ML20117M552

Responds to NRC Re Violations Noted in Insp Repts 50-348/96-03 & 50-364/96-03.Corrective Actions:Will Not Place Any Fuel in Unit 1 or 2 New Fuel Storage Areas Until Exemption or Compliance w/10CFR70.24

ML20117M552
Person / Time
Site:	Farley
Issue date:	06/13/1996
From:	Dennis Morey SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9606180618
Download: ML20117M552 (3)

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4 Southern Nucle:r Oper: ting Company Post Offtc2 Box 1295 Birminghtm. Alibams 35201

, Tewphone (205) 868-5131 L

o.ve uorey Southern Nudear Operating Company Vice President Farley Project the Southern electoC system June 13,1996 10 CFR 2.201 Docket Numbers: 50-348 50-364 U. S Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Joseph M. Farley Nuclear Plant (FNP)

Reply to a Notice of Violation (Notice)

NRC Insocction Report Numbers 50-348/96-03 and 50-364/96-03 Ladies and Gentlemen:

As requested by your transmittal dated May 15,1996, this letter responds to VIO 50-348, 364/96 05, "10 CFR 70.24(a) Criticality Monitor." The Southem Nuclear Operating Company (SNC) response to this violation is provided in the Attachment to this letter.

Confirmation I affirm that the response is true and complete to the best of my knowledge, information, and belief.

Respectfully submitted,

( l h )) W Dave Morey EFB/ cit:nov70-24. doc Attachment cc: Mr. S. D. Ebneter, Region II Administrator Mr. B. L. Siegel, NRR Senior Project Manager l Mr. T. M. Ross, FNP Resident Inspector 9606180618 960613 055 gDR ADOCK 05000348 PDR

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RESPONSE TO VIO 50 348,364/96-03-05 NRC Violation VIO 50-348,364/96-03-05, "10 CFR 70.24(a) Criticality Monitor," states the following "During a NRC inspection conducted on March 17 through April 27,19% a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC l Enforcement Actions," NUREG-1600, the violation is listed below-i Part 70.24(a) of Title 10 of the Code of Federal Regulations, .equires each licensee authorized to i possess special nuclear material (SNM) of sufficient quantity, to maintain a radiation monitoring

system in each area where SNM is handled or stored that will alarm if accidental criticality occurs.

Furthermore, applicable emergency procedures must be maintamed to ensure personnel are

, withdrawn to an area of safety when the alarm sounds  !

4 l 1 Contrary to the above, the licensee never installed a radiation monitoring system in the Unit 1 or 2  !

new fuel storage areas capable of alarming should an accidental criticality occur. Furthermore, the licensee's initial exemptions from the requirements of 10 CFR 70.24(a) (cMM as part of its originalNRC Materials Licenses for possessing SNM) expired when the Unit I and 2 construction permits were converted to operatmg licenses in 1977 and 1981, respectively. At that time, the l licensee failed to install a radiation monitoring system and implement appropriate emergency i procedures, or renew its exemptions. Since then, the new fuel storage areas have been used to

handle and store new fuel assemblies on a regular basis prior to each unit refueling outage.

i This is a Severity Level IV violation (Supplement I)."

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Admission or Denial

'Ihe violation occurred as described in the Notice of Violation. However, it should be noted that the design of and safety analyses for the spent fuel pool and new fuel storage area, as well as the associated I

procedural control and technical specification requirements, ensure that conditions of accidental criticality I l are precluded. Additionally, Farley fuel storage requirements for new and spent fuel were reviewed and approved by the NRC in December 1991 with no safety concems directed at the fuel storage and handling 3

arrangemen at Farley.

, Reason for Violation 1

'Ihe reason for this violation was personnel error. Specific exemptions from 10CFR70.24 were previously grantal and were contamed in the special nuclear matenal hecuses for each unit. However, Licensing personnel failed to recognize the exemptions were omitted from the Part 50 operating licenses at the time those licenses were .

subscquentlyissued.  !

Corrective Stens Taken and Results Achieved l I

SNC prepared an exemption request which was submitted to the NRC on May 31,1996, i

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RESPONSE TO VIO 50-348,364/96-03-05 i

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Corrective Stens That Will Be Taken to Avoid Further Violation SNC will not place any fuel in the FNP Unit 1 or 2 new fuel storage areas until an exemption or compliance with 10CFR70.24 is achieved. Until exemption or compliance can be achieved, new fuel will be stored in shipping containers until unloaded for inspection, then transferred to spent fuel pool storage.

, Appropriate fuel handling procedures have been revised to ensure that new fuel is handled as described j above.

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Date of Full Comoliance June 11,1996.

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