ML18032A577
| ML18032A577 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 09/22/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709300414 | |
| Download: ML18032A577 (21) | |
Text
REGULATORY FORMATION DISTRIBUTION S EM (RIDS)
ACCESSION.NBR: 8709300414 DQC. DATE: 87/09/22 NOTARIZED:
NO DOCKET 0 FACIL: 50-259 Browns Ferry Nuclear Power Btationi Unit ii Tennessee 05000259 50-260 Browns Ferry Nuclear Power Stations Unit 2i Tennessee 05000260 50-296 BT owns Ferry Nuclear Power Stations Unit 3i Tennessee 05000296 AUTH. NAME AUTHOR AFFILIATION GRIDLEYs R.
Tennessee Valieg Auth or 1 tg REC IP. NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
SUBJECT:
Responds to concerns discussed at 870812 enForcement conFerence re SNM control 5 accountability. Chronology oF events associated w/870616 intermediate range monitor sh ip ment.
DISTRIBUTION CODE:
D030D COPIES RECEIVED: LTR I ENCL t
SIZE:
I TITLE:
TVA Facilities Routine CDl respDndence NOTES: Zwolinski 3 cg.
1 cg ea to: Axelradi Ebneteri S.
Richardson'iawi G. Zech> Qli OIA.
Zwolinski 3 cg. fey ea to: Axelradi Ebneteri S.
Richardson'iaw G. Zech Qli QIA.
Zwolinski 3 cg. fcg ea to:
Axelrad> Ebneter i S. Richardsoni Liawi G. Zechi Qli QI*.
0500025m 05000260 05000296 REC IP IENT ID CODE/NAME JAMERSONiC GEARS' INTERNAL: ACRS AEOD F
COPIES LTTR ENCL 1
1 1
1 1
1 1
1 REC IP IENT ID CODE/NAME PD BTANQi J ADM/LFMB OGC/HDS2 COPIES LTTR ENCL 1
1 1
1 1
0 1
0 EXTERNAL:
LPDR NSIC NOTES:
1 1
1 1
f2 12 NRC PDR TOTAL NUMBER OF COPIES REQUIRED:
LTTR 24 ENCL 22
~ I V
E I
TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 5N 157B Lookout Place SEP 82 1987 U.S. Nuclear. Regulatory Commission Attention:
Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Hatter of Tennessee Valley Authority
)
Docket Nos.
50-259
)
50-260
)
50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNIT 1, 2, AND 3 RESPONSE TO TOPICS DISCUSSED AT THE AUGUST 12, 1987 ENFORCEMENT CONFERENCE This letter is to provide TVA's response to NRC's concerns in the areas of Special Nuclear Material (SNM) control and accountability.
These concerns were expressed to TVA in a letter from G.
G.
Zech to S. A. White dated August 10,
- 1987, which transmitted IE Inspection Report No. 87-29.
These issues were discussed with Hr. Keppler and members of his staff at an Enforcement Conference held on August 12, 1987.
Enclosure 1 provides a chronology of events associated with the June 16, 1987 Intermediate Range Monitor (IRM) shipment, TVA's assessments of the root
- causes, and planned corrective actions.
Enclosure 2 describes exceptions TVA takes to some of the statements and conclusions in the report.
The June 16, 1987 incident was another manifestation of past problems with the control of nonfuel SNM at Browns Ferry.
These
- problems, which had become institutionalized through poor procedures, practices, and attitudes, have been difficult to correct.
- However, TVA is committed to establishing and maintaining a top quality SNM program, and has taken significant steps in that direction.
It is TVA's conclusion that the concerns expressed about the IRM incident do not raise significant questions about the overall adequacy of the corrective action program that TVA had underway in the SNM area.
As you are
- aware, TVA in October 1986 discovered that fission chambers containing SNM had been erroneously shipped offsite
~
As a result of this incident, TVA instituted a
comprehensive corrective action program.
This program included improved procedures,
- training, and site management control which at the time of the June 16, 1987 incident had not been fully implemented.
8709300424 870022 PDR ADOCK 05000259 PDR An Equal Opportunity Employer
I 1
~
U.S. Nuclear Regulatory Commission SEP 22 1987 That program has been further improved to address mistakes made during the June 16, 1987 IRM inventories.
Improvements include providing additional procedural guidance on inventory and training methods and more frequent inspections by the corporate program manager.
