable devices containing SNM. In summary, six IRMs, one SRM, and one FLC were discovered misplaced in the March - April 1995 time frame, coinciding with the beginning of the 1995 refueling outage (RFO-10). The misplaced SRM, IRMs, and FLC were subsequently located in the controlled, contzminated material stream. The letter contair.ed several corrective actions including a commitment to conduct a physical inventory of portable devices containing SNM located in the spent fuel pool in order to est:blish a new SNM inventory baseline. The nevi baseline would supersede the previous baseline of SNM cst blished in 1987.

Tha definition of physical inventory is provided in 10 CFR 70.51 subpart (a)(8): "Physicalinventory means d:t:rmination on a measured basis of the quantity of special nuclear material on hand at any given time. The m ;thods of physical inventory and associated measurements will vary depending on the material to be inv:ntoried and the process involved."

Th2 definition of material balance is provided in 10 CFR 70.51 subpart (a)(6): " Material balance means a ditirmination of material unaccounted for (MUF) by subtracting ending inventory (EI) plus removals (R) from beginning inventory (BI) plus additions to inventory (A). Mathematically, MUF = BI + A - El-R."

NRC Form.386A U.S. NUCLEAR RE2ULATORY COMMISSION W85)

I i

LICENSEE EVENT REPORT (LER)

}

TEXT CONTINUATION FACRJTY NAME (1) oOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISloN j

YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATION 05030-293 3 of 7 l

97

@1 TEXT (if more space is required, use addetsonal copies of NRc Form 386A)(17) b Th3 physical inventory of portable devices containing SNM in the spent fuel pool was completed on Junn 30,1996. The method used for the inventory was visual verification (piece count) and segregation from l

i othsr materials into one of four discrete storage locations. Once identified as an item or device containing SNM, l

th3 item was added to inventory and moved under the controls of procedure 4.0, "SNM Inventory and Transfer i

Control," and material balance transfer forms. The completed material balance transfer forms provided the formil documentation for each item included in the inventory. After the inventory, a reconciliation was made of tha portable devices containing SNM inventoried in 1996 to the SNM inventory baseline established in 1987 and subsequent movements of devices containing SNM prior to the 1996 physicalinventory. The 1987 baseline invIntory was reconfirmed as part of the reconciliation. The results of the physicalinventory of SNM and reconciliation were documented in a memorandum dated December 30,1996. The memorandum (OSD 96-135) concluded that the inventory could not account for 18 devices (14 SRMs/lRMs and 4 TIPS). SRMs and IRMs are

]

id:ntical in appearance and, therefore, no distinction between an SRM and an IRM was made for purposes of J

j tha 1996 inventory.

Th3 chemical and physical forms of SRMs and IRMs are as follows. SRMs and IRMs are similar. Each contains U-235 enriched to greater than 90 percent, sealed in a circular fission chamber having a lustrous sheen, dark j

brown to black in color, approximately two inches in length and approximately three-eighths inch in diameter.

Tha sealed fission chamber is integral to a metallic, sheathed cable having a woven appearance and gray in color. Each sealed SRM fission chamber typically contains approximately 0.003 grams of U-235. Each sealed i

IRM fission chambar typically contains approximately 0.001 grams of U-235. The actuallength of the l

SRMs/lRMs that could not be accounted for would vary, depending upon the location of severance from the cabis. - Typically, the cable is severed approximately three to five inches from the end containing the fission chimber.

j Th3 chemical and physical forms of a TIP are as follows: each typically contains approximately 0.001 grams of U-235 enriched to greater than 90 percent, sealed in a circular fission chamber having a dull gray to dark app:arance, approximately two and one-half inches in length anci approximately three-eighths inch in diameter.

Ths sealed fission chamber is integral to an unsheathed, metallic cable. The actual length of the TIPS that could not be accounted for would a'so vary,' depending upon the location of severance from the cable. Typically, the cabin is severed approximatcly <.hree to five inches from the end containing the fission chamber, Problem Report 97.0027 documented the devices containing the SNM that could not be accounted for collnctively contained 0.056 grams U-235, and identified that an evaluation was necessary for applicability of rcporting. This total quantity was conservatively determined assuming each of the SRMs/lRMs and TIPS contlined an amount of U-235 equal to that contained in one SRM detector. The problem report was written on J:nuary 8,1997, and subsequently assigned for reportabnity evaluation.

