IR 05000237/1975024

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Letter Regarding Dresden Units 2 and 3 - IE Inspection Reports 05000237/1975024 and 05000249/1975021 Regarding Physical Inventory and Verification, Examination of Accountability Procedures, Review of Special Nuclear Material Records ...
ML17252B153
Person / Time
Site: Dresden  Constellation icon.png
Issue date: 12/05/1975
From: Hind J
NRC/RGN-III
To: Brian Lee
Commonwealth Edison Co
References
IR 1975021, IR 1975024
Download: ML17252B153 (24)


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UNITED STATES NUCLEAR REGULATORY COMMISSION REGl.ON Ill 799 ROOSEVE.L T ROAD ~-~-----------

  --- --- -GL=EN* Et::l::YN;-1t:L:INOIS -601'3J _____ - - -- - - ---------- ---- -- - --
    -';: c Commomrenlth Edison Company   Dock12t Ho~ 50-237 ATTN: Hr.-Byron Lee, Jr *   Docket No.<3fF2dJ
 .Vice President P. O. Box 767 Chicnr,o, Illinois 60690       ....:.-; ...... lo..:

GentlP.men: This refere to the inspection of your 'Dresden 2 and Dresden 3 facilities conducted on NoW1!'lbar. 12, 13, 14, nnd 17. 1975, by Messrs. Finley, Patterson, and F.olody of this office-and to the discussion of our findings mth Hr. B. B. Stephenson, Superintendent, Dresden Station and otl1er tnl?lilbers of his staff at the conclusion of the in$pcction *. Yotir nctiv1.tiea pursunnt to Title 10, Code of Federal Rep,ulations, Part 70,

 "Special ~ruclear Material" as thay pertain to Licenses n DPR-19 and No~ Dl'R-25 were the subject of the inspectio This material eaf eguard9 inspection con:listed of 11 physical
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inventory and verification, examination of accountabi*lity procedures, r~view of special nucll!!ar materinl re'!ords, \ depletion and production calculations, intarvi~m uith facility personnel, and _oboervatione by the inspectors. 'rhe ~--*- records audit for both licenses waa for the period -.July 1, t ~-.*.::-.~**.'.

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1972 thro~h October 31, 1975. Diffcr~ce9 bet~~.n your

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c81.culated values and the NRC calculated values for uranium ._____ depletion and plutonitnn production are b~ing further rav!01red ~* ; . *:-: ' '

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and will be a subject of a subseq1la.nt inspectio ;._ During this inspection, it was fo1md that certain of your ':i.* actirlties appeat' to_be in noncompliance with rmc requirement The item and reference to tho pertinent requirements arc * listed in the ~nclosure to this lette This notice is s~.rtt to you purouant to. the provioiona of  ::*** Section 2.201 of tho NRC'e ' 1P..ulee of Practice," Part 2, Title 10 1 Code of Federal Regulations. Section 2 *. 201 requir~s .;... you to submit to this off icA within t:l-.-enty dnys of your

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Commomrealth Edison Company - 2 -

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rel':~ipt of this nQ.U.~ a written statement o~ e.~la.nntion

. S.1\ t,r.iY~ 1.11,'?-l~~~1'$.:* (1)' corrective steps wtd~h *ttave ~En)  *.~

taken by *you 9 and the results ncltieved; (2) cor.rective stepo Which will be taken to nvoid further items of noncompliance; and (3) the date wen full compliance ' "rill be achieve .' i: . . . .

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Areas examined during th~ innpection concern: a subject matter which is exempt fro~ disclosure according to Se.ction 2.790 of the NRC's "R1.,1J.es . of Practice, . r.'lrt 2. T.itla 10, Coda of Federal Regulation Conl!laqucntly, our report of thin inspection (No. 050**2J7 /75-24 and No. 050-249/75-21), will

* not be placed in the* Public Document Roo Should you h:lvc an/ quo-'3tio~ conc<?rning thill in~,.icction, we will be glsd to u:l.sc:.~1~9 them ~Jith you *
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Sincerely yourD, J. Ui*l Chi'!.~ S.'lf(!guarr.fo. nrru.1c Eri.closur~: As stated cc w/encl, w/o rpt~ B. B. Stephenson Station Superintcndan~

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ENCLOSURE

     ~~------- - - __*____.__ -*~~.......:.-~*~*.:.---
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. Comloommalth faiison CoJllPany License No. *>>PR-Z *---*--*--**~-  _
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'Ihe following item of noncompliance wa.0 ic.lentif ied during tha I

i .."!',':':*.~ . insptAction conducted on. November 12-14. ond 11, 197 Contrary to Title 10, Codo of Federal Regulations~ Section .fi:~1~s~ 70.SZ which requireo 1.mniediate reportin~ of a loan of SNM~ ..--

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a !ucl loading chmnber, aerial nur.i..her 6579005, containing t"'° grllt18 of 93.35% enriched uranium 235 that could not be locatcul on AUguat 6, 1975p wne not r~port::!tl ue loDt to the Dirnctor of Region III, Offi.Ce of Inei>oction e.ml a\5:t1'rc~!Jmlt Nuclca::- Regulatory Ccmuia:dou w~tll October S, 19'1 ~-,**:* .. *_ -

