ML20137T412

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0036/85-02.Response to Item 4 Unsatisfactory.Response to Encl Comments Requested within 10 Days of Ltr Receipt
ML20137T412
Person / Time
Site: 07000036
Issue date: 01/16/1986
From: Hind J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Lichtenberger
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
Shared Package
ML20137T418 List:
References
NUDOCS 8602180346
Download: ML20137T412 (2)


Text

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  • 'i)M2 JAN 161906 Docket No. 70-36 Combustion Engineering, Inc.

ATTN: Mr. H. V. Lichtenberger Vice President Manufacturing Nuclear Power Systems Windsor, CT 06095 Gentlemen:

This refers to your letter dated November 19, 1985, addressing the violations which we brought to your attention in Inspection Report No. 70-36/85002 forwarded by our letter dated October 18, 1985.

Your response to all but one of the violations identified in the inspectica report dated October 18, 1985, are adequate and we will examine these matters during a subsequent inspection. However, your response to item 4 is unsatisfactory. Our comments concerning. Violation No. 4 are enclosed as an attachment to this letter. You are requested to submit to this office within ten days of the reccept of this letter your response to our comments.

t Sincerely, asaf Jack A. Hind, Director Division of Radiation Safety and Safeguards Enclosure As stated cc w/

Enclosure:

J. A. Rode, Plant Manager DCS/RSB (RIDS)

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f ENCLOSURE Combustion Engineering, Inc. Docket No. 70-36 Hematite Plant We have reviewed your response addressing the violations identified in Inspection Report No. 73-36/85002. These coments address certain inadequacies in your response.

Violation No. 4:

10 CFR 70.57(b)(4) requires veification of the validity of existing mixing and sampling procedures through the use of process and engineering tests.

This requirement refers to sampling procedures rather than random sampling error estimates. Furthermore, the intent of License Condition 4.11 is to allow the exemption regarding the nonperformance of process and engineering tests for UF6 sampling procedures referred to in Section 4.3 of the FNMCP.

Therefore, License Condition 4.11 does not exempt the licensee from' the requirement of determining random errors using current data as stated in 10 CFR 70,57(b)(8) and (9). The licensee must develop.a system of control measurements to provide current data for the determination of random error behavior . . . program data generated during the current naterial balance period shall be used for the determination of the limit of error of the plant material balance. .

The above position was discussed with your licensing reviewer on December 3, 1985, and he concurred with the above findings.

It is therefore concluded that a violation of 10 CFR 70.57(b)(8) and (9) did occur and that corrective action must be taken.