IR 05000219/1985030

Ack Receipt of Clarifying Issue Raised by Violation Noted in Insp Rept 50-219/85-30.Violation Will Be Withdrawn & Enforcement History Corrected Based on New Info & 860523 Telcon

ML20199G359
Person / Time
Site:	Oyster Creek
Issue date:	06/20/1986
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Fiedler P GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8606250196
Download: ML20199G359 (2)

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JUN 2 01986 Docket No 50-219 l GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P.O. Box 388 Forked River, New Jersey 08731 Gentlemen:

Subject: Inspection No. 50-219/85-30 This refers to your letter dated January 23, 1986, in response to our letter dated December 24, 198 Thank you for clarification of the issue raised by the violation cited with our December 24 letter. Based on the new information provided in your January 23, 1986 letter and our May 23, 1986 telephone conversation, we are withdrawing the violation and will correct your enforcement history accordingl Thank you for your cooperation in this matte

Sincerely, L.,Jnal Signed By:

Thomas T. Martin Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc:

M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

NRC Resident Inspector State of New Jersey bec:

Region I Docket Room (with concurrences)

M nag;ncat Assista-t, CTiA Section Chief, DRP OFFICIAL RECORD COPY RL OYC 85-30 - 0001. /30/86 N

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GPU Nuclear Corporation 2 JUN 2 01986

l RI:DRSS RI, RSS R, R, SS Qella Ratta/bc Keimig JIdyner ar n 6//J/86 6/e3/86 6/ 7/86 fr/20/86 0FFICIAL RECORD COPY RL OYC 85-30 - 0002. /30/86

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GPU Nuclear Corporation Nuclear  :: g = = 388 Forked River.New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

January 23, 1986 i

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Thomas T. Martin, Director Division of Radiation Safety and Safeguards

Region I U.S. Nuclear Regulatory Comission 631 Park Avenue King of Prussia, PA 19406 Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 Inspection 85-30 Pursuant to 10CFR2.201, Attachment I to this letter provides our response to the Notice of Yiolation contained in Appendix A to your letter of December 24, 198 ;

If you should have any questions, please contact Mr. John Rogers of iny staff at (609)971-489 I Yery truly yours, A A.]

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A P[t Vice President and Director kbr Oyster Creek PBF/JR/ dam (0142A)

Attachments cc: Dr. Thomas E. Murley, Administrator l Region I

! U.S. Nuclear Regulatory Commission 631 Park Avenue j King of Prussia, PA 19406 Mr. Jack N. Donohew, J U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue, Phillips Bld Bethesda, MD 20014 Mail Stop No. 314 NRC Resident Inspector Oyster Creek Nuclear Generating Station GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

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ATTACHMENT I e

Violation:

10 CFR 70.51(c) requires, in part, that each licensee establish, maintain, and follow written material control and accounting procedures which are sufficien~t to enable the licensee to account for the special nuclear material in his possession under licens Dyster Creek Nuclear Generating Station Procedure 1002.h Revision 9

" Documentation / Accounting of the Receipt, Shipment, Transfer, and Movement of Special Nuclear Material (SNM)", requires (SNM Card File-Purpose 3.4.1 and Entries in the SNM Card File 3.4.2) that upon receipt of a completed Item Control Area (ICA) transfer and/or completed SNM Move Sheet, the Core Engineering Manager or his designee shall record the transfer as provided on the appropriate Fuel Management Card located in the Kardex fil Contrary to the above, the inspector determined on October 3,1985 that the Kardex file had not been maintained to record the movement of certain fuel bundles located in the spent fuel pool which had been relocated on August 25 and 26,1984 as shown on SNM Move Sheet No ,84-124, and 84-12 Response:

GPUN does not concur in the violation as writte CFR 70.51(c) does require that written material control and accounting procedures, sufficient to enable the licensee to account for the Special Nuclear Material (SNM) in his possession, be established, maintained, and followed. The specific GPUN record which details the transfer of all SNM within an Item Control Area (ICA) is the Documentation Fuel Move Sheet, Figure 1002.4-3, contained in site procedure 1002.4, refer to Attachment II. A properly completed Documentation Fuel Move Sheet represents the Oyster Creek Nuclear Generating Station's legal record of a fuel move or transfer. It provides the authorization for the fuel move, documents the time the movement was completed, and provides licensed operator documentation that the movement was accomplished. The completed Documentation Fuel Move Sheet is filed and stored in the Oyster Creek Document Control Center as a permanent record. These records allow for the accounting and traceability of SNM in our possession as required by 10 CFR70.51(c). At no time was any Documentation Fuel Move Sheet found to be incomplete or inappropriately filed or store As an internal management control tool, a Kardex card file system was established at Oyster Creek. It serves only as a convenient central file, enab. ling the . quick retrieval of information. It was not intended to provide any legal record as required by any 10 CFR regulation. It should be noted that between February 1983 and September 1985 over 3200 fuel movements were successfully performed. This required the

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administration of over 900 Documentation Fuel Move Sheets. This was all accomplished without a single violation of regulatory requirements. It was only during the transposition of infonnation from the legal record to the internal tracking system that the three identified omissions occurred. This represented a total administrative error of less than

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0.6%. The administrative controls which exist were and are sufficient to meet SNM accountability requirements. There is no perceived systematic or recurrent problem areas in our, accountability proces The three identified Documentation Fuel Move Sheets were located and the information they contained was entered into the Kardex file syste Site Procedure 1002.4 (Rev. 9) " Documentation / Accounting of the Receipt, Shipment, Transfer, and Movement of Special Nuclear Material" is being revised to clarify any possible ambiguities in regulatory requirement The revision to this procedure is projected for issuance by the end of March 198 .. .

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