ML20012A363

Responds to NRC 900131 Ltr Re Violations Noted in Insp Rept 50-353/89-32 on 891211-15.Corrective Action:Util Will Document Both Receipt & Shipment of Fuel Loading Chambers on Next Semiannual Doe/Nrc Form 742

ML20012A363
Person / Time
Site:	Limerick
Issue date:	03/01/1990
From:	Mccormick M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9003090318
Download: ML20012A363 (7)

Text

4 10:CFR 2 201 ~

D' PHILADELPHIA ELECTRIC: COMPANY-a .

LIMERICK GENER ATING STATION ,

P. O. DOX A SAN ATOG A. PENNSYLV ANI A 19464 (2:s) sz7.tzoo Exv. : March 1,-1990 l

M. J. McCO RMIC M, J... P.E.

6,. . . ./."". .".*l,O "... ...a Docket No. 50-353 License No. NPF .

U.S. Nuclear Regulatory Commission

- ATTN: Document Control Desk Washington, D.C. 20555

SUBJECT:

Limerick Generating Station, Unit 2 Reply to Notice of Violation NRC Inspection Report No. 50-353/89-32

Dear Sirs:

Attached is Philadelphia Electric Company's reply to-the

" Notice.of Violation" contained in NRC-Inspection Report No. 50-353/89-32'for Limerick Generating Station (LGS), Unit-2.

NRC letter dated January 31, 1990,- forwarded NRC Inspection .

. Report No. 50-353/89-32 containing the " Notice of Violation."

This violation of NRC requirements pertains to the control of SpecialiNuclear: Material and was identified during an NRC inspection conducted'between December 11-15, 1989, at LGS, Unit 2.

The attachment'to this letter provides restatement of the violation.and our response.

If you.have any questions, or require additional information, y please contact us.

Very truly yours,-

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- cc: W. T. Russell, Administrator, Region I, USNRC T. J. Kenny, USNRC Senior Resident Inspector, LGS Y 00000A ng3 f

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.. . Inspection No. 50-353/89-32 i

. Reply to Notice of Violation '

LRestatement ofLthe Violation 1 oAs a1 result of the inspection conducted on December 11-15, ,

1989,'-and'in accordance with the General Statement of Policy and '

Procedures for-NRC Enforcement Actions, 10 CFR Part^2, Appendix C j

'(Enforcement Policy-1989), the'following violation was 'I identified:

10 CFR'70.51'(b)(1)_ requires that each licensee shall keep ,

. records showing the receipt, inventory (including location), '

disposa11 acquisition,'and transfer of all special~ nuclear materials (SNM) in his possession regardless of.its origin or.

-method of acquisition. .Also, 10 CFR 74.13 (a)(1) and 74.15 (a) require, respectively, preparation and submission of Material

' Balance: Reports concerning SNM-received:or transferred, and documentation of: receipts or transfers by completion and-distribution of Nuclear Material Transaction Reports.

Contrary to the above, the-inspector determined on December  !

15, 1989 that: )

Two dunking. chambers containing approximately 5 grams of ,

uranium-235 (received from Reuter-Stokes, Inc. on shipment ZSZ-XIS-03 dated May 19, 1989)- were not-recorded nor reported to the NRC on a Nuclear Material. Transaction

-Report, and Material Balance Report as required;-

The same two dunking chambers containing approximately 5 .

grams of uranium-235 were shipped offsite on September 29, 1989 to Public Service Electric and Gas Co.,-were not documented on a Nuclear Material Transaction Report and reportedEto the NRC.on Material Balance Report, as  !

required.

This'is a Severity Level IV Violation (Supplement III).

RESPONSE

Admission of Alleged Violation Philadelphia Electric Company acknowledges the violation.

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Attcchm3nt f W" .. '. Pcg3 2 of 6 f Y Inspection No. 50-353/89-32 Reason for the Violation.

This violation has been attributed to the following causes identified below.

1) Procedures - While administrative controls existed for controlling Special~ Nuclear Material (SNM), the '

procedure implementing the administrative policies was inadequate in that:

o' it did not contain a detailed procedural step for the onsite processing of a Nuclear Material '

Transaction Report, DOE /NRC Form 741, and o no formalized method of communication existed between the plant and corporate groups which handle SNM accountability.

.2) Training - No formalized training-in SNM! documentation, identificat.ica, security, and regulatory requirements existed for 'ie group responsible to physically track-SNM, or the various other personnel working with SNM items.

