ML20154L486

Ack Receipt of 980827 & 1005 Ltrs Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 70-0036/98-03 Issued on 980730.C/As Will Be Examined During Future Insp

ML20154L486
Person / Time
Site:	07000036
Issue date:	10/14/1998
From:	Reidinger T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Kaiser B ABB COMBUSTION ENGINEERING NUCLEAR FUEL (FORMERLY
References
70-0036-98-03, 70-36-98-3, NUDOCS 9810190320
Download: ML20154L486 (1)

Text

-. -.

October 14, 1998 Dr. Bruce Kaiser Vice President, Fuel Operations ABB Combustion Engineering, Inc.

3300 State Road P Hematite, MO 63047

SUBJECT:

RESPONSE TO INSPECTION REPORT 070-00036/98003

Dear Dr. Kaiser:

This refers to your August 27,1998 and October 5,1998, letters of response to the Notice of Violation (NOV) transmitted to you by our letter dated July 30,1998, with inspection Report 070-00036/98003. We have reviewed your corrective actions for the violation and have no further questions at this time. Your corrective actions will be examined during future inspections.

If you have any questions, please contact me at (630) 829-9816.

Sincerely, Original Signed by Timothy D. Reidinger, Acting Chief Fuel Cycle Branch Docket No. 070-00036 License No. SNM-33 cc:

R. W. Sharkey, Regulatory Compliance Manager R. A. Kucera, Director, Missouri Department of Natural Resources f

bec w/ltrs dtd 08/27/98 & 10/05/98: Dockst File PUBLIC IE-07

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i C. Emeigt. NMSS R. Soong, NMSS P. Ting, NMSS R. Bellamy, RI EJM, Ril (e-mail)

D. B. Spitzberg, RIV/WCFO Greens w/o enci DOCUMENT NAME: G:\\SEC\\COM98003.RES To r*ceive a copy of this document, indicate in the box:"C" = Copy without enclosure "E" = Copy with enclosure *N" = No copy OFFICE Rlll

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August 27,1998 Docket Nc,. 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 a Notice of Violation concerning NRC Inspection Report No. 70-36/98-003, dated July 30,1998.

In addition to the actions stated in the enclosed reply, we have taken action to enhance our self assessment program. The enhancement involves frequent (usually weekly) review by plant management of the status ofitems identified during quarterly inspections.

These reviews have resulted in improved completion of noted items.

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 at (314) 937-4691.

i Sincerely, COMBUSTION ENGINEERING,INC.

l W-Robert W. Sharkey Director, Regulatory Affairs cc: Jim Caldwell, Regional Administrator (Acting), NRC Region III RA98/790 l

ABB CENO Fuel Operations Ccanboshon Engvecorm inc 37)0 State Road P Telephore (314) 937-4691 i

l Post Othce Ben 107 St trxns (314) 2% 5640 Hernatite. Mssotsi (,3047 Fas ;314)(A7 795',

d Combustion Engineering, Inc.

Docket 70-36 August 27,1998 License No. SNM33 REPLY TO A NOTICE OF VIOLATION INSPECTION REPORT 70-36/98-003 Response to Violation No. 98-003-01 Violation:

Safety Condition S-1, ofSpecial Nuclear Afaterials License, SNAl-33, authorizes the use oflicensed materials in accordance with the statements representations, and conditions in Chapters 1 through 8 ofthe application dated October 29,1993, andsupplements and revisions thereto.

Chapter 2, Section 2.6, " Operating Procedures, ofthe supplement, dated August 8, 1997, requires, in part, that all operations which afect licensed material shall be conducted in accordance with approvedprocedures.

Sections 6.0 and 7.0 ofOperational Safety Procedure O.S.604.12, " Operational Inspection and Checklists, " required, in part, that certain equipment be checkedper the

" Weekly and Monthly Checklist, " at weekly and monthlyfrequencies to maintain safety and/or operability ofthe Oxide Building.

Section 6.6, ofNuclear IndustrialSafety (NIS) Procedure 213, " Hazardous Afaterials Afanagement, " required, in part, that chemicals shall be compatible with their containers, lockers, containment, and the other materials with which they are stored. A guideline isprovidedin the Hazardous Afaterial Data Table.

