ML20137P281

Forwards Response to NRC Re Violations Noted in Insp Rept 70-0036/97-01.Corrective Actions:Revised Two Procedures to Include Prescribed Statement

ML20137P281
Person / Time
Site:	07000036
Issue date:	04/03/1997
From:	Sharkey R ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY, ASEA BROWN BOVERI, INC.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9704090205
Download: ML20137P281 (3)

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ABB April 3,1997 Docket No. 70-0036 License No. SNM-33 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

REPLY TO A NOTICE OF VIOLATION Gentlemen:

Enclosed is Combustion Engineering's Reply to Notice of Violation dated March 6,1997, concerning NRC Inspection Report No. 070-00036/97001(DNMS).

We will be glad to discuss any questions you have concerning our response. If you have any questions or need further information, please contact me or Mr. Hal Eskridge of my staff at (314) 937-4691.

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l Very truly yours, COMBUSTION ENGINEERING,INC.

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Robert W. Sharkey Director, Regulatory AfTairs

.cc: Bill Beech, Regional Administrator Region 111 l

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Enclosure to RA559

. April 3,1997 a

j REPLY TO NOTICE OF VIOLATION INSPECTION REPORT NO. 070-00036/97001(DNMS) 1 Response to Violation No. 97001-03 Violation:

Safety Condition S-1 of Special Nuclear Material License SNM-33 requires that licensed material be used in accordance with the statements, representations, and conditions in i

Chapters I through 8 of the application dated October 29,1993, and supplements thereto.

Section 4.1.3, Chapter 4 of the license application requires, in part, that criticality evaluations associated with facility changes consider potential scenarios which could lead to criticality and barriers erected against criticality in establishing limits and controls, and that these limits and controls be incorporated into applicable procedures and postings.

Nuclear and Industrial Safety Authorization (NISA) No. 96048, dated December 20.

1996, required, for the rod storage matrix, that the applicable operating procedure must state that, " collisions between heavy equipment and the matrix must be reported to the process engineer and the NCSS [ Nuclear Criticality Specialist]." In addition, the NISA required, for the fuel assemble storage rack, that the applicable operating procedure must

. state that " collisions between heavy equipment and the array or impact with an assembly severe enough to cause assembly damage must be reported to the process engineer and the NCSS."

Contrary to the above, during the period of December 20,1996, and February 6,1997, the applicable Operating System (OS) Procedures, OS No. 3260, IIelium Leak Detection &

1 Transfer Rods To Storage," and OS No. 3310," Crane Instructions for Bundles and Containers," did not include the specified safety controls employed for the respective system.

Response

1. Reason for the violation: The violation occurred because the process engineer who generated the procedures overlooked the requirement to includ: the statement concerning assembly damage by impact or collision.

2. Corrective steps that have been taken and the results achleu& As immediate corrective action, the two procedures were revised to include the prescribed statement.

j The engineer involved was counciled on the importance ofincluding all change evaluation conditions listed in the NISA in the operating system procedures.

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Enclosure to RA559 m

' April 3,1997.

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3. Corrective steps taken to avoid future violations: The importance ofincluding 1

. criticality conditions and reporting upset conditions was stressed in recently conducted criticality safety retraining for engineers and other professional personnel.

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. As part of our Criticality Safety Program Update (CSPU), a new Criticality Analysis i

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Procedure (CAP) has been written, approved and issued. The CAP requires that the j.

procedure reviewer ascertain that criticality safety conditions listed in the NISA are ~

appropriately incorporated in procedures prior to releasing the process or equipment for use with SNM.

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4. When full compliance will be achieved: We are currently in full compliance with 1

the requirement to include criticality safety controls in the applicable OS.

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