ML20215C477
| ML20215C477 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/12/1986 |
| From: | Edelman M CLEVELAND ELECTRIC ILLUMINATING CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| References | |
| PY-CEI-OIE-0236, PY-CEI-OIE-236, NUDOCS 8610100299 | |
| Download: ML20215C477 (3) | |
Text
e-t THE CLEVELAND ELECTR P O. BOX 5000 - CLEVELAND, Ohio 44101 - TELEPHONE (216) 622-9800 - ILLup*iNATING BLDG.
- 55 PUBLICSoUARE Serving The Best Location in the Nation MURRAY R. EDELMAN September 12, 1986 SR VICE PRESIDENT PY-CEI/0IE-0236 L NUC LE A R Mr. James G. Keppler Director, Region III Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Glen Ellyn, IL 60137 Perry Nuclear Power Plant Docket Nos. 50-440; Response to Notice of Violation 50-440/86018-02
Dear Mr. Keppler:
This letter acknowledges receipt of the Notice of Violation contained within Inspection Report 50-440/86018. Your report identified areas examined by Messrs. J. A. Grobe, K. A. Connaughton, G. F. O'Dwyer, P. D. Kaufmann and D. E.
Miller during their inspection from June 23, 1986 through August 4, 1986 at the Perry Nuclear Power Plant, Unit 1.
Our response to Notice of Violation 50-440/86018-02 is attached.
Please feel free to contact me should you have any additional questions.
Very truly
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Murray R. Edeluan Senior Vice President Nuclear Group MRE:nj c cc: Jay Silberg, Esq.
John Stefano (2)
K. A. Connaughton Document Control Desk (USNRC) k PDR SEP 1g r
I IE o/
pr Attachment PY-CEI/01E-0236 L 50-440/86018-02 Restatement of the Violation 10 CFR 70.52(a) states, in part:
"Each licensee shall report immediately to the appropriate NRC Regional Office...any loss, other than normal operating loss, of special nuclear material."
Contrary to the above, The licensee attempted and failed to locate a previously installed source range monitor detector containing special nuclear material on June 13, 1986, but did not inform the NRC Region III Office of its loss until July 2, 1986.
This is a Severity Level V violation.
Corrective Steps Which ilave Been Taken and Results Achieved The delay between the physical inventory conducted June 13, 1986 and the report of a missing SRM on July 2, 1986 was primarily due to insufficient information being available at the conclusion of the physical inventory to make a determination as to what types and how many nuclear instrumentation detectors (NI's) containing Special Nuclear Material (SNM), were actually on-site. The necessary information was collected and evaluated following this inventory and a determination was made on June 25, 1986 that one (1) SRM detector (Serial Number 6,611,604) was missing. This was not reported immediately to NRC since there was still con
- aion as to whether additional detectors (Unit 2 LPRM's) were missing. The vecdor, General Electric, maintained even to June 30, 1986 that they had shipped all (176) of the Unic 2 Low Power Range Monitors (LPRM's). We determined this to not be the case on June 30, but the resulting confusion helped lead to the delay in our reporting of the lost SRM detector.
Following a thorough comparison of shipping papers, QC receipt inspection reports, radiological smear surveys, I&C electrical checks, nonconformance reports, work orders, and numerous personnel interviews, a set of serial numbers was established which represented the NI's believed to actually be on-site.- Of all the NI's in this set, the only one for which the location could not be established following extensive physical searches, was SRM 6,611,604. On July 2, 1986 this SRM was reported as lost.
This event was a direct result of an SNM control program that was inadequate in its control of Nuclear Instrumentation (NI). Although the NI's were recognized as containing SNM and kept in an Item Control Area (ICA), PAP-0802, Control of Special Nuclear Material, erroneously excluded NI's because the quantity of SNM involved was less than 1 Kg.
This, in effect, removed NI's from the normal warehouse accountability control process without establishing any compensatory control provisione.
h Attachment PY-CEI/01E-0236 L PAP-0802, Control of Special Nuclear Material, has been revised to extend control of SNM to nuclear instrumentation including a definition to assist personnel in determining when SNM is actually lost. A requirement for a double entry type of accounting has been established for tracking nuclear instrumentation by location and serial number.
FTI-D02, SNM Physical Inventory, has also been revised to include nuclear instrumentation in physical invento ries.
Personnel involved in this event identified the procedural-discrepancies noted above and took the stated actions to revise the procedures and the SNM accountability program. They are now intimately familiar with the reporting requirements for lost SNM.
Corrective Steps to Prevent Recurrence The steps described above have all been taken in order to prevent the recurrence of a loss of SNM and the untimely reporting of the same.
Date of Full Compliance The procedure changes described above have all been made.
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