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)

See also: IR 05000259/1991033

Text

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DISTRIBUTION

DEMONSTRATION

SYSTEM REGULATORY

INFORMATION

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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

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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.

Enclosure 1 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.

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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.

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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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