ML20235G716
| ML20235G716 | |
| Person / Time | |
|---|---|
| Site: | 07003013 |
| Issue date: | 03/18/1986 |
| From: | Leverenz K COMMONWEALTH EDISON CO. |
| To: | |
| Shared Package | |
| ML20235F489 | List: |
| References | |
| 4-1, NUDOCS 8707140353 | |
| Download: ML20235G716 (12) | |
Text
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Commonwealth Edison Company NUCLEAR PROCEDURE NO. 4 Effective: March 18,1986 Physical Inventories of Nuclear Fuel and Other Supersedes Nuclear Procedure No. 4, Special Nuclear Material dated 1/20/84 (SNM) Items As prescribed by regulations of the U.S. Nuclear Regulatory Commission (NRC) and American National Standard N15.8-1974, physical inventories of nuclear fuel assemblies in reactors, nuclear fuel assemblies and fuel rods in Fuel Vaults and Fuel Pools, and other SNM items, such as detectors and sealed sources, will be taken periodically as outlined herein. Additional or special inventories may also be requested as directed by the NMS Manager.
- The Services Superintendent shall be responsible for scheduling all physical inventories and piece counts.
The taking of all inventories shall be the direct responsibility of the Nuclear Materials Custodian (NM Custodian.)
- With reference to the meaning of the word "uncontained" when used to describe the physical storage of a fuel rod that is not part of a nonnal fuel assembly, the antonym ' contained" can be defined to mean a fuel rod which is contained in a rod storage canister, possibly with other fuel rods in the same canister.
If the combination of the. rod storage canister and fuel rods is integral,. then the serial number of the rod storage canister can be used in place of the set of serial numbers of the fuel rods housed in the rod. Storage canister. However, if a fuel rod can be easily removed from the rod storage canister, then the number of rods in the rod storage canister must be counted and recorded at each inventory in addition to the serial number of the rod storage canister. This fuel rod count and the serial number of the rod storage canister can be used together to identify the combination of the rod storage canister and the fuel rod (s).
- If a fuel rod is removed f rom a rod storage canister and is stored in a i
free condition in the fuel pool, then the existence of the fuel rod l
must be verified at each piece count, and the serial number of the fuel rod mast be verified at each physical inventory.
This can be done with a televisic'. camera / monitor system or some type of periscope.
This procedure consists of the following sections:
1.
Nuclear Fuel A.
Reactor Inventories B.
Fuel Vault Inventories C.
Fuel Pool Inventories II. Non-Fuel Items Containing SNM A.
DOE /NRC Form 741 Pequired B.
00E/NRC Forn 741 Not Required 100770a j
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Nuclear Fuel A.
Reactor Inventories.
physical Inventories A' physical inventory of all nuclear fuel assemblies in a reactor by serial number and location shall be made (a) immediately prior to installing the reactor head upon completion of the initial fuel loading and (b) immediately prior to eachLsubsequent replacement of the reactor head.
Area Responsible Action a
5
- Services Superintendent 1.
Notify the NMS Manager and the Director of Auditing in advance of the time scheduled.for taking a Reactor inventory.
5 Director of Auditing 2.
Assign representatives to serve as-observers and to make such audit tests as are deemed necessary.
3.
Notify the Company's independent public accountants of the time scheduled for taking a reactor inventory and obta's L
4 the names of observers designated.
- 1 N
4.
Inform the Services Superintendent or NM Custodian of the persons designated to be observers.
NM Custodian or 5.
Supervise the Station'personne? in taking His Alternate the inventory in the presence of the designated observers.
Record on a-Reactor Core Map (Form H) the serial number and orientation of each fuel
'J assembly in its reactor core position.
6.
Reconcile all differences between the fuel maps and tagboards, prior to the Audit representatives leaving the station at the completion of the inventory.
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Nuclear Fuel A.
Reactor Inventories Area Responsible Action Physical Inventories l
NM Custodian or 7.
