ML20211C708
| ML20211C708 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/11/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8702200186 | |
| Download: ML20211C708 (22) | |
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l TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 157B Lookout Place FEB 111987 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Office of Nuclear Reactor Regulation Washington, D.C. 20555 Attention: Dr. J. Nelson Grace In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 BROWNS FERRY NUCLEAR PLANT UNITS 1, 2 AND 3 - NRC-0IE RECION II INSPECTION REPORT NOS. 50-259/86-38, 50-260/86-38, AND 50-296/86 RESPONSE TO VIOLATION l Enclosed is our response to your January 2,1987 letter to S. A. White transmitting IE Inspection Report Nos. 50-259/86-38, 50-260/86-38, and 50-296/86-38 which cited TVA with six violations characterized together as one Severity Level IV Violation for our Browns Ferry Nuclear Plant (BFN).
Also enclosed with this response is a report sununarizing our nonfuel Special Nuclear Material (SNM) inventory, the results of which were reported to NRC on January 14, 1987. An extension of the violation response due date to February 9, 1987, was agreed to in a conversation with Al Ignatonis of your staff at our BFN site on January 29, 1987.
If you have any questions, please get in touch with M. J. May at (205) 729-3566.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSE LLEY AUTHORITY R. L. Celd1 y, Director Nuclear Saf ty and Licensing Enclosures cc: See page 2 hdb'.dmS$ff0 B702200186 870211 pf PDR ADOCK 05000259 G PDR ,
An Equal Opportunity Employer
U.S. Nuclear Regulatory Commission cc (Enclosures):
Mr. James M. Taylor, Director U.S. Nuclear Regulatory Commission Office of Inspection and Enforcement Washington, D.C. 20555 Mr. G. G. Zech, Director TVA Projects U.S. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Browns Ferry Resident Inspector Browns Ferry Nuclear Plant Route 2, P.O. Box 311 Athens, Alabama 35611 i
ENCLOSURE 1
RESPONSE
TO NRC INSPECTION REPORT NOS. 50-259/86-38, 50-260/86-38, 50-296/86-38 DATED JANUARY 2, 1987 Item 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 (SNM) 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 2, 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, spene 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:
- a. Since being received by the licensee on April 1, 1976, none of the physical inventories of five fission counters (dunking chambers) were documented on the SNM Inventory Form. The inventories were documented on the " History Form" instead.
- b. During the period November 1, 1983 to January 22, 1985, the five fission counters (dunking chambers) were stored on the Unit-3 refueling floor and in the Unit-3 equipment pit, areas not identified as special nuclear material storage areas.
- c. The licensee's special nuclear material control procedure failed to require authorization paperwork for nonfuel special nuclear material movements.
- 1. Admission or Denial of the Alleged Violation TVA admits the vlotation.
- 2. Reason for the Violation if Admitted
- a. The statement "except as noted" in TVA procedure TI-14 paragraph 5.0 was interpreted by TVA to mean as noted on TI-14 Attachment D (In-Core Detector History Form).
- b. The five fission chambers were regarded as instruments rather than items containing SNM.
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- c. TI-14 was deficient in not requiring a transfer form for transfers of nonfuel SNM.
The underlying cause of these deficiencies was a lack of management attention to the control and accountability of nonfuel SNM.
- 3. Corrective Steps Which Have Been Taken and Results Achieved All nonfuel SNM onsite has been physically inventoried and documented on TI-14 Attachment C (SNM Inventory Form). Four Traversing In-core Probes (TIPS) and nine Source Range Monitors (SRMs) and/or Intermediate Range Monitors (IRMs) were not accounted for. The results of this inventory were reported to NRC on January 14, 1987. Enclosure 2 to this violation response summarizes this nonfuel SNM inventory. TI-14 has been revised to define all storage locations for SNM.
Plant management issued a letter on November 4, 1986, to stress the importance of SNM control and accountability ~ This letter issued guidelines requiring the SNM custodian's involvement in the receipt, transfer, disposal, physical control, inventory, acquisition, loss, or suspected diversion of SNM. This has resulted in subsequent transactions of SNM including the receipt of IRMs, transfer of Local Power Range Monitors (LPRMs), and the installation of an SRM being coordinated with SNM custodian.
