ML17317A909

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IE Insp 50-316/78-35 on 781129-1201.Noncompliance Noted: Improper Procedure Used in Completing Form NRC-742 Re Special Nuclear Matl Handled by Licensee
ML17317A909
Person / Time
Site: Cook American Electric Power icon.png
Issue date: 01/09/1979
From: Finley A, Hind J, Patterson J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17317A908 List:
References
50-316-78-35, NUDOCS 7901290273
Download: ML17317A909 (14)


See also: IR 05000316/1978035

Text

U.S.

NUCLEAR REGULATORY COMMISSION

OFFICE

OF INSPECTION AND ENFORCEMENT

REGION III

Report

No. 50-316/78-35>

Docket No. 50-316

Licensee:

American Electric Power Service

Corporation

Indiana

and Michigan Power

Company

2 Broadway

New York, NY

10004

License

No.

DPR-74

Facility Name:

Donald

C.

Cook Nuclear Plant, Unit 2

Inspection

At,:

Donald

C.

Cook Si.te,

Bridgman,

MI

Inspection

Conducted:

November

29-December

1,

1978

Inspectors:

A.

G. Finley

\\

J.

P. Patterson

.c~'.

('pproved

By:

.

A.

ind, Chief

Safeguards

Branch

Z/pip J

y'izp)

ill ~

Ins ection

Summar

Ins ection on November

29-December

1

1978

(Re ort No. 50-316/78-35)

Areas Ins ected:

Material control and accountability including facility

organization

and operation;

measurement

and controls;

storage

and inter-

nal controls;

inventory and inventory verification; records

and reports;

management

of material control system

and shipping and receiving.

The

inspection involved 32 inspector-hours

onsite

by two NRC

inspectors'esults:

Of the seven

areas

inspected,

no apparent

items of noncompli-

ance or deviations

were. identified in six areas;

one apparent

item of

noncompliance/deficiency

failure to correctly report receipt activity

on the semi-annual

Form NRC-742

(Paragraph

7).

Details (Part 2.790(d) Information)

S-F3-78-254

Copy Q

of

7

copies

Pages.

THIS DOCUMENT IS NOT TO BE

REPRODUCED WITHOUT SPECIFIC

APPROVAL OF RIII

DETAILS

1.

Persons

Contacted

~:E. Smarrella,

Technical Supervisor

Dr. V. Vanderburg;

Nuclear Engineer

  • C. Ross,

Nuclear Haterials

Manager

"'T. Allen, Performance

Engineer

+K, Baker,

NRC Resident

Inspector

W. Gillette, Thermal Engineer

  • Denotes attendance

at exit interview.

2.

Facilit

Or anization

and

0 eration

Overall responsibility for all plant operations is vested in the

Indiana

and Michigan Electric Company with the plant organization

under the functional direction of American Electric Power Service

Corporation

(AEPSC), subsidiary

and service organization of the

American Electric Power

Company

(AEP).

The Nuclear Materials Management

Group

(NMMG), has responsibility

for control and accountability of SNM and is functionally respon-

sible to the Treasurer,

AEPSC.

The %KG is comprised of three

members of the reactor site organization

(Plant Manager,

Technical

Supervisor

and Nuclear Materials Manager) plus

a fourth member of

the

NMMG, the Fuels Material Control Manager,

AEPSC, designated

by

the Section

Head,

Nuclear Fuels

Management,

AEP.

At the reactor

site the Plant Manager

and Technical Supervisor

are permanent

positions with the Nuclear Materials Manager designated

in writing

by the Plant Manager.

ICA Custodians

are designated

in writing by

the Plant Manager

as positions within the reactor site organization.

Control and accountability of SNM is maintained

on an Item Control

Area (ICA) basis with designated

ICA custodians

responsible for

each area.

The new fuel vault as part of ICA I and the spent fuel

pool as part of ICA IV are utilized for both Units 1 and

2.

ICA

designations

(formerly MBA designations),

at the

D.

