ML20126E589

Insp Rept SO-II-76 on 710927-30.No Noncompliance Noted.Major Areas Inspected:Safeguard Controls for Inventory Procedures & Identification Practices,Internal Control,Audit Tests of Nuclear Matl,Thermal Output & Physical Protection of SNM

ML20126E589
Person / Time
Site:	Big Rock Point, 07000660  File:Consumers Energy icon.png
Issue date:	11/03/1971
From:	Kenna W US ATOMIC ENERGY COMMISSION (AEC)
To:
Shared Package
ML20126E587	List: ML20126E583 ML20126E589
References
SO-II-76, NUDOCS 8102060139
Download: ML20126E589 (11)

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NUCLEAR IG.TERIALS SAFIDUARDS INSIECTIO!!

0F SPECIAL I:UCISAR IG.TERIAL AT CO SUPERS PO' DER CO::FALT BlG ROCK FOINT CHARLEVOll, MICHIGA!!

INSPECTION NO. S0-II-76 I

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OFFICIAL USE OulY NUCLEAR MATERI AIS SAFEUARDS INSPECTION OF SPSCIAL NUCLEAR MATERIAL AT CONSUMERS POWER COMPANY BIG ROCK POINT CHARLEVOIX, MICHIGAN INSPECTION NO. S0-II-76 I. INTRODUCTION 1.01 - An inspection of safeguards control over special nuclear material at Big Rock Point (BRP) was made by the District II Safeguards Office, Di; vision of Nuclear Materials Safeguards. The inspection covered the period of opera-tion from September 1, 1969,through June 30, 1971, with the field work being done from September 27-30, 1971.

3.02 - The Big Rock Point station of Consumers Power Company (CPC) is located near Charlevoix, Michigan, on Lake Michigan. The plant uses a General Electric nuclear steam supply system fueled with slightly enriched UO2 clad in stainless steel or zirconium. The last three core loadings have contained varying tnounts of plutonium fuel. There are three mixed oxide (uranium and plutonium) assem-blies in the current core. Current licensed power level is 240 MWt (70 3!Ole) and operations are ' onducted c under Licenses DPR-6 and S!.K-614 outages during the period covered by this 1.03 - ThereCycle inspection. were 7two refueling ended 2/13 /70; Cycle 8 operated from 3/29/70 to 2/12/71; and Cycle 9, the current loading, began 3/13/71.

II. SCOPE l

2.01 - The inspection was made to determine the adequacy of BRP's conformance to safeguards requirements contained in Title 10, Code of Federal Regulations, i Part 70, "Special Nuclear Material," and specific requirements contained in Licenses DPR-6 and SC::-614 In addition,, the licensee 's conformance to 10 CFR 73, " Physical Protection of Special Nuclear Material," was reviewed.

i 2.02 - The licenace 's safeguards controls were reviewed for inventory prece-dures and identification practices, internal control, records and reports.

The inspection team performed independent depletien and production calcula-tions and conducted tudit tests of nuclear material, thermal output, depletion /

production and interns 1 control records. Procedures, practices and facilities utilized for the physical protection of special nuclear material were clso examined.

III.' CONCLUSIONS 3 01 - No itema of ncnuorplianc.e with safeguards provisions of 10 CFR 70 were noted as a result of this inspection. The licensee was in compliance with the posseccion limits of Dia-6 and SUM-614 How3ver, errors were noted in internal control records thst will require centinued surveillance to prevent recurrene. .

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3 02 - At the time of the inspection the licensee was exempt from the require-ments of 10 CFR 73 Nevertheless, during February-March 1970, the licensee possessed greater than 16 kilograms of unirradiated plutonium fuel and was in noncompliance with the following sections of 10 CFR 73 at that time: 73 41(a),

73.41(b), and 73 41(d).

IV. DISCUSSIC:!

A. Safeguards Requirements of 10 CFR 70 4 01 - The inspection revealed the status of safeguards requirements prescribed by 10 CFR 70 to be as follows:

1. CPC was not required to submit FMC's or written material control and accounting procedures under the exclusion provision of 10 CFR-70 51(c).

2. Possession and use of special nuclear material have been confined to the locations and purposes authorized in the license as required by 10 CFR 70.41.

3 SD: has not been transferred except to an authorized recipient as ,

required by 10 CFR 70 42.

4 Records showing the receipt, inventory (including location), dis-posal and transfer of all special nuclear material at BRP have been maintained as required by 10 CFR 70.51(a).

5 Written material control and accounting procedures have been established and maintained as required by 10 CFR 70.51(b)(1).

6. Physical inventories have been conducted as required by 10 CFR 70 51(b)(2). .

I 7 There have been no losses that required reporting under 10 CFR 70.52.

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8. Material status reports have been submitted at the frequency required by 10 CFR 70.53 The last report reviewed during this inspection was submitted as of June 30, 1971.