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UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT ~-c--**---:-------------*-------*---* *-- -- . ---*---** ----- -- --

REGION III

IE Inspection Report No. 050-237/75-24 IE Inspection Report No. 050-249/75-21

 *Licensee: Commonwealth Edison Company
   .p. 0. Box 767 Chicago, Ill{n6~s 60690 Dresden Nuelear Power Station License No. DPR-19 Units 2 and 3  ,Li~e~se ~o. DPR~25 Morrii, Illinbis 60450 Category: C Type of Licensee: })WR, 800 HWe Type of Inspection: Materials Safeguards, Unannounced Dates of Inspection: November 12' 13, 14 and 1 7' 1975
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Principal Ins0ector: A. G. Finley'

     (Date).

!- ~ fat:t£~\ Accompanying Inspectors: J. P. Patterson /2,-3-75 (Date) D. J. Holaday (Date) Other Acc(1111pany i ng Personnel: Norie

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 * Reviewed * bZ/y
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I Safeguards Branch Attachment: Findings* ( 10 CFR 2. 790 Information)

10 CrR l.°.790 INFORM/\ T°ION SUMMJ\RY OF FINDINGS

9.-=----~ --- ~ ---=-- ~-.~--- - ---*

Inspection Summar lnapec~ion cond~cted November 12, 13, 14, and 17, 1975 (Unit 2, 75~24)

 (Unit 3, 75-21): The inspection consisted of a physical inventory and verification, exmnination of accquntabil:ity procedures, review of special nuclear material recotds, material transaction forms, ma~erial *

status reports, and depletion and production calculations. One item of noncompliance was identified. Failure to report immediately . the lo~~ of a fuel loading chamber, serial number 6579005; cbntaining two grams of 93.35% enriched uranium 235. Differences between NRC and licensee calculated values for uranium depletion and plutonium production are being further reviewed and will be a subject of a sub-

 . sequent inspectio Enforcement Items The following item of noncompliance was identified during the inspection:

Deficiency Contrary to Title 10, Code 6f Federal Regulations, Section 70.52, which requires immediate reporting of a.loss of SNH, a fuel loading . chamber, serial number 6579005, containing. two grams of. 93. 35% enricbe.d '"**-:;::'::? uranium 235 that could not be located on August 6, 1975 was not reported as lost to the Director of Region III, Offic~ of Inspection and Enforcement, Nuclear Regulatory Commission until October 8, 197 Licensee Action on Previously Identified Enforcement Items Not applicabl Other Significant Items Systems and Cornponehts Not-applicabl Facility Items (Plans and Procedures) For the period, January 1, to June 30, 1975, the licensee for computation of uranium depletion and plutonium production chan~ed _over _from the Gen:e_ral Electric, San Jose* computer. codes to th.eir own method utilizing both th~ station on-line computer and the Nuclear Fuel Services~ Commonwealth Edison off:--line compute IE Inspection Rpt No. 050-237/75-24

     *IE Inspection Rpt No. 050-249/75-21 IE:III Copy N lJ J.!

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   .. * 10 .CFR 2.790 lNFORJv\/\TION r

10 CFR 2.790 lhl.FORMATION The factlity ts planning tentatively, to insert 140 new fuel =9------ -----,-- -:---------a-s-semlfi-i-e-s -rn---chc-uresden-rand-m:--esoen- J Keactorfr1-Marcn- -------------~--- and September 1976~ respectivel U\ll,"in~ ~he August 1975 fuel reload of the Dresden ~ J_{.~q.~t-9F~- 14Q new assemblies were inserte In 1976, the facility is planning to ship up to 689 _fuel assenililies fro~ the Dresden 2 and 3 fuel pool io General Electric, Morris Operation, when tl;e increased storage capacity has been attained at that facilit Managerial Items About September 1, 1~75, Mr. James Abel became th~ Administra-tive Assistant to the Dresden Station Superintendent. M Abel had been the License Adm~_nistrator for BWR' s. at the Commonwealth Edis6n Com~any Office in Chica~ Noncompliance Identified and Corrected by Licensee Non Deviations Not applicabl Status of Previously Reported Unresolved ltem~ Not applicabl Management Interview A management interview was conducted by Messrs. Finley, Patterson, and Holody of the inspection team with the following' Commonwealth Edison Company personnel: B. E. Stephenson, Plant Superintendent James A_bel, ,\d1ainisl rative Assistant to. Supc.:rintcnclent J. M. Dolter, Lead Nuclear Erigineer _~nd Nuclea~ Material Custodi::m F~ Willaford, Quality Assurance Inspector

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 . The .licensee representatives were infor_med* that they were in apparent noncompliance with 10 CFR 70.52 for the following
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10 CFR 2.790 lf'ff0RMA TIO~~

10 CFR 2.790 Jt!f.ORM/\llOl~l

. reason: Contrary to 10 CFR 70.52, the licensee did not report *

,---_-_ ----- -- ---- ~ - --1 mmccTiately *rn Tlie *o:necf<Yt-;~Re-g-1011.:_TTI--; -office_: of--Inspcction* and--- - -- --:-- - - -

