ML20127D674

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1257/92-08

ML20127D674
Person / Time
Site:	Framatome ANP Richland
Issue date:	01/08/1993
From:	Reese J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Maas L SIEMENS POWER CORP. (FORMERLY SIEMENS NUCLEAR POWER
References
NUDOCS 9301190004
Download: ML20127D674 (2)

Text

, _ _ _ _ ._. _.- -

,. - . _ , .s.. --

d- '

m

~.

JAN D 81993 -

Docket No. 70-1257 License No. SNM-1227 Siemens Power Corporation 2101 Horn Rapids Road P. O. Box 130 Richland, Washington 99352-0130 Attention: Mr. l.oren J. Maas, Manager Regulatory Compliance

Subject:

RESPONSE TO NOTICE OF VIOLATION CONTAINED IN NRC INSPECTION REPORT NO. 70-1257/92-08 Thank you for your letter dated January 4,1993, in response to our Notice of Violation and Inspection Report No. 70-1257/92-08, dated December 4, 1992, informing us of the steps you-have taken to correct the item which we brought to your attention.

Your corrective actions appear to resolve our concerns regarding the violation  !

referenced in the subject report. Your corrective actions will be reviewed during a future inspection.

Your cooperation with us is appreciated.

Sincerely, James H. Reesa, Chief Facilities Radiological Protection Branch

t. :

W. S. Pennington, NMSS/IMSB State of Washington bcc w/ copy of letter dated January 4,1993 Cccket File G. Cook J. Martin-B. Faulkenberry 150022 D. Proulx, WNP-2

)

REGION V CHooker/M Rpese f 1/7/93 1/Y-/93

/

REQ EST COPY QUE T _ COPY ] SE W 0 PDR ES / N0 /1ES /- N0 '

ES / NO 1 .)

-c 7-_

9301190004 930108 i 3 PDR ADOCK 07001257 # -j C PDR g (\ l

, / t-UNITED STATES 4N- NUCLEAR REGULATORY COMMISSION l _1 REGION V S,- - 8 1450 MAA1A LANE

%, ,# WALNUT CRcEK, CAllFOnNIA 94596-5368 JAN 0 81933 Docket No. 70-1257 License No. SNM-1227 Siemens Power Corporation 2101 liorn Rapids Road P. O. Box 130 Richland, Washington 99352-0130 Attention: Mr. Loren J. Maas, Manager Regulatory Compliance

Subject:

RESPONSE TO NOTICE OF VIOLATION CONTAINED IN NRC INSPECTION REPORT N0. 70-1257/92-08 Thank you for your letter dated January 4,1993, in response to our Notice of Violation and Inspection Report No. 70-1257/92-08, dated December 4, 1992, informing us of the steps you have taken to correct the item which we brought to your attention.

Your corrective actions appear to resolve our concerns regarding the violation referenced in the subject report. Your corrective actions will be reviewed during a future inspection.

Your cooperation with us is appreciated.

erely, e,

e t Jah'$

fa lities Radiolo ical Protection Branch CC:

, W. S. Pennington, NMSS/IMSB State of Washington l'

i l

l_

= = = = = - . . _- _.

n:

SIEMENS

['d f"' -7 ll ? 47 January 4,1993 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Reply to Notice of Violation __

Ref: Letter, R. A. Scarano to Sinmens Power Corporation, *NRC Inspection Report No. 70-1257/92-08," dated December 4,1992.

Gentlemen:

Enclosed is Siemens Power Corporation's reply to the Notice of Violation transmitted to SPC by the referenced letter, if you have any questions regarding this reply, please contact me at 509-375-8537.

Very)truly yours, ~

D'\01% su Loren J. Maas, Manager Regulatory Compliance

~

LJM:pm cc: Mr. John B. Martin Region V Administrator g&&

Siemens Power Corporation Nuclear Division - Engineenng and Manufacturing Facihty 2101 Horn Rapids Road, PO Box 130 Richland, WA 993524130 Tel: (509) 375-8100 Fax: (509) 375-8402

- . - _ - . . = - - -.------ -_-------- - -- .

)

.?