Contrary to the above, operations which affected licensed material were not conducted in an:ordance with approved writtenprocedures in thefollowing examples:

a.

From February 1998 to July 17,1998, plant stafffailed to chech certain equipment at weekly and monthlyfrequencies as required by Procedure 0.S.604.12, to maintain safety and/or operability ofthe Oxide Building. Specifically, twelve weekly and two monthly checks were not conductedfrom February 1998 to July 17, 1998.

b.

Prior to July 16,1998, a carboy (approximately 30-gallon container) ofnitric acid was stored on the westfloor ofthe South Vault, where thefloor was contaminated with oil, an organic combustible chemicalincompatible with nitric acid, as defined in the Hazardous Material Table in NIS Procedure 213.

RA96n90

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6 Combustion Engineering,Inc.

August 27,1998 Docket 70-36 License No. SNM33

Response

1. Reason for the violation:

a. Failure to conduct some of the weekly and monthly safety and operability checks l

in the Oxide Building was due to maintaining the checklist on a clipboard which required operator diligence outside of normal daily activities and lack of specific l

assignment of operators to conduct the checks.

b. Storage of the nitric acid carboy in the South Vault was due to the presence of outdated postings in the vault and inadequate training of the operators involved.

l

2. Corrective steps that have been taken and the results achieved:

Weekly and monthly preventative maintenance checks required by procedure a.

O. S. 604.12 have been incorporated into the Maintenance Work Order System which tracks completion of the tasks.

b. The carboy was removed from the South Vault and placed in proper storage. T outdated postings were also removed.

3. Corrective steps taken to avoid further violations:

l l

Incorporation of the checks into the Maintenance Work Order System to provide a.

more formal assignment, tracking and documentation of the checks will avoid further violationsin this area,

b. Training in the proper handling and storage of chemicals will be conducted for operators involved in this activity. This training will be completed by September 30,1998.

4. Date when full compliance will be achieved: Full compliance has been achieved on both items.

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RA98n90 e

ABD Mpp October 5,1998 Docket No. 70-0036 License No. SNM-33 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

SUBJECT:

Additionalinformation regarding inspection 70-36/98-003 Gentlemen:

This letter provides additional infonnation requested by the NRC regarding Combustion Engineering's Reply to a Notice of Violation concerning NRC Inspection Report No. 70-36/98-003, dated July 30,1998.

During this inspection an issue was raised regarding the storage of nitric acid adjacent to non-compatible materials in the south vault. The inappropriate sterage of this material was previously noted in the quarterly radiological and criticality safety inspection and not acted upon by CE until this inspection.

In CE's reply dated August 27,1998, the reason for the violation and corrective actions where provided.

In addition, CE stated "..we have taken action to enhance our self assessment program. The enhancement involves frequent (usually weekly) review by plant management of the status ofitems identified during quarterly inspections. These reviews have resulted in improved completion of noted items."

l Subsequent to our reply, CE has funher reviewed our response with respect to our self-assessment program to determine the reason for missing the opportunity to correct selfidentified issues in a timely manner and provide corrective sction to prevent this from recurring. One reason for not correcting the selfidentified item was the lack of management follow-up of requested corrective actions. The corrective action t

described above has addressed this issue effectively. The format of the quarterly inspection report has also l

lead to delayed corrective action in that no priority or ranking was established to help prioritize corrective l

actions. While reviewing these past quarterly inspections, a significant fraction of the findings involve j

minor administrative or housekeeping issues. Because minor issues of no safety significance are i

intermixed with more significant issues, prioritization by the individuals assigned the action items may not j

be consistent with the significance of the issue. Future inspection reports will provide a prioritization.

Items reccgnized as significant because of safety or license compliance are acted upon immediately.

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 at (314) 937-4691.

Sincerely, i

1 COMBUSTION ENGINEERING, INC.

1 W

{

Roben W. Sharkey Director, Regulatory Affairs i

cc: Jim Caldwell, Regional Administrator (Acting), NRC Region ill

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Patrick lilland, Deputy Division Directee (Acting) Region 111 RA98/808 ABB CENO Fuel Operations

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