9 Transfer reports on shipments and receipts have been prepared as required by 30 CFR 70.54 B. Requirements of. the Licenses DPR-6 and SDI-614 4.02 - Authorized limite and c.ctual possession of SD: under the above licenses as of June 30, 1971, were as follows:

Possessicn Licence Authorized L$ nit DFR-6 1200 kgs. U-235 559 1 kcs. U-235 DPR-6 50 kgs. Pu 14 3 kgs. Pu SR:-614 0.03 kgs . Pu 0.08 kgo. Fu

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C. Inventory 4 03 - The inventory of special nuclear material at BRP included 84 fuel assemblies in the reactor; 20 fuel assemblies and 40 spare fuel rods in new fuel storage; and 17 fuel assemblies and 10 fuel rods in the' irradiated fuel storage basin. The fuel is enriched uranium (originally 2 9 - 4 2%

U-235) idth the exception of the mixed oxide assemblies. In this category are 26 rods containing about 380 grams of plutenium and three assemblies

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containing apprcximately 14 kilograms of plutonium. The plutonium is leased but the depleted and enriched uranium portions of the mixed oxide fuel are privately-owned. BRP also has a leased plutonium-boryllium neutron source. About half of the enriched uranium fuel is leased with the remainder owned by CPC.

4.04 - The special nuclear material content of irradiated fuel was accepted based upon Big Rock Point 's depletion / production calculations as applied to the fabricator's (G.E.) stated SNM content and as confirmed by the inspection team's calculations. Fission counters and the plutonium source are reported at tFn criginal values. Material balance statements covering all SNM at BRP appear as Appendices A, B, C and D.

4.05 - BRP maintains written inventory procedures and a review of the records indicated that the procedures were being followed.

D. Inventory Verification 4.06 - The inspection team had no means of determining the SNM content of the fuel by nondestructive means. Accordingly, the invedtory verifi-cation was limited to certification of the BRP inventory records. The serial number and location of each fuel assembly in new fuel storage was verified to facility records. The presence of 40 unirradiated rods in new fuel storege was confirmed and six of the serial numbers verified.

The presence of 17 fuel assemblies and 10 rods in the spent fuel basin was confirmed and the serial numbers on four of the assemblies were verified. The small size of the numbers, lack of. adequate lighting and the poor contrast with surrounding metal all contributed to the inspector's inability to verify additional assemb]y serial nwnbers. No discrepancies j

were noted in the BRP inventory records.

E. Reactor Thermal Output l

4.07 - The BRP on-line computer perforrs hourly heat balances and prints the average thermal power level for the hour. The sum of the 24 hourly

, celculations is recorded as the thermal output for the day. A manual l version of the heat balance is performed at least once per shift per week to cross check the computer calculatiun and keep control personnel familiar with the procedure in case of computer breakdown. The heat balcnce recounts for the major heat losses and gains to the system and audit of the records revealed no discrepancies of significance.

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F. Nuclear Material Depletion and Production 4.08 - The Big Rock Point computer allots exposure to the fuel assemblies in the core using a G.E. exposure distribution code similar to FLARE. The exposure data output by the computer are sent to the CPC offices in Jackson,

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Michigan, where another code is used to interpolate in fuel depletion / pro-duction tables also furnished by G .E. The inspection team traced data from the computer printouts to the applicable material status report and calcu-lated the resultant depletion / production. No significant discrepancies were noted. The methods and procedures used are considered acceptable.

4 09 - The inspection team performed manual calculations to test the suitability of depletion and production reported by the licensee during the period under review. The calculations indicate that the reported quantities are reasonable and concistent with reported reactor thermal output. Comparison of the reported and calculated quantities is made in Appendix E.

G. Internal Control 410 - The procedures employed at ERP for the control of special nuclear material within the facility hcve been considered acceptable. Ecwever, audit of the records during this inspection revealed that the procedures have not always been followed. Omissions were noted in the internal con-trol records related to the discharge of Cycle 8. These were discussed with the Assistant Plant Superintendent who agreed to take steps to pre-vent recurrence.

H. Records and Reports 411 - The licensee's control records were satisfactory in that all external activity had been recorded and reported to the AEC as required. Each entry into the control records was supported by a source document. Records relating l

l to shipments and receipts were examined and no errors noted. Mated al status l

reports were issued at the required frequency and were found to reflect the I activity of the licensee.

412 - The inspection team performed a 100% audit of Forms AEC-741 and 742 i executed by the licensee during the period under review. The inspectors noted an average delay of over 6 days between shipments of SNM and prepara-tion of the appropriate transfer documents. Failure to show gross ar.d net i weights constituted the most frequent omissions frem the 7hl's covering shipments. Ecceipts of SNM were generally acknowledged within 10 days and on only one occasion was this exceeded (17 days). Ibview of the 742 's l revealed no errors. The discrepancies discussed above were reviewed in I

detail with licensee management, t

1. Pqysical Protection.

i 4.13 - The initici revir.w of phycical protection pracedures, practices end facilitiec at BRP was conducted during this iney2ction. At the time er th_

review all plutonium fuel was irradiated and exe:tpt from 10 CFR 73 under the criteria provided in 73.13(t) . However, during February-March 1970 over 15 kilograms of unirradiated plutonium contained in three fuel assemblies was held at ERP pending loading to the core.

