ML18036A453

Responds to 911029 Ltr Re Violations Noted in Insp Repts 50-259/91-33,50-260/91-33 & 50-296/91-33 & Enforcement Action 91-120.Corrective Actions:Credible Baseline Inventory of All SNM on Site Will Be Reported to NRC

ML18036A453
Person / Time
Site:	Browns Ferry
Issue date:	11/27/1991
From:	Medford M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
EA-91-120, NUDOCS 9112020273
Download: ML18036A453 (14)

Text

ACCELERATED DISTRIBUTION DEMONSTRATION SYSTEM REGULATORY INFORMATION DXSTRIBUTION SYSTEM (RIDS)CESSION NBR:9112020273 DOC.DATE: 91/11/27 NOTARIZED:

NO DOCKET FACIL:50-259 Browns Ferry Nuclear Power Station, Unit 1, Tennessee 05000259 50-260 Browns Ferry Nuclear Power Station, Unit 2, Tennessee 05000260 50-296 Browns Ferry Nuclear Power Station, Unit 3, Tennessee 05000296 AUTH.NAME AUTHOR AFFILIATION MEDFORD,M.O.

Tennessee Valley Authority RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

SUBJECT:

Responds to 911029 ltr re violations noted in Insp Repts 50-259/91-33, 50-260/91-33

&50-296/91-33

&Enforcement Action 91-120.Corrective actions:credible baseline inventory of all SNM on site will be reported to NRC.DISTRIBUTION CODE: IEOID COPIES RECEIVED:LTR 4 ENCL 3 SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice of Vio ation Response NOTES: D A RECIPIENT ID CODE/NAME HEBDON,F WILLIAMS,J.

INTERNAL: ACRS AEOD/DEIIB t DEDRO NRR MORISSEAUiD NRR/DLPQ/LPEB10 NRR/DREP/PEPB9H NRR/PMAS/ILRB12 05-D.-G~-02 EXTERNAL EG&G/BRYCE 1 J~H NSIC COPIES LTTR ENCL 1 1 1 1.2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1'ECIPIENT ID CODE/NAME ROSS,T.AEOD AEOD/DS P/TPAB NRR HARBUCK,C.

NRR/DLPQ/LHFBPT NRR/DOEA/OEAB NRR/DST/DIR SE2 NUDOCS-ABSTRACT OGC/HDS3 RGN2 FILE 01 NRC PDR COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1+1 D D'S NOTE TO ALL"RIDS" RECIPIENTS:.A D D PLEASE HELP US TO REDUCE WASTE!COiVA ACT THE DOCUMENT CONTROL DESK, ROOii'I Pl-37 (EXT.20079)TO ELIIIINATE YOUR NAb, IE FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!TAL NUMBER OF COPIES REQUXRED: LTTR 25 ENCL 25 0

Tennessee Valley Authority, 1101 Market Street, Chattanooga.

Tennessee 37402 Mark O.Medford Vice President, Nuclear Assurance, Licensing and Fuels November 27, 1991 U.S.Nuclear Regulatory Commission ATTN: Document Control Desk Mashington, D.C.20555 Gentlemen:

In the Hatter of Tennessee Valley Authority Docket Nos.50-259 50-260 50-296 BROGANS FERRY NUCLEAR PLANT (BFN)-NRC INSPECTION REPORT 50-259, 260, 296/91-33-REPLY TO NOTICE OF VIOLATION (NOV)(ENFORCEMENT ACTION 91-120)This letter provides TVA's reply to S.D.Ebneter's letter to D.A, Nauman dated October 29, 1991, which transmitted the subject NOV involving the inaccurate TVA special nuclear material (SNM)baseline inventory which was transmitted to NRC on April 17, 1991.Pursuant to 10 CFR 2.201 and as described in the enclosed"Reply to the Notice of Violation," TVA admits this violation. provides TVA's reply to the NOV.Enclosure 2 provides TVA commitments to ensure an accurate and credible SNM inventory at BFN.If you have any questions regarding this response, please telephone 0.J.Zeringue at (205)729-3675, or me at (615)751-4776.Sincerely, Hark 0.Medford Enclosures cc: See page 2 U.S.Nuclear Regulatory Commission November 27, 1991 cc (Enclosures):

