ML20151C403

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Responds to NRC Re Violations Noted in Insp Rept 70-1100/88-03.Corrective Actions:Drums Labeled as to Estimated U-235 Content & Enrichment Limits & Review Conducted of All Secured Mass Limited Containers in Use
ML20151C403
Person / Time
Site: 07001100
Issue date: 07/08/1988
From: Mcgill P
ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
To: Russell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
References
NUDOCS 8807210345
Download: ML20151C403 (10)


Text

e COMBUSTION ENGINEERING July 8, 1988 Docket No. 70-1100 License SNM-1067 Mr. William T. Russell Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Subject:

Reply to Notice of Violation (NRC Inspection Report No. 70-1100/88-03)

Reference:

Letter, G. L. Sjoblum (NRC) to P. L. McGill (C-E),

dated June 6,1988

Dear Mr. Russell:

Combustion Engineering, Inc. has reviewed the Notice of Violation and Enforcement Conference Report received with the reference letter.

This letter provides Combustion Engineering's response to the subject Notice of Violation.

Based on a telephone conversation between Mr. J. Roth (NRC) and Mr. J. Kingseed of my staff on July 6,1988, it is our understanding that this response is considered timely.

Specific replies to each of the seven (7) violations are included in the Enclosure.

In addition to responding to the Notice of Violation, Combustion Engineering wishes to bring to your staff's attention a minor discrepancy recently discovered in our slides used to respond to Apparent Violation 6.

Specifically, in the background section the fourth and fifth bullet on the slide in question could suggest that two scales exist in or near the lower part of the hammermill hood. Only one scale exists (outside of the lower part of the hood) and the fourth bullet probably should not have appeared on the slide.

Further, in the response section we indicated that a revised form would be used in determining the appropriate weights.

We have since found implementation of a new form to be impractical.

We believe that an equally acceptable position is provided in our response to Violation E of the Enclosure.

We regret any confusion that this may have caused.

8807210345 000708 PDR ADOCK 07001100 C

PNU Power Systems 1000 Prospect Hill Road (203) 688 1911 Combustion Engineenng, Inc.

Post Offce Box 500 Telex: 99297 Windsor, Connectcut 06095-0500

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Mr. William T. Russell Page 2 l

July 8, 1988

)

If you any questions, please do not hesitate to call me or Mr. A. E. Scherer, i

our Director of Nuclear Licensing at (203) 285-5200.

Very truly yours, COMBUSTION ENGINEERING, INC.

P Vice President Nuclear Fuel PLM:ss

Enclosure:

As Stated cc:

J. Roth (NRC - Region I)

G. L. Sjoblum (NRC - Region I) i i

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Attachm3nt Page 1 of 7 Combustion Engineering Response to NRC Notice of Violation Violation A Amendment No. 9 to License No. SNM-1067 dated April 8, 1987 incorporates Section 4.1.6, "Marking and Labeling of SNM," dated October 22, 1986 into the NRC-upproved license. application (Part 1-Criteria) which states, in part, that all mass-limited i

l containers shall be labeled as to enrichment and content, Contrary to the above, on February 29-March 1, 1988, the lids on seven mass limited containers (drums labeled as No. 5121, 4565, "contaminated oil", 4564, 4570, 4586, and 4611), containing unmeasured quantities of uranium-235, had been secured between December 20, 1987 and February 2, 1988, and the containers were not labeled with the actual uranium-235 content and enrichment.

Response

1.

The seven (7) drums in question have been labeled as to estimated uranium-235 content and enrichment limits.

Additionally, a review was conducted of all secured mass limited containers in use to ensure that they were properly labeled.

2.

To prevent recurrence, we have increased surveillance of materials in mass-limited containers to ensure that they are appropriately marked and labeled.

In addition, we are reviewing our operations procedures against the requirements of Section 4.1.6 of the NRC-approved license application.

Changes will be made as necessary.

We anticipate that the procedure / application compatibility review will be completed by the fourth quarter of 1988.

3.

All secured mass-limited containers are appropriately labeled in compliance with Section 4.1.6 of the NRC-approved license application at this time.

Attcchm:nt Pago 3 of 7 Violation C' Amendment No. 7 to License No. SNM-1067 dated August 4, 1986 incorporates Section 4.3.9, dated December 16, 1985 into the NRC-approved license application (Part 1-Criteria) which states that the uranium oxide thickness on each of the Pellet Storage Shelves shall be less than four (4) inches.

Contrary to the above, on February 29, 1988, the uranium oxide thickness, at five locations on the Pellet Storage Shelves, exceeded four inches by an amount of 1/8 to 3/4 of and inch.

