ML20043D325
| ML20043D325 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/01/1990 |
| From: | Medford M TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-89-239, NUDOCS 9006070378 | |
| Download: ML20043D325 (7) | |
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TENNESSEE VALLEY AUTHORITY CH ATT ANOOG A. TLNNESSEE 37401 6N 38A Lookout Place JUN 011990 Director, Office of Enforcement U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 REPLY TO NOTICE Of VIOLATION AND PROPOSED IMPOSITION Of CIVIL PENALTY (EA 89-239)
This letter provides TVA's response to the NRC's May 2, 1990 Notice of Violation (NOV) and Proposed Imposition of Civil Penalty involving special nuclear material (SNM) accountability.
Pursuant to 10 CFR 2,201, the enclosure to this letter provides TVA's reply to the NOV. As stated in the enclosure TVA admits the violation as alleged, Payment of the civil penalty in the amount of $18,750 is being sent by electronic fund transfer to the' Director, Office of Enforcement.
TVA takes the issues raised by this violation very seriously and recognizes the importarice of maintaining an accurate Inventory of both fuel and non-fuel SNM at all times.
The comprehensive corrective actions taken.in response to i
this event are intended to establish an accurate SNM baseline inventory and to maintain the accuracy of that inventory over the long term.
These actions should prevent the recurrence of similar violations in the future.
TVA is also aware of the significance of its failure, noted in the NRC's cover letter to the NOV, to report the discovery of eight incore detectors presumed to have been shipped as radwaste prior to 1987.
TVA has revised Off!ce of Nucleai l'Wer Procedure 5.5.2, Special Nuclear Material management, to address a found SNM ltem. Any SNM ltem which is found in a different location than whdt is recorded on the current SNM inventory list will be classified as a 1
Category I event.
The standard procedure also requires that Category I events be reported to the NRC Operations Center in accordance with 10 CFR 70.52.
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An Equal Opportunity Employer
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U. S. Nuclear Regulatory Commission JUN 011990 If you have any questions concerning this submittal, please do not hesitate to telephone me at (615) 751-4776.
Very truly yours, TENNESSEE VALLEY AUTHORITY he Mark O. Medford, Vice President Nuclear Technology and Licensing Enclosures cc: See page 3 onthis/adsubscriedbeforeme Sworn to day of
, 1990.
daaM al#AM Notary Publ1c ~
My Commission Expires //-Y-f2
3-U.S. Nuclear Regulatory Commission JUN 011980 cc (Enclosures)-
Mr. Dennis Crutchfleid Associate Director for Special Projects 11555 Rockville Pike Rockville, Maryland 20852 Ms. S. C. Black, Assistant Director forProjects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 NRC Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35609-2000 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 I
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ENCLOSURE
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REPLY TO NOTICE OF VIOLATION (EA 89-239)
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00CKETS NOS. 50-259, 50-260, 50-296' Restatement of the Violation
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10 CFR 70.5)(c) requires, in part, that each licensee who is authorized to j
possess at any one time special nuclear material (SNM) In a quantity j
exceeding one effective kilogram shall' establish, maintain, and f>llow written material control and accounting procedures which are sufficient to enable the licensee to account for the SNM in his possession under license.
Licensee Procedure TI-14 Special Nuclear Material Control, Revision 15, step 7.8.5 requires that a physical-inventory-of all nonfuel SM will be conducted at least once per year. A partial inventory will be conducted; after each receipt, transfer, or shipment. All inventory discrepancies-shall be documented by initiating a Condition Adverse to Quality Report, i
A discrepancy may be the difference in piece counts, serial number,.
location, etc., between the inventory resuiu, and the history records.
Coatrary to the above, the licensee failed to perform adequate physical inventories in 1987 and 1988 in that an inventory conducted in 1989 identified 26 discrepancies not detected in those earlier inventories.
This is a Severity Level IV Violation (Supplement III)
Civil Penalty - $18,750.
Admission or Denial of the Violation
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TVA admits the violation as cited.