NRC Resident Inspector~Browns Ferry Nuclear Plant Route 12, Box 637 Athens, Alabama 35611 Mr.Thierry M.Ross, Project Manager U.S.Nuclear Regulatory Commission One Mhite Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr.B.A.Wilson, Project Chief U.S.Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 ENCLOSURE 1 Tennessee Valley Authority Browns.Ferry Nuclear Plant (BFN)Reply to Notice of Violation (NOV)(Enforcement Action 91-120)Inspection Report Number 50-259, 260, 296/91-33 NRC STATEMENT OF VIOLATION"During the Nuclear Regulatory Commission (NRC)inspection conducted on September 3 through 6, 1991, a violation of HRC requirements was identified.

In accordance with the"General Statement of Policy and Procedure for HRC Enforcement Actions," 10 CFR Part 2, Appendix C (1991), the violation is listed below: 10 CFR 70.51(d)requires, in part, that each licensee who is authorized to possess at any one time and location special nuclear material (SNH)in a quantity totaling more than 350 grams of contained uranium-'235 shall conduct a physical inventory of all SNH in his possession under license at intervals not to exceed twelve months.Contrary to the above, the licensee failed to perform an adequate physical inventory in 1990.Specifically, the February and March 1990 physical inventory failed to include an item containing SNM, which was identified in the spent fuel pool on September 7, 1991." This is a Severity Level III violation (Supplement III).TVA'S REPLY TVA admits that the results of its physical inventory of SNM conducted in 1991 at BFN were in error.1.Reason for the Violation As stated during the October 4, 1991 enforcement conference, the two inventory discrepancies which are the subject of this violation resulted from the use of engineering judgments during TVA's efforts to confirm the SNH baseline inventory at BFN.

0 BFN considers that the judgments utilized were reasonable.

However, in hindsight certain of these judgments proved faulty and=resulted in the misidentification of two non-fuel SNM items.Consequently, TVA inaccurately cataloged these items in its current inventory records.A discussion of the two events resulting in the inventory discrepancies is set forth below: A.Event 1 On August 21, 1991, a local-power range monitor (LPRM)without a"hot end" (detector assemblies) was discovered.

The LPRM was previously identified in the SNM baseline inventory as containing a"hot end." Mhen the SNM baseline inventory of the Unit 2 spent fuel storage pool (SFSP)was conducted, 18 full length LPRMs stored in the SFSP wore found severely entangled.

The engineer performing the inventory in the SFSP concluded that these 18 LPRMs could not be individually separated without violating the instructions provided in the maintenance request (MR)which was specifically initiated to perform the inventory.

These instructions required the LPRMs to be maintained at least five feet under the surface of the SFSP at all times, to ensure prop'er shielding and for maintaining radiation exposures as low as reasonably achievable (ALARA).Accordingly, a decision was made to rely on a visual inspection of the LPRMs, obtaining the serial number at the cold end where practical.

This was considered a reasonable approach under the circumstances.

The LPRM discovered on August 21, 1991, without a"hot end" was one of these 18 LPRMs from the Unit 2 SFSP.B.'Event 2 On September 7, 1991, while conducting a cleanup of the Unit 1 SFSP a LPRM"hot end" was discovered lying on the SFSP floor.The LPRM"hot en'd" found during the pool cleanup was positioned under a length of Fuel Pool Cooling system piping in the pool and was partially obscured from view by this pipe.This area of the SFSP had been used to store other"cold end" pieces.During the SNM baseline inventory of the Unit 1 SFSP, a visual inspection was performed of the LPRMs stored in the Unit 1 SFSP.However, this LPRM"hot end" was not observed at this location in the SFSP.