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4.14 - The plutonium fuel' assemblies were received on 2/20/70 and loaded to 'the core during t he 3/16-19/70 time period. In the interim the assem-blies were stored in the new fuel storage facility, a reinforced concrete honeycomb built into the floor adjacent to the reactor, all within the containment sphere. Each of the 102 locations in the honeycomb ( a 6 x 17 array) is large enough to acccmmodate one fuel assembly. Each location has a quarter-inch thick steel hatch cover. A latching mechanism allows groups of 34 hatch covers to be opened while the remaining 68 covers are locked. The three latch mechanisms are secured with Master padlocks.

Keys to the padlocks are controlled by the Shift Supervisor, who consults the Reactor Engineer before allowing anyone to use the key. Two air locks (equipment and emergency personnel escape) open to the outside of the con-tainment sphere and a third air lock (personnel) opens to the adjacent turbine building. The equipment and personnel air locks can be electrically opened from either inside or outside the sphere. An alarm sounds within the sphere when either of these two air locks are opened.but there is no alarm in the control rocm. The outside of the sphere, including the equipment and emergency escape air locks, are checked hourly by a Burns guard at night and every two hours during the day. It is cbvious that the facility does not meet the criteria of 73 32(b) regarding storage of S 24. However, the license was not cited for noncompliance due to the short interval of storaga, che -

presence of numerous personnel in the sphere during shutdowr.s (the pl9.nt had been down for a week when the fuel was received) and because of the degree of protection afforded by the locked honeycomb.

4.15 - The BRP facility is surrounded by a fence that meets the criteria of 10 CFR 73 3(f)(1). However, it was determined that records of inspect 1:nc of the protected area had not been maintained and the licensee was cited fc:

noncompliance with 10 CFR 73 41(b) . Records of such inspections will be maintained whenever the facility is subject to Part 73 in the future.

4.16 - The licensee had not designated av.horized representatives in writing. Accordingly, BRP was cited for noncompliance with 10 CFR 73 41(c) .

The requi' red designations will be made immediately.

4 17 - No written procedures for controlling access to protected areas or for controlling accesc to keys for locks used to protect SNM have been prepared by i.he licensee and BRP was considered in noncomplinnee vdth 10 CFR 73.Ll(d). Tne current key control methods were considered accept scle and written procedures will be prepared reflecting these methods. BRI supervision will also prepare procedures for controlling access to the protected area.

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JLU!Miau William @2 L. Ken,na, Ew/&.

Dir(ector District II Safeguards Officc Att9:En t . -

Appendices A, B, C, D, and. E Date of Report!.fN , ' 'i 9 rr

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CONSUMERS P0 DER COMPANY BIG ROCK POINT AEC-ObnED ENRICHED URANIUM MATERIAL BALANCE STATESIT AS OF JUUE 30, 1971 UNITS: Gra~.s Total U U-235 Beginning Inventory 9/1/69 33,914,585 859,175 Receipts 5,352,457 189,588 -

Ship:r.ent s 18,620,774 437,737 i '

T*ansferred to private  !

ownership 10,!472,298 345,324 i

Burnup ,i 82,068 52,595 Ending Inventory 10h091,902 213,107 APPEI! DIX A t

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CUE 31?PIRS PUdER COMPANY BIG ROCK POINT AEC-Ur3 ED PLUTONIUM MATERIAL BAlt,NCE STATE'2!!T AS OF JOUE 30, 1971 UNITS: Grams Pu-239 A 241 Total Pu 781 UNITS: a7g=,

870 ory9/1/69* 14,298 '

16,057 Pu-239

• 241 64 86 91,619 3,102 2,429 11,913 14,412 26,538 y*

61,300 5

Pu, 74 grams Pu-239 +241, 56,857 source - 83 grams APPE!! DIX C .

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CONSUMERS PO4ER COMPA!PI BIG ROCK POII.T FRIVATELY-04NED EG ICHED URANIUM MATERIAL BALANCE STATEENT AS OF JUNE 30, 1971 UNITS: Gra.s Total U U-235 BeginningInventory9/1/69 Receipts 868,557 30,551 Transferred from lease account 10,472,298 345,324 Shipments Burnup 56,936 29,848 Ending Inycntory 11,283,919 346,027 i

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APPENDIX B l

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OFFICIAL USE ONLY CONSUIEtS POWER COMPANY BIG ROCK POItTI' COMPARISON OF DEPLETION / PRODUCTION CAICULATICI!S .

SEPTDTER 1,1969 THROUGH JUNE 30, 1971 UNITS: Kilogra s Reported (PRP) Calculated (AFC)

Cycle ? (o/1/69-EOC)

Total U depletion 40.9 36.5 U-235 deple~ tion 23 0 23 2 Total Pu production 8.8 9.5 Pu fuel depletion 0.4 0.4 Cycle 8 & 9 (EOC 6/30/71)

Total U depletien 98.1 91.9 U-235 depletion 59.5 57.6 Total Pu production 23.9 24.4 Pu fuel depletien 2.7 2.9 APPENDIX E j I

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