EVENT DESCRIPTION

On January 17,1997, it was determined that the total activity contained in the devices containing the SNM that could not be accounted for was approximately 0.1211 microcuries. This total activity exceeded 10 times the activity specified by 10 CFR 20.2201(a)(1)(ii) and identified in 10 CFR 20 Appendix C as 0.001 microcuries (for U-235). Problem Report 97.9047 was written on January 17,1997, to document the determination.

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NRc Forrr>366A.

U.S. NUCLEAR REZUt ATORY COMMISSION i

(4-95)

LICENSEE EVENT REPORT (LER) i TEXT CONTINUATION FACILITY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVISloN YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATION 05000-293 4 of 7 97 001 00 TEXT (if more space is required. use addmonal copies of NRC Form 366A)(17) l A m:eting was held on January 20,1997, to assess the notification requirements for the loss, theft, or misplacement of the SNM that could not be accounted for. The meeting was attended by applicable personnel including personnel from the operations, radiation protection, and regulatory affairs departments. At cpproximately 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, the assessment concluded that notifications were applicable in accordance with 10 CFR parts 20.2201(a)(1)(ii) and 70.52(a). Consequently, the on-shift NWE was contacted and, in turn, the NRC Operations Center was notified in accordance with the one hour notification requiremen*. of 10 CFR 70.52(a) at 1817 hours0.021 days <br />0.505 hours <br />0.003 weeks <br />6.913685e-4 months <br /> on January 20,1997; the notification included the 30 day notificatirm requirement of 10 CFR 20.2201(a)(1)(ii).

The January 20,1997, conclusion that NRC notification was required occurred while at approximately 97 percent reactor power with the reactor mode selector switch in the RUN position. The reactor vessel pressure wrs approximately 1031 psig with the reactor vessel water at saturation temperature.

CAUSE

l Th3 most probable cause was less than effective methods used for control and accounting of devices containing 1:ss than one gram of SNM in the 1975 - 1987 time frame. The cause(s) appears to be similar to those d: scribed in NRC Information Notice 88-34, " Nuclear Material Control and Accountability of Non-Fuel Special Nuclear Material at Power Reactors."

In October 1974, an NRC inspection of the program for control of special nuclear material was conducted. The insp:ction report (74-16) for the inspection documented findings pertaining to procedure 4.0, "SNM Inventory tnd Transfer Control." As a result of the findings, procedure 4.0 was revised (to rev. 2) in January 1975. The control and accounting of portable devices containing less than one gram of SNM - SRMs, IRMs, LPPMs, and TIPS -- was discontinued (that is, deleted) as part of the revision. Fuelloading chambers contain more than one gram of SNM and were not affected by the procedure revision. The cause or reason for the deletion of the SRMs, IRMs, LPRMs, and TIPS from the controls of procedure 4.0 could not be determined with certainty. The procedure change form accompanying the procedure revision (from rev.1 to rev. 2) did not indicate a reason for d:liting devices containing less than one gram of SNM from the controls of the procedure. Apparently, the r:Ison(s) is similar to the reasons or causes described in Information Notice 88-34 in that devices containing 1:ss than one gram of SNM were not tracked or accounted for.

As e consequence of the revision of procedure 4.0 in 1975, devices containing less than one gram of SNM were n:ither controlled as SNM nor included in physical inventories of SNM in the 1975 to 1987 time frame.

M:reover, in the 1975 - 1985 time frame, general cleanups of the spent fuel pool were conducted. The purpose of the cleanups was to remove and ship radioactive waste materials that had acer 1 the spent fuel pool.

Tha spent fuel pool contained numerous irradiated or contaminated SRMs, IRMs, and TIPS. None of tha SRMs, IRMs, LPRMs, and TIPS were tracked or identified as SNM because thw.: emces contained less th2n one gram of special nuclear material (U-235). Radioactive materials were packaged, shipped, and dilivered for disposal at the licensed Bamwell, South Carolina, facility in the 1975 - 1985 time frame. The portable devices containing less than one gram of SNM that could not be accounted for were most likely included in the shipments identified as miscellaneous shipments, not shipments containing SNM.

