ML20128K216

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-1100/84-05. Violation of Section 4.1.3 Re Demarcations on Pellet Shop Floor Rescinded

ML20128K216
Person / Time
Site:	07001100
Issue date:	07/03/1985
From:	Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Lichtenberger ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
NUDOCS 8507240066
Download: ML20128K216 (2)

Text

V jul 031985 Docket No. 70-1100 Combustion Engineering, Inc.

ATTN: Mr. H. V. Lichtenberger Vice President - Nuclear Fuel Nuclear Power System Manufacturing P.O. Box 500 Windsor, Connecticut 06095 Gentlemen:

Subject:

Inspection 70-1100/84-05 This refers to your letter dated Occember 13, 1984, in response to our letter dated December 6, 1984.

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.

With respect to Item A, we have re-examined this violation and concur with you that Section 4.1.3 of your approved license application authorizes you to make changes. in processes, equipment and/or facilities when such changes are docu-mented and approved by the proper personnel and the changes are within the purview of Section 4.2 of the license application. We have determined that the demarcations on the pellet shop mezzanine floor were removed after such a change had been prepared and properly approved as required by Section 4.1.3 of your approved license application. As a result of our re-examination, this violation is rescinded and our records will be revised accordingly.

Your cooperation with us is appreciated.

Sincerely, Original Signed By:

Thomas T. Martin

,-. Thomas T. Martin, Director Division of Radiation Safety and Safeguards cc:

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Nuclear Safety Information Center (NSIC)

State of Connecticut 8507240066 850703 PDR ADOCK 07001100 C

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H POWER SYSTEMS License SNM-1067 Docket 70-1100 December 13, 1984 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:

Edward C. Wenzinger, Chief Projects Branch No. 3 Division of Project & Resident Programs

Reference:

Letter from Edward C. Wenzinger, NRC, to H. V. Lichtenberger. CE, dated December 6, 1984; Inspection No. 70-1100/84-05

Dear Mr. Wenzinger:

This is in reply to the above referenced letter in which you reported that as a result of your inspector's visit to our facility on October 15-19, 1984, cer-tain of our activities were not conducted in full como11ance with NRC require-ments. Our response to the notice of violation, identified as Appendix A to your letter, is as follows:

Appendix A - Item A Section 4.2.6 " Interaction Criteria" of Part I (Criteria) of your approved license application dated April 6,1982 specifies the spacing requirements for 2

a 10.5 inch diameter by 17.7 inch long cylinder as 7.4 ft. Section 4.2.6 fur-ther states that in cases where the spacing extends beyond the equipment boun-daries, the spacing boundary shall be indicated with a colored line (on the floor).

Contrary to the above, on October 18, 1984, at least eight 10.5 inch diameter by 17.7 inch long cylindrical hoppers were located on the pellet shop mezzanine in appropriate storage locations. However, the spacing boundaries (in this case 7.4 ft ), which extended beyond the equipment boundaries, were not indicated 2

with a colored line on the floor.

Response

Section 4.1.3 " Request for Changes and Criticality Analysis" of Part I (criteria) of our approved license application, dated April 6,1982, allows us to make changes in Drocess, equipment, and/or facilities as long as such changes are documented and approved by the proper personnel.

The spacing boundaries (painted floor lines) were removed af ter such a change request had been prepared and approved. What the inspector objected to was that a detailed nuclear safety calculation had not been made even though we felt that such calculations were unnecessary. However, the requested calculations have been performed and have been properly documented and filed for future reference by the inspector.

1. N

H. V. Lichtenberger December 13, 1984 i

Appendix A - Item B Section 4.3, " Specific Criticality Safety Criteria," of your approved license appli-cation (Part I - Criteria) dated September 16, 1983 states in paragraph 4.3.8 that each storage position in the concrete block storage area shall be limited to one con-tainer.

Contrary to the above, on October 18, 1984 three storage positions in the concrete block storage area located in the pellet shop annex contained two containers filled with low enriched uranium-bearing material.

Response

The nuclear safety sign in the concrete block storage area has been changed to make it more explicit.

In addition, employees have been reinstructed on the type (s) and quantity of SN'1 that may be placed on storage shelves.

Aopendix A - Item C 10 CFR 70.3 " License requirements" states that no person subject to the regulations in this part shall receive title to, own, acquire, deliver, oossess, use, or transfer special nuclear material except as authorized in a license issued by the Comission pursuant to these regulations. Materials License SNM-1067 dated March 14, 1983 in License Condition 6 restricts the uranium possessed by the licensee to a maximum of 20 wt % U-235.

Contrary to the above, between April 1, 1982 and October 19, 1984, the licensee pos-sessed approximately 500 grams of U-235 in uranium enriched up to 81 wt % as contam-inated residuals from previously authorized operations.

Possession of this special nuclear material was not authorized by the specific license, SNM-1067, issued to Com-bustion Engineering, Ire.orporated.

Response

An amendment to SNM-1067 requesting approval for us to possess 1000 grams of U-235

... enriched to or greater than 20 weight percent U-235" was submitted to the NRC on November 30, 1984.

Very truly yours.

L H. V. Lichtenberger Vice President, Manufacturing Nuclear Power Systems Division HVL/RES/sse i

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