- 4. Corrective Steps Which Will Be Taken to Avoid Further Violations TI-14 will be revised to (a) clarify the intent of paragraph 5.0 by requiring documentation of all physical inventories on the correct form.
(b) clearly define responsibility and provide instructions for implementing these responsibilities, and (c) require the use of a nonfuel SNM Transfer Form.
- 5. Date When Full Compliance Will Be Achieved Full compliance will be achieved by April 15, 1987 i
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Item 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 immediately 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.
- 1. Admission or denial of the Alleged Violation TVA admits the violation.
- 2. Reasons for the Violation if Admitted TVA management misinterpreted 10 CFR 70.52(a) to mean that the SNM was not officially lost until completion of a plant-wide search. NRC interprets 10 CFR 70.52(a) to mean that the SNM was lost when not found in the last approved location and it should have been reported lost then.
- 3. Corrective Steps Which Have Been Taken and Results Achieved TVA management now understands the reporting requirements of 10 CFR 70.52(a) as demonstrated by a report to NRC on January 14, 1987, concerning the results of a site wide SNM physical inventory.
- 4. Corrective Steps Which Will Be Taken to Avoid Further Violations TI-14 will be revised to reference 10 CFR 70.52(a) and clearly state the requirement for timely reporting of lost SNM.
- 5. Date When Full Compliance Will be Achieved Full compliance will be achieved by April 15, 1987.
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Item C 10 CFR 70.42(c) requires that before transferring special nuclear material to a licensee of the Commission or an Agreement Stato, the licensee transferring the material shall verify that the transforee's licenso authorizes receipt of the type, form and quantity of special nuclear material to be transferred.
Contrary to the above, on March 4, 1985, the licenseo 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.
- 1. Admission or Denial of the Alleged Violation TVA admits the violation.
- 2. Reasons for the Violation if Admitted The SNM was apparently transferred to U.S. Ecology in Richland, Washington. The U.S. Ecology license was not reviewed before the transfer because Browns Ferry Radwasto Section personnel were not awaro that SNM had been placed in the container.
- 3. Corrective Steps Which Have Been Taken and Results Achieved The following correctivo steps have been taken:
- a. Radwasto containers in the plant have been locked to provent untrained personnel from placing SNM or other types of unacceptable material into radwasto containers. The keys to tho containers are kept by Radwasto personnel.
- b. SNM and other unacceptable waste forms are stored in containers which are uniquely marked to indicato that the container is not a radwaste disposal container.
- c. Radwasto personnel qualified as radwasto packagers havo received training to ensure they are awaro that SNM cannot be placed in a radwasto container without the Radwasto Controller's permission. The radwaste packagers were instructed not to allow items that may contain SNM or other unacceptable wasto to bo placed in the radwaste disposal container without the permission of a Radwasto Controller.
- 4. Corrective Steps Which Will De Taken to Avoid Further Violations Radwasto packer and loader training will be revised to include appropriato instructions on the handling of SNM. Ceneral Employeo Training will be revised to include a description of SNM and special handling requirements. These items are niso discussed in our management controls portion of this responso.
- 5. Date When Full Compliance Will Be Achieved Full compliance will be achieved by Apell 15, 1981.
Item 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.
- 1. Admission of Denial of the Alleged Violation TVA admits the violation.
- 2. Reason for the Violation TVA was unaware of the location and, therefore, of the shipment of 10 grams of SNM.
- 3. Corrective Steps Which Have Been Taken and Results Achieved With the completion of a site wide physical inventory of all nonfuel SNM on January 10, 1987, all SNM onsite is now adequately accounted for and controlled. 11 0 shipment of SNM has occurred since November 4, 1986.
Radwasto personnel have been trained on the recognition, control, and accountability of SNM.
- 4. Corrective Steps Which Will Be Taken to Avoid Further Violations Full compliance was achieved with completion of SMN inventory.
- 5. Date When Full Compliance Achieved Full compliance was achieved on January 10, 1987.
Item 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 appropriate 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 grams of fissile radionuclides.
Contrary to the above, on March 4, 1985, the licensee failed 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."
- 1. Admission or Denial of the Alleged Violation TVA admits the violation.
