ML19284B405
| ML19284B405 | |
| Person / Time | |
|---|---|
| Issue date: | 07/14/1980 |
| From: | Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Higginbotham L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| Shared Package | |
| ML19284B397 | List: |
| References | |
| REF-SSINS-0420, REF-SSINS-6100, REF-SSINS-SSINS, REF-SSINS-SSINS-6 NUDOCS 8011100571 | |
| Download: ML19284B405 (1) | |
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UNITED STATES
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i NUCLEAR REGULATORY COMMISSION
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,/ l REGION I 4
631 PARK AVENUE
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,f' KING oF PRUSSIA, PENNSYLVANIA 19406 h
'UL 14 ISM MEMCRANDUM FCR:
Leo 8. Higginbotham, Assistant Director, FFMSI, IE:HQ FROM:
George H. Smith, Chief, FFMS, Region I
SUBJECT:
MANUFACTURERS INSTRUCTICNS FOR INSTALLATION OF GENERALLY LICENSED STATIC ELIMINATICN DEVICES (AITS F01008363HC8)
An inspection was conducted,by the Region I office of the 50 Warren Company in Westbrook, Maine as followup to the failure of a generally licensed static eli-minator bar reported in PNO-III-80-43.
The failure of the static eliminator bar manufactured by the 3M Corporation, Minneapolis, Minnesota appeared to have been caused by the installation of the bar above a steam sprayer.
The General Licensee, S.D. Warren Company, was cited for failure to install the static elimination bar in accordance with the instructions provided by the manu-facturer as required by 10 CFR 31.5(c)(3)(i).
These instructions require that the 3M Model 315 Static Eliminator Bar not be placed in areas where the tem-perature exceeds 200 F.
It appeared that installation of the bar in a steam spray, where the temperature of the steam would exceed 212 :, constituted non-compliance with this recuirement.
In their reply letter, the licensee stated that it was their evaluation that the bar was not exposed to temperatures above 200 F.
Their evaluation with the apparent assistance of the 3M Corporation, is that the moisture from condensa-tion of the steam spray was the agent which caused the failure of the static eliminator bar.
Region I agrees that this is a reasonable interpretation of the available facts.
This indicates that the instructions provided by the 3M Corporation for instal-lation of static eliminator bars were inadequate to prevent the installation of the bar in environmental conditions which resulted in its failure and caused it to present a contamination hazard.
The information contained in the enclosed inspection report and the licensee's reply letter dated May 22, 1980 should be forwarded to the License Management Branch for their information and evaluation with a recommendation that appropriate changes in the installation instruction for this device be required of 3M.
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.s GMe"sa==r H. Smith, C f
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Fuel Facilities and Mater'ials Safety Branch
Enclosure:
Cffice of Inspection and Enforcement Report:
General Licensee 30-01 (5.0. Warren)
Letter from S. D. Warren dated May 22, 1980 CC:
A. Bert Davis, Chief, FFMSI, RIII 80n 100 57/
UNITED STATES
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NUCLEAR REGULATORY COMMisslCN
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$31 P AR K AVENUE
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MM 0 3 39 S.D. Warren Ccmpany ATTN: Mr. Richard Davidson Manager of Chemical Centrol Cumberland Mills Staticn Westbreck, Maine C4092 Gentl eren:
Subject:
Inspecticn 30-01 inis revers :: the inspection ccnducted by Ms. M. Camcbell of this office on March 25-26, 1980 of activities autnerized by an NRC General License and to the discussions cf Our findings held by Ms. M. Caccbell with ycurself, Mr. P. 3rcwn of your staff. Mr. Costie of the State of Maine Cepartment of Human Services, and Mr. Swensen of the 2M Ccepany at tne c:nclusien of the inspection.
Areas examined during this ins:ection are described in the Cffice of Inspecticn and Enf:rcement Inspection Reper which is enciesed with this letter.
Wi thin these areas, the inspecticn consisted of selective examinations of precedures and representative records, interviews with perscnnel, measurements made by :ne inspector, and cbservations by One inspector.
Based en tne results of this inspecticn, it appears that ene cf your activities was not conducted in full compliance with NRC recuirements, as set fortn in tne Notice of Viclation, encicsed herewith as A;cencix A.
in1s item cf ncncem-pliance has been categcri:ed into the levels as described in cur correspondence to you dated December 31, 1974.
This notice is sent to ycu pursuant to the provisiens of Section 2.201 of the NRC's " Rules cf Practice," Par: 2, Title 10, Code cf Feceral Regulaticns.
Section 2.201 recuires you to submit to this office, wi:nin twenty (20) days of your receip: cf this notice, a written state-ment er explanation in repiy including:
(1) corrective steps wnich have been taken by ycu and the results achieved; (2) corrective stecs which will be taken
= void further items of ncnccmpliance; and (3) One data when full ccmoiiance wil
,e achieved.
In accordance with Section 2.790 of tne NRC's " Rules of Practice," Par: 2, Title 10, Coce cf Federal Regulaticns, a copy of :nis letter and the enciesures will be placed in the NRC's Public Cocument Rccm.
If :nis recer: contains any infor-mation that you (or your centractor) believe to be procrietary, it is necessary that you make a wri: ten acplicaticn within 20 days to this office to withhold such information frca public discicsure. Any such applica:icn must be accompanied
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D. Warren Company 2
by an affidavit executed by the cwner cf the information, whicn identifies the cocument or part scugn: to be witnheid, and whicn contains a statement cf reasons wnich addresses with specificity the items which will be considered by the Commission as listad in subparagraph (b) (4) cf Secticn 2.790.
The information sought :0 be withheld snall be incorporated as far as possible in:0 a separate part of the affidavit.