. Enforcement, Nuclear Regulatory Commission, the loss of a fu~l loading chamber., No. 6579005, containing two grams of highly
 ~.\\~ tc:h.~cl u.-~anium 2 3 The Station Superintendent asked what the classification of the item of noncompliance would be? the licensee was informed that at this time, it is considered a deficiency and they will be notified if the classification should .

be

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clrange '. The licensee personnel were informed that three six-month report-ing period~ for both facilities were calculated for uranium . burnup and piutonium production and compjred with. the reported values. The uranium depletion and plutonium production figures for both Dresden 2 and Dresden, 3 reactors reported for the period ending June 30, 1975, included mathematical adjustments. These adjastments r~sulted ftom the licensee changing over from General Electric, San Jose computer codes to their own computer programs for the January to June 1975 period. It was noted to the l{censee that these dif fererices res1,.1lting from this changeover should be documented on the material status reports as adjustments to uranium burnup and pluton~um production. Th~ licensee agreed that future reports wc.iulddocument any adjustments that may be reflected as part of a six month qurnup or production value. The licensee indicated that more consistent uranium burnup and plutonium 0 production data should result with the use of their 0WD computer program The licensee was informed that all 1384 fuel assemblies held under License No. DPR-19 and 1145 fuel assemblies held under License No. DPR-25 had been accounted for and a total gram balance fo~ both Dresden 2 and i as of October 31, 1975, ~greed with both the Station and Commonwealth Edison Company records .

 . It was no~ed to the li~ensee that 88 fuel assemblies in the fuel potil for Dresden 2 and 63 fuel assemblies for Dresden .3 had been physically verif i0d by telescope and that the fuel pool piece-count of 660 fuel assemblies for Dresden 2 and. 421 fo~ Dresden 3 was in agrecmen~ ~ith Station records, Also 100 fuel assemblies from both Dresden 2 and Dresden 3 reactor cores agreed by serial numb~r and location to the individual f~el assembly ~ards with a minor omission of one digit in the core loca~ion column for one fuel assembly. *
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10 CER 2.7..90 INFORM/, TIOt\l The license6 wns requested to scrutinize more car~fully _the material status reports reporting Dresdei1 activity and prepared c:e--- _ * by the General Bcioks, Commonwealth Edison Company Offic6 in

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NRC-741, ZGR-YVF No. 2 were not reported on the June 30, 1974, _ _ materinl status report, hut rather cm the December 31, 1974 material stat\JS; r;:E:;p.0rt.

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   *10 CER 2.790 lt~f.ORM1\TIOt~
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10 (JR '2.790 lf\WORMATIOFl REPORT DETAT.LS

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-::-9----:-_:___ ___ --:---- -L1ccnsee....,Vi~-fr~onlieT-sup-pTfi.11g':'Informan:o-11*------- ----------*-:-- --.. ----- __ _ . ____ -------~-- Dol~er, Lead Engineer arid Nuclear Materials Custodian Petrowsky, Nucle~F Engineer Rau~c~, Nucl~ar tngineer Thompson, NuclP.a r Engineer-, CECO, Chicago Off ice J, Doxsey, Nuclear Engineer Scope of InEection The inspection was made to deterri1inc the licensee.' s compliance with the sa(eguards requirements of Titie 10, Code of Federal Regulations, Part 70, as they pertain to nuclear p6wer reactors licensed pursuant to Part 50. * Facility Organization Th~ Dresden 2 and 3 nuclear procedures are part -0f the Com~onweaith Edison Company nuclear procedures for all Commonwealth Edison

  .owned and. operated nuclear reactors. The procedures were updated in April ~nd September 1975 by the Director of General Procedures and appr:oved by the Vice President and Comptroller. State.ments of responsibility and delegations in writing, where required,
  . have been e~~tablished .for those positions having responsibilities1 f°or receiving, shipping, inventory, storage, internal ~ransfers, records and reports. A fuel assembly caid is mainta{ned as a perpe~ti~l record for each £tiel assembly, r~flecting serial numb~rs, locations, and disposition. A new procedure number DFP 800-25 was initiated *in November 1975, as a result of the lost fuel
  .loading chamber, for the reteiving, handling, storage and ship-ping of fuel loading chambers. Nuclear Procedure No. 3, revised April 1, 1975 ,' provides for documentation of betw'een Item Control Area (ICA) movements and requires ~reparation of ~ Nuclear Transfer Report (Form C), numbered consecutively by year for all such movernents; Reactor inventories are conducted of all nuclear fuel ~ssemblics by serial number- and location prior to _initial fuel lo~1J.i.ngs and each time the reactor heads are removed. During the period of inspection, this hns been more frequent, th;rn required by 10 CFR 70. In addition, . a piece-count inventory
     . of the reactor vessel is required whenever the reactor .heads are removed for mote than one month, and each month reactor heads are removed. Fuel vault inventories are conducted by serial number and location monthly, or once yearly if the vault has been sealed and.the integrity of
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10 CER Q.790 IJ\lEOR:i'/v\T!OI~

