ML20053E942
| ML20053E942 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 02/09/1982 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20053E939 | List: |
| References | |
| NUDOCS 8206100230 | |
| Download: ML20053E942 (4) | |
Text
i PHILADELPHIA ELECTRIC COMPANY 23O1 M ARKET STREET P.O. BOX 8699 PHILADELPHI A. PA.19101 SHIELDS L. DALTROFF ELactnic Pnoo c som February 9, 1982 Docket Nos. 50-277 50-278 Inspection Nos. 50-277/81-25 50-278/81-27 Mr.
R.
R.
Keimig, Chief Reactor Projects Branch #2 Division of Resident and Project Inspection Region I U.S.
Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Keimig:
Your letter of January 11, 1982, forwarded combined Inspection Reports 50-277/81-25 and 50-278/81-27.
Appendix A to the inspection reports addresses two activities which do not appear to be in full compliance with Nuclear Regulatory Commission requirements.
They are restated below along with our responses.
A.
10 CFR 70.51(b)(1) requires each licensee to keep records showing the receipt, inventory (including location),
disposal, acquisition, and transfer of all special nuclear material in his possession regardless of origin or method of acquisition.
Additionally,~10 CFR 70.51 (d) requires a physical inventory of all special nuclear material in his possession under license at intervals not to exceed twelve months.
8206100230 820604 PDR ADOCK 05000277 G
Mr.
R.
R.
Keimig, Chief Page 2 Contrary to the above, on October 15, 1981, the inspectors determined that records of the location of fission detectors (estimated to contain a total of three grams of uranium enriched in the isotope U235 to 93+%) had not been kept and that inventories had not been performed.
The detectors were onsite in locations such as the storeroom, cold storage area, reactor core, and spent fuel pool.
This is a Severity Level V Violation (Supplement III).
RESPONSE
Procedure A-44, Fuel and Special Nuclear Material Accounting arid Safeguards Directives, has been in effect prior to fuel loading on both units at Peach Bottom, (mid year 1973).
This procedure has never addressed fission detectors as individual detector assemblies contain less than 0.005 grams of uranium and the transfer of this material was exempted from the requirement for completion and distribution of nuclear material transfer reports.
Since individual shipments of this material contained less than one gram of Uranium 235, an accounting and inventory system for the detectors was never established.
In response to this recent finding, which has been classified as a Severity V Violation, Philadelphia Electric Company will establish a record keeping system for receipt, inventory (including location), disposal, acquisition, transfer and periodic physical inventory of fission detectors.
This system will be established with appropriate procedures written and revised by July 31, 1982.
Full implementation and accountability using this system will occur by October 31, 1982.
B.
10 CFR 70.51(c) requires each licensee to establish, maintain, and follow written material control and accounting procedures sufficient to enable the licensee to account for the special nuclear material in his possession under license.
Mr.
R.
R.
Keimig, Chief Page 3 Contrary to the above, on October 15, 1981, the inspectors determined that station procedures had not been followed in that the fuel location history sheets which show the location of fuel bundles in the Unit 3 reactor core and spent fuel pool had not been maintained current.
This is a Severity Level VI Violation (Supplement III).
RESPONSE
The Peach Bottom Atomic Power Station procedures which fulfill the requirements of 10 CFR 70.51(c) provide two types of fuel bundle location controls.
The first document of record, the Core Component Transfer Authorization Jheet (CCTA Sheet), documents final fuel bundle locations at the end of various types of fuel bundle manipulations in accordance with procedures FH-5, New Fuel Inspection, Channelling and Placement in the Fuel Pool, FH-6C, Fuel Movement and Core Alteration Procedure during a Fuel Handling Outage, and FH-35, Fuel Pool Accountability.
The CCTA Sheets, for the fuel bundles in the Unit 3 reactor core and spent fuel pool, were completed as required and properly maintained, thus supplying sufficient records to Philadelphia Electric Company to account for the special nuclear material, the subject fuel bundles, in our.
possession under license.
The second document of record, the Fuel Location History Sheet (FLH Sheet), which is completed in accordance with procedure A-44, Fuel and Special Nuclear Material Accounting and Safeguards Directives, accounts for specific fuel bundles over the long term.
Since Procedure A-44 does not specify a time limit within which this update must occur, the FLH Sheets for the fuel bundles in question were not updated at the time of this inspection.
The FLH Sheets for these bundles have been updated since the inspection and in the future these sheets will be updated in a timely-manner. -
t.
wirN
- Mr.
R.
R.
Keimig, Chief Page 4 Philadelphia Electric Company believes that the requirements of 10 CFR.70.51(c) were satisfactorily met for these fuel bundles 'by the completed CCTA Sheets, and request a review of the classification of this finding as an item of non-compliance.
If you have any questions or need additional information, please do not hesitate to contact us.
Very truly yours,
& b',n
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Site Inspector - Peach Bottom 6
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