• On May 20, 1989, Reuter Stokes Inc. shipped one wooden box containing SNM'(5 grams of 93% Uranium-235)'in-the form of two '

fuel loading chambers (i.e., detectors)-to Limerick Generating J Station (LGS). On May 22, 1989, the shipment arrived at LGS, and accompanying the shipment were three. copies of DOE /NRC Form 741. l This form. listed the serial numbers of the fuel loading chambers and other pertinent information regarding the shipment. The three forms were forwarded to the LGS Reactor Engineering Department for dispositioning-in accordance with Administrative Procedure A-44, "Special Nuclear Material Accountability." We note however, that Reuter Stokes, Inc. should have forwarded one of the three copies of the DOE /NRC Form 741 to the Philadelphia

' Electric Company (PECo) business address (i.e., the corporate group involved in handling SNM accountability) as directed by

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NUREG/BR-0006, " Instructions for Completing Nuclear Material '

Transaction Reports."

As previously stated in Item 1 above, a factor to the cause of this violation was that Procedure A-44 did not contain a detailed procedural step that explicitly directed onsite ,

personnel how to process a DOE /NRC Form 741. As a result, the three copies of DOE /NRC Form 741 associated with the shipment were inadvertently placed into the Reactor Engineering SNM correspondence file without the required receipt acknowledgement being sent to Reuter Stokes, Inc. as directed by NUREG/BR-0006.

Formal acknowledgement of SNM receipt by PECo is normally made from the corporate office.

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As previously stated in Item 2 above, a second factor to "

oc the cause'of_this. violation was that the Reactor Engineering ,

group, responsible to physically track the onsite inventory of i

'SNM,1were not trained in-SNM' documentation, identification, or ,

regulatory. requirements._ Since the Reactor Engineering group was  ;

, not trained in the handling of_SNM documentation (i.e., DOE /NRC Form 741), they failed to recognize that receipt' acknowledgement t Lof:the SNM had not been made. As-a result of. mis-handling this ,

DOE /NRC Form 741, the association between the: Form 741'and the fuel loading chambers _was never established. Therefore, the fuel loading chambers were presumed to be a commonly used boron

'trifluoride detectori which contains no SNM, and were not recorded-into the LGS SNM Accountability System. _This system is used by the corporate office to generate the Material Balance a Report, DOE /NRC Form 742. Consequently, between May 23,'1989 and

. September 27, 1989, the fuel loading chambers were not treated as

'SNM. As a result,_. receipt of the SNM was not recorded or-reported to Reuter Stokes, INC. and to Martin Marietta Energy Systems-(SNM accounting consultant for the DOE /NRC) on a DOE /NRC  ?

Form 741 as directed by NUREG/BR-0006. Additionally, receipt of the SNM-was not reported to the NRC on the DOE /NRC Form 742 as t required by 10 CFR 74.'13, that was issued by PECo dated: September.

30, 1989.

F .Between.May 23, 1989 and-September 27, 1989, the fuel loading chambers were moved to the LGS refueling floor, -

unpackaged,-inspected, and stored on the refueling floor in preparation for their use during Unit 2 fuel loading operations.

However,-the fuel loading chambers were never used, and were never contaminated. Therefore, the fuel loading chambers were ,

repackaged and prepared to be shipped back to Reuter Stokes, Inc. '

Between September 27, 1989 and September 29, 1989, the fuel loading. chambers were prepared for shipment offsite. The original destination for the shipment was revised from Reuter Stokes; Inc.' to Hope Creek Generating Station, since Hope Creek personnel requested the use of these fuel loading chambers.

' Exit surveys were conducted by Health Physics personnel, and the chambers were moved from the refueling floor to the new fuel storage area for shipment to Hope' Creek Generating Station. On September 29, 1989, the fuel loading chambers were shipped by

~A ble Netwcrk Inc., under contract to Public Service Electric and 1 Gas (PSE&G) Company, to the Hope Creek Generating Station.

On November 14, 1989, Martin Marietta Energy Systems (MMES)  ;

notified'PECo that there was a 5 gram SNM discrepancy between their records and the PECo Material Balance Report, DOE /NRC Form

'742, for September 30, 1989. After being notified, PECo identified the serial numbers of the SNM in question to be the two fuel loading chambers that had been shipped to Hope Creek Generating Station on September 29, 1989. Since it was not

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c -recognized.by PECo that the shipment contained SNM, no DOE /NRC. 4

, . Form;741 was processed fo'r transmittal-to MMES and-to PSE&G. M

' Additionally, this shipment was not reported to the NRC on;the DOE /NRC Form'742 that wasfissued by PEco dated September 30, 1989.1  !