10 CER 2.790 INFOPJliATIOfl

 *the seal confirmed by inspection. The inventory form is so

=e----~-- ------- noted. A pi~ce-count of fuel pool inventories i~ c6nducted and dqcumen-t:ed-mo.nt-hly,---and--a- -requ-i~I'ed--annua-1- -in-ven-tory---o-f- t-he-f-uel--- --------- -------~ -- pool is takeri by serial number and location. This inv~ntory may serve in lieu of a monthly piece-count inventory. The licensee mai~tains a Fuel Pool Inventory Form (Form G), a Reac~or Inven-tory Form (Form II), and Fuel Vault Inventory form (Form F), and all fonns provide for* si~natu'res of the: Nuclear Material Custodi-'- an, Inventory Observers, .and approval by *the Dresden Station Supcrintenden~. These fo~ms were on fi1e, signed .and approved as required by Company Nuclear Procc<lure * * Fa~ility Operation The Commonweal th Edisoi1 Company_ Nuclear Procedures cover the fol_lowing topics: Organizational responsibil~ti~s and authorifie (Nuclea Procedure No. 1) Establishment and description 6f Item Control Area (ICA).

(Nuclear Protedure ~6. 1) Dresden .2:

  (1) ICA VD2 Dresden 2 Fuel Vault (2) ~CA PD2 - Fuel Pool (3) ICA RD2 - Reactor Dresden 3:
  (1) ICA VD2 Dresden 3 Fuel Vault (2) ICA PD3 - Fuel Pool (3) ICA RD3 - Reactor The Fuel Vault is a single facility used by both Dresden* 2 and . Delegations for the following positions are in writing:* Statio~ Superintendent anJ Assistant Supeiintendent as
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  "authorized individuals" having responsibility for SNM surveillance (letter dated july 19, 1974 from Company President).

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10 (FR 2.790 l~*lFORMA.110H

    * 10 CF~ ~.790 INF0RMATI011 b. *Nuclear M.:iterials S;lfeguards Manager as "authorized

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_:.i!1s_l_i_~lc1ual" havin~ responsibility for. SNr-i surveillance

  -, (letter -ci; t~<l-- j~1y-19~-19-74 Irani -e:0-in-pan:Y--riesi<Jcnt_) ____ ~---- -- - - - ------ - Nuclear Material Custodian design,-ite<l in writing as the
   ~*.uol~a,r Materials Cu.stodiah and Lead t~ngtneer (le_tter dated August 23, 1974 from Station Superintendent). Nuclear Material Custodian maintains a list of author-ized .Fuel Handling Foremen and Fuel Handling personne . SNM records and reports (Nuclear Procedure No. 7) .. Physical inveritory procedures and frequencies for each IC (Nuclear Proced~re No. 4). Uni~radiat~d fu~l shipments in, unirradated fuel shipments o~t and spent fuel s~ipments (Nuclear Procedures No. 2). Company auditors participate in the required annual physical inventory, initial fueling, ref~eling, or rearrangemen~ of fuel in the reactors. Two Company Auditors participated in the May 15 and 16~ 1975 anntial physical inventory. Procedures and practices are also reviewed annually by Company Auditors (Nuclear Procedures No. 1 and 4).

Facility acce~ts shipper's values and has no measurement capability. Licensee has a computerized method for calcula-ting uranium depletion and plut.bnium productio As a result of. the SNr-1 records and reports review, the' pas.session and use of SNH has been confined to. the location

  *and pur~oses auth6rized by Licenses No~ DPR-19 and No. DPR-2~.

Measure~ent and Controls Information from feedwater flow and tetnperatures, steam flow and temperatures, control rod drive flow, recirculating ~ump power and other conttih~tors to thermal power is taken from instrumont~tion in.the reactor control room and fed to a pr6cess computer~ This computer calculates hourly values of megawatts-thermal for the reactor*. If the process computer should break down the licensee has an alternate station approved method for calculating thermal balances and .power with the aid of a Monroe 1880 computer .

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The uranium depletion and plutonium production figures have been provided by a computer progr~m fro~ General Electric Company (GE) San Jose, California up ~o the June. 30, 1975, Material Status 8 -

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    . 10 OJ. L.790 INEOR/1\/*:110~,~

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10 tFR 2.790 lt\JFORMATION Report. Between January nnd June, 1975 GE ch<mged their compu.ter codes,* and. the licensee decided to use their own instead. The

 *11cens~e s codes are designated OD-12, Isotopic Composition of In
---*-- - --- *-Gore--Fue1,...:-an- -en-1-ine---sta-l;..-lon -computer---code.,. and~ .a _Nuclear__F_uel_ ___ :.... ___________

~------ Services Department code designated RICE, Revised Isolux Commo.nwealth Edison, an off-line computer code used in the Commonwealth Edison corporate offic The reported amounts for uranium depletion and plutonium pro-duction fox June 30, 1975 primarily represerit mathematical adjustments resulting from the licensee changing from the GE computer program to their own programs, rather than actual gener - ated quantities. This accounts for the large differences between

 * NRC calculated values and those reported by the licensee for both Dresden 2 and Dresden 3 reactors for that period. Comparison cif data for three reporting periods fcir each reactor are showri in the following tables. Notations are made where the licensee's *

data ~ppears erroneous. * The overall aver~ge differences for each reactor appear to be reasonabl DRESDEN. 2 URANiln-1 DEPLETION - PLUTONIUM PRODUCTION*