'i M85)

U.S. NUCLEAR RECULATORY COMMISSION LICENSEE EVENT REPORT (LER)

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TEXT CONTINUATION 5

FACIUTY NAME (4 DOCKET NUMaER (2)

LER NUMBER (S)

PAGE (3)

SEQUENTIAL REVIStoN p

YEAR NUMBER NUMBER

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PILGRIM NUCLEAR POWER STATION 05000-293 5 of 7 97 001 00 TEXT (if more space is required. use additional copies of NRc Form 306A)(17) l An NRC inspection of SNM controls and accounting was conducted in early February 1987 (inspection 87-06).

l Tha inspection resulted in a finding that procedure 4.0 (then rev. 9) did not provide for the effective control and accounting of items (devices) containing less than one gram of SNM. As a result of the finding, procedure 4.0 i

wIs revired (to rev.10) in March 1987 and a baseline inventory of portable devices containing SNM was ast"blished in 1987. The revision of procedure 4.0 included the addition of devices that contain less than one gram of SNM to the controls of procedure 4.0. In other words, devices containing less than one gram of SNM -

SRMs, IRMs, LPRMs, and TIPS - that had been deleted from the controls of procedure 4.0 when the procedure w:s revised in 1975, were re-added as items controlled by the procedure when the procedure was revised in

[

MIrch 1987.

t I'

Tha 1987 baseline inventory was based on review of SNM material balanc? transfer forms and SNM inventories, i

surches for and review of historical documentation that included receipt inspections of devices that contain j

SNM, radioactive shipments identified as containing SNM, and maintenance requests pertaining to devices contIining SNM. The method used for the 1987 baseline inventory was a piece count of portable devices -

containing SNM except for installed devices ~ or devices in the spent fuel pool. For the 1987 baseline inventory End subsequent semi-annual physical inventories of devices containing SNM, installed devices (SRMs, IRMs, LPRMs, and TIPS) or devices stored in the spent fuel pool were considered inaccessible. Subsequent semi-1 I

annual physical inventories of SNM, including portable devices containing SNM located in the spent fuel pool, l

conducted after the 1987 baseline inventory and prior to the 1996 baseline inventory were similar in that each j.

invsntory was based primarily on review of documentation that included material balance transfer forms and r: conciliation. The method used for the inventories of devices containing SNM prior to the 1996 baseline.

3 inventory, although including a reconciliation, did not include a visual verification (piece count) of installed j

dsvices (SRMs, IRMs, LPRMs, and TIPS) or devices in the spent fuel pool because the devices were considered t'

intecessible. Based on the results of the 1996 baseline inventory, the control and inventory practices for.

port:ble devices containing SNM are adequate for tracking and accounting the addition or deletion of materials from the spent fuel pool.

}

Thrrefore, the most probable cause for the devices containing the SNM that could not be accounted for was I:ss than effective methods used for control and accounting of portable devices containing less than one gram i

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of SNM in the

• 975 - 1987 time frame.

l i

t

CORRECTIVE ACTION

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Tha corrective actions taken and planned for the control of devices containing SNM was contained in the July 21,19E5, reply to the notice of violation. In summary, the corrective actions taken included the following:

I The baseline inventory of portable devices containing SNM located in the spent fuel pool was completed on Juna 30,1996. The inventory established a new baseline for portable devices containing SNM located in the spent fuel pool. After the 1996 baseline inventory, SRMs, IRMs, and TIPS in the spent fuel pool were included in a shipment made to the Bamwell, South Carolina, licensed disposal facility. The disposition of the devices j

j containing the SNM that could not be accounted for was that the devices were most probably included in one or j

mora shipments made to the licensed Bamwell, South Carolina, disposal facility in the 1975 - 1985 time frame, and most probably identified as miscellaneous waste.

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m --U.S. NUCLEAR RE1ULATORY COMMISSION (t95)

LICENSEE EVENT REPORT (LER) l TEXT CONTINUATION FACILITY NAME (1) l DOCKET NUMBER (2)

LER NUMBER (6)

PAGE (3)

SEQUENTIAL REVIStoN YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATION 05000-293 6 of 7 I

97 001 00 l

TEXT (if more space is required, use additional copies of NRC Form 366A)(17)

Procedure 4.0, "SNM Inventory and Transfer Control," was revised (to rev.18). The focus of the revision was to strengthen the procedural controls goveming the control and accounting of SNM.

M intenance procedures were similarly revised to strengthen the controls goveming the use or transfer of d; vices containing SNM. The procedures included:

Procedure 3.M.2-5.1.2, "lRM/SRM Drive Assemblies Removal and Reinstallation for Dry Tube Replacement." The procedure was revised (to rev. 7)in August 1995.