Reconcile discrepancies between fuel His Alternate maps and Nuclear Component Accountability System (NCAS) physical inventory lists within one month of the completion of the inventory.
Director of Auditing 8.
Make such audit tests as may be deemed i
and Audit Staff necessary to determine if there are any discrepancies between the NM Custodian's inventory records, NCAS physical inventory lists and the physical inventories.
9.
Report findings including any unresolved j
discrepancies immediately to the Services Superintendent, NM Custodian, and the HMS Manager for investigation (N.P. 5).
10.
Prepare a Report of Nuclear Fuel Audit for the Nuclear Fuel Services Department (Form 86-2606; see N.P. 1) for each unit audited and send a copy to:
NM Custodian Nuclear Fuel Services Manager NM Custodian or 11.
Sign and date the completed inventory; His Alternate obtain signatures thereon of the obse'rvers and approval of the Services Superintendent, and distribute as follows:
l Original - NMS Manager Copies to:
Services Superintendent Director of Auditing Independent Public Accountants Nuclear Fusi Services Manager NM Custodiar File Others, as. required ID0770a 3/86
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Page 4 i
I.
Nuclear Fuel A.
Reactor Inventories i
Area Responsible Action i
Physical Inventories NMS Manager and
- 12. Review the physical inventory and compare Comptroller's Staff in detail to the records of the NCAS.
Piece-Counts
- 13. Whenever the head of a reactor vessel NM Custodian or His Alternate is removed for more than three months and fuel is in the reactor vessel, make a piece-count inventory of the fuel assemblies in the Reactor concurrently with the piece-count inventory of the contiguous Fuel Pool (s) (see Section C).
The piece-count inventory must be done at least once every three months
)
the head is removed.
a.
Record such inventory on'a Reactor Core Map (Form H), by placing a check mark in each core position occupied by a fuel assembly; show total of assemblies counted.
b.
Sign and date the inventory; obtain signed approval of the Services Superintendent on the inventnry form i
or a summary form, and distribute as follows:
l Original - NMS Manager Copies to:
Nuclear Fuel Services Manager i
Services Superintendent Director of Auditing NM' Custodian NMS Manager and 14.
Reconcile piece counts to records of Comptroller's Staff the Nuclear Fuel Services Department.
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Nuclear Fuel B.
Fuel Vault Inventories A physical inventory by serial number and location of all nuclear fuel i
assemblies, uncontained fuel rods or other special nuclear material in l
each Fuel Vault and any other location where unirradiated fuel l
assemblies or rods are stored, shall be taken at least once every month. However, a physical inventory need not be taken of fuel vaults that have remained sealed since a previous inventory was taken, provided not more than 12 months have elapsed since the previous inventory was taken; the integrity of the seal is confirmed by inspection and the inventory form is noted accordingly.
l
- Fuel vaults that, according to station inventory records, are empty must also be included in the monthly inventory unless the vault is sealed and inventoried once in a twelve month period as above.
Area Responsible Action
- Services Superintendent 1.
Establish schedules for taking physical NMS Manager and inventories with station personnel.
Director of Auditing i
l Director of Auditing 2.
At least once each year, assign
)
representatives to serve as observers at I
a monthly physical inventory at each station.
a.
Notify the Company's independent public accountants of the time scheduled for the inventory-taking and obtain the names of designated j
observers.
b.
Inform the Services Superintendent or the NM Custodian of the persons designated to be observers.
NM Custodian or 3.
Supervise station personnel in taking His Alternate the inventories (in the presence of the designated observers, if applicable).
Record the inventories on Form F - Fuel Vault Inventory.
Note:
Also ensure that fuel vault is secured properly after each inventory.
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Nuclear Fuel B.
Fuel Vault Inventories Area Responsible Action 4.
