ML20154M232
| ML20154M232 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/23/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806010218 | |
| Download: ML20154M232 (8) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374o1 SN 157B Lookout Place IAAY 231988 U.S. Nuclear Regulatory Cormission ATTN:
Document Control Desk Washington, D.C.
20555 Centlemen:
In the Matter of
)
Docket Nos. 50-259 Tennessee Valley Authority
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50-260
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50-296 BROWNS FERRY NUCLEAR PLANT (BFN) UNITS 1, 2, AND 3 - NRC INSPECTION REPORT NOS. 50-259/87-29, 50-260/87-29, AND 50-296/87-29, - RESPONSE TO NOTICE OF VIOLATION This letter is to provide TVA's response to the letter from S. D. Richardson to S. A. White dated April 19, 1988, which transmitted the subject inspection report.
The report cited TVA with two violations in the area of special nuclear material control and accountability, one of which resulted from the shipment of an unaccounted Intermediate Range Monitor (IRM) to the Peach Bottom Facility. provides background information and TVA's response to NRC concerns raised in the subject report. A list of commitments is provided in enclosure 2.
On May 19, 1988, Art Johnson of your staff agreed to an extension of the due dates for this response to May 26, 1988.
If you have any questions, please telephone James E. Wallace at (205) 729-2053.
Very truly yours, TENNESSEE VA AUTHORITY I
R. G idley, Di ector Nuclear Licen tng and Regulatory Affairs Enclosures cc:
See page 2 l
t 8806010218 880523
{DR ADOCK 05000259
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DCD An Equal Opportunity Employer
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U.S. Nuclear Regulatory Commission gg/i[ g g jggg cc (Enclosures):
Mr. K. P. Barr, Actir.g Assistant Director for Inspection Prograns TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. G. G. Zech, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 l
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ENCLOSURE 1
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/87-29, 50-260/87-29, AND 50-296/87-29 LETTER FROM S. D. RICHARDSON TO S. A. WHITE DATED APRIL 19, 1988 Violation 1 10 CFR 70.51(c) requires that cach licensec authorized to possess at any one Lime special nuclear material (SNM) in a quantity exceeding one effective kitegram of SNM shall establish, maintain, and follow written material control and acnounting procedures which are sufficient to enable the licensec to account for the SNM in his possession under license.
Section 7.8.1 of Technical Instruction 14, Special Nuclear Material Control, which was prepared by the licensee to satisfy the requirements of 10 CFR 70.51(c) states that each physical inventory shall be an inventory of fuel assemblics and other SKM by location and serial number including piece count.
Examplo A Contrary to the above, the licensco did not maintain adequate written material control and accounting procedures to enabic the licensec to account for SNM in that at the time of the inspection. Technical Instruction 14 did not provide for:
1.
written dologations of responsibility that were approved by line management, 2.
characterization of non-fuel SNM inventory anomalics as an event requiring a Condition Adverse to Quality Report, 3.
separation of accountability functions that establish necessary checks and
- balances, 4.
descriptions of the various container and/or material configurations that would be encountered by inventory teams, 5.
descriptions of the physical appearance of SNM ltems, the unique characteristics to be used during visual inspection and specisl handling requirements, and l
6.
level of training required for individuals prior to their conducting a physical inventory.
TVA's Response 1.
Admission or Denial of the A11ened Violation TVA admits the violation.
-g-2.
Reasons For the Violation If Admitted TI-14 was inadequato due to insufficient management attention to-the procedural controls in place for SNM accounting and handling.
If TI-14 had addressed the above noted control and accounting deficiencies, the shipment could.have been halted or an investigation could have been initiated to correct the SNM accounting anomalics.
3.
Corrective Steps Which Havo Been Taken and Results Achieved TVA has implemented many programmatic improvements since the incident and they are as follows:
TVA performed a compechensive SNM records search to provido a BFN SNM a.
baseline, and these results were reported to NRC on September 30, 1987, b.
Revised corporate procedure pHP 1801.03 to provido additional guidance on inventory methods, training requirements and on the frequency and extent of SNK system reviews by the corporato program manager. The frequency of these system reviews will be at least twice por year beginning in August 1987, Revised Site Director Standard Practice 26.1 to provido specific c.
details for cito management overview of tha alte's SNM program, d.
Revised the site maintenance proceduros (e.g., EMI-35, SMI-192.2 SMI-192.4. SMI-192.5) to include SNM instructions, and provided training to key cito personnel, Corporate overview of the BFN SNM program will includo a quarterly SNM e.
system review for the 24 months following September 1987 (Bosides the August 18-21, 1987, annual system review, two quarterly status reviews were performed on December 15-16, 1987, and March 10-11, 1988), and f.
The following specific corrective actions have been taken on the six (6) problems with TI-14 specifically identified in this Notice of Violation:
f.1 TI-14 now clearly assigns a designated representativo if the Reactor Engineering Section Supervisor is absent, f.2 TI-14 now requires that all inventory discrepancies shall bo l
documented by initiating a condition Adverse to Quality Report.
f.3 TI-14 now addresses the need for the individual who has performed an SNM physical inventory to compare the inventory results to the i
appropriate SNM history form.
Second-party verification is required for all inventories. A CAQR is required for any discrepancy. Therefore, the comparison and subsequent CAQR will provide the required check and balanco to prevent a recurrence.