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' Corrective? Actions Taken and Results-Achieved i.; On November 16,.1989, PECo acknowledgedJreceipt of-.thei b shipment of the fuel loading chambers to LGS on a duplicate' DOE /NRC Form'741 reissued.by Reuter Stokes Inc. Copies of' thel 1

-Form ,741 were transmitted on November- 16, 1989, to'Reuter. Stokes,; J Inc. and to MMES'as directed by.NUREG/Bl.-0006.

e On December-7,-1989,.a DOE /NRC Form 741-was issued from ,

PECo to MMES and to PSE&G :for the shipment: of the fuel loading.

chambers to Hope Creek Generating Station.that occurred on September 129, 1989.

Per conversation.between PECo and MMES-on November 14, 1989, PECo will document both the. receipt and shipment of the fuel loading chambers on the next Semi-annual DOE /NRC Form-742.-

This report will be completed by April 30, 1990.  !

't iCorrective Actions to Avoid Future Non-Compliance 1.

Reactor Engineering implementing procedures will'be developed to supplement Procedure'A-44, "Special Nuclear Material Accountability," and will. include the ,

following:

o Provide' detailed instructions for the onsite i handling of a DOE /NRC Form 741. These instructions will include the formal transmittal of the DOE /NRC Form 741~to the corporate office. This will ensure that every DOE /NRC Form 741 is recorded into the

u. LGS SNM Accountability System and included into the .

next required DOE /NRC Form 742. -*

o Provide guidance'to assure that communication is coordinated between the plant and corporate groups which handle SNM accountability.

L These items will be completed and implemented by April L 30, 1990.

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[I y 2.- Reactor 1 Engineers'and-the various other personnel j

( working with.SNM items will receive formal' training in.

SNM identification,. handling, security, and-regulatory requirements. This training.will include a yearly one day. requalification training: for .the Reactor Engineers.

L The SNM formal training sessions-will begin during the q 1991 calendar year. . While-the lesson-plans for this .i formal training 1are being developed, Reactor-Engineering personnel will receive training within. ,

their group on the handling and identification of SNM. i W This-interim training will be completed by May 31, 1990.

In addition to the Corrective Actions identified in Items 1  ;

and 2 as stated above, the following additional actions will be 3

implemented. '

Detailed routine procedures to supplement. Procedure

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A-44 will-.be written to:

o govern the recording and logging of all movement of SNM at LGS, and-o control the handling, security, and tagging requirements of SNM.

These items will be completed and implemented by April 30, 1990.

B. Procedure A-44 will be' revised to-accomplish the following. . 9 L o Provide guidance to outline work' group interactions ,

f and regulations governing the procedures to be implemented in the additional Action A, as stated above.

E o Provide for tagging of all SNM in storage or >

transit by requiring the use of distinctive tags.  ;

-The tags-will identify the SNM and will require Reactor Engineering approval prior to the SNM being moved. The significance of SNM tags will be H

addressed as'part of General Employee Training (GET).

, These items will be completed and implemented by April 30, 1990.

L l C. Additional Reactor Engineering implementing procedures L will be developed to supplement Procedure A-44 to L accomplish the following:

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e .o, Control the increased physical' barriers for SNM:

that will'be developed _(i.e., locked. storage cage- ,

for SNM'and LGS storeroom computer coding thatL  ;

' i notifies Reactor Engineering when SNM is being l

-" signed out" or removed from the' storeroom).  ;

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-This item'will be completed and implemented by ...

September 15,'1990. '

o 'A detailed routine procedure will be written to ,

i supplement Surveillance Test Procedure ST-3-097- l 350-0, " Annual Inventory of-Special Nuclear

. _ , -Material,"'to conduct increased periodic' auditing' 1 "i

of SNM at LGS.- ,

This item will beLcompleted'and implemented by April 30,'1990. 4 The Corrective Actions above were' identified.by using the Human Performance Evaluation System (HPES) root cause analysis techniques in-conjunction with an appointed task' force.

Date When Full Compliance Will Be' Achieved-

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Full' compliance will be achieved by April 30, 1990'when i PECo submits.to the NRC the next Semi-annual DOE /NRC Form 742.

Thisfreport will-document both the1 receipt and shipment of the fueliloading chambers.

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