ML20207L759
| ML20207L759 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/02/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20207L734 | List: |
| References | |
| 50-259-86-38, 50-260-86-38, 50-296-86-38, EA-86-194, NUDOCS 8701120338 | |
| Download: ML20207L759 (3) | |
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NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-259, 50-260, 50-296 Browns Ferry License Nos. DPR-33, DPR-52, DPR-68 During the Nuclear Regulatory Commission (NPC) inspection conducted on October 15-17, 1986, violations of NRC requirements were identified.
The viola-tions involved the failure to adequately account for and control five fission counters (dunking chambers) containing 10 grams of enriched uranium-235, and to comply with transportation and disposal requirements for the special nuclear material.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the,particular violations are listed below:
A.
10 CFR 70.51(c) requires that each licensee who is authorized to possess at any one time special nuclear material in a quantity exceeding one effective kilogram of special nuclear material shall establish, maintain and follow written material control and accounting procedures which are sufficient to enable the licensee to account for the special nuclear material in his possession under license.
Licensee Procedure TI-14, Special Nuclear Material Control, Revision 4, September 25, 1986, required the following:
Paragraph 5.0 required that except as noted all inventories will be documented by use of an "SNM Inventory Form" (Attachment C).
Paragraph 2.4 defined SNM storage areas as the new fuel storage vault, spent fuel storage pool, reactor and warehouse.
Contrary to the above, the requirement that the licensee maintain and follow written material control and accounting procedures was not met in that:
1.
Since being received by the licensee on April 1, 1976, none of the physical inventories of five fission counters (dunking chambers) were i
documented on the SNM Inventory Form. The inventories were documented on the " History Form" instead.
2.
During the period November 1, 1983 to January 22, 1985, the five fission counters '(dunking chambers) were stored on the Unit-3 refueling f
floor and in the Unit-3 equipment pit, areas not identified as special nuclear material storage areas.
i 3.
The licensee's special nuclear material control procedure failed to require authorization paperwork for non-fuel special nuclear material movements.
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B.
10 CFR 70.52(a) requires that each licensee report immediately any loss, other than normal operating loss, of special nuclear material.
Contrary to the above, the licensee failed to irrmediately report the loss of five fission counters (dunking chambers) which contained special nuclear material.
The five fission counters (dunking chambers) initially could not be found on July 25, 1986, and the apparent loss was not reported until October 14, 1986.
C.
10 CFR 70.42(c) requires that before transferring special nuclear material to a licensee of the Commission or an Agreement State, the licensee transferring the material shall verify that the transferee's license authorizes receipt of the type, form and quantity of special nuclear material to be transferred.
Contrary to the above, on March 4,1985, the licensee failed to verify that the transferee was authorized to receive the type, form and quantity of special nuclear. material to be transferred prior to shipping five fission counters (dunking chambers) containing special nuclear material to U.S. Ecology, Richland, Washington, under Shipment Number 2886.
D.
10 CFR 70.54(a) requires that each licensee who transfers special nuclear material follow the requirements set out in 10 CFR 74.15(a).
10 CFR 74.15(a) requires each licensee who transfers special nuclear material complete and distribute a Nuclear Material Transaction Report on DOE /NRC Form 741. This should be done in accordance with the printed instructions for completing the form whenever the licensee transfers a quantity of special nuclear material of 1 gram or more of contained uranium-235.
Contrary to the above, on March 4,1985, the licensee failed to complete and distribute a DOE /NRC Form 741 for the transfer of five fission counters (dunking chambers) containing 10 grams of special nuclear material to the U.S. Ecology disposal site near Richland, Washington.
E.
10 CFR 71.5(a) requires that each licensee who transports licensed material outside of the confines of its plant or other place of use comply with applicable requirements of the regulations apriropriate to the mode of transport of the Department of Transportation (DOT) in 49 CFR Parts 170 through 189.
49 CFR 172.203(d) requires that the description for a shipment of radioactive material on a shipping paper must include the name of each radionuclide in the radioactive material, the activity contained in each package and the words " Fissile Exempt" if the package is exempt pursuant to 49 CFR 173.453.
49 CFR 173.453(a) states that fissile material packaging requirements do not apply to a package containing not more than 15 gr:ms of fissile radionuclides.
Contrary to the above, on March 4,1985, the licensee f ailed to comply with DOT regulations applicable to the transportation of five fission counters (dunking chambers) containing approximately 10 grams of special nuclear material to U.S. Ecology, Richland, Washington, under Shipment Number 2886 in that the names of the radionuclides within the radioactive material failed to include the Uranium-235 that was present; the activity contained in the package did not include the activity of the Uranium-235 within the fission counters (dunking chambers), and the shipping paper was not annotated
" Fissile Exempt."
F.
10 CFR 20.201(b) requires that each licensee shall make or cause to be made such surveys as may be necessary for the licensee to comply with the regulations in 10 CFR Part 20.
10 CFR 20,311(d)(1) requires that radioactive wastes be classified according to 10 CFR Part 61.55.
Contrary to the above, the licensee failed to perform an adequate evaluation to show compliance with the radioactive waste classification requirements of 10 CFR Part 61 for Package Number FB-85-2638 within Shipment Number 2886 on March 4,1985, in that the dose to curie evaluation that was made to estimate the total activity within the package failed to consider that the container contents were shielded with lead, resulting in an underestimation of the total activity within the package.
Collectively, these violations have been evaluated in the aggregate as a Severity Level IV problem (Supplement III).
Pursuant to the provisions of 10 CFR 2.201 Tennessee Valley Authority is hereby required to submit to this Office with 30 days of the date of the letter trans-mitting this Notice, a written statement or explanation in reply, including for each violation:
(1) the reason for the violation if admitted, (2) the correc-tive steps which have been taken and the results achieved, (3) the corrective steps which will be taken to avoid further violations, and (4) the date when full compliance will be achieved. Where good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION
't J. Nelson Grace Regional Administrator Dated at Atlanta, Georgia this 2nd day of January 1987
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