- 2. Reasons for the Violation The radwaste shipping manifest did not indicate the names of the uranium isotopes present in the fission counters (dunking chambers) and the manifest was not annotated " Fissile Exempt" because Radwaste personnel were not awa.o that the fission counters containing the SUM had been placed in the radwasto disposal container.
- 3. Corrective Steps Which Have Been Taken and Results Achieved The corrective steps described in response to items C and D of this response have been taken to prevent SNM from being placed into the radwaste disposal containers without the knowledge of the Radwaste controller.
- 4. Corrective Steps Which Will De Taken to Avoid Further Violations Further corrective actions shown in response to items C and D of this response will also be taken to prevent further violations.
- 5. Date When Full Compilance Will De Achieved Full compliance will be achieved by April 15, 1987
Item 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.
- 1. Admission or Denial of the Alleged Violation TVA admits the violation.
- 2. Reasons for the Violation if Admitted Calculations used to show compliance with the radioactive waste classification requirements of 10 CFR Part 61 did not consider container shielding because there was no specific control in place to indicate that the container contents were shielded. At the time the violation occurred, Radwaste personnel relied on personnel who packed the container to note on the control tag that the container was shleided.
- 3. Corrective Steps Which Have Been Taken and Results Achieved Radwaste disposal containers are uniquely numbered before entering the plant protected area so that comments or problems with a container can be tied to a specific container through its serial number. Whenever shielding is placed in a container, the container serial number has an "L" added. The "L" indicates to Radwaste personnel that the container has internal shielding and that an acceptable curio content calculation method must be determined.
- 4. Corrective Steps Which Will De Taken to Avoid Further Violations No additional corrective actions are necessary,
- 5. Date When Full Compliance Will De Achieved Full compliance has been achieved.
MANAGEMENT CONTROLS TVA agrees with NRC that the Special Nuclear Material (SNM: violations indicate weakness of management controls in the area of SNM control and accountability.
A SNM program corrective action plan has been developed which outlines action items to improve the control and accountability of SNM. A summary of the actions in the plan, scheduled completion datos, and responsible organization assignments are as follows:
Action Item 1: Improve site management control in the areas of (a) SNM handling and ac :ountability, (b) radwanto packaging and shipping, and (c) refuel floor activities.
Action Plan: A Browns Ferry Site Director Standard Practice will be written to ensure that line management responsibilities are clearly defined, understood, and agreed upon in the above areas.
Completion Date: March 31, 1987 Responsible Organization: BFN Plant Manager Action Item 2: Improve generic SNM program proceduros.
Action Plan: Implement long-term improvements by writing a corporate standard for SNM.
Completion Date: June 1, 1987 Responsible Organization: Division of Nuclear Services (DNS)/ Nuclear Fuel Action Item 3: Improve plant-specific SNM program proceduros.
Action Plan: (A) Revice plant-implementing procedures to comply with Nuclear Quality Assuranco Manual (NQAM) revisions. The NQAM revisions have boon completed.
Completion Date: April 15, 1987 Responsiblo Organization: BFN/SNM Custodian (B) Reviso plant-implementing proceduros to comply with corporato standard for SNH Completion Dato: September 1, 1987 Rosponsible Organization: BFN/SNM Custodian
_9 Action Item 4: Improve training in SNM handling and accountability.
Action Plan: (A) Develop and administer special training for site SNMC and aides defining requirements for accountability and safeguards.
Completion Date: July 1, 1987 Responsible Organization: DNS/ Nuclear Fuel (B) Modify GET training to include description of SNM and special handling requirements. Training source material will be provided by DNS/ Nuclear Fuel.
Completion Date: April 15, 1987 Responsible Organization: Division of Nuclear Training (DNT)
(C) Revise radwaste packer and loader training to include information on SNM.
Completion Date: Completed January 26, 1987 Responsible Organization: BFN Radwaste Supervisor Action Item 5: Improve control and traceability of radwaste containers and their contents.
Action Plan: (A) Revise Office of Nuclear Power (ONP) Radioactive Material Shipment Manual (RMSM) to incorporato l appropriate recommended corrective actions.
Completion Date: January 26, 1987 Responsible Organization: DNS/ Radiological Control (B) Reviso plant-specific instructions to comply with the I
RMSM and recommended corrective actions.