0 TVA's analysis of the two events reflects that the inventory discrepancies can be directly attributed to the prior inventory problems which were addressed in a comprehensive plan developed in 1990.(This perspective is especially important in view of the fact that TVA has experienced no discrepancies in its new SNM tracking program at BFN.)This comprehensive plan was instituted as a result of the previous enforcement action (EA 89-239).It was in Phase II of this plan that, the inventory discrepancies were identiEied.

2.Corrective Actions Taken and Planned As discussed in the enforcement conference of October 4, 1991, to address previous SHM inventory issues raised in EA 89-239, TVA developed a comprehensive three-phase plan in 1990 to complete non-fuel SNM storage activities.

Phase I of the plan consisted oE performing extensive plant searches and detailed piece counts.High level radwaste barrels and lead bricks were opened, and searches were made in the SFSPs.The searches of the SFSPs involved the use oE robots and video equipment to provide a detailed piece count.In addition, TVA reinventoried previously packaged shipping liners and defined specific SHM storage areas within the SFSPs.Phases II and III consists oE a cleanup of the SFSPs and disposal of non-fuel SHM stored in the SFSPs.The cleanup efEorts provided TVA with a validation of the SFSP inventory and facilitated maintenance of the inventory.

The ef Eor ts include processing approximately 300 non-SNM.items stored in tho SFSPs.These items include: boxes, brushes, cold end material, and miscellaneous fuel assembly parts.In the cover letter to the NOV the Staff requested that BFN"reconfirm" seven speciEic commitments (including schedule)that it states were made during the October 4, 1991 enforcement conference.

TVA'ddresses below each oE these matters."The Plant Manager will be responsible Eor site activities associated with the SFSPs." BFH has enhanced management oversight by reiterating the Plant Manager's responsibility for material stored in the SFSPs.This was communicated to the Plant Operations Manager on November 1, 1991, and subsequently included in Operations'ight orders.The applicable reEueling operations procedure will be revised to clarify the Plant Manager's responsibility for the SFSPs.This revision will be completed by December 23, 1991.

e"Mhen cleanup is complete, the SFSPs will serve only as'emporary storage for spent LPRMs, and the LPRMs will be stored in a manner that assures proper identification and accountability." The applicable refueling operations procedure will be revised to identify the SFSPs as a temporary storage location for spent LPRMs and non-essential components.

This proceduxe will also be revised to provide for recommendations from Operations to the plant manager for disposal of unusable non-fuel SHM and non-essential components in the SFSPs.This xevision will be completed by Decembex 23, 1991.In addition, the applicable maintenance instruction is being revised to address proper storage of LPRMS which will assist in assuring proper identification and accountability.

This revision will be completed by December 16, 1991."Cutting and packaging operations of spent LPRMs for disposal will be performed only at a time just prior to offsite shipment to an offsite burial facility." The applicable radwasto spent fuel pool clean-out procedure is being revised to direct the cutting and packaging requirements.

