ML20236J532
| ML20236J532 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/23/1987 |
| From: | Tiernan J BALTIMORE GAS & ELECTRIC CO. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8708060199 | |
| Download: ML20236J532 (2) | |
Text
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BALTIMORE GAS AND -
ELECTRIC CHARLES CENTER P. O. BOX 1475 BALTIMORE, MARYLAND 21203 JostPH A.TscRNAN Vict PntslotNT.
NUCLEAR Ewenov -
July 23,1987 U. S. Nuclear Regulatory Commission -
Docket Nos. 50-317 Region 1 50-318 g
License Nos. DPR-53 631 Park Avenue '
-l King of Prussia,' PA 19406 -
. ATTENTION:
Mr. T. T. Martin, Director Division of Radiation-' Safety and Safeguards
' Gentlemen.
This refers to' Inspection Report 50-317/87-11, 50-318/87-12; which ' transmitted one item
'of apparent non-compliance with NRC requirements. Enclosure (1) to this letter is in reply to the item noted in Appendix A of your letter dated June 26, 1987.
Should you have any further questions regarding this matter, we '. will be pleased to discuss them with you.
Very truly yours,
. JAT/LSL/dtm Enclosure cc:
D. A. Brune, Esquire
'J.
E.
Silberg, Esquire
' R. A.Capra, NRC
' S. 'A.McNeil, NRC W. T. Russell, NRC
' T. Foley/D. C. Trimble, NRC gs%0 f
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ENCLOSURE (1)
REPLY TO APPENDIX A OF NRC INSPECTION REPORT 50-317/87-11; 50-318/87-12 APPARENT FAILURE TO KEEP ANNUAL PHYSICAL INVENTORY RECORDS We have reviewed the circumstances which led to the apparent violation of 10 CFR 70.51 (b)(1) and (3): specifically, failure to keep records showing that physical inventories (including location) of all special nuclear material (SNM) in our possession were conducted between April 13,1981, and March 30, 1985.
We agree with the inspector's finding that our inventory records during the above period did not document' the specific locations of SNM. Inventories were performed at least annually during this period using storage maps- (which show specific location) to perform a piece count inventory. Inventory results were then documented on SNM Inventory Summary Sheets by general location (i.e., number of. units ' present in Units 1 and 2 Reactor Cores, New Fuel Racks, North and South Spent Fuel Pools, etc.). However, the storage maps were not retained with the summary sheets. Our interpretation of 10 CFR 70.51(b)(1) has been that the SNM I.nventory Summary Sheets, completed and filed every six months with DOE /NRC Forms 741 and 742, served to document our inventory of SNM onsite.
As discussed during the exit meeting with your inspector, we' will more clearly document
-SNM inventory. records. Accordingly, CCI-507, Special Nuclear Material Accounting Procedures, has been changed to ensure records clearly support the detail of the inventory actually performed. These changes provide more specific guidance on the method, frequency, and documentation of SNM Inventories and, substantial assurance that we meet NRC requirements. We have re-inventoried our-SNM using the guidance which is contained in the above changes.
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