Complotion Date: April 28, 1987 Responsiblo Organization: BFN Radwasto Supervisor Action Item 6: Review past SNM audit practicos to determine why loss of SNM r at BFN was not detected earlier.
Action Plan: Review SNM system audits performed by Nuclear Fuel and SNM QA audito performed by Division of Quality Assurance (DQA) to determine the roanons the Browns Ferry problem was not detected. Recommend corrective actions to the audit functions.
Completion Dato: Completed February 1,1987 Responsible Organization: DNS/ Nuclear Fuel An additional action item to complete a thorough physical inventory of all SNM onsito has been completed. The results of this physical inventory woro reported to NRC on January 14, 1987, with the final report provided as an 4 enclosure for this response.
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ENCLOSURE 2 REPORT ON THE PHYSICAL INVENTORY OF NONFUEL SPECIAL NUCLEAR MATERIAL Two independent investigations were conducted concerning the loss of five fuel loading chambers at Browns Ferry Nuclear Plant (BFN). Both of these investigations resulted in recommendations that a physical inventory of all Special Nuclear Material (SNM) onsite be completed as soon as possible. These investigative reports, including their recommendations were discussed at the November 4,1986, Enforcement Conference with NRC. At that time TVA management made a commitment to NRC to complete an inventory of all SNM within 60 days. It was noted at that time that inoperability of the BFN secondary containment may impact completion of the inventory of the spent fuel storage pools (SFSP) within the 60-day commitment. Secondary containment was declared operable on December 23, 1986. The inventories of the SFSP were started on December 24, 1986, and completed on January 10, 1987. The following provides more detailed information concerning the physical inventories involved and the determination of unaccounted for SNM.
A review of past operating practices was conducted by the SNM custodian supported by Reactor Engineering personnel to determino all possible SNM storage locations. This review involved informal discussions with plant personnot as well as physical walkdowns of the plant. The following were identified as possible SNM storage locations.
- 1. Power Stores warehouses
- 2. Chemistry Lab
- 3. Rad Con Instrument Group Lab
- 4. General area of the refueling floor
- 5. Unit Traversing Incore Probo (TIP) Rooms
- 6. Radwaste Evaporator Building
- 7. SFSP
- 8. Maintenanco shops
- 9. New fuel storage vaults
- 10. Reactor Cavities
- 11. Control Rod Drive (CRD) Rebuild Room Discussions with the Instrument Maintenanco. Electrical Maintenanco, and Radwasto Section Supervisors, as well as verbal verifications from thole supporting personnel, determined that the only SNM items onsito were located in the following areas.
- 1. Power Stores Warehouse No. 4 SNM Cage
- 2. Chemistry Lab Source Storage Cabinet Vault No. 4
- 3. Rad con Instrument Group Lab Source Storago Cabinet
- 4. General Area of the Refueling Floor
- 5. Unit TIP Rooms
- 6. Radwasto Evaporator Building
- 7. SFSP
A determination was made by the SNM custodian as to which onsite locations should be used for storage of SNM. Technical Instruction (TI)-14, SNM Control, was revised to identify the following ITEM CONTROL AREAS (ICAs).
ICA Description
- 1. Unit 1 New Fuel Storage Vault
- 2. . Unit 1 Spent Fuel Storage Pool
- 3. Unit 1 Reactor
- 4. Unit 2 New Fuel Storage Vault
- 5. Unit 2 Spent Fuel Storage Pool
- 6. Unit 2 Reactor
- 7. Unit 3 New Fuel Storage Vault
- 8. Unit 3 Spent Fuel Storage Pool
- 9. Unit 3 Reactor
- 10. Unit 1 Refuel Floor, general area including equipment pool
- 11. Unit 2 Refuel Floor, general area including equipment pool 12 . . Unit 3 Refuel Floor, general area including equipment pool
- 13. Power Stores Warehouse Number 4
- 14. Radwaste Evaporator Building
- 15. Chemistry Laboratory Source Storage Cabinet
- 16. RAD CON Instrument Group Laboratory A physical inventory of each of the seven SNM storage locations previously identified was performed. Each of these locations will be discussed separately.