USNRC Document Cbntrol Desk January 4,1993

. Page 1 Siemens Power Corporation (SPC) Reply to Notice of Violation Dated December 4,1992 (NRC Inspection Report No. 70-1257/92 08) 1 Violation 1 CSA U 1.2, dated August 1973 (for the uno 1 vaporization chests), was not adequate to determine that criticality safety criteria were satisfied, in that the CSA failed to incorporate all -!

credible accident conditions, thus failing to adequately determine that no % > condition was capable of causing an accidental criticality. Specifically, flooding of uranluru wxafluoride vaporization chests (unfavorable geometry vessels), with uranium bearing solutions from process systems that vented to the connecting process off gas (POG) system was a credible accident condition that was not analyzed in the CSA. On October 13,1992, such an event occurred when a process tank containing low enriened (4.0 percent U-235) uranyl fluoride overflowed to the POG system and into an unfavorable geornetry vaporization chest, a credible accident.

SPC Response to Violation SPC admits to this violation.

Reason for Violation _

The reason for the deficiency in CSA U-1.2 was a failure to sufficiently predict systems interactions in identifying and analyzing credible accident scenarios.

Immediate Corrective Actions The following actions were taken in the short term to correct the conditions that caused the -

tank 10 overflow, to assure a complete identification of credible accident scenarios, and to update the associated CSAs to reflect all necessary controls. _

• Conversion line 1 was immediately shut down and conversion line 2 was put en standby. Upon being notified of the event, Safety, Security, and Ucensing notified NRC under Bulletin 9101. The fo!!owiag day (October 14) NRC Region .

V issued a Confirmatory Action Letter specifying conditions that would need to -

be met to the satisfaction of NRC Region V prior to conversion line restart.

• An incident Investigation Board (118) was convened to coordinate and oversee a thorough investigation of the _ event, to identify the potential for sim. v events in the other conversion line, and to specify the corrective actions to preclude ,

such events.

• A criticality safety calculation was performed to assess consequences of this event under worst case conditions of maximum solution concentration and-

- ~ - . - . .

nm .

USNRC Document Control Desk January 4,1993 Page 2 depth of solution in the vaporization chest. The calculation showed that the system would remain sub-critical by a substantial margin.

• An independent task force was assembled to evaluate the potential for similar accidents throughout the chemical processing area and to take appropriate corrective actions.

• Addenda were prepared to CSAs U-1.2, U-1.7, and U-1.26 to reflect additional accident scenarios and related criticality safety controls.

• The Startup Council was convened to review the adequacy of the completed corrective actions prior to restarting the conversion lines. Startup approval from the council was granted on October 22. NRC concurrence, i.e.

notification that requirements of the Confirmatory Action Letter had been met, was received on October 23.

Corrective Action to Avoid Further Violations Based on an earlier criticality safety occurrence and resulting NRC inspection (NRC '

Inspection Report No. 70-1257/92-06) as well as subsequent internal evaluation, SPC had already committed to NRC Region V (NRC Enforcement Conference, Sept. 22,1992, Walnut Creek) to undertake a major program to revi3W the accuracy, adequacy and consistency of -

all criticality safety analyses and sub-tier documents. This program, reviewed with NRC Region V staff and outlined in a program plan submitted by B. N. Femreite (SPC Richland Plant Manager) to J. B. Martin (NRC Region V Administrator) on December 30,1992, will include a validation of existing CSA assumptions, revision of CSAs as required (reformatting, enhancing, or reanalyzing), followed by an updating of implementing documentation (Criticality Safety Specifications and Operating Procedures). A copy of this program was also _

sent to the Director of the Office of Enforcement.

Date to be in Full Compliance The immediate corrective actions to preclude recurrence of this event and to remedy the deficient CSA have been completed. The major CSA update program, discussed in the above paragraph, has been initiated. A projected schedule for completion is included with the program description.

Violation 2 Violation 2 addressed deficiencies in SPC's evaluation of the event for reportability and failure to report in conformance with internal reporting requirements. NRC's evaluation of corrective actions submitted by SPC in response to the Confirmatory Action Letter indicated that SPC had corrected this matter. The Notice of Violation indicated that no further written response was required.

__ . - , . . . .. .-