ML20034A823

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp 70-1100/89-07
ML20034A823
Person / Time
Site: 07001100
Issue date: 04/17/1990
From: Bellamy R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Waterman C
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 9004240391
Download: ML20034A823 (2)


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Docket No. 70-1100

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Combustion Engineering, Inc.

ATTN: Mr. C. R. Waterman-Acting Vice President-- Nuclear Fuel Nuclear Power Systems 1000 Prospect' Hill Road Windsor,_ Connecticut 06095-0500' Gentlemen:

Subject:

Inspection No. 70-1100/89-07 This refers to your letter dated April 3,1990, in response to our letter dated March 5, 1990.

Thank you for informing us of the corrective and preventive actions documented in your letter. These actions will be examined during a future inspection of-your licensed program.

Your cooperation ith us is appreciated.

Sincerely, i

Original Signed By:

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Ronald R. Bellamy

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Ronald R. Bellamy, Chief Facilities Radiological Safety and Safeguards Branch Division of Radiation Safety and Safeguards cc:

A. E. Scherer, Director, Nuclear Licensing _

C. B. Brinkman, Manager, Washington Nuclear Operations Public Document Room (PDR)

Local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

State of Connecticut W

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1 Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1) l.

J. Roth, DRSS G. Bidinger, NMSS 1.

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SOMBUSTIONkENGINEERIng April 3, 1990 l

LD-90-027

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Docket No. 70-1100 l

License No. SNM-1067 Dr. Ronald R.

Bellamy, Chief Facilities Radiological Safety.

and Safeguards Branch i

Division of Radiation Safety and Safeguards U.S. Nuclear Regulatory Commission

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Region I 475 Allendale Road King of Prussia, Pennsylvania-19406 Subj ect:

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 on this matter, please L

do not hesitate to call me or Mr. J. F. Conant of my i

staff at (203) 285-5002.

l Very truly yours, COMBUSTION ENGI RING, INC.

,>>>j A. E d h'erer Director Nuclear Licensing AES:jeb

Enclosure:

As Stated cc:

G. Bidinger (NRC) 4 J. Roth (NRC - Region I)

Power Systems 1000 Prospect Hill Road (203) 688 1911 Combustion Engineering. Inc.

Post Office Box 500 Telex: 99297 3.-

Windsor, Connecticut 06095 0500 Dn Ja n i, /1 m 7WrMW7 / ~ /V

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RESPONSE TO NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 70-1100/89-07)

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Response to Notice of Violation (NRC Inspection Report No. 70-1100/89-07)

Statement of Violation 3

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,-

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that shipping container arrays of different types shall be separated from one another by at~least twenty feet.

l Contrary to the above, on November 28, 1989, different l

shipping container arrays were not separated by 20 feet 2

in that an array of Model' CE-250-2 shipping containers-holding scrap uranium residuals in a storage trailer was a

located within 19 feet of an array of Model 927l shipping containers holding fuel assemblies.

Response

Upon notification by the NRC Inspector about.the' subject' 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.

I the edges of the closest Model'927 shipping containers and the residue storage trailer.-

i With the approval of the Program Manager, Radiological' and Industrial Safety, steps were-taken to relocate three Model 927 shipping containers, which were in-a. vertically

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stacked arrangement as a part of a larger array, to achieve the minimum 20' separation required'.

As a follow-up,.a written report of this incident was c

prepared in accordance with Combustion Engineering Nuclear Fuel Manufacturing internal administrative procedure-AP-1, Abnormal-Event Occurrence-(AEO)

Reporting.

Pursuant to this procedure, the.. incident was investigated to determine the root cause and to provide recommendations for permanent corrective actions.

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 intended Model 927 array location was established or an l

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1 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 i

compliance with requirements.-

p In accordance with AP-1, the report of this incident,

-i including the root cause determination and recommendations'for permanent; corrective action, was r7 viewed 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;off20' from-the residue trailer to facilitate the proper location of shipping.

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 details of the incident and to review applicable license requirements for criticality safety for i

I storage of fissile material in the yard area or in the Building 21 warehouse.

This action has been completed.

j 3)

Review the incident report with Radiological-I 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 i

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 measured after containers (or loaded trailers) are spotted.

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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