IR 05000259/1989055

Forwards 1991 Final SNM Accountability Rept for Eight in-core Detectors in Radwaste Evaporation Bldg Re Notice of Violation & Proposed Imposition of Civil Penalty Per Insp Repts 50-259/89-55,50-260/89-55 & 50-296/89-55

ML18033B683
Person / Time
Site:	Browns Ferry
Issue date:	04/17/1991
From:	Zeringue O TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-89-239, NUDOCS 9104260087
Download: ML18033B683 (12)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM.~~SUBJECT: Forwards'1991

'final SNM accountability rept for eight in-core detectors in radwaste evaporation bldg re notice of violation 6 proposed imposition of civil penalty per Insp Repts 50-259/89-55.50-260/89-55

&50-296/89-55.

DISTRIBUTION

'CODE: IE14D'OPIES RECEIVED:LTR J ENCL/SIZE: TITLE: Enforcement.

Action Non-2.790-Licensee Response,.

A 05000259 05000260 D 05000296 D NOTES 1'Copy each to: B.Wilson,'S.

BLACK 1 Copy each to: S.Black,B.WILSON 1 Copy each to: S.Black,B.WILSON REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS).CESSION NBR:9104260087 DOC.DATE: 91/04/17 NOTARIZED:

NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station,-Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296-Browns,Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION ZERINGUE,O.J,.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)RECIPIENT ID CODE/NAME KREBS,M.ROSS,T.COPIES LTTR ENCL 1'1 1 1 RECIPIENT ID CODE/NAME HEBDON,F COPIES LTTR ENCL 1 1 ERNAL: AEOD/DOA DEDRO NRR/PMAS/ILRB12 OE DIR~RGN..RS~1 1 1 1 1" 1 1 1 1.1 1 1 AEOD/DSP/TPAB, 1 1 NRR/DOEA/OEAB11 1 1 NUDOCS-ABSTRACT 1 1 OE FILE'1 1 1 RGN2 FILE 03 1 1 EXTERNAL: NRC PDR NOTES: 5 5 NSIC 1'1 D NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE lVASTE!CONTACT THE DOCUMENT CONTROL DESK, t ROOXI Pl-37 (EXT.20079)TO ELIMINATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TOTAL NUMBER OF COPIES REQUIRED: LTTR 21 ENCL 21 D D

Tennessee vattey Autnority, post Othe Sos 2000 Deca:ut.A!abatna 35609 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.20555 Gentlemen:

In the Matter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROWS FERRY NUCLEAR PLANT (BFN)-1991 FINAL SPECIAL NUCLEAR MATERIAL (SNM)ACCOUNTABILITY REPORT On November 8, 1989, TVA determined that eight incore detectors in the Radwaste Evaporator Building (REB)were not accounted for in the 1986 SNM baseline inventory.

A subsequent search in the REB revealed additional SNM inventory deficien'cies.

On May 2, 1990, NRC transmitted Enforcement Action (EA)89-239 entitled"Notice of Violation and Proposed Imposition of Civil Penalty" for NRC Inspection Report Nos.50-259, 260, 296/89-55 for lack of control of SNM.The Enclosure to this letter provides TVA's final 1991 SNM Accountability Report.This report documents the corrective actions taken to address the referenced NOV.Based on the completion of these corrective actions, TVA concludes that an accurate and manageable SNM program has been established at BFN, and that the corrective actions taken will preclude further violations of.this type.Furthermore, to provide an additional level of confidence the BFN Quality Assurance organization performed an independent review of the SNM inventory and program.In a telephone conversation, TVA and NRC personnel agreed to a new submittal date of April 18, 1991.I104~60087 9104i7 t.'DR t-"tDOCK 0 00025~PDR.((

U.S.Nuclear Regulatory Commission APR f.7 m If you have any questions concerning this SNM report, please telephone Patrick P.Carier't (205)729-3570.Very truly yours, TENNESSEE VALLEY AUTHORITY/pe/0.J.Zer'ue, Vic Pres dent Brp s-rry Operat ons cc: (Enclosure)

Ms.S.C.Black, Deputy Director Project Directorate 11-4 U.S.Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike, Rockville, Maryland 20852 NRC Resident Inspector Brooms"Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000-

'David R.McGuire (enclosure)

Chief Safeguards Section U.S.Nuclear Regulatory Commission Region II 101 Marietta Street NW, Suite 2900 Atlanta, Georgia 30323 Mr.Thierry M.Ross, Project Manager U.S.Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Mary'land 20852 Mr.B.A.Wilson, Project Chief U.S.Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323

ENCLOSURE'ennessee Valley Authority Browns Ferry Nuclear Plant (BFN)1991 Final Special Nuclear Material (SNM)4 I.BACKGROUND On November 8, 1989, TVA determined that eight incore detectors were not accounted for in the 1986 SNM baseline inventory.

Additional searches conducted November 26-29, 1989 of 21 SNM storage drums identified further SNM inventory deficiencies.

This'information was submitted to NRC in TVA's December 1, 1989 report on SNM accountability and in a December 8, 1989 voluntary licensee event report,(LER).

Subsequently, in Inspection Report 50-259, 260, 296/89-55 NRC issued a notice of violation (NOV)and proposed'imposition of civil penalty for lack of SNM control.On June 1, 1990, TVA submitted its reply to the NOV and, proposed imposition of civil penalty.In these submittals BFN acknowledged weaknesses in its 1986 SNM baseline inventory and committed to'significant corrective actions.II.CORRECTIVE ACTIONS TVA took a proactive role to ensure control of the SNM at BFN.An action plan defining TVA's interim recovery plan was developed and immediate corrective actions were taken to support the control of SNM accountability.