C.

Cook Nuclear

Facility are

as listed below:

ICA I New fuel assembly

and movable miniature neutron flux

detector receiving,

inspection

and storage

areas.

ICA II Uni.t 1 reactor,

seal table area

and refueling cavity.

ICA III Unit

2 reactor,

seal table area

and refueling cavity.

ICA IV Spent fuel pit, decontamination

area,

drumming area

and shipping area.

Part

70 License Sly-1753 (for storage

only) was replaced with oper-

ating License

DPR-'74 effective December

23, 1977, with an expiration

date of March 25,,-.2009.

Criticality was achieved for Unit 2 on

March 10,

1978.

All changes

to the

SNH accountability

system must be examined

and

approved

by the

NHHG.

Cumulative burnup

and production values

resulting in isotopic content is the responsibility of the Fuels

Material Control Manager,

AEPSC based

on reactor operating data.

AEPSC issues

a quarterly computerized

burnup

and production report

to the Nuclear Materials Manager in MJO/MTU, cumulative energy

consumed

in BTU, the individual fuel assembly,

region

and total

core isotopic content of SNH in grams.

Semi-annual

audits of accountability records

are conducted in

conjunction with the preparation

of Forms

NRC-742 by the corporate

audit division under supervision of the Treasurer,

AEPSC.

Individual fuel assembly

cards .reflecting date fuel received,

original

SNM values,

fuel identification, location and all fuel

moves are maintained

as perpetual

records.

The licensee's

current

procedures

updated

by revision No. 2, dated

June

16,

1978 were

considered

acceptable

and capable of accounting for SNM possessed

under License

DPR-74.

The licensee

has confined possession

and

use of SNH to the locations

and purposes

authorized

by license.

3.

Measurement

and Controls

Monthly reports which contained daily inputs of thermal power data

were reviewed

by the inspector for the short operating

time of

Unit 2 reactor.

Gross

thermal power was reported

by the licensee

starting in March,

1978 although operating

time was at reduced

power levels until July,

1978.

No discrepancies

were noted

from

the in-plant data reports

and the amounts reported

to the monthly

NRC Graybook.

Uranium burnup

and plutonium production are calculated

based

on

measurements

obtained

from each of the 193 assemblies,

from each

of the three regions of the core,

and cumulatively for the entire

core.

Plant operating data is then sent to the

AEPSC Nuclear

Division Fuel Management

Section for calculation

and extrapolation

into a computer printout.

The data thus generated

is reported

on

a quarterly basis

to the

NMM at the reactor site and represents

the

isotopic composition of the uranium and plutonium isotopes.

A summary

sheet lists the current core composition

by isotope including those

required

to be reported

on the Material Status

Report

(NRC-742).

1

The 2,212 megawatt days

thermal (NKt) generated

from March 19 to

March 31,

1978 was included in the total

MWDt generated

through

September

30,

197K;

Comparison

between

NRC and plant generated

data for uranium burnup

and total plutonium production is made in

the following table.

Agreement is satisfactory for this beginning

operation of Unit 2.

D.

C.

Cook Unit 2 Reactor

In Grams

Time Period

Unit Two

NRC

% Diff.

3/19/78-9/30/78

MWD (thermal)

314,571

Uranium

Uranium-235

Plutonium

536,157

364,943

196,286

513,172

330,534

179,727

-4.29

-9.43

-8.40

4.

Shi

in

and Receivin

There were no physical receipts

or shipments of

SNM for the period

of inspection.

There were,

however,

76 corrected

Forms

NRC-741

issued

by the fuel supplier

(Westinghouse)

to adjust

the 46 Forms

NRC-741 involved in the 193 fuel assemblies

received for the initial

core loading.

These

adjustments

were reflected in facility records

and

Forms

NRC-741 receipted within ten days

and returned to the

shipper

and

DOE Oak Ridge,

Tennessee

as required.

