The recent OE concerning the reactor vessel surveillance capsules, OE32026, has generated a number of additional questions here at Dominion concerning the storage of used non-fuel SNM items in our containment buildings. In particular, how are physical inventories performed when an item is relativity inaccessible during reactor operation (e.g., sub-atmospheric containments)? In the past Dominion has used administrative controls. Realizing the 2009 ANSI Standard, N15.8 "Material Control Systems-SNM Control and Accounting Systems for Nuclear Power Plants" provides some guidance in situations such as this, we are looking for some practical approaches to satisfy this guidance.
1. Do you have Non-Fuel SNM stored in containment (not installed in a system)?
2. If yes, when and how are physical inventories performed on these items, i.e. during outages or at-power entries, item count or container count if protected by tamper-indicating devices (TIDs)?
3. If TIDs are used, do you have a TID control program that follows the May 2010 Reg. Guide 5.80, "Pressure-Sensitive and Tamper-Indicating Device Seals for Material Control and Accounting of SNM"? If you do not follow Reg. Guide 5.80, where do you differ?
4. If a container that is protected by a TID is opened, what actions are taken to assure the contents of the container are properly accounted for prior to applying another TID e.g. piece count of items in the container, simultaneous verification by two individuals of the items added or removed from the container, etc?
Thank you in advance for your help.
Adina LaFrance Reactor Engineer Nuclear Analysis and Fuels, Surry Power Station
Dominion Generation Phone: 757-365-2658; Internal: 8-798-2658 E-mail: Adina.K.LaFrance@dom.com
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