Sign and date the completed inve.7 tory; NM Custodian or His Alternate obtain signatures of the observers, if applicable, and approval of the Services Superintendent on the inventory form or j
summary form and distribute as follows:
j Original - NMS Manager Copies to:
Services Superintendent Director of Auditing Independent Public Accountants (if applicable)
Nuclear Fuel Services Manager NM Custodian Others, as required Director of Auditing 5.
Make such audit tests as may be deemed and Audit Staff necessary to determine whether there are any discrepancies between.the NM-Custodian's records, the NCAS and the physical inventories.
NM Custodian or 6.
Reconcile all differences between the His Alternate fuel maps, tagboards, and where possible, Nuclear Fuel Services Department records prior to the Audit representatives leaving the station at the completion of the inventory.
7.
Reconcile all discrepancies between fuel maps and Nuclear Fuel Services Department records.which are not immediately resolved, within one month of the completion of the inventory.
8.
Report findings including any unresolved Director of Auditing and Audit Staff discrepancies immediately to the
~
Services Superintendent, NM Custodian l
and the NMS Manager for investigation (N.P. 5).
=
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I.
Nuclear Fuel B.
Fuel Vault Inventories Area Responsible Action Director of Auditing 9.
Prepare a Report of Nuclear Fuel Audit and Audit Staff for the Nuclear Fuel Services Department J
for each unit audited and send copy to:
NM Custodian Nuclear Fuel Services Manager C.
Fuel Pool Inventories As outlined below, a physical inventory of nuclear fuel assemblies and uncontained nuclear fuel rods in each fuel pool shall be taken by serial number and location after each refueling of the related reactor and at intervals of approximately six months thereafter.
However, when a related reactor is scheduled for refueling which is expected to be completed within nine months of the previous pool inventory, the six month interval may be extended to coincide with the inventory required after the refueling.
- Based on.the unique situation involving the Dresden Unit 1 fuel pool, inventories may be taken using the following guidelines:
l.
Physical inventories of nuclear fuel assemblies by serial number and location in the Dresden Unit 1 fuel pool will be required at least once in a twelve month period.
However, additional physical inventories may.be required by the Director of Auditing or the NMS Manager, if deemed necessary.
2.
Piece-count inventories every three months as required by this procedure.
- It is acceptable'to use the canister serial number for each fuel assembly (West Valley) which is housed in a canister with a lid in the Dresden fuel pools provided the lid on the canister is sealed in some nenner. The security of the sealed canister and its history must be verified by proper documentation.
In this manner, the canister serial-number can serve as the serial number for the fuel assembly which is sealed in the-canister.
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Nuclear Fuel C.
Fuel Pool inventories Area Responsible Action Piece-Counts - All Fuel Pools 1.
Make a piece-count inventory of the NM Custodian or His Alternate nuclear fuel rods and assemblies in each Fuel Pool at intervals of three months after the most recent physical inventory.
Record each inventory on Form G, Fuel Pool Inventory.
a.
Sign the completed inventory; obtain the approval of the Services Superintendent on the inventory form or summary form and distribute as 1
follows:
Original - NMS Manager Copies to:
Services Superintendent Directo'r of Auditing i
Nuclear Fuel Services Manager NM Custodian File NMS Manager and 2.
Reconc'ile piece counts to records of Comptroller's Staff the Nuclear Fuel Services Departn:ent.
Physical Inventories
- Services Superintendent 3.
Establish schedules for taking NMS Manager and inventories with station personnel.
Director of Auditing A' sign representatives to serve as Director of Auditing 4.
s observers.
a.
Notify the Company's independent public accountants of the time scheduled for the inventory-taking l
and obtain the names of designated j
observers.
i b.
Inform the Services Superintendent or the NM Custodian of the persons i
designated to be observers.
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Nuclear Fuel C.
Fuel Pool Inventories Area Responsible Action i
Physical Inventories j
NM Custodian or 5.
Supervise station _ personnel in taking His Alternate the inventories in the presence of the designated observers.
Record the i
inventories on Form G - Fuel Pool Inventory.
i 6.