Instructions for

Reporting Nuclear Material Transfers

on Form NRC/DOE-741;

have been

incorporated into the facility's Special Nuclear Material Account-

ability Manual.

5.

Stora

e and Internal Control

The licensee

maintains

a system of internal control of

SNM by ICA

and total plant which provides

knowledge of the quantity, identity

and location of all

SNM possessed

under license.

Prenumbered

ICA

Transfer

Forms

and Internal Transfer

Forms are issued

and con-

trolled by the Nuclear Materials Manager.

The ICA Transfer

Form

provides administrative control over

SNM moved into, out of, or

between ICA's.

The Internal Transfer

Form controls movement of

SNM within ICA's.j. Both these internal forms are initiated by

either the Nuclear Materials Manager or responsible

Item Control

Area Custodian.

Soth the ICA Transfer

Form and Internal Transfer

Form must be signed

by the Technical Superintendent

or Plant Manager

before it is considered

approved

and before any movement

takes

place except for temporary storage

under the responsibility of the

Fuel Handling Supervisor.

Other exceptions

not requiring prepar-

ation of the Internal Transfer

Form is movement of

SNM in an

ICA

for storage

less

than

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

and during reactor core loadings

when fuel shuffle data sheets

are utilized and approved

by the

Plant Manager.

Except for receipt of new fuel stored in ICA I,

both the Internal Transfer

Forms

and

ICA Transfer

Forms are valid

for only ten days after approval.

The preplanned

Unit 2 core loading

(December

24,

1977 to January

2,

1978),

agreed

by serial

number

and location to the initial core

loading sheets

and fuel assembly

cards

and no exceptions

were noted.

All 193 fuel assemblies

were accounted for as being in the reactor.

In a letter dated

August 24, 1978,

from the Plant Manager, indi-

vidual ICA Custodians

for the four ICA's were designated

as

required'he

Fuels Material Control Manager

was designated

in writing by the

Section

Head, Nuclear Fuels

Management,

AEP in a letter dated

September

22,

1977.

~Invenrnr

The first core loading,

Cycle

1 of Unit 2 Reactor,

was verified by

the Nuclear Materials Manager

on January

3, 1978.

Initial criti-

cality was obtained

on March 10,

1978 and full commercial

power

operation

began July 1, 1978. 'he fuel inventory consists of the

193 fuel assemblies

in Unit 2.

The balance of other

SNM items

considered

part of inventory consists

of Movable Miniature Neutron

Flux Detectors

(MMNFD), discrete serial

number identified items

each containing less

than reportable

amounts of U-235.

These

detectors

are used interchangeably

in either reactor

and are

accounted

for only by piece count

and serial

number.

To verify the current Unit 2 reactor core,

the inspector

observed

the videotape

made of Cycle

1 core loading.

The videotape listing

was verified with the official core loading diagram verified pre-

viously by the

NMH and accepted

by licensee

management

as

the

current Unit 2 core loading.

No errors were detected

from the

actual core mapping as

shown

on the videotape

and the schematic

core

diagram verified by

NMM.

The only other part of the

SNM inventory

verified by the iqspector consisted

of 13 cold MMNFD's, identified

by serial

numbers 'written on the outer packaging;

stored in a locked

metal cabinet in the cold fuel vault.

The balance of the MMNFD's,

32, are distributed to either reactor unit or as irradiated items

stored in shielded

casks in the Drumming Storage

Area.

Procedures

for physical inventories

are included in Section 4.2.1,

Page

19 of the Special Nuclear Material Accountability Manual for

the Donald

C.

Cook Nuclear Plant,

Revision No. 2, June

16,

1978.

ICA-I Receiving, Inspection

and Storage

Areas for new fuel

assemblies

and

HMNFD's must

be physically inventoried at least

quarterly.

Unit 1 Reactor

and Unit 2 Reactor constituting ICA-II

and ICA-III, respectively,

are inventoried prior to replacement

of

the reactor vessel

each

time the head is removed for refueling

operations.