Procedure 3.M.2-5.6.12, "TIP Detector Removal and Replacement." The procedure was revised (to rev. 6) in August 1995.

Procedure 3.M.2-5.7, " Installation and Checkout of the Fuel Loading Chambers." The procedure was revised (to rev. 6) in August 1995.

Procedure 3.M.2-5.13, "lRM and SRM Detector Changeout." The procedure was revised (to rev.10) in August 1995.

Procedure 3.M.2-5.14, "SRM/lRM and TIP Detector Testing." The procedure was revised (to rev. 7) in August 1995.

Tr-ining on SNM and devices containing SNM was conducted. The training was included as part of general cmployee training. Training of greater focus was also conducted for personnel who may work with devices containing SNM.

SAFETY CONSEQUENCES

The devices containing the SNM that could not be accounted for pose or posed no threat to national defense or public health and safety.

Th:) devices containing the SNM that could not be accounted for contained a total of 0.056 grams U-235. The qu:ntity is less than the quantity defined in the 10 CFR 70.4 definition of special nuclear material of low strategic significance.I

- -..-. ~. - - -.._- -- _ - -. ~. -

!U.S. NUCLEAR RECULATORY COMMISSION

(&es)",,.

LICENSEE EVENT REPORT (LER)

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TEXT CONTINUATION 1

FACKJTY NAME (1)

DOCKET NUMBER (2)

LER NUMBER (4)

PAGE (3)

SEQUENTIAL REVISION 1-YEAR NUMBER NUMBER PILGRIM NUCLEAR POWER STATloN 05000-293 I

7 of 7 97 001 00

" TEXT (if more space is requred. use adetonal copes of NRc Form 366A) (17)

Th3 total activity in the devices containing the SNM that could not be accounted for is approximately 0.1211 microcuries. This activity, although greater than 10 times the activity specified in 10 CFR 20(a)(1)(ii) and id::ntified in Appendix C for U-235 (0.001 microcuries), is less than 1000 times the activity for U-235 specified by 10 CFR 20.2201(a)(1)(i). The SNM that could not be accounted for was contained in sealed devices (SRMs, IRMs, TIPS). These sealed devices were most probably irradiated and/or contaminated. Contaminated or not, thtse devices were and are handled as devices that contain radioactive material. Radiation detection and monitoring is regulated and controlled and is accomplished through several means including radiation surveys s

and survey instrumentation, radiation work permits, postings and/or barriers, personnel dosimetry, friskers, area

[

r dirtion monitors, and portal monitors. It is reasonable to conclude the devices containing the SNM that could not be accounted for were maintained in the controlled waste process stream. Therefore, it is reasonable to conclude that no unregulated exposures occurred to persons in restricted areas as a result of exposure to the

]

devices containing the SNM that could not be accounted for. The device's containing the SNM that could not be accounted for were most probably included in radioactive materials shipments made to the licensed Bamwell, South Carolina, disposal facility. The packaging, transport, and disposal of radioactive materials is regulated and controlled. Therefore, it is reasonable to conclude that no unregulated exposures occurred to persons in unrzstricted areas as a result of the devices containing the SNM that could not be accounted for. Based on the smtll amount of SNM contained in the devices that could not be accounted for, and that the devices were most likIly included in shipments to a licensed disposal facility in the 1975 - 1985 time frame, there are no actions 3

planned to recover the devices that could not be accounted for.

This report is submitted in accordance with 10 CFR 20.2201(b) becausa the activity of the devices containing ths SNM that could not be accounted for was greater than 10 times the activity identified by 10 CFR 20 j

Appendix C (0.001 microcuries for U-235).

j SIMILARITY TO PREVIOUS EVENTS A rsview of Pilgrim Station LERs submitted since January 1984 was conducted. The review focused on reports involving special nuclear material (SNM). The review identified no LERs involving the loss, theft, or misplacement of SNM. A similar review of LERs submitted since 1972 was conducted and the review identified no LERs involving the loss, theft, or misplacement of SNM.

)

t ENERGY INDUSTRY IDENTIFICATION SYSTEM (Ells) CODES e

l Tha Ells cooes for th;s report are as follows:

COMPONENTS CODES 4

Det:ctor (SRMs, IRMs, LPRMs, TIPS)

DET j

Monitor (SRMs, IRMs, LPRMs, TIPS)

MON SYSTEMS 3

Incore monitoring system IG

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