ML20012D104
| ML20012D104 | |
| Person / Time | |
|---|---|
| Site: | 07002917, 07002941 |
| Issue date: | 03/22/1990 |
| From: | Wallace E TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9003260470 | |
| Download: ML20012D104 (4) | |
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TENNESSEE. VALLEY AUTHORITY
. CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place s
MAR 221990 1
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cr U.S. Nuclear Regulatory Commission l
ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of the.
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Docket Nos. 70-2917 Tennessee Valley-Authority-
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70-2941 BELLEFONTE NUCLEAR PLANT (BLN) - REQUEST FOR AN EXEMPTION FROM 10 CFR 70.51(d)
References:
- 1.
TVA letter dated June 13, 1989, "Bellefonte Nuclear Plant (BLN) - Request for an Exemption from 10 CFR 70.S1(d)"
l 2.
TVA letter dated August 11, 1989, "Bellefonte Nuclear Plant (BLN) - Request for an Exemption from 10 CFR 70.51(d)"
In the references, TVA requested an exemption, in accordance with 10 CFR 70.14, to allow ~the use of tamper-indicating Type E seals to secure the nuclear fuel assembly' storage areas at BLN instead of conducting annual physical inventories.
He_also requested to take credit for the last physical inventory of.these storage areas.
The purpose'of this letter is to rescind TVA's previous request.
TVA now
- requests ar, exemption from the requirements of 10 CFR 70.51(d) based upon the
' completed actions described below.
This rescission, the new request, and the completed actions were discussed with Don Carlson of your staff.
On August 16 -1989, TVA personnel performed a physical inventory of all L'
410 nuclear fuel assemblies stored at BLN. There are 140 assemblies stored in the New Fuel Storage Vault.(NFSV) with the remaining 270 assemblies stored in the Unit 2: Spent fuel Storage Pool (SFSP). Also on this date, after completing the inventory, tamper-indicating Type E metal seals were installed as described in the references--with one modification. The seal for the steel garage-style roll-up door was not added to the hasp on the'inside of the Unit 2 SFSP area.
Instead, holes were drilled in the door and its frame near the floor on the outside of the Unit 2 SFSP area. A wire loop was run through these two holes and a seal was added to the wire loop. With this modificatloa, the verification and inspection of all seals which permit access to.either the NFSV or the Unit 2 SFSP can be performed from the outside of these storage areas.
This modification was discussed with Mr. Carlson on August 15, 1989.
In all, seven Type E metal seals were installed.
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.A BLN site procedure was written to specify the requirements on the use of these seals. ' These requirements, which were also discussed with Mr. Carlson, l
include the following:
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An-Inventory of the assemblies in the NFSV and the Unit 2 SFSP shall be performed before the installation of any seals.
2.
Another inventory of these assembi hs is not required after the-installation.of the seals, unless the integrity of the seals is violated or tampering with the seals is indicated.
3.
Each seal shall be verified and inspected at intervals not to exceed twelve months after its installation.
4.
Entry into the NFSV or the Unit 2 SFSP, if required, is possible without requiring a new inventory.
Permission for entry shall be obtained from the Radiation Control Supervisor, with the reason for entry documented.
The existing seal (s) may be removed to allow entry after the verification of its/their identity and integrity by two disinterested individuals (ones not involved with the reason for entry). During the interval between the removal of the existing seal (s)'and the installation of a new seal (s), these two disinterested persons shall keep the entry crew under continuous observation.
Any violation of this "Two Man Rule" shall compromise the integrity of the original sealing of the particular storage area and a new inventory shall be required.
5.
A special exception shall occur with the declaration of a tornado
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warning.
Lifting or removal of one NFSV cover is now required to prevent possible damage to the assemblies stored in the NFSV.
The crane operator and the member of the BLN security organization who are required to be present can also be the two disinterested individuals, since no entry into the NFSV is planned and the cover is replaced as soon as the warnliig is lifted.
Enclosed is a list which provides a summary of the completed actions.
If you have any questions, please-telephone P. J. Hammons at 615/751-2736.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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lallace)MaVader E. G.
Nuclear Licensing and Regulatory Affairs Enclosure cc:
See page 3
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in U.S. Nuclear Regulatory Commission lAAR 22199(I t
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cc-(Enclosure):
Ms. S. C. Black, Assistant Director' for Projects TVA Projects-Division U.S. Nuclear' Regulatory Commission One White Filnt, North 11555 Rockville Pike u
Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projocts Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Site."esident Inspector Watts Bar Nuclear Plant P.O. Box 700-Spring City, Tennessee 37381
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ENCLOSURE BELLEFONTE NUCLEAR PLANT (BLN) -
REQUEST FOR AN EXEMPTION FROM 10 CFR 70.51(d)
The following11s a summary list of completed actions contained in this request for an exemption from'10 CFR 70.51(d).
g 1.
Added tamper-indicating Type E seals (seal) to each end of 'he metal locking bar over the NFSV.
L Added a wire loop and seal on the outside of the Unit 2 SFSP area to the f
2.
main personnel door into the SFSP area.
3.
Added a wire loop and seal to the other personnel door on the outside of the Unit 2 SFSP area.
4.
Added a wire loop and seal to the steel garage-style roll-up door on the outside of the Unit 2 SFSP area.
5.
Added a wire loop and seal to the storage room doors (2) inside of the Unit 2 SFSP area.
6.
Wrote instructions for entry into the NFSV or the Unit 2 SFSP area.
Instructions covered reason for entry, approval, breaking of seals, and new seal installation.
COMMITMENT FOR FUTURE ACTION 1.
Inspect the five seals accessible from the fuel-handling floor at intervals not to exceed 12 months.
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