NRC-89-0118, Requests Exemption from 10CFR74.13(a)(1) Re Submittal of Matl Balance Rept & Physical Inventory Listing.Performing Physical Inventory in Sept Would Cause Stoppage of Refueling Operations & Thus Adversely Impact Outage Schedule

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Requests Exemption from 10CFR74.13(a)(1) Re Submittal of Matl Balance Rept & Physical Inventory Listing.Performing Physical Inventory in Sept Would Cause Stoppage of Refueling Operations & Thus Adversely Impact Outage Schedule
ML20244C491
Person / Time
Site: Fermi DTE Energy icon.png
Issue date: 06/06/1989
From: Sylvia B
DETROIT EDISON CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-89-0118, CON-NRC-89-118 NUDOCS 8906140341
Download: ML20244C491 (2)


Text

.

D. R;lph Sylvia Senior Vice President Detroit ,,.,m_ o,. e ,,

Edison =="-

June 6,1989 NBC-89-0118

- U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555

References:

1) Fermi 2 NFC Docket No. 50-341 NBC License No. NFF-43
2) IURBG/BR-0007, " Instructions for Completing Material Balance Report, Physical Inventory Listing and Concise Note Forms"

Subject:

Request for Exemption from 10CFR74.13,

" Material Status Reports __

'Ibe purpose of this letter is to request an exenption from 10CFR74.13 (a) (1) . The regulation requires licensees to complete DOF/NBC Forms 742, " Material Balance Report", and 742C, " Physical Inventory Listing", as of March 31 and September 30 of each year and submit them within 30 days. The requirement to comply with the printed instructions for completing the forms is also in i

10CFR74.13 (a) (1) .

Reference 2, Part II states in part: l This form, DOE /NBC Form 742, describes the status of the nuclear material reported on Lines 80 and 81 of DOF/NBC Form 742, as of the date of physical inventory.

The physical inventory is a piece count with verificatica of assembly serial numbers. Literal interpretation of the regulation requires that a physical inventory be conpleted each March 31 and September 30.

However, Fermi 2 is scheduled to begin a refueling outage in early September 1989 and fuel handling may well be in progress on September

30. Performing the physical inventory on September 30, per the l apparent requirement, would cause stoppage of refueling operations and thus adversely impact the outage scredule.

Detroit Edison requests an exemption from 10CFR74.13(a) (1) to allow  ;

the physical inventory to be performed in early September prior to l commencement of fuel handling and Form 742C due Septenber 30,1989 to Vf W \

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o USNIC June 6, 1989 10C-89-0118 Page 2 be completed based on book inventory. The book inventory would be based on where documentation indicates each fuel assembly is located on September 30, 1989.

Detroit D31 son has committed to complying with ANSI N15.8-1974, as reemmended in Regulatory Guide 5.29, "Naclear Material Centrol Systems for Nuclear Power Plants", for all special nuclear material that has been removed from its original shipping container. ANSI N15.8-1974 requires that for fuel assemblies or elements in an irradiated fuel area, a piece count, together with a verification of assembly serial numbers, be taken at least every six months an3 after each refueling of the reactor. It does not specify the date of inventory.

Based on the physical inventory to be conducted in early September, that an a3ditional physical inventory will be completed following refueling, and the adverse irpact of performing the physical inventory on September 30, Detroit Edison believes adequate justification exists to allow the inventory conducted on September 30, 1989 and documented on Form 742C to be a book inventory. Allowance for specific exemptions to 10CFR74.13 is provided in Section 74.7 " Specific Exenptions".

If the NBC determines that the rule already permits Form 742C to be coupleted based on book inventory and an exemption is not necessary, please provide documentation of the determination. Please note that 1(CFF70.51(d) requires that a physical inventory be performed every 12 months, while literal interpretation of 10CFR74.13(a) (1) requires the physical inventory twice a year.

A prompt review of this exemption request would be appreciated since its outcome will affect the refueling outage schedule. If there are any questions, please contact Lynne Goodman at (313) 586-4211.

Sincerely,

[

cc: A. B. Davis i

R. C. Knop T. Madeda W. G. Rogers J. F. Stang l

.