ML17261A369
| ML17261A369 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 01/12/1987 |
| From: | Kober R ROCHESTER GAS & ELECTRIC CORP. |
| To: | Lear G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8701210232 | |
| Download: ML17261A369 (6) | |
Text
ROCHESTER GAS AAD LE<.i~ ~ ~
p'
."" ~,. '
99 E ST AVENUE, ROCHESI=.R:.'.
Ia649-0001 4i~v., 'P lV, 'rCQQgg
<ESiCC'JT RIQ fill'g>Q " li January 12, 1987 U.S. Nuclear Regulatory Commission Document Control Desk Attn:
Mr. George Lear PWR Project Directorate No.
1 631 Park Avenue Washington, D.C.
20555
Subject:
I&E Inspection Report No. 86-20 Notice of Violations R. E. Ginna Nuclear Power Plant Docket No. 50-244
Dear Mr. Lear:
Routine Safeguaids Inspection Report No. 86-20, appendix A',
'tated in part:
"As a result of the inspection conducted on November 4-6,
- 1986, and in accordance with the General Statement of Policy and Procedure for NRC Enforcement
- Actions, 10CFR Part 2, Appendix C
(Enforcement Policy 1986) the
~ following violation was identified:
A.
10CFR 70.51(c) requires the licensee to'establish,
- maintain, and follow written material control and accounting procedures which are sufficient to enable the licensee to account for the special nuclear material (SNM) in its possession under license.
10CFR 70.51(d) requires the licensee to conduct physical inventories of the special nuclear material (SNM) in its possession under license at intervals not to exceed twelve months.
Contrary to the above, on November 5, 1986, it was deter-mined that:
I 1.
The licensee failed to establish written material control and accounting procedures to account for.
the SNM in neutron fission detectors.
':pg>i" y
t.i+
].<8~
ttr. Ceorge Lear 2.
The licensee failed to conduct physical inventories for the SNM in neutron fission detectors at intervals not to exceed twelve months between December 1983 and November 1986.
The last physical inventory of these detectors was conducted on November 14, 1983."
RG&E agrees with violation A as stated above in that we do not presently have a written procedure which addresses the control, accounting, or physical inventory of the Special Nuclear Material located in our neutron fission detectors.
- However, RG&E has previously developed and implemented written procedures to comply with all sections of 10CFR 70.51 as we understand the requirements.
These procedures were developed using the guidance of U.S. Nuclear Regulatory Commission NUREG/
BR-0006, "Instructions for Completing Nuclear Material Transaction Reports".
A letter was sent to all licensees with NUREG/ BR-0006, dated December 17,
- 1984, from Theodore S. Sherr, U.S.
NRC Chief Material Transfer SG Licensing Branch stating:
"These instructions apply to reporting nuclear material transactions in accordance with Title 10 of the Code of Federal Regulations (10CFR)
Parts 40, 50'0'5j and 150."
RG&E presently complies with NUREG/BR-0006, Rev.
2, through the implementation of RG&E procedure A-1704, "Special Nuclear Material Inventory and Record Requirements,"
and procedure RF-46, "Special Nuclear Material Physical Inventory".
The Special Nuclear Material (SNM) content in each"'-incore fission chamber has been determined to be 0.0041 grams of 904 enriched U235.
The reporting requirements.of special nuclear material as stated in NUREG/BR-0006 is as follows:
"Any special nuclear material (SNM) inventory changes, including shipments,
- receipts, burnup,. production, onsite gains or losses, inventory difference, or any other inventory adjustment, involving one gram or more of contained uranium-235, uranium-233, or plutonium, or any combination thereof."
Since the SNM content in a fission
- chamber, and the content of all fission chambers on site, do not total one gram of U235, RG&E has not reported these fission chambers to the NRC.
As referred to in NRC Inspection Report No. 50-244/86-20, a
physical inventory of the incore fission chambers was conducted by RG&E on November 14, 1983.
The purpose of this "one time'~
inventory check was to verify that the total sum of all fission chambers "on site" did not total 1 gram or more U235.
This inventory check was not performed to satisfy the requirements of 10CFR
- 70. 51 (d) as stated in the inspection report.
Since NUREG/BR-0006 exempts less than 1 gram of SNM from reportability, RG&E did not consider less than one gram of U-235 to be report-
- able, accountable, or a physical inventory required, as stated in the preceding paragraph.
RGCH~STc=.R )~'
"~ -~-( >:~~P-"
?
~ t 3
<<Qg T<
'ienu~r!~
12, 198" Vr. George Lear In item 3. b paragraph 2, of inspection report 86-20, the inspector stated "the licensee promptly initiated action to establish such procedures so that they are available prior to any shipment of unirradiated fuel."
As clarification to the
- above, it was and remains our intent to establish such procedures for shipment of unirradiated fuel at the time of need.
To establish this type of procedure with no expected shipment anticipated, would be premature.
To date, there have been no shipments of unirradiated fuel from Ginna.
Current administrative controls are in place to require the use of said procedures prior to commencing any shipments..
As a result of this inspection and pursuant violation, RG&E will perform the following corrective actions to comply with the stated requirements of 10CFR 70.51(c
& d):
1 ~
Ginna Station Administrative procedure A-1704, "Special Nuclear Material Inventory and Record Requirements" will be revised to include reporting and inventory requirements for Special Nuclear Material located at Ginna Station regardless of element weight.
The reporting of SNM will be completed as per NUREG/BR0006, Revision 2.
An inventory system will be created to track all incore detector fission chambers located at Ginna Station.
Applicable procedures will be created and/or revised to institute this program.
~
The above listed corrective actions will be completed by May 1, '1987.
As of that date, RG&E will be in full compliance with 10CFR 70.51 paragraphs (c
& d).
V truly y urs, Ro r W. Kober Subscribed and sworn to me on th 12th day of January, 1987.
XC<<
U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA. 19406 T. Pollich Ginna Resident Inspector RINARDf. CAITEHBERGfR Heter'SNc~ ofNew Votk hfonrae~ AY.
Commission f~Nanh 80 f9-Reg. Ha 2235126