   *REACTOR REPORTED DATA VS CALCULATED Period  MWD (Thermal) *Licensee NRC Calculated % Differnece 7/1/73-12/31/73 3j3,490 Uranium   436, 8"68 455,861 +4;3 Uranium~235   234,340 239,597 + Plutonium   114' 008 106,788 - /1/74-12/31/74 161,917
 .Uranium-   214,595 211,483 - Uran.ium-235   98,.31f7 104,610 - Plutonj um   45~699 55,660 +23.2*

1/1/75-6/30/75 56,509 Uranium 78,226 86,L~39 +10.5* Uranium-235 52,086 51 ;565 -1'.o Plutonium 17,908 ~43 +50.8* Totals 551,916 Uranium 729, 689 753,783 + Uranium-23 ,773 395, 772 + Plutonium 177,615 189,491 + . tER 2.790 ll:IEOR1v\ATi0~~ r-*-

10 (FR 2.790 l~,IFORM;\TIOFJ * DRESDEN 3 URJ\NIUH DEPLETION - PLUTONIUM PRODUCTION ~~--* --- - . - ----- - - ------- - --* - -- ------ ------ ---- - -- ------- ..__ -- - ------ ---*

   . REACTOR REPORTED DATA VS CALCULATED MWD(Thermal) Licensee NRC Calcula~~d % Difference 1I1I711-6 I 30 I 74 148,190 Uranium   214,082 237,192  +10. 7 Uranium-235  148,237' 147, 672  - Plutonium   73,223 69, 115  - /l/7L1-12/31/74 286,970 Uranium   355,478 399,116  +12.4*

Uranium-235 212,082 214,380 + Plutonium * 89,160 94,928 + /1/75-6/30/75 11.3, 002 Uranium 221,947 154 ;210 -30.5*

  *uranium-2 35  . 67,415 80,881  +20.0*

Plutonium 27' 101 35,416 +30.6* Totals 548,162

  ,Uranium  ?91,507 790,518  - Uranium-235  .427,73/i 442,933  + Plutonium  189,484 199,459'  + *denote.s difference which will be reviewed in mcire detail subsequent to the isstiance bf this repor Shipping and Receiving All Dresden 2 and 3 receipts of nuclear fuel for the period of inspect{on agreed by both piece-cotint and fuel assembly seri~l number~ with the s~ipper's dat All fuel shipped fro~ both.Dre~den 2 and 3 for the peri6d of inspection reflected on the inter~al tr~nsEer form (Form C), the total piece-count and fuel assembly serial numbers of all items shippe The licensee pripares an advance signed internal transfer (Form C)

reflecting the total fuel and individual serial nunibcr:'ed items to be shipped, the receiving*RIS, sJate of shipment and ICA from which

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10 CEP. 2.790 lt!F.01\/v\,~ TIO ti

10 CFR Q.790 INFORtl1.L\TIOt'J material is to be removed. This atlv.:111ced copy is submitted to General Books, Commonwealtl1 Edison Company Officei for prepar-

=e-.---:-:----:,-,- -ca.t-ion-of--thec..Eo-r:m._NRC=-:-7AL __When __the __ ship.m.cn.t _is__ rel~ a sg.d_, _ _t~ --------*---~ ________ _

Nuclear Materials Custodian .notifies General Books by telephone, . the date is entered on the Form NRC-741 and distribution is made * . * the i:; '-'me.. ciQ,i ., General Books maintains a computer data balanc~ for each fuel assembly and upon receipt of the signed Forin C .ftom the reactor site prepares the Form NRC-741 with gram values for both element and isotope. This Fo~~ NRC is held in. abeyance until the Nucleat M~terial~ Custodian notification by telephone that the shipment has been released (same day).

A fuel assembly card is maintained for each fuel assembly and reflects serial number, fu~l assembly movemcrits, .and curtent location. SNM values* for fuel assemblies arc maintained by -the isotopic inventory program at the Commonwealth Edison Company Offic Receiving Reports. (F~rm A) are prepared by the reactor site for incoming fu~l, serial numbers are checked, and the form signed by

 ~andling Personnel that all fuel assemblies have been verified and inspected. Apptoval signatures are required fro~ both the Nuclear Materials Custodian and Station Superintendent. *The Receiving Report is, submitted to General Books within seven days of receipt in order to receipt and return the Form NRC-741 to the NRC and the shippe * Storage and Internal Conttol The licensee maintains. in addition to fuel as~embly cards for each fuel assembly which reflect serial numbers and ICA locations, a.current fuel . vault .

inventory

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sheet, 1* a core

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diagram and fuel pool inventory sheets f6r both Dresden 2 and 3 that also reflect serial numbers and locations within the ICA. Except once annuall~ the pool inventory sheets will.show a total piece-count relecting occupied and unoccupied positions within the pools which is verified by piece-count monthly. Annually serial numbers and positions are verified. . . Perpetual inventory records (fuel assembly cards) are posted to reflect ch.:rnges from internal transfer forms and n~conci. Led on serial number and total piece-cpunt with phy~ical inventorie CE~ Q.790 ll'H-Ol~!-1\1\ TIU~ I r