TVA has also reinventoried nonfuel SNM and found no significant problems, and is recreating SNM history records as completely as possible.
A list of commitments is provided in enclosure 3.
He do not recognize any other items described herein as commitments.
Please refer any questions to M. J.
May at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY Enclosures cc (Enclosures):
Mr. G.
G. Zech, Assistant Director Regional Inspections Division of TVA Projects Office of Special Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta St.,
NW, Suite 2900 Atlanta, Georgia 30323 R.-
- ridley, irector Nuclear Saf..ty, and. Licensing Mr. J.
A. Zwolinski, Assistant Director for Projects Division of TVA Projects Office of Special Projects U.S.
Nuclear Regulatory Commission 4350 East-Nest Highway ENN 322
- Bethesda, Maryland 20814 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant P.O.
Box 311
- Athens, Alabama 35611
~
~
~
~
ENCLOSURE, 1: -"
NRC INSPECTION REPORT NOSK 50-259/87-29, 50-260/87-29, 50-236/87-29 LETTER FROM G. G.'ECH,TO S.
AP WHITE DATED AUGUST 10, 1987'
SUMMARY
A comprehensive corrective action program was deueloped as a result of the October 1986 SNM incident.
At the time of the "June 1987 Intermediate Range Monitor (IRM) shipment, all aspects of thi.s. program were not fully implemented.
Implementation of.that program hajj:ontinued, and the program has been further improved to correct misRkes made during the IRM shipment.
The IRM inventory error was due primarily to a procedural caution against moving detectors.
That caution was based on a management decision that the inventory could be done without removing the
-ERMs, and that the cost of the IRMs warranted, this caution.;
Hindsight shows that this decision
, 'was 'in error.-
A poor decision also was made by a manager when a 'serial number discrepancy was identified between the June inventory, and earlier inventories; Addition'ally,'he -decision to focus -'increased management attention primarily on the shipping aspects of th'egSNM transfer proved to be incorrect, and communications during the event were imperfect.
These failures,'whether considered individually or.. collectively, did not result in a threat to the health and safety of the public, nor do they indicate a significant lack of management control o'f SNM.
The failures do indicate the need for increased attention to detail'n assigning and performing work and the need for improvements in training and procedures in specific areas.
~
~
II.
CHRONOLOGY During the week of June 8,
- 1987, BFN was contacted by another licensed facility concerning the loan or sale of five IRHs.
On June 15,
- 1987, BFN Power Stores contacted the maintenance organization to determine if sufficient IRM inventory was available at BFN to allow the sale of five
, IRHs.
Based on information provided by Power Stores, maintenance agreed
'o.the transaction.
The afternoon of June 16, 1987,, Power Stores contacted the SNM aide to inform him of the impending shipment.
The SNM aide then contacted the Assistant to the Technical Services Superintendent (Technical Services is the organization responsible for the control and accountability of SNM) and the Radwaste Sections Since the SNH aide was not able to remain at the plant site after normal working hours, he requested a Reactor Engineering Section co-op student to perform the SNM inventory for shipping the IRMs.
The SNM aide instructed the co-op student in the responsibilities of the SNM control and accountability program as delineated, in BFN Technical Instruction 14 (TI-14).
A Reactor Engineer who was trained and knowledgeable of the requirements of the SNH Control and Accountability Program became aware of the instructions being given to the co-op student.
He was concerned that she might not properly understand the requirements of the job.
The Reactor Engineer reinstructed the co-op student in the requi.rements of the SNH inventory necessary before shipping the IRMs offsite.
He then called the SNM Custodian (SNMC), who was at home that day, to inform him about the IRH shipment.
The SNMC thought at the time that the IRM shipment was being handled by the Reactor Engineer.
The Technical Services Superintendent, when informed of the requested IRM
- shipment, contacted the technical lead at the requesting licensed facility to confirm the stated immediate need for the IRMs.
Because of recent increased awareness in the SNM area and regulatory performance history in the radioactive material shipping area, the Technical Services Superintendent was primarily concerned with the transportation aspects of an SNM shipment and secondarily concerned from an SNM control and accountability viewpoint.
As a result of the concerns, increased management attention was focused on the SNM shipment process in the form of two additional Radwaste Controllers for this shipment, one of which was the Radwaste Section Supervisor.