A. Power Stores Warehouse No. 4 SNM Cage This location was defined in TI-14 to be ICA-13.
A physical inventory was completed on October 28, 1986, with the following items being accounted for:
Traversing Incore Probes (TIPS) 5 items Source Range Monitors (SRMs) 2 items Intermediate Range Monitors (IRMs) 8 items B. Chemistry Lab Source Storage Cabinet Vault No. 4 This location was defined in TI-14 to be ICA-lS.
A physical inventory was completed on October 29, 1986, with the following items being accounted for:
Plutonium Beryllium sources 2 items
C. Rad Con Instrument Group Lab Source Storage Cabinet This location was defined in TI-14 to be ICA-16.
A physical inventory was completed on November 2,1986, with the following items being accounted for:
Calibration sources 16 items D. General Area of the Refueling Floor This location was defined in TI-14 to be three separate ICAs, Unit 1 Refuel Floor ICA-10 Unit 2 Refuel Floor ICA-11, and the Unit 3 Refuel Floor is ICA 12.
A physical inventory of these ICAs was completed on October 28, 1986.
ICA-10 contained no SNM items, ICA-11 contained 21 new LPRM assemblies, ICA 12 contained 17 new LPRM assemblics. The 21 LPRM assemblies in ICA-11 were later transferred to ICA-12, making a total of 38 LPRM assemblies stored in ICA-12.
E. Unit TIP Rooms This location was not defined in TI-14 to be an ICA. The decision was based on the fact that we anticipate replacing the TIP detectors which contain SNM with a new design TIP detector which does not contain SNM.
This replacement should occur during the next operating cycle of each reactor. In this interim time period, procedural controls shall be in place which will require the immediate transfer of TIP detectors to the High Rad Storage Room in the Radwaste Evaporator Building.
A physical inventory of all TIP detectors located in the unit TIP rooms was conducted between November 30 and December 3, 1986.
TIP detectors were all located in canisters inside lead casks in the three unit TIP rooms. The casks were transferred to the Control Rod Drive rebuild room in the unit 2 Reactor Building for inventory purposes . When removed from the TIP machine, the TIP detectors with a short length of cable attached are wound around a spindle inside the canister. This arrangement made it very difficult to remove the individual items. Because of the high dose rates associated with the unit 1 and 2 TIPS, we were unable to verify that these canisters were completely empty. The following individual TIP detectors were removed from their canisters and accounted for.
Unit 1 3 Unit 2 3 Unit 3 7 Total 13 TIPS
_4 All of the above TIP detectors have been repackaged in 55 gallonsde as sealed and are stored in the High Rad Storage room of the Radweste Evaporator Building. The drums have been labeled as containing SNM to prevent inadvertant shipment and future loss. ..
F. Radwaste Evaporator Building -
1 This location was defined in TI-14 to be ICA-14. e
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After discussions with Radwaste Section personnel it 6as determined that all SNM items were located in either the High Rad Storage Room or
- Radwaste Basement Storage Room No. 2, in the Radwaste' Evaporator Building.
A physical inventory of all SNM items stored in the High Rad Storage
- Room was performed between November 24 and November 29, 1986 A search of all drums suspected of containing SNM itnms una conducted. A total of 24 drums were involved; six drums, identified as containing SNM and 11 drums identified as contnining trash were opened and inspected; seven other drums known to contain non-SNM _
trash or sludge were not opened.
A problem was immediately encountered when opening the first drum.
SRMs and IRMs, when removed from their respective dry tubes, are sometimes placed in a hollowed-out lead brick, the caule is then cut, and the hole in the lead brick is then plugged. 'The plugs in
{ several of the bricks could not be removed. For those bricks in ,
which the plug could be removed, the detector could not be removed. It is speculated that when the plug is delven into the brick, it drives the detector firmly into the lead. It was decided i that the consequences of cutting into a detector when removing it from the lead were unacceptable from a radiation control point of view. We, therefore, decided to count each lead brick as an SNM 4
item. In addition, two detectors were found which could not be specifically identified as SRMs or IRMs because of:the high radiation levels associated with them. The following summarizes the results: , ,
J SRM 3 IRM 5 Lead Brick (SRM or IRM) 12 j
Total 20 A physical inventory of all SNM items stored in Radwaste Basement Storage Room No. 2 was performed on January 6, 1987.
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'I One SRM and one IRM were identified by serial number. In addition, four lead bricks were found which could not be specifically identified as SRMs and IRMs. The following summarizes the results.