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  * . CF,R 2.7S>O /NFORMA TI0~1

£-., . Internal transfers (Forms C) ~re prepared for all offsite receipts, shipments and internal fuel movements and signed by

------botfi -the.F\iel--H;J.ii(fflng-Foi~inaff and tlle-Nucle.w-mrn~r-1*a-1--cnstodian-;.,- --*------ - ------

All fuel assemblies received and shipped by both Dresden 2 and. 3 since July 1, 1972 agreed with internal tr~nsfcr forms and fuel assembly card records. Internal transfer- forms had *he?_n *P~*cpp.r~d

 . for all the receipts and shipments. J\grccmen*t with fuel ass'cmbly cards revealed the following mino~ errors for the Dresden 3 Unit~

Fuel assembly DDOJ8 -No date for last transfer; fuel assemblies DD020 and LJ1997 teflected latest transfer d~te~ but no location These we~e ~h~cked with the ICA diagrams and DD020 ~as in .the reactor, LJ1997 in the pool, and DD038 in the reactor in August 1975. These corr~ctidns were made to f~el assembly card Copies of receiving reports for offsitc receipts and internal transfers for offsite shipments ar~ submitted to the General Books, Company Office as a basis for signing, distributing and prepar'ing Forms NRC-74 Inventory and Inventory Verification The entire physical inventory of the Dresden 2 reactor consists of 724 fuel assemblies in the reactor and 660 irradiated fuel assemblies in the pool. There were no cold fuel assemblies in, the va~lt at the time 6f inspecti~ To verify the reactor core loading, 100 fuel assemblies were randomly selected as listed on.the current reactor core loading diagram. These assemblies were checked with the fuel assembly card records ~or correct location. One discrepancy on the cards was. detected which amounted to a digit being omitted from the locating points on. the core diagraci for one assembly~ A piece-count by the inspection team of the irradiated fuel

 *assemblies in the Dresden 2 pool confirmed that 660 assemblies were present. With the aid of a telescope attached to a moving bridge over the ~ool, the inspection team identified 88 assemblies by serial number. These 88 assembJ.ies were then verified with the current official Dresden 2 pool diagram. There were 25 other as.semblies as part .of the pool holdings selected whose serial
 .numbers were not legible through the telescop Th~ Dresden l reactor has a physical inventoTy which consists of 724 fuel assemblies in the reactor ~rid 421 irradiated f~el assembli~s
- :-~* .in the pool. There were no fuel assemblies in the vault at the time of inspectio I
   - 12 -

10 (EP~ "r)_.7_90 lt,lFOR!v\i\T\O~!

10 CFR 2.790 INFORMATIOt~ A total of 100 fuel assemblies in the reactor wer~ randomly selected to verify the identity bnd location as listed on the * current rcac tor core loading di*agram . . These asscniblJes were ~ c.lleckecl -,~Hlr t*11e--*fue*1-*as-s-c:moly--c-anl re-ccn:-ds ;-*an<l -irn-discrepanctes- ,- -- were detected for loc.ation or .idcnt.ity. To verify the inventory in the pool, first a total piece-count of 421 ass.emhlies was taken by the inspection team which confi.rmcd the official number listed by the licensee. Then wJth the aid of a telescope attached to a moving bridge over the pool, the inspection team jdentified 63 assemblies by serial number. These were checked with the current locator board listing for the pool, and nn discrepancies were detecte Records and Reports Official SNM values are computerized and maintained by ICA at G.eneral.Books, Commonwealth Edison Company Office based on .input from the reactor site. These computer printouts are presently on a se~i~nnual ba~is in c~njunction with required Form NRC-742 reporting period. *An exception to.this is during a fuel reload or sustained shut dmm when a computer printout is prepared and submitted to the site. This computer is known as the Revised ISOLUX Commo~mealth Edison (RICE). The reactor site also has a* process computer known as OD-12 (OD - on demand) tied in. with the reactor operation. Hhile the reactor is operating th.is computer has the capability of determining power distribution every four

*hours and is programmed to determine every 2l1 hours (at 11: 00 p.~.) exposure or burnup and production of fuel assemblies: A
*disadvant:agc of this system is that during any outage, shutdown or reload, a manual input into the computer is required to update for the period of nonoperation. A monthly print.out is obtained from this program and these values arc utilized (possibly with .

some adjustment), for monthly ICA bun:iup,. production, and SNN . values at the reactor site. These numbers are then reconciled semiannually with the RICE printout data. A copy of each monthly OD-12 printout is iubmitted to the Commonwealth Edison Company otfic~. * * All forms NRC-41 repres~nting receipts and shipments for both Dresden 2 and 3 were. available and agreed to facility activit~ as reporte ICA balances are maintained monthly and reconciled to the OD-12 computer printou Review of Forrris NRC-741 revealed that all transfers of SNM have been to and from authorized recipients as requir-ed bi 10 CFR 70.4 .,

*.