Additionally, the Technical Services Superintendent was informed the Reactor Engineer would be staying to assist the co-op student.
The Reactor Engineer, after completing the required forms and reassuring himself that the co-op student understood the requirements for the job, left for the evening.
Subsequent to this, the Technical Services Superintendent informed the Plant Manager of the requested
- shipment, the confirmation of immediate
- need, anticipated trouble points, and the intention to hold additional personnel to ensure the shipping aspects of the transfer were properly executed.
The co-op student then met with the person who had been assigned to perform the function of Radwaste Controller for the IRM shipment.
The Radwaste Controller was familiar with this task, having performed a
similar function for SNM in a previous job at another BWR facility.
The co-op student then. called the SNMC to inform him she was going to do the inventory.
He asked if she needed assistance.
She replied that assistance would not be.needed and that she could do the inventory herself.
The co-op student, the Radwaste Controller, and a radiological control technician then went to meet a Power Stores employee at the SNM cage in the Power Stores warehouse.
The Radwaste Supervisor had suggested before their departure that they search for a shipping crate containing only five IRMs to minimize handling of detectors and to have a readily available shipping container.
The group found several crates of IRMs and source range monitors (SRMs) at the SNM cage.
They moved the crates around until a crate was found which had been marked as containing five IRMs.
The crate had been marked by the SNM aide during a previous SNM inventory and...indicated the serial numbers of five IRMs contained inside.
The crate was inventoried in accordance with TI-14, without removing the detectors from the crate, by locating the serial number of the instrument on the vendor-supplied ID tag attached to each detector.
The Radwaste Controller called out the serial
- number, and the co-op student recorded it.
After the Radwaste Controller had made a complete trip around the box searching for serial number tags and had found five IRMs, she asked the co-op student to confirm the IRM count.
The co-op student confirmed that they had counted five IRMs in the shipping crate.
At this point, the co-op student also recorded the serial numbers listed on the shipping crate.
A comparison between the just recorded serial numbers and those on the shipping crate was not performed.
The lid of the crate was
- replaced, and the personnel returned to their offices to complete the shipment paperwork.
While the co-op student was preparing the SNM forms required by TI-14, she noted a discrepancy in the serial numbers from their inventory.
The SNM history forms and the list of serial numbers written on the shipping crate were in full agreement.
- However, the inventory just performed did not agree with these records.
Specifically, the SNM history forms and the shipping crate did not show serial number TANCE1-005.
The just performed inventory did show TANCEl-005.
Conversely, the SNM records and shipping crate listed serial number TANCE1-003, but the just performed inventory did not.
The co-op student called the Radwaste Controller to confirm she had found TANCE1-005 and did not find TANCEl-003.
Subsequently, the co-op student returned to the warehouse and reinventoried the shipping crate.
This inventory agreed with the inventory performed earlier in the evening.
The.co-op student then contacted the SNMC and explained the discrepancy.
Based on this exchange of information, the SNMC concluded that a
transcription error had been made in recording the serial numbers on the container lid.
The conclusion was that TANCE1-005 was the correct serial number of the IRM and that TANCE1-003 had been mistakenly recorded.
The SNMC thought that the shipment had already left the BFN site and any immediate actions'to resolve the discrepancy would be without benefi t.
He informed the co-op student that the SNM records would be reviewed the next day upon his return.
'n reality, the shipment had not left the site.
The co-op student understood the SNMC's instructions as permission to allow shipment.
The Radwaste Controller contacted the co-op student concerning the discrepancy.
Hhen informed that the discrepancy was resolved, the crate was loaded onto the waiting truck and shipped offsite.
On June 18,
- 1987, the receiver of the IRMs notified BFN that they had received six IRMs, including serial numbers TANCEl-003 and TANCE1-005.
y
~III.
Root Causes of IRM Incident Directly Contributing Causes:
Inaccurate inventory of the IRM shipping crate.
Not individually removing the IRMs from the shipping crate contributed to the miscount during this incident and during previous inventories.
The detectors were not removed because of a procedural caution not to move the detectors.
This caution was a management decision based on the need to eliminate unnecessary handling of expensive instruments.
2.
Failure to take appropriate corrective action by the SNMC.
Immediate followup by the SNMC after the inventory discrepancy was reported might have prevented the shipment.
. Indirectly Contributing Cause:
Lack of adequate inventory records of nonfuel
- SNM, Prior problems in the SNM area resulted in inaccurate SNM inventory records of the IRMs stored in the warehouse.