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[ ,' IRM Lead Brick (SRM or IRM) 1 4
- t. Total 6 All SNM items that were located in the Radwaste Evaporator Building o have been repackaged in 55-gallon drums, sealed, and are now stored in
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the High Rad Storage Room of the Radwaste Evaporator Building, ICA-14. The drums have been labeled as containing SNM to prevent
- inadvertant shipment and future loss. The following summarizes the total number of SRM and IRM items stored there:
J SRM 4
- . IRM 6
The SFSPs were defined in TI-14 to be three ICAs, Unit 1 SFSP ICA-2, Unit 2 SFSP ICA-5, and the Unit 3 SFSP is ICA-8. A physical inventory of these ICAs was started on December 24, 1986 and completed on January 10, 1987.
LPRM assemblies when removed from the reactor cores are transferred to the SFSP and cut. The hot end, which contains the LPRM detectors is stored in the SFSP. The cold end, which has the serial number on it is then cut into smaller pleces in preparation for shipment. LPRM hot ends, with one r4 exception have always been stored in the SFSPs by either tying them off to the SFSP" railing or by placing them horizontally in a storage rack. The one exception to this was during February through April of 1979, when the LPRM hot ends which were removed during the first unit 1 refueling outage were cut into approximately four foot lengths and placed in a cask liner.
The cask liner was then transferred to the unit 3 SFSP whero it is now being stored. The LPRM hot ends in the SFSPs cannot bo identified by serial nuiber. We, therefore, used the following methods to account for
, individual LPRM detectors.
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- 1. Each long length (approximately 14 feet) of hot end tied to the railing or in a ntorage rack contains four detectors.
, 2. The sections of hot end material stored in the liner in the unit 3 SFSP were categorized and measured in a effort to determine the number of detectors present. We have concluded that the Lince contains 104 i
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detectors or 26 LPRM hot ends. Thefollbwingsummarizestheresults of the SFSP inventories. '
ICA-2 68 ICA-5 77 ICA-8 113 Total 258 .
The previously discussed physical inventory efforts have been to establish a baseline of SNM items for which we will be held accountable for in the future.
Table 1 summarizes the inventory and storage location of all SNM items including fuel assemblies onsite as of January 10, 1987.
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3 Table 1'
/ SNM Onsite as of January'10, 1987
, i i .i i i d. Lead Brick i i i d ICA # (Pu Sourcesd TIP d SRM / IRM /(SRM or IRM)d LPRM / Fuel d i i i i d i i i i d 1 4 0 4 0 d 0 d 0 d 0 / 0 4 0 4 i i i i i i i i i d 2 / 0 / 0 4 0 d 0 d 0 / 68 4 2112 4 i i i i i i i i i d 3 d 0 / 5 d 4 4 8 4 0 4 43 d 0 4 4 4 i i i i i i i
/ 4 4 0 / 0 d 0 d 0 / 0 d 0 4 0 4 i i i i i d i i i d5 4 0 4 0 / 0 / 0 / 0 4 77 4 1956 /
i ;t i i i .i i i i d 6 4 0 / -5 / 4 4 8 4 0 / 43 4 0 /
4 i i i i i i i i
/ 7 d 0 / 0 d 0 4 0 i 'O 4 0 4 0 /
4 i i i i i i i i d 8 4 0 4 0 4 0 d 0 4 0 / 113 / 1004 4 4 i i i i i i i i
/ 9 / 0 / 5 4 4 / 8 4 0 / 43 / 0 /
i i i i i i i i i d 10 d 0 / 0 '/ 0 4 0 d 0 / 0 4 0 d i i i i i i i d i d 11 d 0 4 0 / 0 / 0 4 0 d o d 0 4 4 i i i i i i i i d 12 4 0 4 0 / 0 4 0 4 0 4 38 4 0 4 i i i i i i i i i d 13 4 0 4 5 d 2 d 8 4 0 d 0 d 0 (
/ 4 i i d i i i i d 14 4 0 / 13 4 4 4 6 4 16 / 0 d o d i i i i i i i i i d 15 4 2 4 0 4 0 d 0 / 0 / 0 / 0 4 4 i i i i i i i i d 16 d 16 4 0 / 0 4 0 4 0 / 0 / 0 4 d i i i i i i t i
/ Total d 18 4 33 4 18 d 38 4 16 4 425 4 5836 4
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In an effort to determine the number of SNM items unaccounted for, we have compiled a list of all SNM items that are known or suspected to have been in the possession of BFN.