10 CH~ 2.790 INFORMATION ~-=-- -- Material status reports (Forms NRC-742) have been prepared and

-~-- ---{~-~l~i~fei~i~~E-~~t~ynt~s~!~-~_o ~-~~-) -£;~~~~~ p~~{~~!_~_ii;i~~~=~t"io Forms NRC- 711 l f<?cI both Dresden 2 and 3 have been 1pl;'".e.parcd* 1'!Pf1 dJstribu(:ed as required by 10 CFR }0.54 and special inst:rur.t-ioQ The licensee records system provides* sufficien't. information to comply with the requirements of"lO CFR Part 70.as they pertain to nuclear power reactor The licensee reconciles balances monthly with the Process Com-puter (OD~l2) Printout_and semiannually with the RICE computer printout. During periods of reloading and sus.tained shutdown reconcilation.with the RICE computer printout is also accomplishe The at.tached Exhibits A, B, C, and b reflect the Dresden*2 and 3 activity for enriched uranium and plt1tonium for the period of insp~ctio The following information is a reconcilation of the fuel assembly activity for both Dresden 2 and 3 for the audit period (July 1, 1972 - October 31, 1975)

Dresden 2, License No. DPR-19: No. of fuel assemblies previous inspection (053-237/72-06) 1477 No. of fuel assemblies received 156 _No. of fuel assemblies shipped 249 Dresden 2 Balance on hand 10/31/7 Dresden 3, License No; DPR-24: No. of fuel assemblies previous inspection (053-249/72-06) 724 No. ~[ fuel assemblies received 45 No. of fuel assemblies shipp.ed 32 Dresden J Balance on hand 10/31/75 1145 Also shipped from the Dresden J account to General Electric Morris

*****

Opetation on March 1,. 1973~ was the 449 fuel rods ori hand durin the previous inspection. This data in not included in the abov~ assembly balance . cu*: 2.790 INFQR;\*\ATIOH

10 CFR ?..7.90 lt\IFORMATIOt~J

... - - - - - - - - - - - - - _- *- - - - - - - - - - - - - - - -

=.~--

. .

As *of the i.nspec tion, location of fuel assemblies *on han~l for both Dresden 2 and 3 was as follows:

 ~-----
 .
  .

Dresden 2:

    -- *----- -- --- *-- - *--- -- ------- - --*- --------- --- ---

In Reactor Core I~1 Fuel -Pool Total i384 Dresden 3: In Reactor Core 724-In Fuel Pool 421 Total 1145

 * There ~as n6 cold f~el in either the Dresd~n 2 -0r 3 fuel vault.*

License No. DPR-19 (Dresden 2) authorize~ possession of 6,000 kilograms of *u-ranitim 235 and as of O.ctober 31, 1975 possessed 3,897.087 kilograms. License No. DPR-25 (Dresd~n 3) authorizes possession of 5,000 kilograms of uranium 235 and as of October 31, 1975 po~sessed 3,112.910 kilogram Management of Material Control System The licensee by his own procedures requires a company auditor to_ participat~ and test inventory pra~tices during the required . annual inventory and initial fueling, refueling or rearrangement of fuel in the reactor; buring the annual in~entory of Dresden 2 and 3 conducted May 15 and 16, 1975, t"-'O company auditors partiCipate The findings were reported in a letter from the Company Auditor to the Nuclear Materials Safeguards Manager dated July 16, 1975 .. Only a minor p~oblem, of dccipheri~g a couple of fuel a~sembly . setial nu~bers in the fuel pbol was encountered by the auditors and this was imrnediateh correcte Each time a company audito~ participates in a fuel loading, he is accompani0d by a representative fro~ the Arthur And~rson Compan Dresden 3, License No. DPR-25 experi~nced a loss, as previously noted,. of _cme fuel loading chambe1:* containing two. grams of highly enriched uranium. The licensee has .been advised to report this as an accidental ioss on the enric.hed uranium material status rep6rt for th~ period ending Decemher jl, 197 . .

    - 15 -
        *r..,..-*

I

*.
; '

10 CFf~ 2.790 l~ffORM1\TIOl~l Summar>' of: E_v~ri-~s Involving Lost Fuel Load inf.' Chimher (FLC) August 6, 197S. During rcloadii1g of Dresden 3 Uhit, fuel handlers were looking for five FLC's in anticipation that they may be used. Four were located, but FLC No. 6S7900S could ncit be located. Fuel Handling Forema~ notified the Nuclear Materi~ls Custodian and the Assistarit Superintendent that the FLC c6uld ~ot be loc~fed and the following two decisions were made: Complete Dresden 3 core reloading. The FLC's are under the jurisdication of Fuel Handling-Foreman. Consequently,

 * fuel handlers (union persbnnel) only could .coriduct
 .search. Management personnel coul~ n6t conduct search with~ut fuel handling personne Fuel Handling Foreman
 .is considered .managemen To dectare the FLC missing, not lost, to Station Super-intendent. Consequently, no report would be require *.. The search was resumed bn August 26, 197S, (20 days after s~art of reloading) ~nd continued until Sep~emher 1, 197 Three separate searchcs.comp~ising team of 3 to 10 handling personnel \:,ere conducted. This was because management could not open SS-gallon drums (union requirement).