Recent efforts to reconcile SNM inventory differences by means of a thorough search of all receipt, transf'er, and installation records had not been completed.
~ t
J
~
~
~
IV.
Corrective Actions The fuel loading chamber incident which, occurred in October 1986 resulted in the identification of several deficiencies in the management of nonfuel SNM at BFN.
A corrective action plan was prepared to address specific BFN problems and also to extend the BFN experience to other sites through corporate program improvements.
At the same time, as a
result of implementation of the new centralized organization, emphasis was being placed on increased central office involvement in defining consistent technical requirements for site activities.
These events prompted an examination of the overall SNM program.
One result was a complete restructuring of the Office of Nuclear Power SNM program definition document.
The restructured document (PMP 1801.03) which was approved on July 10, 1987, after the IRM shipment, defines a
fundamentally sound program which incorporates the lessons learned from 15 years of successful management of SNM in nuclear fuel assemblies and those learned from the October 1986 BFN incident.
The program wi 11 continue to evolve as experience accumulates.
The corrective actions described below are in response to the June 16, 1987 IRM shipment incident and represent an additional evolutionary step.
A.
Corrective Actions That Have Been Taken l.
An investigation of the IRM shipment incident by the corporate program manager was completed June 25, 1987.
A summary report was issued July 9,
- 1987, and the final report was,.i.ssued August 10, 1987.
2.
Other TVA nuclear sites were informed of this problem by phone on June 24,
- 1987, and by memorandum on July 1, 1987.
Confirmation of accurate nonfuel SNM inventories at the other TVA nuclear sites was requested and received.
3.
The corporate program manager completed a detailed review of the BFN inventory process,
- results, and records on August 21, 1987.
This included a complete independent reinventory of nonfuel SNM.
4.
Physical inventories of all BFN item control areas containing
- SNM, with the exception of the spent fuel storage pools (fuel and spent local power range monitors) and the reactor cavities, were performed.
No new discrepancies were discovered'
5.
TI-14 was revised on June 30, 1987 to:
a.
Require an empty-the-box inventory of all nonsealed SNM items.
b.
Require personnel who perform physical inventories to be knowledgeable in the requirements of and description of SNM items.
c.
Define the SNM Cognizant engineer to have signature authority for the SNMC when the SNMC is not present.
d.
Require that a check of physical inventory results to the most recent history records be performed at the time of the inventory, not as a post-inventory review.
e.
Require a two-party inventory verification.
6.
Site procedures have been revised to:
a.
Provide more details on the method of performing physical inventories for each known storage location.
This will include the physical appearance of each SNM item normally, inventoried, the location of the serial
- number, and unusual characteristics.
b.
Require that all inventory discrepancies be documented by a Condition Adverse to guality Report.
I I c.
Require that fuel assembly history records be updated within 10 working days of the receipt of completed fuel assembly transfer packages.
B.
Corrective Actions That Will Be Taken l.
Obtain shipping information from GE on all nonfuel SNM shipped to BFN.
Obtain all available site information on the receipt or transfer of SNM items.
Use the above information to recreate SNM history records as completely as possible.
Reconcile differences between the physical inventory and the records search.
A report will be submitted to NRC by September 30, 1987.
2.
Revise the corporate procedure PMP 1801.03 by November 30, 1987, to provide additional guidance in the following areas Improvements in some of these areas have already been implemented at BFN.
a.
Inventory methods b.
Training requirements c.
Frequency and extent of SNM system audits by the corporate program manager (frequency will be at least twice per year at each site beginning in August 1987) 3.
Revise site procedures by December 1,
1987, to require that only
~
personnel who have had specific SNM training be assigned to SNM duties.
Following the procedure revisions, one month will be required to implement the procedures so that the training in item 4 below can be completed.
4.
Provide training to additional key site personnel to ensure the adequate implementation of the SNM program by January 1,
1988 Key members of the Power Stores,
- Radcon, Instrument Maintenance, Electrical Maintenance, Operations,
- Radwaste, and Reactor Engineering organizations will be instructed on their specific responsibilities required to implement the program.
b.
Additional SNM cognizant engineers will be trained and qualified as required to ensure adequate resources for around-the-clock activities.
c.
Reactor Engineering personnel will be trai.ned on the recognition and proper methods of performing inventories and maintaining records.