Piece

counts

and listing of identification numbers

of each

SNH unit shall constitute

the physical inventory of ICA-I,

II and III.

For ICA-IV which includes

the Spent Fuel Pit, Decon-

tamination Area,

Drumming Area and Shipping Area piece-count

of fuel

assemblies

along with their locations shall constitute

a physical

inventory.

Gram quantities of SNH by ICA are recorded

on the

SNM Summary Account.

The MMNFD's are listed only by number, currently 45 total,

as referred

to above.

The fuel assemblies

are listed by number

and weights for

each

ICA.

The

SNH Summary Account is completed

on

a quarterly basis

and represents

the total gram quantities of SNH for the entire nuclear

plant.

Records

and

Re orts

The licensee

was found in apparent

noncompliance with lO,CFR 70.53

and related instructions for not correctly reflecting the receipt

activity for the period October 1,

1977 to March 31,

1978 on the

attached

subschedules.

Also,

13 corrected

documents

dated April 6,

1978 were erroneously

included for activity reported

as of March 31,

1978, instead of the report period April 1, 1978 to September

30,

1978 as required.

Seventy six corrected

Forms

NRC-741

(13 dated

in April 1978) representing

adjustments

to previously received fuel

were not reflected

as part of the receipt activity on the attached

subschedule

for the period ending March 31,

1978.

Twenty two of

the corrections

involved

14 shipments

reported

as received at

original values for the period ending September

30,

1977.

Instead

of reflecting only the differences for these

22 corrections,

the

subschedules

again reflected

the original amounts

received

(minus

or plus) the adjustments,

thus including a major portion of

originally reported values.

The subschedule

did not reflect the

true activity {adjustment only) and no corrected

Forms

NRC-741

were documented.

,/he remaining shipments

Nos.

15 through 46 plus

corrected

copies

(54 corrected

copies)

did occur in the report

period ending March 31, 1978, but again,

none of these

corrected

copies were documented

to determine

how the amounts

received

on

documents

15 through

46 were accounted for.

The inspector did

determine that the total receipts

reported

on line 30 of the

Form NRC-742 was mathematically correct,

but not in agreement

with the larger figures reflected

on the attached

subschedules.

This determination

was

made

by referring to the original shipping

documents

and netting all subsequent

corrections

(many had

2

corrections).

In auditing the Forms

NRC-742 for any given six month period,

absence

of the corrected

Forms

NRC-741 from the document listing

provides

no assurance

to the

DOE,

Oak Ridge personnel

that all

documents

are accounted for during the six month period being

audited.

The

SNM summary account maintained

by the Nuclear Materials Manager

on a quarterly basis

summarizes

information contained in ICA transfer

forms, internal transfer

forms and the individual fuel assembly

card.

This summary provides

SNM values

and number of

SNM items contained

in each

ICA.

SNM values

are maintained at the reactor site,

supported

by docu-

mentation

on both

an ICA and total plant basis.

The only external

activity for the period of inspection

was

76 corrected

Forms

NRC-741

to adjust values for the previously received

193 fuel assemblies

on 46 Forms

NRC-741 received in the period August 25,

1977 to

November 17, 1977.

All 76 Forms

NRC-741 representing

corrections

to previously received

data were reviewed

and determinations

made

that they were receipted for and filed as required

by 10 CFR 70'4.

All adjustments

agreed

to licensee

records,

but the licensee

was

found in apparent

noncompliance for not correctly reporting these

data in accordance

with 10 CFR 70.54

and referenced

instructions.

Burnup and production data are provided quarterly in the form of

computer printouts prepared

by AEPSC from plant operating data.

This report reflects quarterly burnup

and production data in grams

on a cumulative basis for individual fuel assemblies,

region and

total core.

Balances

were determined

and agreed with Forms

NRC-742

for the periods

ending March 31 and

September

30,

1978.

Balances

for both enriched

uranium and plutonium are reflected

on the attached

Exhibits A and

B for License

DPR-74.