Specifically, LPRMs will be stored in the SFSPs in a full-length condition until just prior to the time of shipment to an offsite disposal facility."All currently known non-fuel SNM items and non-essential components will be removed from all spent fuel pools, and[TVA]will refrain from using the spent fuel pools to store these items during future operations." Known non-fuel SNM items have been removed from the SFSPs and shipped offsite for disposal.Known non-essential components are being readied for disposal.As stated above, procedures will be revised to ensure that SFSPs are used only for temporary storage.Additionally, some non-essential components (e.g., control rod blades, filters,'tellite rollers from the control xod blades, small items xetrieved duxing the vacuuming px'ocess, Unit 3 vibration strings)must remain in temporary storage until equipment is available to process these items.These items will be processed and shipped for disposal duxing Phase III as required by our disposal action plan of 1990.However, the disposal of the stellite rollers is pending evaluation to determine if the activity oE the rollers is low enough to allow disposal at an offsite burial facility.If the activity is not low enough, the rollers will have to remain in the SFSPs until such time as the activity has decreased sufficently to allow shipment.TVA expects the non-essential components, excluding the stellite rollers, to be removed from the SFSPs by June 1, 1992."[TVA]will vacuum clean sludges and other debris Erom all spent fuel pools and video-tape all items remaining in the pools after clean up is complete." Accessible floor areas of the SFSPs are being vacuumed, and accessible floor areas and fuel storage areas are being videotaped to ensure thoroughness of the searches in the SFSPs for non-Euel SNM.If previously unaccounted for non-fuel SNM items are identified, they will be promptly included on BFH's inventory List and prepared for disposal in accordance with Phase III of BFN'omprehensive plans.Those discrepancie will be reported to NRC, as appropriate.

Vacuuming will be completed by January 9, 1992.Final videotaping will be performed after the non-essential components, discussed above, are removed from the SFSPs.TVA expects the final videotaping to be completed by July 1, 1992."[TVA]will establish and report to HRC, an accurate and credible baseline inventory of all SNM on site ([TVA]indicated that this item would be completed by October 26, 1991)." TVA believes it will have a credible baseline SNM inventory when the vacuuming and videotaping of the SFSPs are completed.

Vacuuming dif Eiculties (e.g., vacuum cleaner breakdowns, and vacuuming under 40 feet of water)have extended the October 26, 1991 completion date that was previously scheduled in the.plan-of-the-day report provided during the enforcement conference.

It should be noted that the fuel racks were not disassembled or moved due to the difficulty of moving the spent fuel stored in the SFSP."[TVA]will have an independent organization from outside the Tenne soe Valley Authority evaluate the entire SNM control and accounting program at the Browns Ferry Plant." As a continuing corrective action and to provide further assurance of our programmatic control of SHM, TVA will provide for an independent evaluation oE SHM control and accounting by an outside organization.

TVA expects thi evaluation to be completed by July 1, 1992.If a change occurs to this schedule, TVA will notify the StaEE.

3.Date When Full Co lienee will be Achieved TVA considers that full compliance will be achieved when procedure revisions are complete, SFSPs are vacuumed and videotaped, and the independent evaluation is.completed.

TVA expects these actions to be completed by July 1, 1992.Should TVA discover any discrepancies as a result of the independent evaluation, TVA will report such discrepancies as appropriate.

PLLIC207/42

~~~~ENCLOSURE 2 Tennessee Valley Authority Browns Ferry Nuclear Plant Commitments from Enclosure 1 1.Revise refueling operations procedure to address plant manager'responsibility for the spent fuel storage pools (SFSPs).This revision will be completed by December 23, 1991.2.Revise refueling operations procedure to provide for recommendations from operations to the plant manager for the disposal of unusable non-fuel special nuclear material (SNM)/non-essential components in SFSP and a step which states the SFSP is only a temporary storage area for non-fuel SNM/non-essential components.

This revision will be completed by December 23, 1991.3.Complete vacuuming of SFSPs.Vacuuming will be completed by January 9, 1992.4.Videotape SFSPs to ensure no non-fuel SNM is stored in SFSP.Videotaping will be completed by July 1, 1992.5.TVA will provide for an independent evaluation of SNM control and accounting by an outside organization.

TVA expects this evaluation to be completed by July 1, 1992.6.Maintenance Instruction i being revised to address proper torage of LPRM which will assure proper identification and accountability.

This revision will be completed by December 16, 1991.7.Radwaste procedure is being revised to address cutting and packaging requirements for LPRM storage.This revision will be completed by December 16, 1991.8.Dispose of non-essential components in SFSP.Disposal of non-essential components, excluding stellite rollers, will be completed by June 1, 1992.

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