The searche~ were considered extensive by the l{censee but not entirely inclusive because both the barrel area containing* S5-gallon drums and third fl6or ~f refueling building contain-ing 55-gallon drums were considered possibly severely contaminated areas and were not ~earched at that t{m . September 1, 197S. The Dresden Unit. l was.shut.down because of a crack in six-inch cleanu~ line and a decision was made to utilize f0el handlers to stp and reload Unit 1 fuel-(duration: September 1. - 2S, 197S). Fuel Handling Quarterly Personnel exposure review was co~ductc<l about September 30 and a decision was made that fuel handlers might exceed quarteriy limits if search c~ritinued at this time. This

 .resulted in a further delay of about a week.

,,*,

   - 16 -

r~ . I

=e-----.-------------_ Fuel handlers were further required for a Unit 1 outage

 -~~urat_~~~l_'._ __o_ct?~_E:!i::_ ~---=:~_~7_5_~ :_ ___ __-___ -~- ------~------~ ____________________ --:------~- October 7, 1975. A completed search of the reactor building with the exception df the two possibly severely contaminated areas.was mad . October 8, ~975. The two contaminated are~s were serirched with negative results. Another tomplctc search of re~ctor buildirig was conducted, prio~ t6 notifications of the loss to an onsite Region Ill inspectio According to 10 CFR 70.52, each licensee shall report immediately to the NRC Regional Director, by telephone, trilegram or teletype, any loss of special nucleai material. The time pe~iod from August 6, 1975, (licensee first noted that the FLC could not be located) to October 8, 1975, (reported loss to NRC) does .not*

consti'tute "inm1ediately" as referred to in 10 CFR 70. 52, but their letter of*October* 17, 1975, from B. B. Stephenson~ S~per intendent, to James G. Keppler, Region III Director, does ai;>pear responsive to corrective actions pertaining to the prevention 6f * a similar loss of an FL Attachments: Exhibits A through D

    .:. . 17 -*
  ....

10 CFR 2./90 lt'.JFOPJr.1\TION Dresden 2 ~-~- - - . - - - - - - ~ --~_:-~~-eommonwFa-lth--r:cltson-eom1Yany-*--=--YVE--:--*-.-------- ---~--------:---- -

* *. Material Ilalance Report - Privately Owned Enriched Uranium *  * *
 * * For Period 7/1/72 - 10/31/75 No. of  Grams Fuel As~ u U-235
      - --

Beginning Inventory 7/l_/72 1, 4 77 283, 145, 722 5,428,409 Re".cipts 156 ~872,54lf 710, 885 Total* to Account For _!_,633 -31220181266 6,1391294 Exhibit A

**'*"

--- ~ ~.**'. .. . -

Dresden 2 ~-- - -~--~-- ------- - - -- ------- -*-- ----- - - - - ------- *---------* Commonwealth Edison Company - YVE Material Balance Report - Privately 0*~1ed Plutonium For Perio<l 7/1/72 - 10/Jl/75

    *crams Pu  Isotope Begin~~ng Inventory 7/1/72 359,607  327,904 Production  727' 385  560,174 Receipts  -0-  -0-:-

Total to Account For 1,086,992 888,078 Shipments 105,355 94,507 Ending Inventory 10/31/75 981,637 793,571 e Total Accounted For 1,086,992 88~078

     . Exhibit B
* ..

10 CF" ...... *

   *r, 2:1~>0 lhJFO,~/*.i\'/\JIOJ\J'

Dre;den 3

=e-- -----------:-- --.---------- ---eommonwea-ltlr-Edtson-:-Company----Y-V-F---*---.. - --- --- - -------- - ------ ---

Material Balance Report for Privately Owned Enriched Uranium Fcir Period 7/1/72 ~ 10/31/75 No. of Grams Fuel Assy u U-235

 * Begihning Inventory 7/1/75  724 141,160,198 . 2,523, 727 Receipts   453 85,016,495 1,838,747 Total to Account For  1, 177 226,176,693 4,362,474 Shipments   32 7,761,452 169,508*

Accidental Loss !:_/ Burn up 2,035,036 1,080,054 Ending Inventory 10/31/75 1,145 216~380,203 3,112!910 e Total Accounted For 1, 177 .. 226,176,693 4,362,474 Jj Loss of fuel loading chamber No. 657900 Exhibit C r ': '*'

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. .. ..
..
 "":-
' . \ ..'~

10 CFR 2.790 INr-ORMATIOr~I Dresden 3-c9---------- ---.------:---_ --------:- ~-- --- commori~.ie~-lrt11:---Ea1son -cori1pany---.---- :--------------------:--- - --

 . * Material Balance Report* - Privately Owned Plutonium YVF  * *
*    For Period 7/1/72 ~ 10/21/75 Crams Pu  Isotope Beginning Inventory 7/1/72 275,700 270,900'

Receipts 80,766 72' 368 Production 542,975 377,801 Total.to Account For 721, 801 Ending Inventory 10/31/75 899,"141 721,069 Total Accounted For 899,441 721,069 Exhibit D

--~,
...,;.*
  . I 10 CER 2 790 lt'-:FO!U,\;\i 1(>t*~ *
*': '**
      .

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