The licensee's

record

system

and material control procedures

provide

sufficient informakion to comply with the requirements

of 10 CFR Part 70 as they pertain to a nuclear

power reactor.

Mana

ement of Material Control

S stem

The licensee

has

a requirement for conducting semiannual audits of

the accountability records

under the supervision of the Treasurer

of AEPSC.

Independent

corporate audits

are timed to take place

prior to the semiannual

reporting dates

(March 31 and September

30)

for Form NRC-742 to establish

Form NRC-742 accuracy prior to

signature

and submission

to NRC.

The initial core loading of

Unit 2 from December

24,

1977 to January

2,

1978 was witnessed

by

a member of the corporate

Special Audit Division.

An audit was

conducted April 11-14,

1978 by members of the Special Audit

Division to agree weight balances,

and burnup

and production cal-

culations for Unit 2 as of March 31,

1978.

Report issued in

April 1978 to management

reflected

no pertinent problems.

Audit

performed in October

1978 for verification of D.

C.

Cook Nuclear

Plant activity as of September

30,

1978 by the Special Audit

Division reported

to management

in November

1978 and

no problems

noted.

Exit Interview

The inspectors

met with Mr. D. Shaller, Plant Manager,

Mr. J. Stietzel,

QA Supervisor

and licensee

representatives

and the

NRC Resident

Inspector

(denoted in Paragraph

1) at the conclusion of the inspec-

tion on December

1, 1978.

Explanations

and examples

were given for

the apparent

item of noncompliance

(deficiency) for not correctly

reporting the receipt activity on the subschedule

of the Form

NRC-742 for the period ending March 31, 1978,

and for including

subsequent

receipt activity (April business)

on the Form NRC-742

for the period ending March 31,

1978.

The scope of the inspection including the findings resulting from

reviews

and tests

conducted

by the inspectors

were noted in the

areas

of physical inventory, shipping and receiving, internal

control, records

and reports

and calculations for uranium depletion

and plutonium production.

It was further noted that the procedures

for SNM accountability

and control were found current

and

acceptable'nd

that independent

audits

to verify SNM holdings

on the semiannual

Material Status

Reports

had been

conducted

and reported

as required

by procedure.

Attachment:

Exhibits

A and

B

(Part 2.790(d) Information)

Donald

C.

Cook Nuclear Plant

Unit 2

Material Balance Statement

Enriched

Uranium DPR-74

For Period 11/23/77

9/30/78

Beginning Inventory 117t23/77

Number

Of Fuel

Assemblies

193

Enriched

Uranium

In Grams

U

U-235

88,684,164

2,308,572

Receipts

-0-

6 969

(1 913)-1/

Total to Account For

193

88 691,133 ',306

659

Shipments

-0-

-0-

Burnup

536,157

364,943

Ending Inventory 9/30/78

193

88 154

976

1 941

716

Total Accounted

For

193

88

691 133

2 306

659

1/

Includes adjustments

to previously received fuel.

S-F3-78-255

Copy 3

of

7

copies

/

Page.

THIS DOCUMENT IS

NOT TO BE

REPRODUCED WITHOUT SPECIFIC

APPROVAL OF RIII

EXHIBIT A

Donald

C.

Cook Nuclear Plant

Unit 2

Material Balance

Statement

Plutonium DPR-74

For Period 11/23/77

9/30/78

Beginning Inventory 10/1/77

Pu

-0-

Plutonium

In Grams

~2soeo

e

-0-

Production

196

286

178 485

Total to Account For

196 286

178 485

Ending Inventory 9/30/78

196 286

178,485

Total Accounted

For

196 286

178 485

S-F3-78-256

Copy D

of

7

copies

/

Page.

THIS DOCUMENT IS NOT TO BE

REPRODUCED WITHOUT SPECIFIC

APPROVAL OF RIII

EXHIBIT B

4flI

I

(~*'

P