5.
For a period encompassing the next 24 months, the corporate program manager wi 11 perform a quarterly check of the status of the SNM program at BFN.
I
~
~
ENCLOSURE 2
TVA EXCEPTIONS TO NRC INSPECTION REPORT NO. 87-29 TVA takes exception to several statements and conclusions reached in the subject report.
The NRC inspector concluded on page 3 of the inspection report that of the four separate inventories of the container conducted by TVA since October
- 1986, none was performed correctly or according to procedure TI-14.
2.
TVA agrees that an error was made in performing the inventory.
- However, the provisions of TI-14 were followed.
TI-14 states that physical inventories shall be an inventory by location and serial
- number, including a piece count.
It further states in paragraph 7.8.5.1 "Check all serial'umbers of SNM items in opened shipping containers and/or other locations, if possible, without moving the incore detectors."
The caution not to move the detectors resulted from a management decision based on the need to eliminate unnecessary handling of expensive instruments.,
The physical inventories since October 1986 were performed in accordance with TI-14.
The inventories were erroneous because of compliance with the procedural caution against removing the detectors from the shipping container.
The inspection report states on page 4 that delegation of a preshipment inventory verification task to a co-op student occurred without the knowledge or written consent of line management This part of the report suggests incorrectly that there was no management involvement in determining who would do the IRM inventory.
Management did in fact review and approve the assignment of the co-op student to do the inventory, based on (1) the understanding that she would be accompanied by an experienced engineer and (2) the knowledge that she had been instructed regarding inventory and recordkeeping requirements of TI-14.
Because of a communications
- problem, the engineer was not aware that he should participate in the inventory.
3.
The report states on page 6 that inadequacies in PMP 1801.03 "led to the condition on June 16, 1987, during an irregular shipment of SNM to another licensed facility when cognizant licensee management were not onsite."
The report also states that procedural deficiencies and failures of the plan to implement long-term improvements "have been determined to have contributed to the licensee's failure to conduct accurate inventories which resulted in an improper offsite shipment."
C The long-term program improvements identified in response to the October 1986 incident had not been fully implemented and, therefore, the NRC conclusions are unwarranted.
PMP 1801;03, which was approved for implementation July 10,
- 1987, addresses issues raised in the inspection report concerning management responsibilities and co'rrective action.
The
'MP clearly assigns overall responsibility for management of SNM, whether
.in usual or unusual circumstances, to the plant manager, and specifically assigns responsibility for conducting inventories to the Source and SNM Custodian.
It also requires that nonconformances in materials,
- methods, services, or activities be reported to the responsible supervisor "who shall ensure that the nonconformance is appropriately and properly addressed."
The procedure identifies Part I, section 2.16 of the Nuclear Quality Assurance Manual as the source of requirements for corrective action.
As stated previously, PMP 1801.03 defines a fundamentally sound program which will undergo further refinements as a result of lessons learned from the June 16, 1987 event.
The inspection report concludes on page 7 that the updating of fuel history records following the unloading of fuel from unit 3 was not completed within a reasonable time period as specified in TI-14.
The NRC inspector noted that history records were updated in a period of two to four months following the completion of the unloading activities.
The delay in updating the fuel history records was not caused by inattention on TVA's part, but was due to inaccessibility of the automated data base where the records were normally kept.
The computer hardware on which the automated data base system',.operates was being physically relocated at BFN.
The return to operation of this computer took significantly longer than originally anticipated.
Management knew that all history data for the unloaded fuel assemblies was available and could be easily provided upon request at all times that the computer was inoperable.
Under these circumstances, the two-to.
four-month time period was reasonable.
r
~
I I
~
~
~
g
~
)r~'NCLOSURE 3
LIST OF COMMITMENTS Enclosure 1
(SNM) 1.
Report to NRC by September 30,
- 1987, the results of the SNM records search.
2.
Revise corporate procedure PMP 1801.03 by November 30,
- 1987, as described
-in enclosure l.
3.
Revise BFN procedures by December 1,
1987, for implementation by January 1,
1988, to require that only personnel with specific SNM training be assigned SNM duties.
4.
Provide SNM training to additional key site personnel by January 1,
1988.
5.
For a period encompassing the next 24 months, the corporate program manager will perform a quarterly check of the status of the SNM program at BFN.
/
F7
~
g a
I
~ g