Response

1.

Criticality limits on the pellet storage shelves were implemented by the following:

(a)

A nuclear criticality sign was located at the shelves specifying a 4 inch high slab limit, (b)

Pellet trays measuring two inches in height were limited to stacking two high so that the four inch slab limit would not be exceeded, and (c)

An engineered safeguard in the form of a steel bar was installed on the shelves.

(The purpose of this bar was to limit the stack height of trays to four inches.)

In the process of loading pellets into the trays, employees would occasionally load the pellets non-uniformly, resulting in the tray covers being slightly raised. When stacking two trays in this condition on the shelves, the steel bar would be, at times, raised slightly to slide the pellet trays under the bar.

To correct this situation, the following additional steps have been taken:

- Procedures have been modified to require leveling of pellets in trays, Employees have been instructed on the importance of leveling pellets, and As an additional engineered safeguard, an inflexible steel bar has been installed on the storage shelves to preclude its being raised beyond the 4 inch slab limit opening.

2.

Recurrence of this violation is precluded by the actions i

already taken and outlined in Item 1.

3.

Combustion Engineering believes that it is now in compliance with the 4 inch slab requirement of Section 4.3.9 of the NRC-approved license application.

2 Attachmsnt Pago 2 of 7 Violation B Amendment No. 9 to License No. SNM-1067, dated April 8, 1987 incorporates Section 2.7.2, dated October 22, 1986 into the NRC-approved license application (Part 1-Criteria) which states, in part,.that it is the responsibility of the Plant Manager to assure that all operations involving radioactive materials have written procedures which include the appropriate safety requirements.

Those procedures must be approved by the Manager, Nuclear Licensing, Safety, Accountability and Security (NLSA&S),

The Nuclear Criticality Safety Specialist, or the Supervisor, Health Physics and Safety prior to the start of any operation.

Contrary to the above, as of February 29, 1988, the Plant Manager did not assure that all operations involving radioactive materials had properly approved written procedures in that the Quality control procedures did not contain safety precautions nor were they properly approved.

For example, operations Sheet No.

945, Revision 39, dated December 10, 1987, did not include any safety precautions, and there was no written approval by the Manager, NLSA&S, the Nuclear Criticality Safety Specialist or the Supervisor, Health Physics and Safety.

Response

1.

The specific operation Sheet (No. 945, Revision 39) noted in the Notice of Violation has been reviewed and approved by the Manager NLSA&S.

2.

Combustion Engineering recognizes that room for improvement exists in our controls for including appropriate safety-precautions in shop operating procedures. We have already begun to correct this problem.

In this regard, the following actions have been or will be completed during the fourth quarter of 1988:

(a)

The new Plant Manager has been instructed to ensure that all changes to operations sheets are reviewed and approved and contain the appropriate safety precautions before being authorized.

(b)

As committed in a response to a related violation from a previous inspection, all operation Sheets are presently being rewritten and upgraded to include appropriate safety and criticality precautions.

These upgraded operation Sheets will be reviewed and approved by the appropriate personnel.

3.

Completion of the procedural upgrade task is expected by the fourth quarter of 1988.

t.

Attachmsnt

.Paga 4 of 7 Violation D

. Amendment No. 3 to License'No. SNM-1067 dated. October-1, 1984 incorporates Section-4.1.3 "Requests-for Changes,and CriticalityL Analysis" dated June 15, 1984 intoLthe NRC-approved license application-(Part.1-Criteria)'which states that-all proposed changes in process,: equipment,-and/or. facilities that could affect nuclear criticality, radiological 1or-industrial safety shall be approved in accordance with the requirements set forth in Section.2.2.2 of.this part.

Amendment 3 also incorporates-Section 4.1.5 "Internal Review Requirements" which states, in part, that all process / equipment / facility changes which~could.

affect nuclear criticality safety shall be reviewed.and~ approved in writing by the. Nuclear Criticality Specialist.. Section-2.2.2 states that the General Manager delegated 1to the Production and.

Material Control Managers and.to'the Engineering Manager responsibility to assure that all operations involving nuclear materials have'been analyzed to establish the required safety limits and controls. The Manager, NLSA&S or Nuclear Criticality-Specialist shall assist the Engineering Manager and the Production and' Material Control Manager by performing the analysis required and establishing.the appropriate controls.

Contrary to the above, at some time prior;to March'1, 1988, a change was made at the facility, namely, covering the Batch Makeup Hood Conveyor, resulting in the potential accumulation of uranium oxide powder under the conveyor, and an analysis was not performed prior to the change to establish the required-safety limits and controls.