Reasons for the Violation TVA has concluded that there were three primary root causes of the violation:
an inaccurate 1986 non-fuel SNM inventory; inadequate training of-personnel 4
performing SNM inventories; and a programmatic breakdown of the SNM accountability, including insufficient management involvement in SNM accountability issues.
3 A.
Inaccurate Non-Fuel SNM Inventory As part of TVA's corrective action in response to the NRC's 1986 enforcement action involving SNM inventory discrepancies at BFN, a baseline inventory of fuel and non-fuel SNM was performed.
TVA has now determined that the non-fuel portion of that inventory was inaccurate.
The majority of the inaccuracles identified are associated with items that 3
were stored in tue Radwaste Evaporator Building.
Three major errors were made when inventorying these items. The first error was not removing all drums of radioactive material (SNM and non-SNM) from the storage room; therefore, the nonfuel SNM ltems reported to NRC in LER BFR0-50-259/89016 had net been identified nor placed on the active inventory. list.
The second error was not consistently identifying which detector cables had detectors attached and which detector cables did not have detectors
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The third error was,not opening and'lW pecting the contents of I
lead bricks used to store cut-off detectors.
The secondiand third errors discussed above resulted in the double counting of items.
Consequently, the non-fuel SNH inventory performed in January 1987 formed an inaccurate d
baseline.
Upon completion of this inventory, the cables and bricks-were placed in sealed drums.
Subsequent inventories in 1987 a'nd-loBB only j
ensured that the drum seals were intact.
l B.
Inadequate Training of Personnel Performina SNM' Inventories A contributing cause of the inadequate baseline inventory discussed above
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was insufficient training.
TVA's review of the training provided to-personnel performing non-fuel SNM inventories in the 1986-87 timeframe revealed that models of non-fuel SNM ltems were not included in the l
training curriculum.
Additionally, the training did not include an explanation of the source of high dose rates which would be encountered while performing the SNM search.
The SNM searchers did not realize that the high dose rate experienced during the search came from the cable and not from a detector.
Therefore, the SNH searchers presumed that each
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cable had a detector.
C.
Breakdown of SNM Accountability During the 1986-1987 search and inventory, several organizations provided Information to the SNM custodlan (SNMC), resulting in inaccurate supporting documentation for the inventory.
Furthermore, the physical inventory performed was based on the decision to minimize personnel exposure whereby the searches of the drums stored in the radwaste evaporator building might have been performed hurriedly. -Therefore, a physical verification to ensure that each cable had a detector attached was not performed and, in some cases, inadequate supporting documentation was used.
Corrective Steps That Have Been Taken and Results Achieved i
A.
Immediate and Short-Term Corrective Action As reported to the NRC in LER'BfRO-50-25?/89016, on November 4, 1989, RADCON personnel performing housekeeping activities in the Radwaste Evaporator Building discovered three-buckets containing seven lead bricks presumed to contain neutron instrumentation detectors and one'polybag presumed to contain SNM material.
The SNMC was notified of the discovery and subsequently determined that these items were not being carried on the current SNM Inventory.
As part of the immediate corrective action in response to the discovery of the non-fuel SNM items, searches for additional SNM items were undertaken, resulting in TVA's identification of the 26 inventory discrepancic: referenced in the cited violation.
Upon discovery of these inventory discrepancies, TVA promptly began to develop and implement an SNM Program Action Plan consisting of the following: improved training of SNM for personnel involved in control, accountability, and plant searches, ; physical searches of plant areas where non-fuel SNM ltems were likely to be located; and a 100 percent
.a iPage 3 of 4 review of the search plan by the BFN Quality Assurance (QA) organization.
This QA review ensured that the search was conducted ptope were trained, and documentation of the search was thorough,rly, personnel j
B, Long-Term Corrective Actions
+1 TVA's long-term corrective actions are intended to minimize the likelihood of additional SNM Inventory discrepancies. These corrective' actions are being taken in the areas of training, inventory' searches, and p
accountability enhancements.
A formal training course for personnel performing.SNM inventories has been implemented.
