LD-90-027, Responds to NRC Re Violations Noted in Insp Rept 70-1100/89-07.Corrective Actions:Desirable Location for Residue Storage Trailer,Minimizing Trailer Movement, Established & Training Session Conducted
| ML20033H147 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 04/03/1990 |
| From: | Scherer A ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| LD-90-027, LD-90-27, NUDOCS 9004180297 | |
| Download: ML20033H147 (4) | |
Text
,
m ggggggggg April 3, 1990 LD-90-027 e
Docket No. 70-1100 License No. SNM-1067 D'r. Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, Pennsylvania 19406
Subject:
Response to Notice of Violation (Inspection Report No. 70-1100/89-07)
Reference:
Letter, R. R..Bellamy (NRC), to C. R. Waterman (C-E), dated March 5, 1990
Dear Dr. Bellamy:
Combustion Engineering has reviewed the Notice of Violation received with the Reference letter and our reply is provided herewith (Enclosure I).
l If I can be of further assistance en this matter, please l
do not hesitate to call me or Mr. J.
F. Conant of my staff at (203) 285-5002.
Very truly yours, COMBUSTION ENGI RING, INC.
ny n
'A. E d h'erer l
Director Nuclear Licensing AES:jeb
Enclosure:
As Stated cc:
G. Bidinger (NRC)
J. Roth_(NRC - Region I)
I Power Systems 1000 Prospect Hill Road (203) 688 1911 Combustion Engineenng, Inc.
Post Othee Box 500 Telex: 99297 '
i 9004163297.900403 Windsor. Connecticut 06095 0500 PDR ADOCK 07001100 l
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' 8 Enclosure I to LD-90-027 t
RESPONSE TO NOTICE OF VIOIATION (NRC INSPECTION REPORT-NO. 70-1100/89-07)
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j Response to Notice of Violation l
(NRC Inspection Report No. 70-1100/89-07) j Statement of Violation Section-4.3.19, " Specific Criticality Safety Criteria",
of Part 1,-Criteria, of the NRC-approved license application for License No. SNM-1067. states, in part, that shipping container arrays of different types shall i
be separated from one another by-at least twenty feet.
contrary to the above, on November 28, 1989, different-shipping container arrays were not separated by 20 feet in that an array of Model CE-250-2 shipping containers holding scrap uranium residuals in a storage trailer was located within 19 feet of an array of Model 927. shipping containers holding fuel assemblies.
ResDonse Upon notification by the NRC Inspector about the subject l
violation, Combustion Engineering Nuclear Fuel Manufacturing facility management personnel inspected the area immediately.
Measurements were taken which confirmed that about 18' 10" separation existed between r
the edges of the closest Model 927 shipping containers and the residue storage trailer.
With the approval of the Program Manager, Radiological l
and Industrial Safety, steps were taken to relocate three Model 927 shipping containers, which were in a vertically stacked arrangement as a part of a larger array, to achieve the minimum 20' separation required.
t As a follow-up, a written report of this incident was prepared in accordance with Combustion Engineering Nuclear Fuel Manufacturing internal administrative procedure AP-1, Abnormal Event Occurrence (AEO)ident was Reporting.
Pursuant to this procedure, the inc investigated to determine the root cause and to provide l
recommendations for permanent corrective actions.
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The investigation revealed that material handlers and the warehouse supervisor were aware of the applicable posted criticality safety limits and the minimum 20' separation requirement between arrays of different. types'of shipping containers.
These individuals, however believed that the required separation existed.
The incident was apparently caused either by an error in measuring the minimum standoff point from the residue trailer as the inter.d9d Model 927 array location was established or an 1
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error was made as the closest Model 927 shipping container was set down.
A second measurement was not made after the closest container was set down to verify j
compliance with. requirements.
In accordance with AP-1, the report of this incident, including the root cause determinationfand recommendations for permanent corrective action, was reviewed by the AEO Committee.
The Committee approved the following-corrective actions:
1)
Establish a desirable location for the residue storage trailer which does not require frequent movement of the trailer.
Establish a clearly visible painted line on.the pavement area around the trailer at a minimum of 20' from the residue trailer to facilitate the proper location of shipping
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container arrays by material handlers.
This action has been completed.
2)
Conduct a training-session for warehouse material handlers and the warehouse supervisor to review the
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' details of the incident and to review applicable t
license requirements for criticality safety for storage of fissile material in the yard area or in the Building 21 warehouse.
This action has been completed.
3)
Review the incident report with Radiological Protection Technicians to increase their awareness for similar conditions which could be observed during routine inspections.
This action has been completed.
4)
Since it is not feasible to paint a boundary line around temporarily established shipping container arrays, the Plant Manager issued a written directive to the Warehouse Supervisor requiring that measurements be made before establishing'an array of shipping containers or trailers loaded with shipping containers).(and that the distance again be L
l measured after containers-(or loaded trailers) are spotted.
p This action has been completed'.
Combustion Engineering, Inc. believes that the above actions, which have been completed, will preclude the recurrence of the cited violation.
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