For SRMs, IRMs TIPS, and LPRMs, this list was created by reviewing SNM history records of TI-14 and Power Stores receipt records. For LPRMs this list was then compared to records of LPRM replacement from LPRM depletion information. This list does not include any LPRM assemblies which might have been damaged during installation and subsequently placed in the SFSP. The following summarizes our findings for SRMs, IRMs, TIPS, and LPRMs.
i i iWarehoused Refuel Floor i Incore 4Radwasted SFSPs i i dItemdShipped d ICA-13 (ICA 10.11 & 12d ICA 3. 6 94 ICA 14 DICA 2. 5 & 84 Total /
4 i d i i i i i i
/SRM / 6 d 2 / 0 / 12 / 11 d 0 / 31 /
i i i i d i i i i dIRM d 3 / 8 d 0 i 24 d 24 / 0 / 59 /
i i i i d i i i i (TIP d 21 4 5 4 0 d 15 d 17 / 0 / 58 4 i i i i i i i i i
/LPRMd 21 d 0 / 38 / 129 d 0 4 256 4 444 d The following information portains to the items listed as shipped. The 21 LPRMs were returned to CE unieradiated in two shipments, 10 assemblies on August 4, 1975, and 11 assemblies on June 7, 1978. The shipments of SRMs, IRMs, and TIPS all occured between 1975 and 1978. The date of shipment is documented on TI-14 history records. No other information concerning the details of these shipments can be found. It is assumed that they were shipped as part of a planned shipment to the Barnwell, South Carolina facility.
As a result of our physical inventories, the following table summarizes the SNM items that are accounted for.
4 i / Warehoused Refuel Floor d Incore dRadwasted SFSPs i i dItem/ Shipped d ICA-13 /ICA 10.11 & 12d ICA 3, 6 9d ICA 14 (ICA 2. 5 & 8d Total d i i i i d i i i i dSRn d 6 / 2 d 0 d 12 d 4 / 0 4 24 /
i i i i d i i i i (IRM d 3 / 8 d 0 / 24 4 6 d 0 / 41 /
i i i i i i i i i d* d 0 / 0 / 0 d 0 d 16 d 0 / 16 /
i i i i d i i i i (TIP d 21 4 5 4 0 / 15 / 13 d 0 / 54 /
i i i i i d i i i
/LPRMd 21 d 0 / 38 / 129 d 0 d 258 / 446 4
- lead brick SRM/IRM
As discussed previously, we were unable to distinguish the contents of the lead bricks inventoried in the Radwaste Building. We have, therefore, combined SRMs and IRMs into a single category for determining the number unaccounted for. From the previous tables it car. be determined that the number of SRM/IRM and TIP items unaccounted for is as follows.
Item Number Having Been Onsite Accounted For Unaccounted For SRM/IRM 90 81 9 TIP 58 54 4 The overcount of two LPRM assemblies is attributed to detectors damaged during installation which were subsequently left in the SFSP. The previous lack of and adherence to accounting procedures enabled this to go unrecorded. We believe that all LPRM assemblies have been accounted for and are currently located onsite.
The location of unaccounted-for SNM items can only be speculated upon. Our best estimate is that they were shipped from radwaste in low-level shipments over the operating nistory of the plant. In this case, they would have been shipped to the Barnwell, South Carolina, facility or the U. S. Ecology, Richland, Washington, facility.
The following facts are known:
- 2. From radwaste shipping records, all shipments made before July 20, 1982 were to Barnwell, South Carolina.
- 3. From TI-14 history records, Monthly Operating Reports, and information from Power Stores records, the number of SNM transfers from the reactor before July 20, 1982 are:
SRM/IRM 40 TIP 37
- 4. From TI-14 history records, and Monthly Operating Reports the number of SNM transfers from the reactor after July 20, 1982 are:
SRM/IRM 4 TIP 1
- 5. From radwaste shipping records, the number of shipments to Barnwell, South Carolina, after July 20, 1982 is 128.