Specifically, areas where SNM might have been stored and which could present a significant radiological hazard to onsite personnel were searched for SNM items.This included the traversing incore probe (TIP)rooms and the drywell undervessel areas in all three units, the Radwaste Evaporator Building (REB), the Power-Stores warehouse SNM storage area, the Chemical Laboratory SNM.vault, the RADCON Instrument Lab SNM cabinet;and the local power'ange monitor (LPRM)box on the refuel floo Page 2 of 4 Additionally, SNM drums in the REB were segregated from non-SNM radwaste.The SNM drums were emptied and the SNM items (detectors)

were separated from other waste including the detector cables, canisters and shielding bricks.The SNM was labeled and placed in one drum which=is currently stored in an area separate from non-SNM waste.Discrepancies between the previous BFN inventory list and the drum contents were reported to NRC in LER 259/89016.

TVA also identified long-term corrective actions to prevent similar events from recurring in the future.The corrective actions included: (1)providing SNM training for personnel involved in the search and inventory of SNM, (2)reviewing previous corrective actions for adequacy;.

(3)monitoring the SNM inventory and program by Quality Assurance (QA)to ensure a high confidence level, (4)developing an action plan for disposal of unusable SNM items, (5)establishing a temporary storage area for'SNM, and (6)performing a new baseline inventory of SNM.These actions have been completed, and are discussed in more detail below.Reactor Engineering personnel were trained to identify SNM and byproduct source material (BSM)such as TIPs, LPRMs, source range monitors (SRMs),,intermediate range monitors (IRMs), and fuel ,loading chambers (FLCs).Upon completion of this training a quiz was given to assess each persons knowledge.

The results of the quiz determined if they were qualified to search for SNM and BSM.All Reactor Engineering personnel involved in the inventory of SNM have been qualified.

Also, personnel from other site organizations were trained for the purpose of conducting a'site search.The training and testing of these personnel were the same as mentioned'bove.

2.Review of Previous Corrective Actions Corrective actions for previous violations involving control of SNM were reviewed for bad assumptions, weak or missing information, and inadequate or incomplete program fixes.Basic lessons learned from these events were incorporated in the'ngoing SNM inventory.

These general lessons were: inventories should entail a search of the entire area in question;when inventorying or searching for an item the personnel involved should have first-hand experience in recognizing the item and any packaging that it might be inside;and items should be removed from containers for countin Page 3 of 4 3.gA Review The BFN QA organization performed an independent assessment of the overall SNM program, the methodology for conducting the 1991 SNM baseline inventory, and initial portions of.the physical inventory to ensure that the control and accountability of SNM were-adequate at BFN.QA performed this assessment using three major objectives:

Procedural review to determine adequacy and proper implementation of upper tier requirements and regulatory commitments;

~~Accountability/inventory review to determine, if fuel and non fuel requirements were met, and Programmatic review to determine root cause and further weaknesses, if any.'lthough this independent QA assessment identified areas where further activities were needed, the methodology for completion of the 1991 SNM Baseline Inventory was found acceptable.

The identified areas for improvement were subsequently resolved during performance of the inventory.'

4.SNM Dis osal Plan An action plan was developed to dispose'f unusable SNM which is located in the REB and the spent fuel storage pools.SNM located in the REB has been identified, consolidated and stored for off-site disposal.In addition, a schedule for cleaning out BFN's spent fuel storage pools has been developed.

5.Tem orar Stora e Area A temporary storage area for SNM was established in the REB.This area is controlled as a locked, high radiation area in accordance with BFN's Technical Specifications.

In addition, the temporary storage area is controlled as an item control area in accordance with the SNM program.These actions provide adequate control to ensure that only authorized plant personnel access the SNM storage area.R 1 1 SNM Baseline Inventor The 1991 SNM Baseline Inventory involved physical searches to identify the location of SNM, labeling of SNM and verification of SNM serial numbers where practica Page 4 of 4 The physical searches were conducted by several site organizations.

However, the main search of the Reactor Building, Turbine Building, Radwaste Buildings, refueling floor, and Power Stores Warehouse was,conducted by teams composed of Reactor Engineering and Radcon representatives.

These searches involved a daily planning session and generation of detailed maps'of each area searched.The maps depicted boxes, drums and other containers which were found in each area.Following completion of the searches, SNM was labeled and verified.'pecifically, the serial numbers of each of the installed TIPs, IRMs, and SRMs in Units 1, 2, and 3 were visually verified.The serial numbers of LPRMs in Unit 2 which can be seen by underwater, camera were also verified..

However, the serial numbers of Westinghouse LPRMs can not be read while the detector is installed because verifying the serial numbers would , involve removing the assemblies which is a destructive process.Therefore, these serial numbers were not verified.TVA instead assigned a unique serial number to these LPRMs to ensure accountability upon removal.Additionally, the LPRMs were quantit'atively verified by undervessel observation of the electrical connector ends.Spent fuel and used LPRMs in the spent fuel storage pools were verified by serial number and/or a positive piece count process.SNM items in the REB were consolidated into one drum which only contained lead shielding and'the individually bagged and labeled detectors.

Finally, SNM such as new detectors, sources, and FLCs was inventoried by physical observation and serial number.As a result of the-1991 SNM Baseline Inventory, BFN considers that it has positively identified each item of SNM on site.TVA is maintaining a record of SNM location, serial number, type, and last inventory date.III.SIHKARY TVA has completed the aforementioned immediate and long-term corrective actions.TVA considers these corrective actions will preclude further SNM accountability deficiencies.

Additionally, no SNM discrepancies were identified since the initial deficiencies were reported in LER 259/89016 dated December 8, 1989.Therefore, TVA concludes that it has established an accurate and maintainable SNM baseline inventory, and is in full compliance with provisions of 10 CFR 70.51(c).