If we do not hear frcm you in this regard within the specified pericd, the report will be placed in the Public Dccument Rocm.
Shculd ycu have any questions concerning this inspection, we will be pleased to discuss them with you.
Sincerely, r
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'H'i,1bert W. Crccker, Acting Chief Mater:als Raciclogical Frctacticn Secticn Encl osures.
1.
A:cendix A, Nctice of '/iclation 2.
Cffice of Inspection and Enforcement Inspection Reper: Numcer SC-01 bcc:
IE Mail & Files (For Apprcpriata Distributicn)
Central Files Public Document F.ccm (FDR)
Huclear Safety Informaticn Center (NSIC)
REG:I Reading Roca S ta te cf Maine A. Sert Cavis, Chief, FF1MS, RIII
APPENDIX A NOTICE OF VIOLATION S.0. Warren Company Wes tbrock, Maine C4092 General License Based en the results of an NRC inspecticn conducted on March 25-25, 1980, it appears that ene of ycur activities was not conducted in full comoliance with NRC regulaticns as indicated belcw:
10 CFR 31.5(c)(3)(i) recuires that ycu install devices generally licensed containing byprcduct material in accordance with instructicns proviced. ine instructicns provided by 2M Cor;oratien with their Mccel 315 Static Eliminator require that it not be placed. in areas where tne temcerature exceeds 2CC0F.
Contrary to this recuirement, as of the dates cf the ins;ecticn, March 25-25, 1980, a 2M Mcdel 315 Static Eliminatcr device was installed in an area wnere it was subjected to steam of a temperature exceeding 2120F.
This is an inf acticn.
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U. S. NUCLEAR REGULATCRY CCFMISSION OFFICE CF INSPECTION AND ENFCRCEMENT REGICN I Reper: No.
30-01 Cocket No.
License No.
General Priority Category Licensee:
S.C. Warren Comcany Westbrock, Maine C4C92 Facility Name:
Inspecticn A :
Inscecticn Conducted:
March 25-26.1980 Inspectors :
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'M. %. (Catceij., Raciation Sceciails:
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s J'F/Ps Approved /by):
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. Crocxer, Acting Chief, Materiais
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~ diclogical Protection Secticn, ??LMS Branch Ins:ecr.e Summary:
Areas Ins::ectec:
Special, announced inscection of the circumstances surround.ng
- ne failure of a cenerally licensed static eliminator bar centaining Fo-210, in-cludinc notification of the failure of the bar, tour of the facility, decantam--
ination of ne facility, confirratory measurements, and review or beta gauges, ine
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-ac-4 n involved 8 inspector-hours on site by one NRC inspector, item of ncnccmpliance was identified icn in accorcance with instructions pro-DUPLICATE DOCUMENT Entire document previously entered into system ur. der:
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May 22, 1950
?+;. Hilbert W. Crocker Acting Chief,.v terials Radic1cgical a
Protection Section United States Nuclear Regulatory Con::ission negicn I 631 Park Avenue King of P:ussia, Pennsylvania 19406
Dear Mr. Crccker:
inis is in response to ycur letter of May 9,19SO, which details de cutcc=e of an inspection cenducted at $is clant b.v v. cur a
Ys. M. Campbell on March 25-26, 1930.
Me d= age which was apparently sustained by a 3i % del 313 Static Eliminator at this iccation was felt by both 3M perscnnel and."S. C2=hcIl to be caused by cur installation
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of the device in proxi":ity to a steam shoker. An immediate respense was -ade to this advice in -hat the s:c= shcwer was rendered inoperative by tagging the centrci valve, prohibiting temporarily its operation. On April 5, 1950, a more per;anen:
solutien was i.9 0mented by relocating the Static Eliminator a 1
distanca cf several feet away from the s:can shcwer, thus climinating any contact of the bar by live steam.
in ac,citica :c :nc corrective measures u,escriu, abeve, tn,e
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installation of another Static Eliminator en a related piece of ecuipment was reviewed. Ecugh that cperation also involves the use of a s c= shower, its loca:icn is several feet distant frcr. Se Static Eliminator and is further isclared by reans of an acrflic barrier.
Although the ccrrective measures described have been fully implemented, there are certain allegaticns made in your reper:
which deserve further ccmment.
In particular, we respeciully dens the conclusien dat the device was subjected to :cmperatures exceeding 2009, contrarv to the instructions provided by the mar.ufacturer.
Cur rcasurements indicate that de s:ccm shcwer in cuestica was
.:ccated a distance c: : m ve) inches beneath $e Static :.,:.m:.na to r (5is distance is cited as "a'ocut 3 inches" cn page 3 cf M. C=pi'c11's inspection repert).
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2 Actual temperature measurements made at this distance (5 inches).
ab:ve the steam shower have ran;;ed from 32 to 93 F, with de C
steam turned on.
It is apparent that the steam cender.ses into a mist of water a very short distance frcm the shcwer pipe.
Ne submit that any damage dcne to de Static Eliminater was as much the result of exposure to moisture as to high temperature, which, in fact, did not exceed 200cF. We reach this conclusion not cnly frca cur cwn temperature measurements, but also en de basis of a ccanent made by the 3'! reoresentative during the inspection visit that the phenexy resins which maintain the integrity of this device are susceptible to damage by steam and/or meisture. Any cautions against such expcsure are not a part of tne installa:ica instractions, there being cnly de cm.ent abcut avoiding excessive temperatre exposure.
Verv truly ycurs,
Philip F. Brown, Ph.D Technical Director of 3'anufacturing PFB/.ihn cc:
Mr. Tcm Lahr, 3'I Ccccany Str. Dostie, State of "aine Deparment of & man Ser/ ices 9