- 6. From radwaste shipping records the number of shipments to Richland,
- Washington, after July 20, 1982 is 243.
l
V Using the following assumptions, the number of items sent to Barnwell, South Carolina, and Richland, Washington, can be determined.
Assumption 1: All unaccounted for items were inadvertently shipped in low-level radwaste shipments Assumption 2: The rate of these inadvertent shipments is the same as the rate of availability (e.g., they were shipped at the same rate that they were removed from the reactor core.)
Assumption 3: The probability of shipment to Barnwell or Richland after July 20, 1982 is dependent on the number of shipments made to each site relative to the total number of shipments made.
The percentar;e of SNM transfers before July 20, 1982 is:
SRM/IRM 40/44 = 90.9%
TIP 37/38 = 97.4%
The percentage of SNM transfers after July 20, 1982 is:
SRM/IRM 4/44 = 9.1%
TIP 1/38 = 2.6%
The number of SNM items shipped to Barnwell before July 20, 1982, is:
SRM/IRM 9 X 0.909 = 8.18 or 8 TIP 4 X 0.974 = 3.90 or 4 The number of SNM items shipped after July 20, 1982 is:
SRM/IRM 9 X 0.091 = 0.82 or 1 TIP 4 X 0.026 = 0.05 or 0 For the time period after July 20, 1982, the percentage of shipments made to Barnwell is:
128 = 34.5%
371 The percentage of shipments made to Richland is:
243 = 65.5%
371 The number of SRMs or IRMs shipped to Barnwell af ter July 20, 1982 is:
1 X 0.345 = 0.345 or 0 l
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The number of SRMs or IRMs shipped to Richland, Washington, af ter July 20, 1982 is:
1 X 0.655 = 0.655 or 1 Based on the above calculations it is speculated that eight of the unaccounted for SRMs or IRMs and all four_of the unaccounted for TIPS were inadvertently shipped to the Barnwell, South Carolina, facility. One SRM or IRN was shipped to the U.S. Ecology, Richland, Washington, facility.
An estimate of the maximum weight of uranium-235 (U-235) inadvertently shipped can be made. There is 0.003 gram of U-235 contained in each SRM and 0.001 gram in each IRM and TIP. From the previous tables it can be seen that up to seven SRMs and up to 18 IRMs are unidentified. Considering the 16 unidentified lead brick SRM/IRM items found, there are no more than seven SRMs unaccounted for thus leaving the remainder of the SRM/IRM balance to be two IRMs. There are four TIPS unaccounted for. Therefore, the maximum amount of U-235 is:
SRM 7 X 0.003 = 0.021 gram IRM 2 X 0.001 = 0.002 gram TIP 4 X 0.001 = 0.004 gram Maximum Total = 0.027 gram If the 16 unidentified lead bricks included the seven IRMs the minimum weight of U-235 inadvertently shipped would therefore be.
SRM 0 X 0.003 = 0.000 gram IRM 9 X 0.001 = 0.009 gram TIP 4 X 0.001 = 0.004 gram Minimum Total = 0.013 gram Efforts to gather and review information which will eliminate the uncertainty in the total number of items having been onsite are continuing. This information may help to identify the specific serial number of SNM items located and accounted for. As this new information is reviewed, the number of unaccounted-for items may change. The above determination of unaccounted items was made with the best available information as of January 10, 1987.
Concerning the five fuel loading chambers (FLCs) discovered lost during October, 1986, the following information is provided.
The report titled "Offsite Investigation of Loss of Special Nuclear Material (SNM) at Browns Ferry Nuclear Plant (BFN) Executive Summary," concludes that:
There is a 94-percent probability that the SNM was shipped offsite as low-1cvel radwaste and a 6-percent probability that it is still onsite.
_11_
The probability that the SNM was shipped to the U.S.
Ecology facility in Richland, Washington, is 89-percent. The is a 5-percent probability that the SNM was shipped to Barnwell, South Carolina. I Our onsite search and physical inventories have eliminated the six-percent probability that the FLCs are onsite. The probability that the FLCs were shipped to the U.S. Ecology, Richland, Washington, facility is now 89 f g4 ,
94.7 percent. The probability that the FLCs were shipped to Barnwell, South Carolina, facility is S /94 = 5.3 percent.
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