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. f.4 TI-14 now describes fuel bundle unique packaging and non-fuel SNM containces, f.5 TI-14 now dolineates the need for Radeon coverage during special handling requirements and includes descriptions of physical appearance and physical storago configurations, f.6 TI-14 now assigns the responsibility to the SNM custodian for determining that individual (s) performing inventories have appropriate knowledge and experience.
Their knowledge and experience is verified by reviewing the training records of individuals assigned physical inventory duties.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Quarterly corporate system reviews will be conducted for 24 months starting in September 1987.
5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved. However, TVA will continue to perform the quarterly corporate system reviews until September 30, 1989.
Example B Contrary to the above, Technical Instruction 14 was not followed in that during four (4) separate inventories of SUM stored in a wooden box on October 28, 1986, January 30, 1987, and twice on June 16, 1987, en accurate piece count and listing of serial numbers was not obtained.
As a result, a radioactive material shipment on June 16, 1987, was improperly documented as a shipment of five (5) Intermediate Range Monitors (IRMs) containing about one milligram of SNM cach, as opposed + o the actual count of six (6) IRMs contained in the shipment.
1.
Admission or Denial of the Alleged Violation TVA admits the violation, i
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Reasons For the Violation If Admitted The four separate inventories of SNM stored in a wooden box were inaccurate.
The initial inventory performed on October 28, 1986, was conducted by an SNM Aide who did not empty the box to obtain an accurate IRM piece count. The SNM Aide recorded an inaccurate count of the IRMs on the crate. At that time. TI-14 instructed the SNM Alde to "check all serial numbers of SNM items in opened shipping containers and/or other locations, if possible, without moving the incore detectors." This minimized the unnecessary handling of expensive instruments. Therefore, the SNM Aide believed the initial inventory was performed according to the procedure. The same procedure was agaita used during the subsequent inventories including the two inaccurate inventories performed just before the shipment on June 16, 1987. On the day of the shipment, a serial number discrepancy was noted. This discrepancy was dismissed as a transcription error, whereas, both detectors were in the wooden box.
Consequently, an additional IRM containing about one milligram of SNM (U-235) was inadvertently shipped. Again, the management caution (not to remove the detectors) was not questioned by personnel performing the inventories.
3.
Corrective Steps Which Have Been Taken And Results Achieved TI-14 was revised on June 30, 1987, to remove the management caution and require qualified personnel to remove cach SNM item from its respective container to ensure an accurate piece count, verification of location, and verification of serial number.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations None 5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
Violation 2 10 CFR 70.51(c) requires that each licensee authorized to possess at any one time special nuclear material (SNH) in a quantity exceeding one effective kilogram of SNM shall establish, maintain, and follow written material control and accounting procedures which are sufficient to enable the licensee to account for the SNM in his possession under license.
Section 7.9 of Technical Instruction 14 Special Nuclear Material Control, which was prepared by the licensee to satisfy the requirements of 10 CFR 70.51(c), states that all established internal accountability records i
shall have prepared signature or initial lines, where required, to expedite and promote proper documentation and identification of the responsible l
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- individuals. These records should readily yield information about SNM receipts, internal transfers of SNM, and any shipments of SNM.
Updates of these records should be completed within a reasonable time after the event necessitating the update.
Contrary to the above, the provision for the update of accountability records within a reasonable time was not met in that Fuel Assembly Transfer Forms for the unit 3 core unload performed between January and February 1987 were not updated in a reasonable time with some being updated as late as four months af ter physical movement of the fuel.
TVA's Response 1.
Admission or Denial of the Aller,ed Violation TVA admits the violation.
2.
Reasons For the Violation if Admitted Af ter unit 3 fuel assemblies were unloaded, the computer data base was not updated at that tima due to the computer hardware being relocated onsite.
This relocation made the data base inaccessible. The required history data was available for nanagement tracking by means of two separate documents.
These documents were verified to accurately indicate the existing location of unit 3 fuel assemblies when a physical inventory was completed on March 4, 1987. When the computer was available to the responsible engineering section, the history data was put into the computer, and the update was completed before the subject inseaction.
3.
Corrective Steps Which Have Been Taken and Results Achieved TI-14 was revised on August 28, 1987, requiring an update of transfer history data within 10 working days of the transfer event or the SNM custodian will notify the Technical Support Services Superintendent in writing of a potential update delay to ensure corrective actions can be taken to minimize the delay.
4.
Corrective Steps Which Will Bo Taken To Avoid Further Violations None 5.
Date When Full Compliance Will Be Achieved Full compliance has been achieved.
ENCLOSURE 2
RESPONSE
NRC INSPECTION REPORT NOS. 50-259/87-29, 50-260/87-29, AND 50-296/87-29 LETTER FROM S. D. RICHARDSON TO S. A. WHITE DATED APRIL 19, 1988 LIST OF COMMITMENTS 1.
Report to NRC by September 30, 1987, the results of the SNM records search.
(Completed - September 30, 19,87) 2.
Revise corporate procedure PMP 1801.03 by November 30, 1987, as described in enclosure 1.
(Completed - November 25, 1987) 3.
Revise BFN procedures by December 1, 1987, for implementation by January 1, 1988, to require that only personnel with specific SNM training be assigned SNM duties.
(Completed - November 30, 1987) 4.
Provide SNM training to additional key site personnel by January 1, 1988.
(Completed - December 17, 1987) 5.
For a period encompassing the next 24 months beginning September 1987, the corporate program manager will perform a quarterly check of the status of the SNM program at BFN.
6.
Revise Technical Instruction 14 requiring update of transfer history data within 10 working days or notify management in writing of a data update delay.
(Completed - August 28, 1987)