ML20151G345
| ML20151G345 | |
| Person / Time | |
|---|---|
| Site: | 07001100 |
| Issue date: | 02/17/1987 |
| From: | Lichtenberger ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151G344 | List: |
| References | |
| NUDOCS 8804190342 | |
| Download: ML20151G345 (3) | |
Text
. _ _ _ _ _ _
COMBUSTION ENGINEERING February 17, 1987 License SNM-1067 Docket 70-1100 U. S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 Attention:
Mr. Thomas T. Martin, Director Division of Radiation Safety aad Saf eguards
Reference:
Letter from Thomas T. Martin, NRC, to H. V. Lichtenberger, CE, dated January 21, 1987; Inspection No. 70-1100/86-04
Dear Mr. Martin:
This is in reply to the above ref erenced letter in which you reported that certain activities at our facility were not conducted in full compliance with NRC requirements. Our response to the violations noted in your inspection summary is as follows:
Failure to check quarterly violation of fire door on the virgin powder storage area under power failure conditions (Paragraph Sf (1)).
Section 4.3.2 of the criteria section in the NRC approved license application i
states that the fire door in the virgin powder preparation storage area shall close automatically on activation of the fire alam and/or upon electrical power f ailure (in case the f ailure precedes or is incident to a fire).
The automatic closing feature of the door on the virgin powder storage area is to be verified quarterly and records of its perfomance are to be maintained.
These nuclear criticality saf ety requirements were incorporated into the facility license to assure that the storage area will not become wet in the event of activation of the fire sprinklers located outside the storage area.
In discussions with licensee representatives and through review of licensee records, che inspectors detemined that the operation of the door on activation of the fire alam is checked monthly, but the operation of the door under power failure conditions had not been tested since January 3,1984.
This was identified as a violation of NRC requirements.
The inspectors noted that, although the tests are to be perfomed by Maintenance personnel, the responsibility for assuring that the tests are completed is assigned to the Health Physics and Safety Supervisor, with no apparent program to assure that the tests are perfomed.
Power Systems 1000 Prospect Hill Road (203) 688 1911 Combushon Engineering. Inc.
Post Offce Box 500 Telex: 99297 Windsor, Connectcut 06095-0500 804190342 880412 DR _ADOCK iC
^
07001100 DCD
e
' Respdnse Our Maintenance department tested the virgin powder storage area door each month, instead of the required 4 times a year, to verify that the door closed when the fire alarm was activated. The last formal test of the door under power failure conditions was conducted by the Maintenance de-partment on January 3,1984.
Subsequent quarterly tests were not conducted as required by SNM-1067 as noted in the referenced letter.
Instead, the power failure test was conducted once a year by the Maintenance department as part of their overall check of electrical equipment during the annual l
vacation shutdown of our facilities.
Permanent records of both the fire alarm and power failure tests were maintained by the Maintenance department but records were not available in the file of the Supervisor, Health Physics and Safety at the time of the ref erenced inspection.
Revisions to the Maintenance test procedures have been implemented which now require testing the virgin powder area door for both a fire alarm and power failure condition a minimum of 4 times a year.
Health Physics per-sonnel will witness the tests each time they are conducted and will sign the test result sheet to signify they have witnessed and accepted the tests. A permanent record of all such test results will be maintained by the Supervisor of Health Physics.
Failure to conduct a nuclear criticality saf ety evaluation for the storage of natural uranium rods on top of a saf e slab in the Building 2 vault (Paragraph 5f (1)).
During a tour of the Building 2 complex, it was observed that natural uranium rods were being stored on top of an NRC-approved 3.7 inch saf e slab of uranium oxide. Through discussions with licensee representatives, the inspectors determined that a nuclear saf ety evaluation was not completed for this condition, as required by Section 2.2.2 of the NRC-approved license application. A nuclear saf ety evaluation for this storage condition is required because the original evaluation of the slab was based on water and concrete reflection, not natural uranium, which is a better reflector. This was identified as a violation of NRC requirements.
Response
A nuclear safety evaluation was never conducted for this cond!. tion. The natural uranium rods were never intended to be placed on top of the rod box stored in Building 2 and were placed there by persons unknown.
The natural uranium rods were removed from the top of the rod box and Building 2 per-sonnel were reinstructed in the established nuclear safety limits for that area.
In addition, we are presently making plans to remove all of the material from Building 2 and place it in a vault located in Building 5 A
license revision to SNM-1067 to cover this change was submitted to the Uranium Fuel License Branch on November 6,1986. We are presently discussing this requested change with NRC Branch personnel.
r-(...
.e
\\ )
With regard to the. recommendations that.uere made in the referenced letter, we wish to assure you that we are taking whatever steps are necessary to satisfy the conditions of the subject license as well as meet all regulatory requirements that cover the operation of our facilities.
Very truly yours, H. V. Lichtenberger Vice President, Nuclear Fuel I
est, '
O' I
A
--..,-,-y
,,-,n, e,-
,,,.<,e~,-
<--e
- + - -
,,,.n
--