Further, this change in equipment, which could affect nuclear criticality safety, was not reviewed'and approved in writing by the Nuclear Criticality. Specialist.

Response

1 i

1.

Subsequent to the NRC inspection,-the~ gap.between the Batch Makeup Hood and the conveyor.was reduced by the addition of a piece of sheet metal to minimize residual powder from potentially entering.and accumulating under the conveyor.

This change was reviewed and approved in. writing by the Nuclear Criticality Specialist for acceptability.

2.

The Manager, Radiological and Industrial Safety or the Nuclear Criticality Specialist'will review all future proposed process / equipment / facility changes and determine if a specific safety analysis is required.

All credible nuclear criticality scenarios will be analyzed before being approved.

3.

Combustion Engineering believes that it is now in compliance with the requirement of its'NRC-approved license application as regards analysis of credible nuclear criticality.

scenarios.

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Attachm3nt-Page 5 of 7 Violation E Amendment No. 3 to License No. SNM-1067 dated October 1, 1984 incorporates section 4.1.4 "Posting of Limits", dated June 15, 1984, into the NRC-approved license application (Part 1-Criteria) which states, in part, that all work stations shall be posted with a nuclear safety sign approved by the Manager, Nuclear Licensing, Safety, Accountability and Security'(NLSA&S) or the Nuclear Criticality Safety Specialist.

Section 4.1.2 states, in part, that it shall be'the responsibility of the supervisor to assure that each work station is properly posted and that operations are performed in compliance with posted limits.

Contrary to the above, on February 27, 1988, a work station was not properly posted in that the posted nuclear safety limit of 24.0 kilograms uranium oxide appeared to be exceeded by about 1.1 kilograms as the result of a weighing error.

Response

1.

Combustion Engineering has instructed supervisory personnel and operators of the hammermill hood on.the correct procedures for determining total weight, tare weight and the balance of material remaining in the hammermill hood.

2.

To prevent recurrence, the operating procedure for the hammermill hood will be revised to include an administrative safeguard acticn limit. This action limit will be established at a value less than the criticality safety limit and will require supervisory personnel to verify the actual quantity of material in the hood.

Should the action limit be reached, the hammermill will be shut down if verification can not be established.

In addition, we intend to conduct an evaluation to determine if other means exist to ensure that safe criticality limits are not exceeded.

3.

Combustion Engineering believes that it is now in compliance.

In addition, we will complete the action limit and evaluation identified in item 2 by the first quarter of 1989.

l Attcchm:nt Pago 6 of 7 Violation F 10 CFR 70.51 (b)(1) states that each licensee shall keep records showing the receipt, inventory (including location), disposal, acquisition and transfer of all special nuclear material in his possession regardless of its origin or method of acquisition.

Contrary to the above, on March 2, 1988, the inspector determined that the licensee did not maintain inventory records, including

~

location, of between 70 to 300 grams of uranium-235 in enriched uranium oxide that was found in liquid waste tanks and pipes during 1985.

Response

1.

The subject material was previously identified to the NRC and added to the formal inventory records on May 2, 1988.

It was subsequently shipped to the Barnwell Waste Management Facility on May 13, 1988.

2.

In the future, the Manager of Accountability and Security will ensure that all materials are inventoried, as necessary, without undue delay.

3.

The actions noted sbove have corrected the inventory records discrepancy.

Combustion Engineering believes that it is now in compliance with 10 CFR 70.51 (b)(1).

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Attachm3nt Pago 7 of 7 Violation G Amendment No. 9 to License No. SNM-1067 dated April 8, 1987 incorporates Section 2.6.1 "Initial Training", dated October 22, 1986 into the NRC-approved license application (Part 1-Criteria) which states, in part, that all new employees shall attend a formal training session prior to working in restricted areas.

Specialized training for radiation protection and nuclear criticality safety shall be commensurate with the extent of the employees contact with radioactive materials.

All personnel whc will be working with radioactive materials must satisfactorily complete a test to ascertain the effectiveness of the training.

Contrary to the above, as of March 28, 1988, personnel working with radioactive material, who required specialized training in nuclear criticality safety, were not required to satisfactorily complete a test to ascertain the effectiveness of that training.

Response

1.

As committed in a response to a related violation from prior inspections, Ccmbustion Engineering is presently upgrading our General Employee Training Program.

The revised program, which will contain modules covering radiation protection and nuclear criticality safety, will be given to all employees who work with radioactive materials.

The employees will be required to complete a test to ascertain the effoutiveness of the training.

2.

The upgraded training and testing program should preclude recurrence of the subject violation.

3.

Combustion Engineering expects the upgraded training and testing program to be completed by the fourth quarter of 1988.

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