This training includes detailed models of radiation detectors such as: local power range monitors, neutron sources, intermediate range monitors, source range monitors,'tra,nsverse incore probes and are included as part of the curriculum to ensure that personnel are able to identify devices which contain non-fuel SNM.-
Furthermore, the expertence and training of the reactor engineering staff involved in SNH control has-been assessed, with the result that each person is fully aware of the requirements involved with SNM activities.
In addition to the inventory which was undertaken immediately following the discovery of unaccounted for non-fuel SNM in November, BFN is-conducting a physical search of approved SNM storage areas' the protected area, the Administration Building, and Power Stores area of the BFN site for non-fuel SNM.
Fuel assemblies located in the spent fuel storage pools and the reactor cavity also have been inventoried.
Discrepancies between-the actual items located and BFN's SNM inventory have been' reported to the NRC.
As of May 15, these searches were completed except: a physical inventory of the LPRM liners in the Unit 2 and 3 Spent Fuel Storage Pool, a physical inventory of the area under the Unit 2 reactor pressure vessci
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a head and its mirror insulation located on the refueling floor, and a-l physical inventory of the new fuel storage vaults for each unit.
TVA does not intend to ship its non-fuel SNM offsite for disposal until the new SNM baseline inventory is complete although a temporary SNM storage area for shipping has been established.
Corrective actions have been implemented to provide an additional level of assurance that the control and accountability of.SNM at BFN meet regulatory requirements.
Based ~on its evaluation of this event, TVA has concluded that tracking non-fuel SNM by serial numbers will only perpetuate past SNM inventory inaccuracles. As part of the new baseline inventory, non-fuel SNM will be labeled and/or reassigned a unique identifier.
This is intended to minimize carryover of prior errors into the new SNM inventory program.
BFN plant management involvement in SNM accountability issues and the SNM inventory process has been increased.
Since the initial event, key site management positions have been filled by TVA personnel in lieu of contractors. Although TVA noted in the Enforcement Conference that the responsible manager for SNM would be the RADCON manager, TVA has reeveluated its position and concluded that SNM custodlan 1
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'NPage4of4 responsibilities will' remain with the BFN reactor engineering g aup.
This
~ decision was made to ensure that the corporate organization responsible for SNM accountability and control will only interface with reactor engineering groups at each site. Additionally, the TVA SNM program will be consistent with industry practices.
,J The Site Quality Assurance organization-has completed an overview of: the t
SNM program, the SNM baseline Inventory, and SNM procedures..This effort included:
a review to determine the adequacy and proper implementation of upper tier requirements and regulatory commitments in plant procedures;SNM an assessment of the SNM inventory to determine if both fuel and non-fuel requirements were met; an assessment to compare SNM records against'fleid inventories; and finally an assessment of the SNM program to evaluate the l
effectiveness of past corrective actions.
The QA organization performed this assessment as an in-process review.
The.QA' organization has I
determined thet those portions of the completed corrective actions and
-completed action items that have been finished are adequate.
However, the y
QA organization has also determined that it is essential to complete an accurate SNM baseline inventory in order to provide adequate recurrence, control for the SNM program at BFN.
Previous SNM commitments and corrective actions were also reviewed for lessons learned and for incorporation into the SNM program.x Conclusions reached were that inventories should entall a search of the entire area; personnel involved in inventories should have first-hcnd experience in c
recognizing the item and/or packaging; and SNM ltems should be removed from their containers to ensure accurate piece count, r
Corrective Steps Which will be Taken to Avoid Further Violations ns noted above, TVA will complete its new baseline-SNM inventory by performing-the following activities: a physical inventory of the LPRM liners in the Units 2 and 3 SFSP, a physical inventory for the area under the Unit 2 reactor pressure vessel head and its mirror insulation located on the refueling floor, and a physical inventory of the new fuel storage vaults for eacn unit.
Date When Full Compliance will be' Achieved Full compliance will be achieved when the SNM inventory is completed prior to Unit 2 start-up.
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