Sign the completed inventories; obtain signatures of the observers and approval of the Services Superintendent thereon and distribute as follows:
I Original - NMS Manager Copies to:
Services Superintendent Director of Auditing Independent Public Accountants j
Nuclear. Fuel Services Manager NM Custodia Others, as required I
7.
Make such audit tests as may be deemed Director of Auditing and Audit Staff necessary to determine whether there are any discrepancies between the NM Custodian's inventory records, Nuclear i
Fuel Services Department records, and physical inventories.
NM Custodian or 8.
Reconcile all differences between the His Alternate fuel maps, tagboards and where possible, Nuclear Fuel Services Department records prior to the Audit-representatives leaving the station at the completion of i
the inventory.
i 9.
Resolve all discrepancies betw'een fuel maps and Nuclear Fuel Services Department records which'are not immediately reconciled within one month of the completion of the inventory.
10.
Report findings including any unresolved Director of Auditing and Audit Staff discrepancies.immediately to the i
Services Superintendent, NM Custodia'n and the NHS Manager for investigation (N.P. 5).
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I.
Nuclear Fuel l
C.
Fuel Pool Inventorie$,
Area Responsible Action Physical Inventories q
l Director of Auditing 11.
Prepare e Report of Nuclear Fuel Audit and Audit Staff for the Nuclear Fuel Services Department (Form 86-2606) for each inventory and send a copy within two weeks to:
1 Nuclear Fuel Services Manager NMS Manager and 12.
Review the physical inventory and Comptroller's Staff compare in detail to the records of the Nuclear Fuel Services Department.
1 II.
Non-Fuel items Containing SNM A.
DOE /NRC Form 741 Reauired A physical inventory by location of all non-fuel items which contain at least one gram of SNM, other than fuel assemblies and fuel rods covered by Section I of this procedure, for which a DOE /NRC Form 741 was 4
required when shipped, shall be taken at least once each month.
However, the inventory need not be taken if the storage or use location i
has remained inaccessible (e.g. locked warehouse, etc.), since the previous inventory was taken.
- Services Superintendent 1.
Establish schedules for taking physical inventories with station personnel.
Director of Auditing 2.
At least once each year, assign representatives to serve as observers at a monthly physical inventory and inform the Services Superintendent or the NM Custodian of the persons designated to be observers.
NM Custodian or 3.
Supervise station personnel in taking the c
His Alternate inventories (in the presence of the designated observers if applicable).
Record the inventories on Inventory of Non-Fuel Items Containing SNM (Fonn 86-2610, see N.P.1).
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- 11. Non-Fuel items'Containina SNM A.
DOE /NRC Form 741 Reauired Area Responsible Action 4.
Sign and date the completed inventory; NM Custodian or His Alternate obtain signatures of the observers, if applicable, and approval of the Services Superintendent on the inventory form or Sunnary Form and distribute as follows:
Original - HMS Manager Copies to:
Services Superintendent Director of Auditing NM' Custodian File Director of Auditing 5.
Make such audit tests as may be deemed and Audit Staff necessary to determine whether there are any discrepancies between the NM Custodian's inventory records and the physical inventories.
I a.
Report findings including any unresolved discrepancies immediately to the Services Superintendent; NM t
Custodian and the NMS Manager for investigation (N.P. 5).
I i
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II. Non-Fuel Items Containino SNM B.
DOE /NRC Form 741 Not Required Items containing exempt quantities of SNN do not require the preparation f
of DOE /NRC Form 741 by the shipper (10CFR70.54).
Receipt and shipment of j
such materials are subject to Nuclear Procedure No. 8.
As prescribed in Nuclear Procedure No. 6, Section C, Nuclear Licensing shall arrange for i
the periodic physical inventories and the Manager of Quality Assurance is responsible for auditing of compliance with procedures, NRC licenses, and certificates of registration.
j Director of General Procedures APPROVED:
Vice President j
Vice President and Comptroller ID0770a 3/86
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